Question 6: Do you support or object to the vision and objectives for Greater Norwich?

Great vision: let's see it delivered. At the moment what is written reads like a political manifesto, and we know how they end up.

The projected vision is based on the premise that growth will deliver all sorts of wonderful good things - enhance the environment, the economy and peoples lives. The problem with this is that the received experience of much development in all parts of Britain and certainly in Norfolk since at least the 1970s is that it does not do this. Development brings more pollution, traffic, worsened services, more environmental damage, loss of countryside and lower quality lives. Unless the statements made can be proved by empirical evidence, they are nothing more than mis-selling advertising, and should not be included in any statement related to the policies being suggested. It is important that the public should not be mislead and the statement clearly does so at present based on the past experience of 40 years of 'growth policy'.

The vision and objectives highlight the need for the Greater Norwich Area to continue to develop, whilst maintaining its character.

The environment section looks self satisfied and self congratulatory. In fact this attempts to hide the reality that little has been done. This complacent attitude is disturbing considering the challenges that are there to be faced. Today in the Guardian 23/02/2020 the top scientists are saying that we are nearing the tipping point. When this happens there will be runaway climate change and attempts to control it well be too late. Most resources are already under strain due to over development. Take water - there are already disagreements between the farmers and the nature reserves.

I wholeheartedly support the objectives but there is a wide gap between writing the objectives and actually delivering on them. I think the delivery will be a massive problem because it requires commitment, real understanding and consultation with the local communities so these objectives are carried through WITH the residents rather than inflicting change upon them.

The strategy seeks "growth [that] will be clean and resource efficient, with significantly reduced emissions", yet much of the growth proposed will inevitably deliver exactly the opposite effect, largely because the (wish-list) infrastructure simply does not exist in the right locations and, for the most part, will not in the foreseeable future. The 'village cluster' concept is particularly flawed in this respect and a handful of primary schools capable of some expansion, which forms much of its cited 'infrastructure', is nowhere near adequate. Prioritising brownfield sites in Norwich and the larger satellite communities would be a more responsible choice.

The topics included within the Vision and Objectives for GNLP are generally supported. However, it is considered that the objectives related to homes and delivery would not be achieved in full because in some instances inappropriate sites have been selected as preferred options or reasonable alternatives.

For example, a number of strategic extensions (for 1,500 dwellings) and garden villages (for 6,500 dwellings) have been identified as reasonable alternatives for housing allocations at Wymondham. These sites are inconsistent with the preferred development strategy in GNLP, which identifies a contingency approach of only 1,000 dwellings for Wymondham to offset non-delivery. It is very unlikely that strategic extensions or garden village would be delivered quickly enough to address a housing land supply shortfall in the short term. The lead-in times for these types of developments are typically more than 5 years, largely because they are complex and require significant levels of primary infrastructure to be provided e.g. roads and drainage in advance of housing. It is also typical that strategic extensions and new settlements are unable to provide policy compliant levels of affordable housing during the initial phases because of the costs of providing primary infrastructure. Therefore, it is considered that the strategic extensions and garden villages identified as reasonable alternatives for housing allocations at Wymondham would not meet the mixed housing tenure aim of the homes objective or meet the housing needs aim of the delivery objective. As set out in the representations to the GNLP Site Allocations document for the Wymondham sites, there are constraints at the strategic extensions and garden villages sites which indicate that they should not have been identified as reasonable alternatives, and should not have been identified in preference to smaller sites which can be delivered more easily and where constraints can be mitigated e.g. land south of Gonville Hall Farm in Wymondham (Ref. GNLP0320).

The topics included within the Vision and Objectives for GNLP are generally supported. However, it is considered that the objectives related to homes and delivery would not be achieved in full because in some instances inappropriate sites have been selected as preferred options or reasonable alternatives.

For example, a greenfield site at land south of Le Neve Road, Marsham (Ref. GNLP2143) is identified as a preferred housing allocation, when a site containing vacant and unused buildings/hardstanding associated with a former poultry unit at Fengate Farm, Marsham (Ref. GNLP3035) is available for development but is identified as an unreasonable alternative. This outcome would not make efficient use of land, which is part of the homes objective for GNLP. As set out in the representations to the GNLP Site Allocations document for the Marsham sites, there are no technical constraints to residential development at the Fengate Farm site and as a 2.6ha site with vacant buildings and having existing residential development on three sides it should have been preferred for housing ahead of any greenfield site.

A major concern is that the draft plan largely consists of a wish list, but lacks real targets or actions, particularly on the environment and climate change. For example, our environment is lauded but the draft plan notes in paragraph 37 that life expectancy for men in Norwich is 10.9 years lower in the most deprived areas compared to the least deprived. We cannot see any specifics within the draft plan as to how this shocking fact is to be addressed.

Paragraph 120 stresses the need for ‘good access to services and facilities’ for ‘our suburbs, towns and villages’. While this is provided in the first two categories of settlement there is insufficient provision or access to services in many of the settlements within the “village clusters”. The decision to allocate additional new housing beyond what is already allocated within the JCS is based almost solely on the existence of a primary school with available places or potential for expansion within the “cluster”. This does not amount to the provision of ‘good access to services and facilities’ and therefore this level of new housing in “village clusters” should not be permitted within the GNLP.

Paragraph 125 is perhaps the strongest argument for not allocating additional housing to “village clusters” within the GNLP. Clearly, there will be a major need for journeys from and to work for many of those living in any such new housing, in addition to additional journeys by delivery vehicles to this new housing. This paragraph states the need for ‘a radical shift away from the use of the private car, with many people walking, cycling or using clean public transport.’ For the majority of the plan period it is highly wishful thinking to think that ‘electric vehicles will predominate throughout Greater Norwich’. These additional journeys will not only add to the “carbon footprint” but will also add to congestion on the road network, affecting air quality and the wellbeing of residents. If the intention of the GNLP is to locate housing close to jobs, which we agree should be a major aim, then any additional allocations of housing should be located in or close to Norwich, where there are realistic opportunities to walk or cycle to work and to services, or to use public transport to do so. The existing allocations of housing within the JCS and to be carried forward to the GNLP will provide sufficient new accommodation close to other places of work in main towns and key service centres.

Paragraph 129 states: ‘greater efficiency in water and energy usage will have minimised the need for new infrastructure, and further reductions in carbon emissions will be delivered through the increased use of sustainable energy sources. New water efficient buildings will have also contributed to the protection of our water resources and water quality, helping to ensure the protection of our rivers, the Broads and our other wetland habitats.’ We strongly feel that it is imperative that Per Capita Consumption (PCC) of water is further reduced to below the Government’s prescribed 110 litres per person per day in order to deliver this statement in paragraph 129. East Anglia is the driest region in the UK: our aquifers, rivers and wetlands are already at breaking point, as are many of the region’s farmers, who are seeing their abstraction licences reduced or revoked. If more demanding standards to reduce PCC water consumption are not set as part of the GNLP, this will further adversely impact upon the environment, impacting on the Broads and wetlands, which in turn will impact the region’s aspirational growth for tourism and will severely impact the regional agricultural economy. To ensure that the water-supply to existing users is not compromised it is sensible to restrict the number of new houses to a level that realistically covers actual need, and this fact reinforces our case for phasing of housing and our questioning of the need for a higher than necessary buffer.

Paragraph 132 makes the claim that new quality development will be located to minimise the loss of green-field land. CPRE Norfolk strongly suggests that the best way to achieve this is not to allocate additional sites for housing in “village clusters”. Indeed, there are already sufficient allocated sites for housing in the JCS being proposed to be carried forward to the GNLP in the Norwich fringe parishes, main towns and key service centres to keep pace with the likely build rates of development. The exception to this should be any brownfield sites, particularly those within Norwich, which should be prioritised into a “brownfield first” policy. This should form part of a phased approach to new housing, so that existing allocations from the JCS and any brownfield sites should be developed before permitting any additional allocated sites to be built-out.

One effective way to prevent the unnecessary loss of much greenfield land would be to institute a green belt on the “green wedges” model around Norwich, as requested by 84 respondents and 1,912 petition signatories (currently at 2,200 signatures) calling for this according to the draft statement of consultation, September 2018, for the Stage A Regulation 18 Site Proposals and Growth Options consultation. CPRE Norfolk is very concerned that this proposal or option has been removed from the current consultation.

In conclusion for this question, we find that the vision and objectives contain serious flaws, especially in regard to the way in which they conflict with policies within the current Local Plan, which withstood the rigorous inspection process.

A major concern is that the draft plan largely consists of a wish list, but lacks real targets or actions, particularly on the environment and climate change.

Paragraph 120 stresses the need for ‘good access to services and facilities’ for ‘our suburbs, towns and villages’. While this is provided in the first two categories of settlement there is insufficient provision or access to services in many of the settlements within the “village clusters”. The decision to allocate additional new housing beyond what is already allocated within the JCS is based almost solely on the existence of a primary school with available places or potential for expansion within the “cluster”. This does not amount to the provision of ‘good access to services and facilities’ and therefore this level of new housing in “village clusters” should not be permitted within the GNLP.

Paragraph 125 is perhaps the strongest argument for not allocating additional housing to “village clusters” within the GNLP. Clearly, there will be a major need for journeys from and to work for many of those living in any such new housing, in addition to additional journeys by delivery vehicles to this new housing. This paragraph states the need for ‘a radical shift away from the use of the private car, with many people walking, cycling or using clean public transport.’ For the majority of the plan period it is highly wishful thinking to think that ‘electric vehicles will predominate throughout Greater Norwich’. These additional journeys will not only add to the “carbon footprint” but will also add to congestion on the road network, affecting air quality and the wellbeing of residents. If the intention of the GNLP is to locate housing close to jobs, which we agree should be a major aim, then any additional allocations of housing should be located in or close to Norwich, where there are realistic opportunities to walk or cycle to work and to services, or to use public transport to do so.
Paragraph 129 states: ‘greater efficiency in water and energy usage will have minimised the need for new infrastructure, and further reductions in carbon emissions will be delivered through the increased use of sustainable energy sources. To ensure that the water-supply to existing users is not compromised it is sensible to restrict the number of new houses to a level that realistically covers actual need, and this fact reinforces our case for phasing of housing and our questioning of the need for a higher than necessary buffer.

Paragraph 132 makes the claim that new quality development will be located to minimise the loss of green-field land. Hempnall Parish Council strongly suggests that the best way to achieve this is not to allocate additional sites for housing in “village clusters”. Indeed, there are already sufficient allocated sites for housing in the JCS being proposed to be carried forward to the GNLP in the Norwich fringe parishes, main towns and key service centres to keep pace with the likely build rates of development. The exception to this should be any brownfield sites, particularly those within Norwich, which should be prioritised into a “brownfield first” policy. This should form part of a phased approach to new housing, so that existing allocations from the JCS and any brownfield sites should be developed before permitting any additional allocated sites to be built-out.

In particular we ask that if additional sites, such as on the Britvic/Unilever Carrow Works site or the Anglia Square site (both in Norwich) become available for development, then these will not be counted as additional houses to the published targets, but that instead the extra housing numbers provided by these sites will be taken off the numbers scheduled for rural areas, reflecting the favoured view from the previous consultation for concentration of housing in and close to Norwich. In addition, this would help the GNLP to meet its Climate Change targets as well as providing more sustainable housing. We hope that a change of this nature can be accommodated before the Regulation 19 stage of the GNLP.

One effective way to prevent the unnecessary loss of much greenfield land, which in most instances is of a high quality for agriculture, would be to institute a green belt around. It is a matter of regret that this option has not been included in the current Draft plan.

In conclusion to this question, we find that the vision and objectives contain serious flaws, especially in regard to the way in which they conflict with policies within the current Local Plan, which withstood the rigorous inspection process.

The objective of delivering high quality homes that contribute to the delivery of mixed, inclusive, resilient and sustainable communities that are supported by appropriate economic and social infrastructure is fully supported. The approach is fully consistent with the National Planning Policy Framework.

The whole document argues for " growth" in an unthinking and unchallenging manner and then pins labels on it, such as "sustainable". The plan is "generating the right levels of growth in the right places will help our local economy." As the plan places "growth" sites everywhere from "clusters" to Greater Norwich it is difficult to assess the validity of such a claim. Without zero carbon targets it is impractical to argue that the levels of construction, occupation, new journeys proposed will not fuel greenhouse gas emissions. It is disappointing that no future proofing or new thinking is shown.

Again we talk about communities , but to big and you will kill the existing communities , and potentially drive people away . We moved to Wymondham for the town and community we and others will not want to live in a massive housing development. particularly as since we moved onto our new development withy the plans for new schooling new care homes and health facilities none appear to be materialising . We know of families that are having to use taxis to get their children to school outside the area as Wymondham is full.

The vision clearly states the need for "a radical shift away from the use of private car, with many people walking, cycling or using clean public transport". Horsford has limited local employment so further development within the village would mean more use of cars to get to work to in Norwich, and Norwich is a long way to walk or cycle to work, so this vision is not possible for the residents of Horsford.

The objective of delivering high quality homes that contribute to the delivery of mixed, inclusive, resilient and sustainable communities that are supported by appropriate economic and social infrastructure is fully supported. The approach is fully consistent with the National Planning Policy Framework.

The objective of delivering high quality homes that contribute to the delivery of mixed, inclusive, resilient and sustainable communities that are supported by appropriate economic and social infrastructure is fully supported. The approach is fully consistent with the National Planning Policy Framework.

Lanpro is generally supportive of the overall vision. We support paragraph 108 which states:

“our aim is that it will support growth of a diverse low carbon economy which will compete globally through its world class knowledge-intensive jobs in the Cambridge Norwich Tech Corridor”.

We support the ambition set out in paragraph 119 that:

“Most new homes will have been built in and around Norwich and in the Cambridge-Norwich Tech Corridor.”

However, we are not convinced the plan will deliver on either of these aims for reasons set out in our answers to questions 13 and 14 in particular.

Paragraph 113 should also refer to employment growth being provided on strategic sites in the Cambridge-Norwich Tech Corridor as well as in and around Norwich. Otherwise the aim set out in paragraph 108 cannot be met.

We are concerned that the vision for new schools, health facilities to be expanded to serve growing communities (paragraph 127) is not compatible with the dispersal of such significant numbers to small villages in the rural parts of South Norfolk.

Lanpro offer their support to the concept of village clusters, agreeing that there is a need to allocate new housing in accessible, rural locations to help support sustainable patterns of growth. However, we do not consider that dispersal of such large numbers (1200) homes to small villages throughout South Norfolk is compatible with the stated environment objectives, which include reduction of emissions, as it will inevitably increase car and other journeys. Small villages, particularly those falling outside of the old Norwich Policy Area are not generally sustainable locations for growth and directing 9% of allocations to such settlements is too high a figure. A smaller proportion of homes directed to accessible cluster villages with a primary school would be more appropriate.

We need to move the 'Environment' to the TOP of the list as this provides our basic human needs - water, air, food etc. The economy etc should be strategised within the confines of the environment not the other way round - go back to Brundtlands 'sustainable' definition to meet the needs of the present WITHOUT harming the ability of future generations to meet their needs. Don't just 'provide' for active travel or passive homes but prioritise these to make them a natural preferred choice for people - eg with local facilities not having to drive to supermarkets

Many "Village Clusters" do not have sufficient provision or access to services.
The "Village Clusters" concept does not work towards the 'radical shift away from the use of the private car' as most do not have reliable public transport or are near areas of employment.
Most development in "Village Clusters" will be on green fields.

Glavenhill Ltd is generally supportive of the overall vision. We support paragraph 108 which states:

“our aim is that it will support growth of a diverse low carbon economy which will compete globally through its world class knowledge-intensive jobs in the Cambridge Norwich Tech Corridor”.

We support the ambition set out in paragraph 119 that:

“Most new homes will have been built in and around Norwich and in the Cambridge-Norwich Tech Corridor.”

However, we are not convinced the plan will deliver on either of these aims for reasons set out in our answers to questions 13 and 14 in particular.

Paragraph 113 should also refer to employment growth being provided on strategic sites in the Cambridge-Norwich Tech Corridor as well as in and around Norwich. Otherwise the aim set out in paragraph 108 cannot be met.

We are concerned that the vision for new schools, health facilities to be expanded to serve growing communities (paragraph 127) is not compatible with the dispersal of such significant numbers to small villages in the rural parts of South Norfolk.

Glavenhill Ltd offer their support to the concept of village clusters, agreeing that there is a need to allocate new housing in accessible, rural locations to help support sustainable patterns of growth. However, we do not consider that dispersal of such large numbers (1200) homes to small villages throughout South Norfolk is compatible with the stated environment objectives, which include reduction of emissions, as it will inevitably increase car and other journeys. Small villages, particularly those falling outside of the old Norwich Policy Area are not generally sustainable locations for growth and directing 9% of allocations to such settlements is too high a figure. A smaller proportion of homes directed to accessible cluster villages with a primary school would be more appropriate.

Para 109: The vision statement prioritises economy over people - this does not feel right. Why not explicitly link appropriate elements of the Norfolk County Council Plan core outcomes: Thriving People, Strong Communities and Growing Economy? Para 110 addresses some of this, but this is not the Vision - these are described as outcomes of the vision.

Point 120, in practice, increased housing and population is leading to inner city wilderness NOT “lively and vibrant city and district centres”
Norwich and norfolk have a lively and vibrant city centre now and many of the outlying towns also (eg Sheringham, Reepham) please don’t seek to “fix something not broken! The towns that are losing their vibrant identity are those plagued by doughnut development eg Stalham High Street which should be the heart of its community has been destroyed by the development of the supermarket on its fringes, a scenario which has played out all over the UK now.

Regarding infrastructure/transport point 123
Will there ever be good weekend service provided to and from London (not available for the last 20 years + to my knowledge?!?) Will it be possible to use the train rather than the car for leisure commutes in either direction, this one simple change could save very many unnecessary car journeys to and from East Anglia and create a culture change to encourage train use. It is difficult to have faith in the statement that our transport infrastructure will have been enhanced by 2038 when this basic requirement has been so elusive for so long

We are pleased that the greater part of the new GNLP developments will be in the Norwich area. Fortunately, Norwich has many brownfield sites available. Even more important, Norwich has the infrastructure and services to support development. For example; hospitals, universities, research parks, good schools, museums, entertainment facilities, public transport and so on.
It is, therefore, of concern that South Norfolk are proposing 1200 additional dwellings by providing for estate development throughout the village clusters as well as small scale windfall developments amounting to an extra 400 houses. These would be in addition to the 1349 dwellings already allocated.

The site owners support the vision and objectives for the Greater Norwich Area with regards to the economy as they recognise the role that smaller scale employment sites have in helping to deliver good access to jobs for all. However, the role that smaller scale employment sites across the area will play in delivering jobs should be recognised within Policy 6 ‘The Economy’, and a flexible policy approach should be adopted that allows for the appropriate expansion of existing small and medium size employment sites to meet needs not anticipated by the Local Plan and businesses changing requirements.

With the above national policy context in mind, we consider draft Policy 6 is not flexible enough to meet the changing requirements of businesses and request that paragraph 2 is amended to allow for the expansion of small and medium sized sites, such as Abbey Farm Commercial Park. We therefore request that Policy 6, Paragraph 2 is amended as follows:

2.The needs of small, medium and start-up businesses are addressed through:
• the allocation and retention of smaller scale employment sites across the area and the
potential expansion of, a range of existing small and medium sized sites (LPP suggested text);
• encouraging the provision of small-scale business opportunities in all significant residential
and commercial developments and through the appropriate use of rural buildings;
• Encouraging flexible building design and innovative approaches in new and existing residential
developments to encourage local working and business opportunities.

Please see attached for consultation response from Hempnall Parish Council.

Please see also the Hempnall Parish Council Position Statement on sites in Hempnall proposed by landowners for inclusion in the GNLP - included with this submission. This Position Statement, which deals directly with the detail of what Hempnall Parish Council wants for Hempnall, should be considered alongside our consultation response which makes a number of more general comments about the Draft GNLP.

We support the vision for Greater Norwich, it is considered that the proposals for a new settlement, Honingham Thorpe, with associated Country Park and relationship with the Food Enterprise Park would provide a unique opportunity to achieve these.

Yes, the RSPB supports the principles outlined, but is difficult to provide specific comments due to the lack of detail provided. We support calls for greater aspiration with respect to achieving net zero emissions as early as possible (i.e. before 2050) and more stringent water targets. If Norfolk County Council has adopted steps for their assets to be carbon neutral by 2030 (as highlighted in footnote 51 of the Strategy Document, p.40) surely this should be applied to new development in the Greater Norwich area as a minimum and 2038 (i.e. the end of the plan period) as a maximum? We urgently to take steps as quickly as possible to tackle the climate crisis. Nature has a major role to play and the GNLP has a key role in championing nature-based solutions. The RSPB would be happy to be part of conversations to explore this approach.

Please find attached representations, submitted on behalf of our Client – Berliet Limited.

Please see attached for full submission