A straightforward solution would be to revise the Reg. 19 draft to align with the Reg. 18 proposals for target housing numbers; justify the job numbers target as realistic, remove the NWL from the plan and tighten up the policies and provide targets for the environment and climate change before submission to the Inspector for approval.

THE FOLLOWING IS AN OFFICER-CREATED SUMMARY OF MR CAWDRON’S REPRESENTATION. THE FULL TRANSCRIPTION IS ALSO ATTACHED

The changes between the Reg18C draft plan and the Reg 19 version include a significant increase in housing numbers, which has not been subject to public consultation. Furthermore, the latest Government advice from December 2020 is that the 2017 method of calculating housing requirement would continue, negating the need for the additional housing and buffer. Using the 2017 method, the projected need for 20 years for Greater Norwich is around 40,000 homes, closely aligning with the Reg18C draft plan. The Norwich Wensum Link should not be included as a legal assessment made in 2016, which is still current, found that the integrity of the SAC would be adversely affected and only relatively little weight would be attached to the need to relieve congestion in the Norwich area. The GNLP attempts to distance itself from the HRA obligations connected to the NWL, which is a project which overrides a legal opinion in 2016. There is no mention of the December 2020 Government carbon target emissions reduction of at least 68% by 2030.
To correct these issues, revise the Reg. 19 draft to align with the Reg. 18 proposals for target housing numbers; justify the job numbers target as realistic, remove the NWL from the plan and tighten up the policies and provide targets for the environment and climate change before submission to the Inspector for approval.