Object

Representation ID: 24504

Received: 22/03/2021

Respondent: Norwich Green Party

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy 4: Transport

The GNLP is unsound
- Not positively prepared: the GNLP Policy 4 on Transport relies on an inadequate and incomplete evidence base. GNLP Transport Policy 4 is a summary of Draft Norfolk Local Transport Plan 4 Strategy (Draft LTP4) and the Strategy has not yet produced a chapter relating to Norwich. Only one strategy was consulted upon: continuation of the approach in the adopted Joint Core Strategy 2006 – 2026, as informed by the Norfolk LTP3 2011-2026 and now being reflected in the Draft LTP4, which as it stands would not meet the area’s objectively assessed needs in relation to climate change. Alternative strategies which would cut carbon emissions on a path to Net Zero and that include traffic reduction measures were not considered.

- Not consistent with national policy. Draft LTP4 Strategy will increase transport carbon emissions and is not consistent with the legally binding target of Net Zero

Not justified: the Draft LTP4 Strategy and proposed Policy 4 on Transport would result in additional traffic growth and carbon emissions. The Sustainability Appraisal (SA) of Draft LTP4 incorrectly concluded that the Draft LTP4 Strategy would have a positive impact on carbon emissions. It incorrectly concluded that there was no need to consider reasonable alternatives to the Draft LTP 4 Strategy with regard to climate change. In the SA Scoping Report, the SA incorrectly accepted the Norwich Western Link as part of the current baseline.

Not effective: Draft LTP4 Strategy and GNLP Policy 4 would not deliver a cut in Norfolk’s transport carbon emissions consistent with the need to achieve Net Zero by 2050. The Norwich chapter in the Draft LTP4 Strategy has not been published for consultation and the Norwich Area Transportation Strategy Implementation Plan 2013 (since renamed Transport for Norwich) is reaching its end date.

The GNLP should be declared unsound and a revised LTP4 Strategy prepared for framing the GNLP transport policy that involves an ambitious programme which will contribute to Net Zero.

Inadequate Evidence Base
The transport evidence base for the GNLP is incomplete. The GNLP Reg 19 evidence base for transport gives a link to the Greater Norwich Local Plan Infrastructure Needs Report (Jan 2021), (alongside a version relating to the Reg 18 Consultation of 2018 which has been superseded). The Needs Report is a review of the infrastructure requirements to provide for growth planned through the GNLP. It lists transport plans and strategies which have yet to be approved or published:
Norfolk Local Transport Plan 4 Draft Strategy 2021 -2036
The GNLP Policy 4 on Transport is a summary of the Draft LTP4 Strategy.
It is NCC’s intention to adopt the LTP4 in April 2021. The Green Party view is that further work is required on this wholly inadequate document. As a start, the consultation version (autumn 2020) included two national climate change targets under the Climate Change Act 2008: an 80% reduction in carbon emissions on the 1990 baseline by 2050 and further on, a reference to net zero by 2050. The document is a continuation of Norfolk LTP3 2011 – 2026 in seeking to address carbon reduction, tackle the infrastructure deficit on major road, rail and bus connections, ensure good transport connections in urban areas and towns to serve planned growth that includes bus priority lanes on certain corridors, improve connectivity between rural areas and services in urban centres and support new transport technology to respond to a changing society and economy.
Draft LTP4 Strategy does not contain a separate chapter on Norwich which instead is addressed in a sub-section amounting to one third of a page in a chapter on Increasing Accessibility where the County’s ambition for Norwich is expressed thus:
“NCC (Norfolk County Council) want to encourage the use of more sustainable forms of transport, such as public transport, cycling and walking, while also improving the capacity of the road network, in particular through the completion of the Norwich Western Link.”
We read in the Sustainability Appraisal of LTP4 (3.2.7) that the assessment of the Transport for Norwich strategy policies will be reported on separately, once it becomes available, and will be appended to the SA Report. This had not happened.
Norwich City Council responded to the draft LTP pointing out that LTP4 contained seven short paragraphs on Norwich, that Norwich Area Transportation Strategy Implementation Plan (NATS, 2013) was out of date and Transport for Norwich update overdue, undermining the ability to plan land use and transport together. In relation to general content of Draft LTP4, the Council commented:
Our overall view is that the document is deficient due to a lack of clarity of expression, with too many words and too few images; generic policies that unsuccessfully attempt to straddle the needs of the City and the rest of the County; specific commitments to infrastructure schemes that promote long distance car-based connectivity but a lack of equivalent scheme commitments that would support the more environmentally progressive policies in the document; and a general lack of ambition and recognition that the world must be radically different by the end of the plan period……... (para 1.9)
The City Council offered a set of high-level policy principles and interventions for incorporating into the suite of transport policy documents being updated.
Transport for Norwich Strategy
The GNLP Reg 19 evidence basis for transport gives a link to Transport for Norwich webpage which as noted above is becoming out of date.
Norfolk Rail Prospectus
A consultation to update rail priorities contained in the 2013 Prospectus was carried out in early 2020, but a final version has not been published. The 2013 Plan listed new stations at Postwick and at Broadland Business Park on the Wherry and Bittern lines as medium-term aims and it advocated a new station on the Bittern Line at Rackheath for investigation in conjunction with developer proposals for the North East Norwich Growth Triangle, but there has been little progress.

GNLP Policy 4 on Transport would increase transport carbon emissions

GNLP Policy 4 would increase transport carbon emissions, contrary to Net Zero.
In their Sixth Carbon Budget Report, the Climate Change Committee advises on the need for a 70% reduction in surface transport emission by 2035 and for year-on-year reduction in traffic growth under the Balanced Pathway to Net Zero by 2050.
Surface transport has made little progress to date; emissions have fallen by just 1% since 2011 due to the increase in road traffic and rise in the sales of heavier sports utility vehicles, cancelling out expected reductions from sales of electric and hybrid vehicles.
The SA/SEA Scoping Study for Draft LTP4 Strategy considers the current baseline for transport. It notes:
- ‘Transport is one of the largest contributors to greenhouse gas emissions in Norfolk’.
- “There was no change in emissions related to transport between 2016 and 2017 which remained at 27% (125.9 MtCO2e).”
- Transport carbon emissions increased for all Norfolk authorities between 2015 and 2016. (Table 3.13). Total CO2 emissions from transport were highest in South Norfolk District Council, which accounted for 424.6 kt CO2 in 2016, and the lowest emissions were in Norwich City Council with 132.3 kt CO2.
Notwithstanding this negative situation, the SA/SEA Report assessment of LTP4 is :
‘Polices have resulted in predominantly significant positive effects on climate change and carbon emissions.’
The LTP4 policies largely rely on electric vehicles to do the heavy lifting work on cutting carbon emissions, together with an enhanced degree of modal shift. However, there is growing scepticism that electric vehicles will solve carbon emissions from road transport.
THE SA does not recommend the need for alternative strategy in order to achieve radical cuts in greenhouse gases. Furthermore, it suggests that a Norwich Western Link should form part of the Scoping Report baseline. We note that WSP who conducted the SA of Draft LTP4 also lead on the NWL for Norfolk County Council.
The SA/SEA of the GNLP (Jan 2021) tabulates the carbon emissions for all local authorities in Norfolk for 2016, 2017 and 2018, (an additional year on the SA of the Draft LTP4 Strategy). Table 9.4 shows that carbon emissions for transport increased in all three years in South Norfolk and Broadland. Transport emissions in Norwich increased between 2016 and 2018 and fell slightly in 2018. Emissions from the transport sector in Broadland were more than double the figure for Norwich, whilst South Norfolk was more than three times the level for Norwich.
This trajectory for Broadland and South Norfolk ought to have set alarm bells ringing for Norfolk County Council and put them on a different path. Policy 4 is the continuation of Business As Usual.

Recent major road schemes around Greater Norwich are adding to transport carbon. The Norwich Northern Distributor Road (NDR) will increase Norfolk’s transport carbon emissions by 6.17% between 2018 and 2032. Dualling of the A11 between Ketteringham and Cringleford increased traffic volumes by 25% between 2012 and 2017 is part of the explanation in the huge growth in South Norfolk’s transport carbon emissions. Nonetheless, Draft LTP4 continues to promote strategic road connections such as the Norwich Western Link. In addition, national strategic road schemes sought by Norfolk will further bump up emissions. Highways England recognise that A47 North Tuddenham to Easton scheme and the A47/A11 Thickthorn Junction Improvement will increase greenhouse gas emissions.

Norwich Airport is a further source of greenhouse gases. Optimistic assumptions about future expansion of national and regional airports are open to question following the Climate Change Committee Sixth Budget report and recommendation,
‘that there should be no net expansion of UK airport capacity unless the sector is on track to sufficiently outperform its net emissions trajectory and can accommodate the additional demand’. (Table p81, p29).

Need for an ambitious transport strategy based on traffic reduction
Because most local authorities in Norfolk have allowed transport carbon emissions to rise with little check, in particular levels in South Norfolk and Broadland, radical action will be necessary to address the problem. Transport can no longer rely on other sectors to achieve net zero.
An important lesson to be drawn is that the Transport for Norwich Strategy has lowered emissions in tandem with local population and economic growth by encouraging modal shift and cutting traffic in Norwich city centre. On the other hand, traffic around the periphery of Norwich, along strategic road corridors and in rural areas continues to grow in consequence of planning and transport decisions.
In built up areas, Government transport policy is encouraging modal shift and active travel through a number of policy papers such as ‘Decarbonising Transport’. In his Ministerial Foreword, Grant Shapps, Transport Minister declares:
‘Public transport and active travel will be the natural first choice for our daily activities. We will use our cars less and be able to rely on a convenient, cost-effective and coherent public transport network’.
The growth in digital technologies coupled with the covid-19 pandemic has speeded up changes in society with ramifications for transport and travel, such as the greater moves to on-line shopping and home working and the vital importance of fast broadband. The GNLP transport policy must reflect these upheavals and the overarching need to radically cut carton from the transport sector. We need to see measures that:
- Support for low car and car free living in high density communities concentrated around Norwich. The Centre for Sustainable Energy paper proposes changes to the text on Policy 4 Strategic Infrastructure Transport relating to non-car modes with a target for ‘half of all journeys in towns and cities being cycled or walked by 2036’ and additional wording on the need for new infrastructure in support of this.
- Enable substantial model shift through well- funded comprehensive * packages to include the types of measures set out in the Norwich City Council response on the Draft LTP4 consultation.
- An end to further major road building to accommodate traffic growth. The future of travel and will be heavily shaped by information technology and digitally connected Smart infrastructure.
*Comprehensive means simultaneous consideration of bus, rail, cycling, walking, park and ride, information services, marketing, traffic management, allocation of road capacity among the competing users, formal travel planning in residential areas, workplaces, schools, and other major attractors, parking provision, telecommunication impacts (home working, work conferences), traffic calming in residential areas and pedestrianisation.


Transport Policy 4: Norwich Western Link

We strongly object to this road scheme on soundness grounds. The NWL should be deleted from Transport Policy 4. The fact that the NWL has not been allocated in the GNLP suggest that growth identified is not dependent on the NWL for its delivery.
Given the reference to the NWL in implementing the Transport for Norwich Strategy, it should be a subject for discussion at the plan examination (with a view to its deletion).
Not positively prepared: NPPF Para 102 states that "transport issues should be considered from the earliest stages of plan-making..." The NWL referred to in Policy 4 is not an allocation in the emerging plan and officers inform us that adoption of the GNLP will not result in a route being safeguarded. However, Norfolk County Council regards the NWL as a critical part of the current Transport for Norwich Strategy and is proceeding with the NWL in parallel with preparation of the GNLP. This has denied the public the opportunity for commenting on the NWL as part of an integrated land use planning and transport plan.
A paper to the GNDP Board on 10 July 2020 considered a revised timetable to allow a focussed consultation. ‘This would include the possibility of including a specific allocation for use of land for the NWL within the GNLP, supported by a considerable evidence base such as a wider package of transport planning measures to be included in the Transport for Norwich Strategy and consideration of reasonable alternatives’.
Following the Planning White Paper, a paper to the GNDP Board on 30 Sept 2020 concluded that the allocation of the NWL envisaged in July would not be possible: ‘However, as in the draft version of the GNLP, the road would still be promoted by policy 4 on implementation and would be delivered through the Transport for Norwich Strategy.’
Reference to the NWL in Reg 19 is not ‘supported by a considerable evidence base’. The County Council has not published an updated Transport for Norwich Strategy.
Alongside preparation of the local plan, the NWL must be subject to a Habitat Regulations Assessment (HRA) as it would cross the River Wensum SAC. Because the NWL is not allocated in the GNLP, the SA/SEA of the plan is able to conclude that none of the allocated sites coincide with, or are located adjacent to, a European site. (SEA/SA of GNLP Reg 19, Box 8.3).
Also, because the updated Transport for Norwich has not been published, there has been no HRA screening of the NWL as part of the SA/SEA of the Draft LTP4.
There is a wholesale lack of information relating to the NWL and GNLP.
Under the Habitats Directive, development that adversely impacts upon a SAC must demonstrate for planning purposes ‘an imperative reason of overriding public interest’. Norfolk County Council has not done this.
The ecological importance of the River Wensum valley in the NWL study area has become more evident. Recently, significant numbers of rare barbastelle bats have been identified by Wild Wings Ecology consultancy in the corridor crossed by the NWL. The findings will add weight to the need for full habitat and species assessments under the EU directive.
Not Justified: Inclusion of the NWL is not appropriate and reasonable alternatives have not been considered. Besides the large adverse environmental impacts of the NWL,Norwich Green Group is also concerned about its land use and transport consequences. The NWL would create a complete third orbital road around Norwich and lead to further car-based urban sprawl and traffic growth. It would increase travel by private car especially between NE Norwich where major housing is located and SW Norwich where there are major employment sites. The report, Trunk Roads and the Generation of Traffic (DoT,1994) examined as a case study a full length NDR connecting up with the A47 southern bypass to the west and east of Norwich. It concluded that large scale development of land along the NDR corridor would result in “very significant” level of induced traffic on the new road.
Already, Broadland and South Norfolk Councils have located a major Food Hub which is dependent on car and lorry access, on land at Easton overlooking the Wensum valley. Land at Honingham, next door to Easton is flagged up in the GNLP Reg19 as a possible location if a new settlement is required.
Public transport catering for orbital movements is not in place. The NWL is not supported by a package of sustainable transport measures for discouraging traffic growth arising from the road scheme and encouraging modal shift.
The NWL Options consultation considered a large number of individual transport interventions, but it did not put forward comprehensive packages of sustainable transport options.
Not consistent with national policy and the legal target of Net Zero by 2050. The NWL would generate new traffic as shown by the case study in ‘Trunk Roads and the Generation of Traffic’ and this would increase carbon emissions.