Question 5: Is there anything you feel further explanation, clarification or reference?

Comment

Representation ID: 19903

Received: 11/02/2020

Respondent: Professor Stephen Church

The heading of this document is 'The Strategy'. There is no strategy here, just a report with some generalised comments about hopes for the future. The OED defines strategy as: 'The art or practice of planning or directing the larger movements or long-term objectives... '. You have no detail here so how can we comment?

Support

Representation ID: 20045

Received: 22/02/2020

Respondent: Mr Christian Amos

Much of our public transport runs in traditional routes but the road network now supports potentially increasing routes across communities to the north of the city from the UEA/Hospital to Broadland business park, rather than going in to the City to go back out again.

Object

Representation ID: 20592

Received: 10/03/2020

Respondent: Climate Friendly Policy and Planning (CFPP)

Please see attached for full representation

CONS bullet 84 introduces per capita CO2 footprints, whilst SA 2.11 (page 25)
introduced the population-wide footprint (from the DBEIS data for UK local
authority and regional carbon dioxide emissions national statistics). Whilst
both ways of looking at the data (per capita or population-wide) are valid, it
would be preferable to use just one. The population-wide footprint is the most
appropriate as that relates directly to the overall CO2 budget available.

Need for baseline carbon emissions, budgets and targets
17 The draft plan contains quite a few statements on Climate Change that sound promising
(for example, bullet CONS 82 “Mitigating the effects of climate change within the
Greater Norwich area is a cornerstone of the GNLP”) but which lack substance and any
clear demonstration of a route to their deliverability.
18 We have made the case, many times previously (please refer back to previous
consultations responses from NGP, CEPP and Dr Andrew Boswell) that the gap between
warm words and deliverability can only be achieved by fully understanding baseline
carbon emissions, setting a GNLP carbon budget that is aligned to national and
international obligations, and with measurable targets for achieving it. None of this
exists in the draft plan.
19 Again, we refer to the Stroud Draft plan as an example of good practice. Here the
Council declared a target to become carbon neutral by 2030, ahead of the current
Government target. This target has been brought into the local plan, joining up political
will with strategic planning3.
20 The situation in Greater Norwich is less clear politically with the County Council stating
in its Environmental Policy that it will work towards carbon neutrality by 2030, the City
Council having a 2050 target. And Broadland and South Norfolk apparently working
towards positions. There is a clear need for a unified target across the area, and for it
then to be embedded into the GNLP with the necessary policies to help deliver it through
the strategic planning system. No work appears to have been done on this, although the
time before the Regulation 19 consultation and subsequent process, gives space for
related political decisions to be progressed.

Object

Representation ID: 20759

Received: 12/03/2020

Respondent: Mr Andrew Cawdron

Flood Risk. This provides limited context to Norwich, but ignores the elephant in the room so clearly defined on the Greater Norwich Flood risk area, that if the sea/coastal defences are allowed to "naturally retreat" and not be defended, then a breach takes out large areas of the County. Is there a developed emergency plan ?
Para 88 And what warnings are in place for residents to relocate cars or prepare for flood in Norwich?

Comment

Representation ID: 20760

Received: 12/03/2020

Respondent: Mr Andrew Cawdron

Transport for Norwich: Until standards of affordability, reliability and quality to public transport are raised, there will be no substantive "modal shift" As these are privately owned companies (albeit subsidised) there are few opportunities to make them improve, particularly the bus companies.
Para 71 The "Wensum Link" option may have been identified, but does not have funding or planning and should therefore not be assumed in the GNLP.
Para 75 The cycle network. Where are the cycle network maps/boards in the City Centre? Why do you construct contra flow lanes without protection ? e.g Duke Street

Object

Representation ID: 21068

Received: 15/03/2020

Respondent: Saving Swainsthorpe Campaign

It is very hard to provide an effective commentary for this documents. The whole draft plan is in fact not a plan, it lacks any clear strategy, it reads as an aspirational 'wish list' rather than a statement of emerging priorities and supporting funding streams.

Comment

Representation ID: 21253

Received: 16/03/2020

Respondent: Lanpro Services

Agent: Stephen Flynn

Lanpro has a number of comments/questions on the following: It would be useful if actual numbers of required homes were specified in the document. Does the delivery percentage figure for 2015/16 and 2017/18 relate to the combined annual requirement for these years? Please can this be clarified? More information is needed on the City Deal – what it is and what it commits the Councils to deliver in terms of extra housing and employment over and above the JCS targets.

Comment

Representation ID: 21282

Received: 16/03/2020

Respondent: Dr Sarah Morgan

How is a need for 28% “affordable housing” to be met? Developing more homes does not make them “affordable” Affordable housing is an impossibility in the private sector because prices will only drop if the market becomes flooded and if that happens then the number of householders in negative equity will rocket with a very negative impact on social stability.

Comment

Representation ID: 21375

Received: 16/03/2020

Respondent: Glavenhill Ltd

Agent: Stephen Flynn

Glavenhill Ltd has a number of comments/questions on the following: It would be useful if actual numbers of required homes were specified in the document. Does the delivery percentage figure for 2015/16 and 2017/18 relate to the combined annual requirement for these years? Please can this be clarified? More information is needed on the City Deal: what it is and what it commits the Councils to deliver in terms of extra housing and employment over and above the JCS targets?

Comment

Representation ID: 21714

Received: 16/03/2020

Respondent: RSPB (East of England Regional Office)

Greater detail is required on resource management through the Local Plan. The HRA needs to be revised to fully reflect the importance of the area and not rely on reports that have not yet been finalised.

Comment

Representation ID: 21715

Received: 16/03/2020

Respondent: Brown & Co

It should be ensured that the strategy, and all carried forward and new allocations protect and enhance the special characteristics of not only the Greater Norwich area, but the County and Region as a whole. In order to meet the challenges of climate change it is vital to protect designated and non-designated sites, valued landscapes and biodiversity.

Comment

Representation ID: 21829

Received: 16/03/2020

Respondent: Natural England

Information provided under ‘The natural environment’ section needs to be improved and expanded as it currently is unclear or incomplete. It needs to recognise and include the issues that the natural environment, both within and adjoining the Plan area, is facing including biodiversity loss, climate change, habitat fragmentation, pollution etc and how the proposed Plan may impact on and address these issues. Currently, it could be read as the only issues facing our natural environment are those identified under (98), which is clearly not the case.
(97) Under (97) and throughout the Local Plan all references to ‘Natura 2000 sites’ should be replaced with ‘European Sites’ since Britain has left the European Union. It would be helpful to explain that in the National Planning Policy Framework (NPPF) these are referred to as ‘habitats sites’ as it is unclear from the text and Map 4 Major Habitat Sites in Norfolk nor are the abbreviations in the legend on the map explained. In addition to Map 4, a separate map (or series of maps) should be included which clearly illustrate the other natural environmental assets found within or adjacent to the GNLP area.

(98) This section needs to be expanded and made clearer with the impacts resulting from growth on water quality and water resources separated from recreational disturbance impacts. The Plan needs to recognise that recreational disturbance impacts affect not just internationally designated sites, but a wide range of other sites that are important for wildlife, including County Wildlife Sites (CWS).

(101) It needs to be clearly stated here that the existing green infrastructure (GI) network needs to be protected from further loss and severance, as well as new GI being created. Mention should also be made of the vital role of GI in:
 supporting biodiversity
 combating climate change
 reducing pollution
 helping to create attractive homes and places to work
 enhancing landscapes
 reducing flood risk, and
 contributing to wellbeing
The Plan needs to recognise that the protection and delivery of quality GI is key to delivering many of its objectives and growth cannot be regarded as being sustainable without this. In particular the Local Plan should promote the delivery of a strategic green infrastructure network that is resilient to the scale of development proposed, capable of protecting designated sites and supporting habitat, and delivering the wider range of environmental services to meet development needs.

Comment

Representation ID: 22033

Received: 13/03/2020

Respondent: East Suffolk Council

Paragraph 70 notes that the A146 forms part of the Government’s Major Road Network (MRN) of local non-trunk roads of national importance. East Suffolk is pleased that the importance of the A146 has been recognised as it is a key link between Lowestoft, Beccles and Norwich. The Suffolk County Transport Model (SCTM) – Preferred Option Traffic Forecasting Report (March 2018) notes that the A146 Norwich Road/Loddon Road and the A146 Norwich Road/A143 Yarmouth Road are two junctions that will reach 90-99% capacity by end of the Waveney Local Plan period, 2036. The two junctions are close to Beccles but fall within the South Norfolk Council/Greater Norwich area. Measures to address traffic issues on the A146 near Beccles are likely to be necessary in future reviews of Local Plans. (See page 36 of The Suffolk County Transport Model (SCTM) – Preferred Option Traffic Forecasting Report (March 2018) https://www.eastsuffolk.gov.uk/assets/Planning/Waveney-Local-Plan/Background-Studies/Suffolk-County-Council-Forecast-Highway-Modelling.pdf)

It may be of interest to the Greater Norwich Planning Policy Team to know that the Barnby Bends bypass Major Route Network improvement proposal has progressed to the next stage with funding to prepare an outline business case. Improvements to the section of the A146 near Barnby, commonly known as the Barnby Bends, would benefit the whole A146 route between Lowestoft and Norwich, and the A143 link to Diss and Bury St Edmunds.

Paragraph 73. The Norwich rail service provides direct access to Lowestoft. Please update the text to include Lowestoft in the list of rail destinations accessible from Norwich

Comment

Representation ID: 22180

Received: 16/03/2020

Respondent: Environment Agency (Eastern Region)

Emissions and climate change (page 23)
Paragraph 86 should be expanded to state that opportunities for carbon sequestration through environmental habitat improvements should be sought on-site and offsite either through carbon offsetting or biodiversity net gain.
This section states that climate change mitigation is a cornerstone of the plan. Reducing CO2 per capita is only one aspect of this. The plan should also seek to outline carbon sequestration measures, as well as strategic planning to ensure that there is greater resilience to temperature and rainfall increases. This policy should be underpinned by NLLP compulsory net gain.
Flood Risk (page 24)
The Flood Risk section includes Map 3 showing present day Flood Zones 2 and 3. However, the revised NPPF requires planning applications to include a Flood Risk Assessment if they are in the Future Flood Zones taking into account climate change. It would therefore be beneficial if the climate change enhanced flood outlines, as shown in the Greater Norwich 2017 SFRA, could be included in the flood risk section of the Local Plan. In addition, the title of Map 3 states ‘fluvial flood zones’, however the estuaries are at risk of tidal and fluvial flooding and so the map should be entitled ‘fluvial and tidal flood zones’. Tidal flood zone 3 has an annual probability of 0.5% (1 in 200) so the key on the map which states ‘Flood Zone 3 - 1 in 100’ should also be revised.

We agree that the plan will need to provide ‘strategic level policies to address flood risk in new development’. We recommend that the flood risk policies include details on what would be required to be included within a Flood Risk Assessment (FRA), and define what is safe in different situations, and so provide greater clarity that that provided in the PPG.
The policy should include information on the following:
 Sequential Test
 Exception Test
 Sequential Approach – higher vulnerabilities on lowest risk parts of the site
 Safety requirements for actual and residual risk for different development types – floor levels, resistant/resilient construction, access egress, flood emergency plans
 Offsite flood risk – compensatory storage
The new Greater Norwich SFRA includes some details about the FRA requirements, but it would be good if the requirements could be echoed or expanded upon within the flood risk policy, or the SFRA referred to in the policy.
In particular, it is the responsibility of the LPA and their Emergency Planner to determine when an Emergency Flood Plan can ensure the safety of a development and when the development requires dry floors and/or safe access to enable it to be safe in a flood. It would be advantageous if the Local Plan’s flood risk policy could stipulate these requirements for different development types at residual risk of flooding in a breach, and different development types at actual risk of flooding.
We require new more vulnerable development to have dry floors in the actual risk design fluvial 1% (1 in 100) / tidal 0.5% (1 in 200) annual probability flood event including climate change, and we require all development types to have refuge above the actual risk and residual risk 0.1% annual probability flood event including climate change.
We do not have minimum floor level requirements for less vulnerable development at actual or residual risk, or more vulnerable development at residual risk, instead they are allowed to be managed with Flood Response Plans and flood resistant/resilient construction, to the satisfaction of the LPA and their Emergency Planners. Therefore if the Local Plan could include details as to when this type of management of flooding is acceptable, or when there might be minimum floor level requirements for these type of developments to prevent flooding, then this is something that the flood risk policy should address.
Ecology
Regarding paragraphs 87 to 91 referring to flood risk, we would like to see more natural functioning of the water environment, including natural flood management measures from slowing the flow and retaining water upstream to reconnecting floodplains in the lower reaches of rivers. This will help to restore natural processes and contribute to improving the water environment under the Water Framework Directive.
As we have previously advised, all new developments should implement appropriate Sustainable Urban Drainage Systems (SuDS). We would like to see all new developments retaining as close to 100% of surface water as possible.

Given the importance of wetland habitat to the Greater Norwich area, this measure would help in protecting the water environment. SuDS provision will need to be included as part of the green infrastructure planning.
 Flood attenuation – helping to preventing surface water flooding, and flash flooding in the locality.
 Groundwater recharge – Storing surface water run-off and allowing it to be released slowly will help water to percolate back in to underground aquifers.
 Filtering Pollutants, allowing sediments to settle.
 Ecological benefits through creation of ponds, swales wetland areas and tree planting as part of SUDs schemes. This will create new habitats, and where land was previously industrial or agricultural, bring a quantifiable increase in ecological diversity. These features can also enhance the appearance and appeal of the built environment and have amenity value.
 A reduction in pressure on local sewerage infrastructure which may already be at capacity.
 Provide a source of water for urban activities such as gardening and bring benefits for recreation, education and wellbeing.
 www.susdrain.org/delivering-suds/using-suds/suds-principles/suds-principals
Using surface water as a resource is likely to become increasingly important as pressures on water resources increase in the future. Change in rainfall through climate change, rising population and urbanisation are all driving factors. Capturing and using rainfall within the urban environment can provide environmental benefits as well as increasing amenity value
Environmental Assets (The Natural Environment and Landscape) (page 26)
Paragraph 97 requires amending as Natura 2000 are European protected sites and not international as stated.
In terms of paragraph 100, county wildlife sites have no statutory protection and so needs rewording for example as “sites identified as of local conservation importance”. Local Wildlife rich habitats have no official designation but which are recognised as of biodiversity importance under S41of the Natural Environment and Communities Act. A good example of this in the Greater Norwich area are chalk streams, reedbeds and fens which may not have designations.
This section as a whole could be more progressive and more ambitious to include statements around natural capital, green infrastructure and natural functioning ecosystems.
The plan would benefit from having a specific section for the water environment. A specific section would help ensure all issues are covered. This plan must link to the Anglian River Basin Management Plan and state that developments must carry out Water Framework Directive (WFD) compliance assessments following guidance in Planning Inspectorates advice note 18 and ensure that the development does not cause a deterioration in WFD status of any element. The plan must explain the ‘no deterioration’ objective.
The plan should also refer to the Catchment Based Approach and Broadland Catchment Partnership. The Broadland Catchment Plan could provide opportunities for mitigation and net gain through partnership working.

The water environment section should also reference any significant water management issue which is frequently cited as a reason for not achieving good if it is linked to a development.
Water (page 29)
Water stress is impacting on chalk streams and other water dependent habitats in the Greater Norwich area.
Water Quality and protecting the local water environment must be referenced in this section. The Local Plan needs to acknowledge that growth and development in the area will put pressure on the water environment, especially in respect to meeting the tight environmental legislative targets set to protect bodies of water such as WFD and Habitats Directive. The "water" section should have a couple of sentences discussing this and highlight that the risks posed to the water environment primarily come from increased discharge volumes from wastewater discharges (sewage works/Water Recycling Centres) which will received a significant increase in wastewater from development within the district. The Local Plan is an essential instrument to ensure that additional foul drainage arising from new development does not put local rivers (and existing properties) at unnecessary risk of pollution and/or flooding by sewage and/or wastewater.

It is also essential that this section acknowledges that most of the River Wensum and two of its tributaries are a designated SAC (protected area under the Habitats Directive) and therefore have more stringent conservation (including specific water targets) to meet. The importance of ensuring this protected site is not impacted by growth and development should be highlighted.

Comment

Representation ID: 22270

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: 22382

Received: 16/03/2020

Respondent: Norwich Green Party

Delivery: exclude 'delivery' as factor to weigh against objectives in the interim sustainability appraisal. EG 'delivery' skews distribution of housing allocations in favour of dispersal options. Delivery is not an objective in the SA and should be disregarded for purpose of weighing up policies on sustainability grounds.

Para 83, per capita emissions underestimate carbon emission levels as they exclude, consumption, production, aviation, shipping and hence and hence reductions necessary is under-stated.

Para 84 needs to explain implications of hotter drier summers and warmer wetter winters for region and policy making. Need to refer to sea level rise, rise in river levels and possible implications for Norwich area.

Comment

Representation ID: 22483

Received: 16/03/2020

Respondent: Highways England

Useful if Map 2 Greater Norwich main transport links highlighted the Trunk Road and Major Road networks, together with the major scheme proposals which are programmed for delivery.

Comment

Representation ID: 22507

Received: 16/03/2020

Respondent: Broadland Green Party

How is a need for 28% “affordable housing” to be met, simply developing more homes does not make them “affordable”. Affordable housing is an impossibility in the private sector because prices will only drop if the market becomes flooded and if that happens then the number of householders in negative equity will rocket with a very negative impact on social stability. Councils within the GNDP need to develop workable schemes to fund low-carbon social housing on a scale that has not yet been realised.

The rail network – with the Greater Anglia franchise which started in August 2019 more reliable and frequent services should be planned to encourage travel and commuting by rail. Until there is a good weekend rail service it will not be possible to use the train, rather than the car, for leisure commutes within and out of Norfolk in both directions. This one simple change could save very many unnecessary car journeys to and from East Anglia and support a culture change to encourage train use.
The plan suggests Norwich Airport is a catalyst for economic growth but it is growth that is incompatible with a low-carbon economy and minimising the impacts of climate change. The Environmental objective (para 8c) of the NPPF specifically states the need to “mitigate and adapt to climate change, including moving to a low carbon economy.” It further states that “opportunities can be taken to secure net gains across each of the different objectives”. The expansion of Norwich Airport is clearly not compatible with the NPPF environmental objective.
The cycle network - there has been a 40% increase in cycling since 2013 in the Norwich urban area. Whilst there is focus on the city in the plan there is little mention of cycling elsewhere in Greater Norwich. At a recent consultation with Highways England on the dualling of the A47 at North Burlingham it was stated that footpaths and cycle routes will be looked at once the road has been designed. This is old style thinking and is not giving walking and cycling the prominence they deserve for the good reasons of health, sustainable transport and tourism.
Rural transport – little is said in the plan of developing rural bus services. Given the urgent need to reduce car journeys a greater emphasis needs to be put on rural transportation which includes bus, rail and cycling. Greater emphasis and integrated planning is needed with initiatives such as Connecting Norfolk to promote the use of demand responsive transport services and car sharing.
Digital infrastructure is vital to support rural enterprises and home-working. The mobile phone network is notoriously poor and the Better Broadband for Norfolk programme has not been successful in reaching many houses in villages where there has been the roll out of fibre broadband to a central node in a village but not beyond. Digital infrastructure must be given a greater priority in the years to come.
Emissions and climate change
It is stated in para 82 that “Mitigating the effects of climate change within the Greater Norwich area is a cornerstone of the GNLP”. In which case much more needs to be done in curbing carbon emissions through a radical review of the transport policy as explained above, and the building of energy efficient homes. The expansion of Norwich Airport and the road network is not compatible with “mitigating the effects of climate change”. This has a knock on effect on air pollution which it is accepted remains an important issue with more work to be done. To reinforce the need to review transport options it is also stated in para 84: they (CO2 emissions) are above the national average in rural parts of the area, partly due to a greater reliance on car journeys.
Renewable energy
92. Our plan should support further development of decentralised, renewable and low carbon sources of energy.
Greater emphasis needs to be placed on community energy schemes. Councils should consider smart grids, greater efficiency in housing (including retrofit insulation), greater on-site renewable energy production and energy balancing and storage. See later under Policy 2 regarding Part L of the 2013 Building Regulations.

Object

Representation ID: 22529

Received: 16/03/2020

Respondent: Historic England

Comment & Suggested Change:
Paras 93-96: We suggest a little more descriptive detail about the heritage in the Local Plan area. What is unique and distinctive about this place? What needs to be protected, conserved and enhanced? What heritage is at risk? What about historic landscape characterisation?

Para 93: We suggest changing historic assets to heritage assets, in accordance with the terminology used in the NPPF.

Para 95: We suggest you use the term Registered Parks and Gardens.

Para 96: We suggest you use the term scheduled monuments rather than ancient monuments, in line with the NPPF. Modern convention is to refer to scheduled monuments rather than scheduled ancient monuments, given that a wide range and age of monuments are scheduled.

Table 3: As above – use the terms Scheduled Monuments and Registered Parks and Gardens.

Object

Representation ID: 23069

Received: 16/03/2020

Respondent: Orbit Homes

Agent: David Lock Associates

Our concerns with regard to the Spatial Profile are closely related to the introductory comments
above and focus on the lack of alignment with the policy direction of the Plan. We make the
following observations:
• Wymondham is the largest settlement outside of the Norwich Urban Area. Whilst it has
been subject to a number of development site allocations/consents in recent years, the
location of Wymondham and its services and amenities make it an ideal location for
strategic growth. This is not realised in the Plan. Some minimal additional growth is
allocated in two locations on the edge of the town, but it is not of a scale which can secure
significant investment in infrastructure and thus will put pressure on existing services and
facilities. Examining the potential for the reasonable alternative of a new settlement in
this location – which would deliver a more sustainable pattern of growth than that
currently proposed for allocation – is not considered in the plan.
• There is need to re-balance growth in the Greater Norwich area which has focused on
Norwich itself and the north east triangle in particular. This growth is not aligned with the wider growth and economic strategies which underpin the plan. As the next largest
settlement in the plan area, as well as being located in the Cambridge-Norwich Tech
Corridor and with a close relationship to the world class facilities at Norwich Research Park
, Wymondham should be identified as the priority location for accommodating strategic
development.
• Paragraph 67 states that the A11 corridor is a major focus for growth. We do not consider
this to be the case in the GNLP as no strategic sites with immediate/direct access to this
route have been allocated. SGV is positioned squarely within the A11 corridor with direct
access to it, and therefore it is not clear why this location has been overlooked for
allocation to realise the Plan’s stated growth objectives.
• In addition - and contrary to the statement that the A11 is a major focus for growth - the
Plan highlights the growth opportunities arising from other priority road investment
schemes. These improvements have not yet been undertaken, and some still need to
secure approval and funding, yet growth is more closely associated with these ‘uncertain’
future improvements than it is with the newly dualled A11. We cannot understand how
this approach can be presented as robust or sustainable, given it fails to maximise
infrastructure investments already completed.
• The context of the Transforming Cities funding bids is welcomed as the projects identified
are important in promoting the modal shift away from the private car. However, as noted
above such investments should inform and lead the approach to allocating growth to
ensure that sustainable transport connections can be planned in from the outset and that
the benefits of funding and investment can be maximised. This is the case for the
Wymondham Mobility Hub which will significantly improve Wymondham’s public transport
offer and as such should influence and facilitate growth. If modal shift is to be achieved,
particularly in new developments, it is essential that they are well positioned and have
direct access to the improved public transport network, but also that they are of a scale
which does not simply perpetuate current mobility patterns to access necessary services
elsewhere.

Comment

Representation ID: 23099

Received: 31/03/2020

Respondent: Salhouse Parish Council

Why should Norwich not have a Green Belt (para 104)? This would address some of the objectives eg. paras 132, 133 and 144