Object

Representation ID: 23100

Received: 31/03/2020

Respondent: Salhouse Parish Council

A major concern is that the draft plan largely consists of a wish list, but lacks real targets or actions, particularly on the environment and climate change. For example, our environment is lauded but the draft plan notes in paragraph 37 that life expectancy for men in Norwich is 10.9 years lower in the most deprived areas compared to the least deprived. We cannot see any specifics within the draft plan as to how this shocking fact is to be addressed.
Paragraph 120 stresses the need for ‘good access to services and facilities’ for ‘our suburbs, towns and villages’. While this is provided in the first two categories of settlement there is insufficient provision or access to services in many of the settlements within the “village clusters”. The decision to allocate additional new housing beyond what is already allocated within the JCS is based almost solely on the existence of a primary school with available places or potential for expansion within the “cluster”. This does not amount to the provision of ‘good access to services and facilities’ and therefore this level of new housing in “village clusters” should not be permitted within the GNLP.
Paragraph 125 is perhaps the strongest argument for not allocating additional housing to “village clusters” within the GNLP. Clearly, there will be a major need for journeys from and to work for many of those living in any such new housing, in addition to additional journeys by delivery vehicles to this new housing. This paragraph states the need for ‘a radical shift away from the use of the private car, with many people walking, cycling or using clean public transport.’ For the majority of the plan period it is highly wishful thinking to think that ‘electric vehicles will predominate throughout Greater Norwich’. These additional journeys will not only add to the “carbon footprint” but will also add to congestion
on the road network, affecting air quality and the wellbeing of residents. If the intention of the GNLP is to locate housing close to jobs, which we agree should be a major aim, then any additional allocations of housing should be located in or close to Norwich, where there are realistic opportunities to walk or cycle to work and to services, or to use public transport to do so. The existing allocations of housing within the JCS and to be carried forward to the GNLP will provide sufficient new accommodation close to other places of work in main towns and key service centres.
Paragraph 129 states: ‘greater efficiency in water and energy usage will have minimised the need for new infrastructure, and further reductions in carbon emissions will be delivered through the increased use of sustainable energy sources. New water efficient buildings will have also contributed to the protection of our water resources and water quality, helping to ensure the protection of our rivers, the Broads and our other wetland habitats.’ We strongly feel that it is imperative that Per Capita Consumption (PCC) of water is further reduced to below the Government’s prescribed 110 litres per person per day in order to deliver this statement in paragraph 129. East Anglia is the driest region in the UK: our aquifers, rivers and wetlands are already at breaking point, as are many of the region’s farmers, who are seeing their abstraction licences reduced or revoked. If more demanding standards to reduce PCC water consumption are not set as part of the GNLP, this will further adversely impact upon the environment, impacting on the Broads and wetlands, which in turn will impact the region’s aspirational growth for tourism and will severely impact the regional agricultural economy. To ensure that the water-supply to existing users is not compromised it is sensible to restrict the number of new houses to a level that realistically covers actual need, and this fact reinforces our case for phasing of housing and our questioning of the need for a higher than necessary buffer.
Paragraph 132 makes the claim that new quality development will be located to minimise the loss of green-field land. CPRE Norfolk strongly suggests that the best way to achieve this is not to allocate additional sites for housing in “village clusters”. Indeed, there are already sufficient allocated sites for housing in the JCS being proposed to be carried forward to the GNLP in the Norwich fringe parishes, main towns and key service centres to keep pace with the likely build rates of development. The exception to this should be any brownfield sites, particularly those within Norwich, which should be prioritised into a “brownfield first” policy. This should form part of a phased approach to new housing, so that existing allocations from the JCS and any brownfield sites should be developed before permitting any additional allocated sites to be built-out.
One effective way to prevent the unnecessary loss of much greenfield land would be to institute a green belt on the “green
wedges” model around Norwich, as requested by 84 respondents and 1,912 petition signatories (currently at 2,200 signatures) calling for this according to the draft statement of consultation, September 2018, for the Stage A Regulation 18 Site Proposals and Growth Options consultation. CPRE Norfolk is very concerned that this proposal or option has been removed from the current consultation.
In conclusion for this question, we find that the vision and objectives contain serious flaws, especially in regard to the way in which they conflict with policies within the current Local Plan, which withstood the rigorous inspection process.