Object

Publication

Representation ID: 24417

Received: 22/03/2021

Respondent: Mr Andrew Cawdron

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

F) Policy 4 Strategic Infrastructure. There is little acknowledgement within the plan that medical facilities in Norfolk are stretched, GPs are in reduced numbers, police forces are barely coping, ambulance staff are not being reinforced and teachers are not being retained. Despite this, the stated ambitions are to increase employment numbers and add 118,000 people to the population, acknowledged to be mostly from inward migration into the County. Add the consequent increased vehicle journeys and there is no enhancement or improvement to the environment or quality of life for the existing and indeed future residents. Acres of productive farmland in one of the most climatically advantaged counties are being sacrificed and the County is acknowledged as a water stress area. The final draft of the Water Study (January 2021) demonstrates significant upgrades to waste and supply are required to match such demand. There is NO capacity for increased surface water flows, which must imply that future flooding will increase as an issue.
The Sustainability Appraisal (largely a repeat of that available at Regulation Reg18C) states that these growth aspirations will have a significantly negative impact on air, noise and light pollution to the detriment of well being (SA1) climate change (SA2) biodiversity and natural resources, waste and contaminated land (SA14).
H) Policy 4. Transport ‘improvements’. The GNLP does not demonstrate how ‘modal shift’ from car use is to be made. For example, improvements to the ‘spokes of the wheel’ could be argued to be essential to this ambition and sustainability gain.
The radial roads that lead out from the centre of the City into the suburbs to allow safe cycling, walking and public transport routes require improvement. Many of these roads particularly to the North East of the City and the ‘Growth Triangle’ remain rural roads without footpaths or the widths for a safe cycle route. We refer to the Plumstead Road, the Salhouse Road, the Buxton Road, the North Walsham Road and the Wroxham Road as classic examples. It is however a City wide suburban challenge. The Rail Halt near the Broadland Business Park has been touted for over twenty years without any significant progress and investment and improvements to rail halts near expanding areas, Blofield/Brundall for example, should be given greater emphasis, all to reduce dependency upon the private car, van and truck.
I) Policy 4. The Norwich Western Link Road. Where resources should have been provided to existing networks as above, instead a policy has been made to provide a new dual carriageway link across the protected Wensum River Valley to link the end of the newly constructed Broadland Northway to the proposed to be dualled section of the A47. In sustainability assessment terms this is a ‘major negative’. In cost terms it increases Norfolk County Council risk and long term Debt. In Climate terms it is incompatible with policy. In real need terms it has failed to be justified. It does not have planning consent. The inclusion of the NWL in the plan is therefore unsound.

Change suggested by respondent:

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.

Full text:

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.