Question 8: Is there anything that you feel needs further explanation, clarification or reference

Support

Representation ID: 20022

Received: 21/02/2020

Respondent: Mr Trevor Bennett

I am happy with the explanations given

Support

Representation ID: 20876

Received: 13/03/2020

Respondent: Town and Country Planning Association

The TCPA is pleased to see the proposed vision articulates a commitment to vibrant, healthy, inclusive and growing communities. We would urge the Councils to further recognise and include the role of high-quality design in creating healthier environments to promote active lifestyles in their vision.

Comment

Representation ID: 21263

Received: 16/03/2020

Respondent: Lanpro Services

Agent: Stephen Flynn

Explanation and justification should be provided for removing the Norwich Policy Area (NPA). If it is the case that the Strategic Growth Area effectively replaces the NPA then the plan should ensure that new allocations are focussed within that area, particularly the Cambridge Norwich Tech corridor part of it.

Comment

Representation ID: 21379

Received: 16/03/2020

Respondent: Glavenhill Ltd

Agent: Stephen Flynn

Explanation and justification should be provided for removing the Norwich Policy Area (NPA). If it is the case that the Strategic Growth Area effectively replaces the NPA then the plan should ensure that new allocations are focussed within that area, particularly the Cambridge Norwich Tech corridor part of it.

Comment

Representation ID: 21435

Received: 16/03/2020

Respondent: Dr Sarah Morgan

Point 130, what will actually produce greater efficiency in water usage?Equally point 130 how will reduction of air pollution be achieved despite the massive planned road expansion and destruction of woodland and green areas which are planned ?

Comment

Representation ID: 21718

Received: 16/03/2020

Respondent: Brown & Co

Further clarification should be provided as to how delivery will be achieved, and how the delivery of individual sites will be evidenced, particularly for those sites which failed to deliver during the previous Plan period. Further clarification should also be provided on when the Council would seek to intervene in the non-delivery of infrastructure and how this would be done.

Comment

Representation ID: 21727

Received: 16/03/2020

Respondent: RSPB (East of England Regional Office)

As per comments in question 6, the objects as written come across more as aspirations than objective statements. We recommend a tabular representation showing how the objectives link to outcomes and outputs. Objectives are best understood and conveyed when they are SMART – specific, measurable, achievable, realistic and time-bound, otherwise they are just aspirational statements. The RSPB would be happy to discuss options and help shape this element of the plan.

Object

Representation ID: 21818

Received: 12/03/2020

Respondent: Barford Parish Council

Why do the architects of the GNLP vision believe the continued building of clay-brick-built houses is compatible with environmentally sustainability given the high carbon footprint of such technology?

Comment

Representation ID: 22181

Received: 16/03/2020

Respondent: Environment Agency (Eastern Region)

Environment (page 34)
In regards to paragraph 130, there is an enormous challenge in finding water for new developments. We don’t currently have the technology with no consumptive use of water. Some technologies being considered could produce high amounts of carbon e.g. desalinisation, pumping water from other areas. This should be recognised here and the fact that we need to be thinking more holistically about water use for example increasing infiltration and groundwater recharge in headwaters. Using slow the flow techniques and retrofitting water saving measures to existing properties could be considered. We would suggest the following addition: "New water efficient buildings will have also contributed to the protection of our water resources and water quality, helping to ensure the protection and encourage enhancement of our rivers, the Broads and our other wetland habitats". This section should discuss the importance of ensuring that new development does not result in a breach of environmental legislation. A breach of legislation due to the increased polluting load from wastewater treatment works serving those developments.
It is not clear how greater efficiency in water and energy usage will minimise the need for new infrastructure – any new development will still require connection to facilities such as sewerage, mains water and electricity supply; as well as transport links.
Water efficient building can contribute to the protection of water resources, however more people, more buildings and more infrastructure will inevitably lead to greater pressure on the broads and wetland habitats. The plan should insist that all new development is required to aim for 100% retention of surface water through a variety of means. This is the opportunity to raise the bar for development in the GNLP area.
The plan should be clear in stating that there is the need for new developments to incorporate water saving and grey water recycling technologies, sustainable heating solutions and good insulation for example.
Paragraph 133 should mention the importance of trees in providing climate resilience through increased percolation rates (reducing flood risk), shading and cooling rivers in as well as urban and rural areas (also contribute to net zero carbon emissions).

Comment

Representation ID: 22183

Received: 16/03/2020

Respondent: Environment Agency (Eastern Region)

Environment
This section should ensure that the biodiversity crisis is just as pressing as the climate crisis and that the two problems are linked. It should be given more weight with separate plans and objectives.

Comment

Representation ID: 22273

Received: 16/03/2020

Respondent: Barton Willmore

Q6, Q7 & Q8 – Vision & Objectives for Greater Norwich
2.12 The vision is broadly supported, but the means of achieving it and how growth is distributed
is not supported by our client. For reasons set out in responses to latter questions, the
number of homes to be delivered should be increased, to improve affordability, particularly
in context of shortfalls to date. To reduce emissions and enhance green infrastructure,
development needs to be planned for in a means that minimises the number of trips
undertaken. People will always need to travel for work, and for various other purposes, and
it is important therefore to locate growth in areas where public transport is accessible.
However, it is also essential to minimise the number of small trips – i.e. to a convenience
store; to a local school etc. particularly for those less affluent who may not be able to afford
electric and hybrid vehicles in the short-medium term. The plans for NE Wymondham
presented will provide immediate day to day convenience needs and a primary School serving
in excess of circa. 1,000 homes within walking distances of the Site, alongside access to bus
stops within walking distances with services into Norwich and the train station, as well as
dedicated cycle access to Norwich.
2.13 Paragraph 114 of the Strategy advises that jobs growth will be delivered on strategic sites in
and around Norwich, with good access to the public transport and the major road network.
However, the Cambridge – Norwich tech corridor represents the most sustainable option to
achieve such growth, but equally it is essential that new homes are made available in the
same corridor to cater for those that may be employed by the new jobs. Strong cycle links
into the City Centre are also essential, and this highlights the need to focus development in
locations where public transport, major roads and cycle access is readily available.
Wymondham is one such location within the Tech Corridor. The Authorities’ desire to locate
up to 1,200 homes in villages – based on allocations that would support no more than 25
homes, would in most instances mean that none of these three criteria would apply. To
actively set aside an arbitrary number of homes (1,200) potentially in areas where there are
limited services, no cycle facilities and limited public transport, would be contradictory to the
principles of sustainable development, and thus contrary to the NPPF and the NPPG. It would
fail all 4 tests of soundness contained in Paragraph 35 of the NPPF.2.14 Paragraph 117 highlights that sustainable communities will be where people have good access
to “services and facilities including schools, health care, shops, leisure, and community
facilities and libraries – which in turn reduce the need to travel”. Accordingly, irrespective of
previous allocations, this Local Plan should undertake services audits of each settlement
(including the villages), outside the obvious case of the city centre, and identify a hierarchy
of centres. Those centres with the greatest variety of services and accessibility should then
be identified as the priority for accommodating future growth. There appears to be no suchassessment within the Local Plan or its supporting evidence base, and thus the soundness of
the strategy for growth is brought immediately into question. Indeed the Growth locations
identified in Map 7 appear to have no rationale, aside from simply carrying forward allocations
from the previous plan period irrespective of whether they have delivered, or meet the tests
of soundness for compliance with national policy in 2020, as opposed to when the previous
iteration of the Plan was prepared.
2.15 Similarly, our client wholly supports the sentiment of Paragraph 126, seeking to achieve a
radical shift away from the use of the private car. Locations with good quality footpath and
cycle links, as well as access to public transport are the most likely locations to achieve such
a shift. This is the case for land to the northeast of Wymondham, which has footpath links to
the town centre, and dedicated cycle routes into Norwich City Centre. However, achieving
this shift will be far more difficult in rural locations and small settlements, where roads are
narrow and cannot accommodate cycle/footpaths.
2.16 The Plan’s Objectives are set out on Page 34, with reference to promoting the ‘delivery’ of
housing, jobs and infrastructure to meet needs. The word delivery being key, as it is a key
test of the NPPF. The previous Plan period has failed to deliver the needs of the Greater
Norwich Area, particularly in respect of housing as set out in our response to Question 9.
This has impacted on affordability and access to housing. The Plan should recognise the
shortfalls of over 6,100 homes across the Norwich Policy Area and seek to remedy it through
directing growth to locations that have delivered successfully.

Comment

Representation ID: 22322

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

2. VISION AND OBJECTIVES
2.1 The Vision for Greater Norwich identifies that the GNLP will stimulate the creation of a strong, enterprising, productive and broad-based economy including through the provision of smaller scale employment sites within the market towns and villages to provide access to jobs for all. This accords with the economic objective of sustainable development which is to be welcomed. It will require that an appropriate distribution of jobs and homes is achieved through the plan.
2.2 The Vision aims to ensure that people of all ages will have good access to services and facilities including schools, health care, and community facilities which will reduce the need to travel. This accords with the economic, social and environmental objectives of sustainable development which is supported. It will require that housing which supports the needs of all age groups is delivered in locations which have good access to community facilities particularly with good access to sustainable transport connections.
2.3 The Vision seeks to ensure that a range of types, tenures and sizes of homes will have been built to respond to the needs of the area, including those of the older population and those in affordable need. Again, this accords with the social objective of sustainable development and is supported.
2.4 The Vision then indicates that the need to travel will have reduced including through a better alignment of the distribution of homes and facilities, an increase in home working, as well as an increase in the use of sustainable modes of transport. This will require that new housing is provided at locations where there is a shortage of workers and/or that housing is provided in locations with sustainable transport connections to major employment hubs.
2.5 The Vision also identifies that educational and healthcare facilities will have been expanded or new facilities provided which again accords with the social objective of sustainable development and is to be welcomed.

Comment

Representation ID: 22363

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

2. VISION AND OBJECTIVES
2.1 The Vision for Greater Norwich identifies that the GNLP will stimulate the creation of a strong, enterprising, productive and broad-based economy including through the provision of smaller scale employment sites within the market towns and villages to provide access to jobs for all. This accords with the economic objective of sustainable development which is to be welcomed. It will require that an appropriate distribution of jobs and homes is achieved through the plan.
2.2 The Vision aims to ensure that people of all ages will have good access to services and facilities including schools, health care, and community facilities which will reduce the need to travel. This accords with the economic, social and environmental objectives of sustainable development which is supported. It will require that housing which supports the needs of all age groups is delivered in locations which have good access to community facilities particularly with good access to sustainable transport connections.
2.3 The Vision seeks to ensure that a range of types, tenures and sizes of homes will have been built to respond to the needs of the area, including those of the older population and those in affordable need. Again, this accords with the social objective of sustainable development and is supported.
2.4 The Vision then indicates that the need to travel will have reduced including through a better alignment of the distribution of homes and facilities, an increase in home working, as well as an increase in the use of sustainable modes of transport. This will require that new housing is provided at locations where there is a shortage of workers and/or that housing is provided in locations with sustainable transport connections to major employment hubs.
2.5 The Vision also identifies that educational and healthcare facilities will have been expanded or new facilities provided which again accords with the social objective of sustainable development and is to be welcomed.

Comment

Representation ID: 22390

Received: 16/03/2020

Respondent: Norwich Green Party

Environment policy would benefit from re-wording, “......and to significantly reduce emissions to ensure that Greater Norwich plays a full part in meeting national commitments to achieve net zero GHG emissions by 2050 as well as implementing adaptations to climate change”.

Need to clarify what is meant by 'clean growth'. We have concerns about this term which derives from the Government's 'Clean Growth Strategy' (and reflected in the New Anglia LEP Clean Growth strategy). Firstly, 'clean growth' doesn't go far enough in cutting carbon emissions consistent with net zero carbon by 2050 and secondly, it includes programmes which are inconsistent with net zero carbon, notably improving road links to cut congestion and support economic growth.

Comment

Representation ID: 22484

Received: 16/03/2020

Respondent: Highways England

To promote the timely delivery of infrastructure to support existing communities, growth and modal shift in transport use; and to improve connectivity to allow access to economic and social opportunities.
Suggest that this is reworded to highlight the delivery of infrastructure to provide improved connectivity by encouraging modal shift and other carbon reducing measures, and where this cannot be achieved, other physical measures to support existing community to allow access to economic and social opportunities

Comment

Representation ID: 22510

Received: 16/03/2020

Respondent: Broadland Green Party

Para 130: Good to have the aspiration but where are the practical measures in the GNLP to actually produce greater water and energy efficiency?
Para 131. “Air pollution levels will be reduced through a combination of better design and location of development, supported by technological changes.” Equally, how will reduction of air pollution be achieved with the massive planned road expansion and destruction of woodland and green areas as a consequence?
The plan's objectives
As general aspirational objectives they are fine except for the objective “to achieve net zero greenhouse gas emissions by 2050”. This objective needs to be much more ambitious given the severity of the situation. Norfolk County Council has adopted a target of achieving net zero carbon emissions by 2030 for council owned land and buildings and for travel. In addition, they will work towards carbon neutrality for the county, also by 2030.

Object

Representation ID: 22530

Received: 16/03/2020

Respondent: Historic England

Para 110: Change historic assets to historic environment. The historic environment is considered the most appropriate term to use as a topic heading as it encompasses all aspects of heritage, for example the tangible heritage assets and less tangible cultural heritage.

Environment: It would be helpful to separate out the natural and historic environment here?

Para 132: We welcome the reference to distinctive local characteristics of our city, towns and villages. However, also need to refer to landscape. Again would be helpful if you can describe in more detail what is unique and special about your area in terms of heritage.

Objectives: We broadly welcome the objective for the environment. Again it might be helpful to either separate out into Natural and historic environment or at least change the title to include specific reference to built, historic and natural environment.

Object

Representation ID: 23102

Received: 31/03/2020

Respondent: Salhouse Parish Council

Paras 117 and 125 are wrong because facilities are closing and people have to travel further to use them.
Green infrastructure is a misnomer because it refers to a patchwork of unconnected green spaces which do not necessarily permit biodiversity across the area.