Object

Representation ID: 22754

Received: 16/03/2020

Respondent: Mr Bryan Robinson

I have looked at the GNGB annual monitoring since 2011.

Norwich has dropped from 9th in the national retail rankings to 13th in the last decade ith a overall reduction in retail floorspace. It is acknowledged that on-line shopping is changing peoples’ shopping habits but the consultation fails to recognise other factors which have contributed to this decline. The vibrant city is dying due to transport and development policies. Cities need a mix of activities which feed off each other but the Plan continues the isolation of the city by moving retail and employer to the edges.

The CO2 emissions from transport per capita for all three LPAs have not decreased since 2011. This is without the impact of the NDR which will increase emissions further. The ambition for a modal shift in transport patterns is not working and I question whether this is a real intention or merely words to make the document conform to government policy.

“Accessibility to market towns and key centres of employment during the morning peak (0700-1000), returning in the afternoon peak (1600-1900)” has declined year on year. One must therefore ask whether the employment centres are in the right locations.

Both the general housing and affordable housing completions are shown as green on the RAG analysis. However until 2018/19 overall housing has fallen short of targets. More worrying the failure to achieve affordable housing targets resulting in a backlog need as outlined in the 2017 SMHA report. This is reviewed in more detail later.

There have been major losses in permitted employment floor space since 2011, particularly in Norwich. The minor increases in Broadland and south Norfolk fall well short of compensation. The fact that employment over the same period has increased would suggest a democratic change in work patterns of small start-ups from home which is totally ignored in the Plan.

I am unclear what the annual measurement for “Percentage of permitted town centre uses in defined centres and strategic growth locations” demonstrates but the figures suggest that this ambition is spectacularly failing.

“Objective 7: to enhance transport provision to meet the needs of existing and future populations while reducing the need to travel” is similarly failing.