Object

Representation ID: 24411

Received: 22/03/2021

Respondent: ClientEarth

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

It would appear that the adverse effects [identified in the SA report] have been exacerbated by the decision to plan for ….. development on greenfield land and in unsustainable locations.
The impact of this decision is clear from looking at a few examples of the Sustainability Appraisal’s assessment of allocations made in the plan:
• In respect of the Village Clusters allocations:
o “There is a vast network of [Public Rights of Way] across Greater Norwich. This would be likely to provide good pedestrian access within and around these settlements. However, many of the Village Clusters are situated in remote areas within Greater Norwich, with limited access to railway stations, which are primarily located within Norwich and the east of the Plan area, with some stations also located to the west of South Norfolk. Site end users in more rural locations would also be expected to have limited access to regular bus services, despite some expected transport improvements in line with Policy 4. It is likely that a large proportion of site end users would be situated outside the target distance of public transport links. The rural location of development proposals under this policy would be expected to contribute to a relatively high reliance on personal car use…” (C.10.12.1)
o “Under this policy, it is likely that development will occur at a number of greenfield sites, which would be expected to result in a net loss of agriculturally and ecologically valuable soils. As the significant majority of soils in the Plan area are Grade 3 land, it is likely that this policy would result in a net loss of BMV land. This impact would be permanent and non-reversible and would also reduce the carbon sink capacity of soils across the Plan area.” (C.10.14.1)