Comment

Representation ID: 22868

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

Sustainability Appraisal and Strategic Environmental Assessment of the Greater Norwich Local Plan (Jan 2020)

Loddon P&R
It is considered that the Sustainability Appraisal's (SA) assessment of the Loddon P&R site has been undertaken in an overly broad manner, resulting in negative impacts being stated for categories where this is not justified. The matters will be discussed here in the order taken by the SA.

Objective 1 'Air Quality', the SA states air and noise pollution concerns occur because of its location adjacent to the A146. Any minor negative impact on air and noise quality at the site fails to take account of the circumstances of the site’s proposed use and the bigger picture. A Park and Ride will by nature have users which are transitory – being on the site no more than 15 – 30 minutes, and more importantly, the provision of P&R facilities improves air quality within the city centre, by removing cars that would otherwise drive in. Air quality and noise pollution should therefore not be counted as negatives against the proposal.

Under Objective 2 'Climate Change Mitigation and Adaption', the location of the site in Flood Zone 1 should be a major positive impact (rather than minor positive) as the proposal will locate end users on a site with the least possible risk of fluvial and surface water flooding.

Under Objective 3 'Biodiversity', a minor negative impact is stated because of the site being located within 5km of The Broads SAC and Broadlands SPA and Ramsar, and within the IRZ of the Yare Broads and Marshes SSSI. The provision of a P&R site in this location will not add to direct pressure on those sites, and ecological impacts can be mitigated within the design. Impact should therefore be neutral at worst.

The section on Objective 4 'Landscape' states development of the site would have a minor negative impact on the local landscape character. While it is accepted that the introduction of a P&R would invariably alter the character of the site itself, it is considered that impact on the wider countryside character could be appropriately mitigated through careful, landscaping-led masterplanning of the site. A full Landscape and Visual Impact Assessment will be submitted at a later stage to demonstrate the landscape effects of the proposed P&R scheme.

It is unclear how the proposed development could have a negative impact on access to local services, as stated under Objective 6 'Population'. A P&R would actually have the opposite effect, allowing a greater range of users easier access to services via public transport.

In a similar vein, under Objective 8 'Health' it appears the site has been assessed for health purposes as if the proposal is for housing. The proposal would not restrict access to the Norfolk and Norwich University Hospital. The site being located outside of the target distance of the nearest GP surgery, hospital and leisure centre is not of relevance to the proposed use as a P&R and should therefore not be recorded as a major negative impact.

The major positive impact on the local economy stated under Objective 11 'Economy' is agreed with. As well as creating jobs through the construction and operation of the P&R itself, there will also be a positive impact on the Norwich economy as the P&R will make it easier and more convenient for workers and visitors to travel into the city centre.

Under Objective 12 'Transport', the SA has recorded minor negative impacts in terms of access to bus and rail services. This conclusion is entirely contradictory to the purpose of a Park and Ride which will improve access to bus services for a range of people, allowing access into the city centre in a more convenient and sustainable manner. This should therefore instead be recorded as a major positive impact.

Objective 13 'Historic Environment' states potential impacts to designated heritage assets identified as the setting of the Grade II Listed Bixley Mill, Crown Point Registered Park and Garden, and the Scheduled Remains of Medieval Settlement 380m south of Park Farm. As only a minor negative impact has been identified by the Council, the development of the P&R site is not considered to result in substantial harm to the heritage assets. However, to ensure that development of the site appropriately takes into account the setting of the identified heritage assets, a detailed assessment of the potential impacts will be undertaken to inform the masterplanning of the site. With these measures, it is considered that heritage impact is not an onerous constraint to the allocation of the site.

Under Objective 15 'Water', it is stated that the site is within the catchment (Zone III) of a groundwater SPZ, and minor negative impacts are recorded due to a risk of groundwater contamination. It is considered that this risk can be effectively mitigated through the implementation of a robust drainage strategy tied in with the use of appropriate hard surfacing across the site, and there would therefore be no negative impacts.