Comment

Representation ID: 22817

Received: 16/03/2020

Respondent: Norwich Green Party

Energy: a number of City Council car parks have electrical load restrictions which limit the provision of additional chargers for electric vehicles especially rapid chargers. UK Power Networks might require grid improvements for the city centre area to enable new chargers to be connected to the network.
Green Infrastructure: Policy 1 Infrastructure refers to green infrastructure. We would like to see a step change in the provision of green infrastructure. The latter should be in addition to and not a replacement for the ongoing loss of informal green spaces such as sports grounds and playing fields to housing and other development. Green infrastructure relating to active travel has in several instances involved the removal of greenery to the detriment of urban heating and biodiversity; for example grass verges have been removed in order to widen shared pedestrian/cycle paths. All green infrastructure should involve the enhancement or new addition of green soft landscaping,
We object to the GNLP reliance on individual private car use for accessing essential infrastructure, notably:
Health Care Requirements (ref Appendix 1): Parking is referred to in relation to 'Additional need resulting from growth' for the categories of 'Hospital' (NNUH) and Mental Health' (Julian Hospital). The expansion of car parking at NNUH is a major concern which needs addressing. Firstly, additional car parking facilitates the growth in car travel to the hospital and leads to an increase in carbon emissions and in air pollution. The NNUH has the largest car park in Norfolk which is more a policy failure than a proud record. The climate change emergency and the air pollution crisis have major public health implications and yet the NNUH and GNDP reliance on car travel is making public health worse. Secondly, there is a social equity problem because public transport provision serving the NNUH is unaffordable and second rate for many low income households and those without a car. Catering for car access to the NNUH has been a higher priority for policy makers whilst the provision of public transport to the NNUH has largely been left to the market. Money will need to be found for improving public transport infrastructure for serving the NNUH (such as re-organising the rather chaotic dropping off/picking up public transport arrangements outside the main entrance) in view of the smaller than anticipated Transforming Cities grant.
Waste Management (ref Appendix 1) we are concerned about the out-of-town locations of the planned recycling centres which will increase reliance on car-borne access. The increase in carbon emissions from additional car mileage could potentially negate any energy savings benefits from recycling. It would be helpful to calculate the net environmental costs and benefits of this recycling model (users take by car and van a range of materials to central location for recycling) to inform decision making, otherwise the local authorities could end up creating a net disbenefit and increasing the use of energy and carbon emissions.
High quality public transport infrastructure is referred to in Section 5 Policy 1 (para 168) and the Key Diagram shows eight Strategic Bus Corridors. We wish to reiterate our point that the GNDP authorities' Transforming Cities application was unsuccessful and Norwich, Portsmouth and Stoke will have to share a £117m pot.
As a consequence, the draft plan is not deliverable due to uncertainty around the ability to develop a city-wide public transport system for serving growth (including the level of growth to 2026 envisaged by the JCS). There are no other large sources of funding on the horizon which can make up for the deficiency. A lack of funding means that the draft GNLP fails the NPPF 'Effectiveness' test.