Question 4: Are there any topics which have not been covered that you believe should have been?

Comment

Representation ID: 20044

Received: 22/02/2020

Respondent: Mr Christian Amos

Population by each of your defined areas would have been good to see, I believe, for instance Sprowston is officially identified as a town which is important in relation to infrastructure or lack there of, be it from a health, transport or social viewpoint.

Object

Representation ID: 20430

Received: 06/03/2020

Respondent: Miss ANGELA MAKINSON

Transport in villages on the outskirts of Norwich struggle with insufficient, unreliable bus services and without a car the only way to get to villages close by for access to shops, and other essential services, is by taxi which not everyone can afford. So some residents become isolated and feel abandoned. Ridiculous when they may only be four miles from the City. There is no reference that I could see to community transport solutions, nor low carbon options such as electric buses.

Comment

Representation ID: 20758

Received: 12/03/2020

Respondent: Mr Andrew Cawdron

Para 85 " Policies in the GNLP will need to contribute " should be "policies will contribute" and take the opportunity to set standards for any new development to be carbon neutral and provide bio-diversity net gain.

Comment

Representation ID: 21280

Received: 16/03/2020

Respondent: Dr Sarah Morgan

How to achieve Happiness and well being of the community now and in the future.Growth is not the solution.

Comment

Representation ID: 22269

Received: 16/03/2020

Respondent: Barton Willmore

Q3, Q4 & Q5) Greater Norwich Spatial Profile
2.7 Table 1 highlights the size of Wymondham as a settlement of significantly greater scale than
other centres. It is over double the size of the next settlement (Diss), and the facilities
available in Wymondham reflect that. Further Wymondham is served by a train station with
regular services to the regional employment hubs of Cambridge and Norwich. It is on the A11
linking the cities and within the Cambridge – Norwich Tech Corridor, highlighted in the
previous chapter as a strategic objective for growth. It is an obvious location to accommodate
growth.
2.8 Paragraph 34 acknowledges the residential profile of the area with a high student population
and an ageing population. It is accepted that students will live in smaller accommodation,
but page 16 of the Strategy clearly highlights that 81% of the housing need is for houses. As
such seeking higher density development (i.e. flatted developments) within the City Centre,
or within the Norwich Policy Area, will not deliver this need. High density family houses need
to be delivered in areas that are appropriate to that context, and where those most in needcan access local facilities. The focus of housing within the most urban areas will arguably
deliver housing that is not tailored to need. The Strategy and direction of growth should
clearly correspond to where the need can be provided for – and that is locations that can
deliver a range of 2 to 5-bedroom houses, including the appropriate amount of affordable
housing. Further, consistent with the vision, it should be directed to locations such as the
A11 and Cambridge to Norwich Growth Corridor, rather than such a broad distribution as
advocated. Again, it is clear that housing has been delivered in Wymondham and has delivered
the type of homes tailored to the local need, including 1-bed to 5-bed market and affordable
homes. This makes it a location to ‘rely’ on when actually ‘delivering growth’. In the context
of under-supply, and the unreliability of existing/previous allocations to deliver, the
Authorities should place greater emphasis on where the market is confident it can deliver.
Wymondham is this such location.
2.9 Reference at Paragraph 44 of the Draft Strategy that 87% of the Housing Target has been
delivered is inaccurate. Against a requirement of 22,506 dwellings in the period 2008/09 –
2018/19, only 18,221 dwellings have been delivered (a 4,283 dwelling shortfall), representing
circa. 80% delivery. The situation is even worse in the Norwich Policy Area where, against a
requirement of 20,163 dwellings only 13,994 dwellings have been delivered (a 6,169 dwelling
shortfall), representing only circa. 69% delivery.
2.10 Further reference to 133% of the housing target being delivered between 2015/16 and
2017/18 is wholly misleading, given the shortfall that exists (as highlighted further in
response to Question 9) of 4,283 homes. The shortfall increases to 6,169 homes within the
‘Norwich Policy Area’ where growth has been directed in the previous Plan period to 2026.
This extent of under-delivery requires the Authorities to fully assess how to ensure delivery
of the growth to 2038. It requires a review of where delivery has successfully occurred vs
where it has not, and as necessary re-calibrate the direction and location of growth to those
locations that have met or exceeded delivery requirements such as Wymondham.2.11 Drawing comparison to average performance across the Country is irrelevant, and the extent
of under-delivery we highlight in response to Question 9 should be clearly highlighted here,
as it impacts on affordability of housing, which is as local issue, rather than a national issue,
and highlighted as an acute issue in the Greater Norwich Area, worse than the national
average. It clearly provides the justification for a 20% buffer to be applied rather than the
9% advocated, a matter supported in assertions from the HBF.

Comment

Representation ID: 22381

Received: 16/03/2020

Respondent: Norwich Green Party

Para 81 refers to 'mitigating effects of climate change' but it is also essential to adapt to climate change (eg address risk of over-heating from rising temperatures) and to build resilience (eg strengthen local economic supply chains, protect agricultural land and green open spaces).
Flood risk: sea level rise and rising water levels in Broads and river systems have implications for flood risk in Greater Norwich.

Natural environment: reference needed to biodiversity emergency and nature-depleted state of UK. In order to enhance biodiversity, reduce urban over-heating, provide access to natural environments, reduce noise and air pollution and improve the quality of life: there is a need to: create new wildlife habitats as well as protect and enhance existing ones; substantially increase tree coverage and hedgerows in rural and urban areas; protect urban green open spaces from development eg sports grounds and not replace grass with hard surfaces.

Historic assets: (92) add 'medieval street pattern' as having shaped historic development of Norwich and line of city wall. See attached briefing paragraph 5. Norfolk Structure Plans referred to medieval street pattern which gave added protection to Norwich historic city centre.

Comment

Representation ID: 22506

Received: 16/03/2020

Respondent: Broadland Green Party

How to achieve happiness and wellbeing of the community now and in the future? Continued growth is not the solution. Norfolk Association of Local Councils (NALC) has a “Wellbeing strategy” which shows the way forward for a healthy and happy Norfolk. NALC represents nearly 500 councils and parish meetings across Norfolk with perhaps three or four thousand councillors, clerks, other staff and volunteers – all of whom are working for the well-being of their residents. Themes addressed in the NALC strategy include many issues that are pertinent to the GNLP and could be ideally referenced in the plan including:
• Low carbon economy and towards net zero
• Trees, hedges and wild flowers
• Biodiversity and wild life
• Neighbourliness, inclusive communities & inter-generational issues
• Water, flooding and irrigation
• The built environment, Housing & Planning
• Cars, car parking. park and ride, lift-sharing and public transport
• Services e.g. doctors, dentists, etc.
• Loneliness
• Shopping
• Coming to terms with the new technologies and AI
• Employment, self-employment, small businesses

CPRE expressed strong support for the NALC Well-being initiative and have agreed to work with NALC to achieve the mutually compatible aims.

Object

Representation ID: 22754

Received: 16/03/2020

Respondent: Mr Bryan Robinson

I have looked at the GNGB annual monitoring since 2011.

Norwich has dropped from 9th in the national retail rankings to 13th in the last decade ith a overall reduction in retail floorspace. It is acknowledged that on-line shopping is changing peoples’ shopping habits but the consultation fails to recognise other factors which have contributed to this decline. The vibrant city is dying due to transport and development policies. Cities need a mix of activities which feed off each other but the Plan continues the isolation of the city by moving retail and employer to the edges.

The CO2 emissions from transport per capita for all three LPAs have not decreased since 2011. This is without the impact of the NDR which will increase emissions further. The ambition for a modal shift in transport patterns is not working and I question whether this is a real intention or merely words to make the document conform to government policy.

“Accessibility to market towns and key centres of employment during the morning peak (0700-1000), returning in the afternoon peak (1600-1900)” has declined year on year. One must therefore ask whether the employment centres are in the right locations.

Both the general housing and affordable housing completions are shown as green on the RAG analysis. However until 2018/19 overall housing has fallen short of targets. More worrying the failure to achieve affordable housing targets resulting in a backlog need as outlined in the 2017 SMHA report. This is reviewed in more detail later.

There have been major losses in permitted employment floor space since 2011, particularly in Norwich. The minor increases in Broadland and south Norfolk fall well short of compensation. The fact that employment over the same period has increased would suggest a democratic change in work patterns of small start-ups from home which is totally ignored in the Plan.

I am unclear what the annual measurement for “Percentage of permitted town centre uses in defined centres and strategic growth locations” demonstrates but the figures suggest that this ambition is spectacularly failing.

“Objective 7: to enhance transport provision to meet the needs of existing and future populations while reducing the need to travel” is similarly failing.

Comment

Representation ID: 22842

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

Paragraph 54 of the Draft Plan states:
“Greater Norwich is key to the region's economy with considerable potential for growth in world class knowledge intensive jobs. Strategic employment sites and competitive land and business lets, mainly those in and around the Norwich and Wymondham area, support a globally significant growth axis within the Cambridge Norwich Tech Corridor.”

The Greater Norwich economy includes life-sciences, agri-tech, IT, leisure and culture, and retail. The Greater Norwich City Deal 2013 focusses on science, technology and advanced manufacturing. Paragraph 60 of the Draft Plan notes that “Rural enterprises are important to the local economy and home working is increasing in significance. The proportion of micro-businesses employing up to nine people is above the national average in Broadland and South Norfolk.”

We consider that whilst the GNLP emphasises the growth of hi-tech and food-tech industries, it has not addressed the low-tech sector. Whilst rural businesses are acknowledged as important to the local economy, we are concerned that this acknowledgement is not translated into policy later in the GNLP. We discuss this further, later in this representation.

Norwich City Centre has largest concentration of employment in Greater Norwich and is a focus for further employment growth. Paragraph 78 of the Draft Plan notes that successful modal shift has already been achieved through previous Transport for Norwich programme, with a 375,000 increase in Norwich bus journeys. This requires building on, with further improvement of the Park and Ride network which will allow capacity to rise in line with demand as more journeys switch to bus and as the growth strategy comes to fruition. The Draft Plan is constrained by a lack of detail on the Transport for Norwich review. This will include the Park and Ride network. We are promoting the Loddon P&R site, located on the only major transport route into Norwich without P&R facilities, as part of the solution to ongoing strategies to achieve sustainable transport and modal shift.