Question 48. Do you support or object or wish to comment any other aspect of the draft plan not covered in other questions? This includes the appendices below. Please identify particular issues.

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
We support Broadland District, Norwich City and South Norfolk Councils’ preparation of a joint Local Plan to ensure a consistent approach to planning across the Greater Norwich area, with policies aligned with the revised National Planning Policy Framework (NPPF).

We have made detailed comments in this letter in relation to the following Greater Norwich Local Plan (GNLP) consultation documents:
 Draft Local Plan – Part 1 The Strategy
 Draft Sites Document
 Habitats Regulations Assessment of GNLP, December 2019
 Sustainability Appraisal and Strategic Environmental Assessment, January 2020

Natural England acknowledges that the findings of supporting documents including the draft Greater Norwich Water Cycle Study (WCS) (AECOM 2019) and the emerging Green Infrastructure and Recreational Impact Avoidance and Mitigation Strategy (GIRAMS) will need to be incorporated in the policies of the Local Plan and supporting documents, once these are finalised.
To summarise our response briefly, we broadly welcome the progress and development of aspects of the Local Plan and supporting documents to date, though Natural England is not yet satisfied that the relevant Plan polices will provide sufficient mitigation to ensure that there will be no adverse impacts to designated sites alone, and in-combination, through changes in water quality and resources and in regard to recreational disturbance, and to demonstrate that policies are sustainable.

Please see attached for full submission

Re: POLICY GNLP2019, Land at Rectory Road and south of the Bure Valley Railway, Coltishall (approx. 1.43 ha) is allocated for residential development.
We object strongly to the Proposal to bring Greenfield site GNLP2019 as the preferred option for a housing estate.
We question the accuracy and validity of the GNLP background documents concerning Coltishall as they hold many misconceptions. Firstly, we do not have good transport links as stated. We have a skeleton bus service of one-hour intervals between North Walsham and Norwich only. This service ends just after 6pm from Norwich and is rarely used by commuters due to practical considerations. We have no public transport provision to our nearest Town, Supermarket and Rail Station in Hoveton and Wroxham. Recently a parishioner enquired about a hop on bus service but this does not exist. Our School has reached its capacity intake, a similar situation applies to the Health Practice, both will struggle with a large rise in residents as no plans have been developed to further fund these institutions.
The proposed sites as you have mentioned yourselves will cause chaos in Rectory Road. This is a small residential road which is already problematic at peak time due to vehicles attending the School and Health Practice. We fail to see how this can be addressed without a huge alteration to the streetscape damaging the feel and safety aspect of the village in this designated conservation area.
We have questions too about how Crocus Homes seemed to have prior knowledge of your intentions regarding showing The Parish Council detailed drawings of development on this site. We can see that without Crocus Homes cooperation the proposed site would be landlocked.
On a wider Issue, in the light of the landmark ruling regarding Heathrow Airport expansion, ruling it illegal as it failed to consider Climate changing issues and adherence to CO2 emission as agreed in the Paris agreement, this has thus been proved a legally binding commitment. No such assessment has been made for the Village Clusters and until this is drawn up and considered against sites nearer employment and public transport, we call for these proposals to be dropped.
Our final question at this stage; numerous letters of complaint have been sent to the Monitoring Officer at Broadlands District Council demanding the Chair of the Greater Norwich Development Partnership Board (consultants for the GNLP), Cllr Shaun Vincent, step down immediately given his conflict of interests as a developer himself and having his own consultancy company advising on planning matters. I have read S28 and 29 of the Localism Act 2011 and my understanding is that Cllr Vincent should have no involvement in the selection process. How is this situation being managed and does it not now put a question mark on why certain sites have been preferred over others and more widely the validity of the whole GNLP.

Please find the below officer level response from Great Yarmouth Borough Council on your Regulation 18 Draft Strategy and Site Allocations Consultation.
The Strategic Planning team welcomes the document and would support the Greater Norwich Local Plan (GNLP) Team on reaching this important stage of plan production. They would agree that this is an appropriate strategy and that it should comply with the updated 2019 NPPF. Strategic Planning would also agree that the document is in conformity with the aims and agreements of the Norfolk Strategic Planning Framework.
Strategic Planning would note the references within the Strategy document which relate to Great Yarmouth and would suggest that the strategic links to Great Yarmouth are strengthened and the importance of the offshore energy sector, related growth opportunities and tourism industry in Great Yarmouth are made more explicit. This is particularly so with the full dulling of the A47 which is supported by our local authorities through the A47 alliance.
Overall Strategic Planning would have no further comments to make on the documents at this time, but would reserve the right to comment on future stages of the plan production.

Please see attached for full submission

Please see attached for full submission

Please see attached for full submission

Please see attached for full submission

Please see attached for full submission

Please see attached for full submission

Marlingford & Colton Parish Council

1) Specific points:

There are already sufficient allocated sites for housing proposed in the JCS to be carried forward to the GNLP in the Norwich fringe parishes, main towns, and key service centres to keep pace with the predicted rates of development. The exceptions should be brownfield sites, particularly those within Norwich, which should be prioritised in a “brownfield first” policy.

Any additional sites for new housing should be in and close to Norwich, where they will be more sustainable, being closer to jobs and infrastructure, will help keep employment development on already allocated sites, and will have a less negative effect on climate change.

Existing allocated sites for housing in the JCS should be developed before any newly allocated sites in the GNLP are built on (phasing). If they are not, developers will use the most profitable sites, including newly allocated greenfield sites, which would be directly contrary to the GNLP's environmental/sustainability goals and would mean that the land bank of currently allocated sites will grow even larger.

The existing settlement hierarchy should be maintained. The concept of "village clusters" works against the GNLP's stated environmental goals, since it is based on flimsy or non-existent infrastructure - often only on the availability of a few primary school places - and would therefore have a much greater negative environmental impact by, for example, creating many more vehicle movements.

This "new GNLP" seems to have moved the focus for a lot of the new housing away from the NDR (Broadland Northway) and its corridor.
The exorbitantly high environmental and financial cost of the NDR's
construction was justified, in large part, by the supposed needs of traffic to and from housing development on the northern edges of Norwich and in the N.E. "Growth Triangle". Encouraging dispersal of housing across other rural areas would mean such development would be unsustainable given the lack of infrastructure, services, and public transport.









2) General points:

While there is a genuine need for affordable housing, there is no demonstrable need for the scale and category of housing which development of the sites proposed in the GNLP would result in.

Whitehall’s projections, on which the GNLP 2038 housing ‘need’ is based, are highly questionable and will tend to create the wrong category of housing in the wrong locations, not least because the developers’ drive for profitable, often greenfield, sites will hold sway over local authorities’ ability to regulate.

The effect of existing regulations means most developers start projects in the certain knowledge that they cannot be made to fulfil even the modest quotas set
for the less profitable affordable houses, and they regularly play the 'viability' card to avoid building them. What is actually happening with many of the developments is a damaging kind of social engineering, which this GNLP would encourage. Developers have scant regard for local need, knowing their prime targets are buyers with deeper 'equity release’ pockets who relocate from London, Birmingham, Manchester and other conurbations and for whom greenfield locations are particularly attractive.

There remains a very considerable disconnect between the developers’ objectives and community needs, while the need to protect the rural environment receives only the slightest recognition. Many of the sites in these documents fail the basic environmental and sustainability tests.

Meanwhile, those without the means to afford most of the housing on these new developments, who in the main are younger, local and without a foot already on
the housing ladder continue to be locked out, which weakens communities.

It's long overdue for policymakers, local and national, to stop supporting the cynical game the developers play and instead push for strong regulatory reform
that will actually deliver the affordable housing that’s needed and, importantly, do so on sites where it’s supported by sufficient infrastructure.

Very little in the current plan suggests it can achieve what’s needed, which also means the environmental and sustainability objectives of the plan might as well
not exist. Indeed, much of this ‘Greater Norwich’ concept seems set to weaken existing communities, create more dormitory estates, force more commuter journeys, depress the rural economy, reduce quality of life, and have a negative effect on climate change.

SUBMISSION FROM NORFOLK COUNTY COUNCIL LIBERAL DEMOCRAT GROUP

Our 10-point plan detailed below has been put together following discussions and meetings with Lib Dem councillors on Norwich City Council, Broadland District Council and South Norfolk District Council. Each district Lib Dem group reserves the right to make its own separate submission under the consultation, but we reached a consensus around all of the comments listed below.
1. Invest in a 'CrossRail for Norfolk' to link our county to the fast-growing knowledge economy in the Cambridge/Oxford corridor. Start by building a new rail station at Thickthorn on the southern edge of the city. Expanding Wymondham station is an inadequate half measure that will not reduce car-dependency far enough and will increase pressure for infill housing development along the A11.
2. Establish bus hubs in the rural hinterland where arterial routes into Norwich are timetabled with smaller buses which cover rural villages and connect with the main operators.
3. Put sustainability at the heart of development plans with the inclusion of 'green corridors', adequate cycle and bus infrastructure and ambitious requirements for the use of low carbon building materials and installation of renewable energy generation.
4. Strongly discourage the building of new houses on flood plains because of the increased risk posed by climate change. If such development is necessary, then ensure that living accommodation is on the first floor or above.
5. Oppose the creation of ‘village clusters’. Placing 9% of growth in small villages is not sustainable, and if this goes ahead it could face a challenge of contradicting the climate change measures contained in the Plan.
6. Norfolk County Council should shift the focus of its own house building plans from projects that aim to turn a quick profit to the provision of homes that are designed with the needs of older people at their heart.
7. Strict requirements on developers to provide adequate numbers of affordable homes.
8. Ensure that good health is built into plans with easy access to community facilities, design that encourages walking and cycling and health care facilities to meet the needs of the coming century such as GP services and health clinics.
9. Fix the schools funding gap. There is a £70 million gap in the budget for building the new schools that will be needed to support the house building plans. We cannot accept a 'something will turn up' attitude to solving this problem.
10. Create a roads and transport strategy for the rest of the county that will cope with the increased population and the pressures this will create as more people spend time visiting our fantastic coast and countryside.

Housing
• Housing designated as ‘affordable’ should be just that, most is not. Perhaps lessons could be learnt from another part of the country which is now taking local economics and local salaries into account for ‘affordable’ housing prices. Also perhaps it would help to have some scheme similar to parts of Cornwall, where local long term residents are given priority for housing. Thus preventing the situation which now exists on the North Norfolk coast.

• Notwithstanding the need to ensure affordable homes are affordable, developers should be required to provide enough ‘affordable’ properties. Sometimes it appears that large developments, for example 200 homes, might only have a requirement for something like 14 ‘affordable’ homes. This is ridiculous. Councils should require a higher percentage of ‘affordable’ properties and this should rise in scale with the developments taking place.

• Similarly to the above point, perhaps developers should be required to build a certain number of bungalows. As it is known the population is aging, and that Norfolk already has a high proportion of older people, the housing stock needs to be suitable. However, again, bungalows need to be affordable, if, for instance, they are favoured by older, retired people who no longer have a salary, otherwise this defeats the object. If there were more affordable bungalows for those who wish to downsize, this would free up larger family homes and make for a better functioning housing market.

• Developers once give permission to build should have a time limit within which to commence building, rather than being allow to ‘sit‘ on land and ‘land-bank’ until prices rise. Planning permission should be rescinded in these cases.

• The Councils should support local, smaller building firms to be involved in local developments so not all the building is carried out by multinationals. This could perhaps be achieved by ensuring some building land is sold in smaller blocks to make it financially viable for smaller builders. This would also provide greater variety (and possibly quality) in the housing stock.

• Developments need to provide a variety of properties bungalows, houses, flats – in larger towns/Norwich, from 1 bedroom upwards, to suit all people and help achieve mixed communities.




Where to Develop
• Although there is mention of using brownfield sites, this does not always seem to be the case. More emphasis should be given to this.

• There seems to be too many green field sites allocated for building, which takes away productive farmland and also the traditional rural and agricultural nature of Norfolk county. With an increasing importance of locally gown crops, less food miles, bio-security etc., we need to maintain productive farmland. If as I understand the Council recognises the climate emergency, this is all the more important.

• Whilst I recognise that after Norwich, perhaps the next level of growth will be within towns, there needs to be some limits to continued expansion. Wymondham, for example, has seen growth over probably the last twenty years, some of which, incidentally, was not included in the original town plan. Eventually the market towns will lose their unique character. It is not exaggerated to say, in the case of Wymondham, it will soon connect to Hethersett, which, in turn, will connect to Norwich.

• Villages should not be subject to ‘oversize’ developments, otherwise, again you lose the very fabric and nature of a village. Perhaps developments here should be in the ‘tens’ rather than ‘hundreds’, and specifically in proportion to each village’s size. The situation where villages double in size does not seem appropriate.

• The Council should not approve planning permission for developments on land susceptible to flooding. An EDP article dated 7/12/2019 p8, highlights where Councils have currently given permission to developments which fall within the Environment Agency’s mapped areas for flooding. This is shortsighted at best. The article quotes 20,000 houses for proposed developments in the County fall in these areas, and whilst all are not part of the GNLP some proposed sites are i.e. Hethersett, Hethel, Wymondham, Marsham, Deal Ground, Trowse ( Notwithstanding the issue re: landbanking (see above), for this latter site where the article states permission was given in 2013, but work is yet to start), plus others.

• If as is expected the completion of the new Northern Bypass NDR round Norwich will now start a gradual implementation of development around the north of the city, perhaps the Council should act now to ensure development only occurs between the city outskirts and the new road, and to prevent the incursion of development outside of this road and into the countryside. The northern side of the NDR could be designated greenbelt.

• The practice of ‘plonking’ a new settlement in the middle of the countryside lacks the necessary infrastructure and destroys greater areas of the environment i.e. the previously proposed mid-Norfolk development, and now Hethel.



Environmental Issues – whether housing/business/roads/infrastructure

• Over development on farmland should be avoided, as it diminishes the nature of the Norfolk countryside. This not only takes productive land out of use it also affects wildlife. For example, many farmland birds are already on the conservation ‘red list’ for severe decline in numbers.

• The Councils should not approve planning permission for developments where this involves removing old established trees/ancient woodlands. This is not acceptable. The usual mantra of ‘new trees will be planted’ is not good enough. A newly planted woodland of saplings elsewhere will not replace an established wood with its mature habit, bio-diversity, food sources and shelter. By the time new wooded areas have matured, many more species may be lost/threatened.

• Following on from the above point, whilst some tree planting may have taken place i.e. along the new NDR, many of the new trees have not been cared for and have died off, EDP date 7/12/2019 page 2. - a quarter of new trees lost. But again, although planting of native trees along the new road is positive this does not replace mature, quiet woodlands away from a busy road where wildlife can thrive. (Research has also shown (BBC East Inside Out) that simply saying ‘we’ll include bat bridges’ for new roads has not been a success.)

• The Councils should take a much more serious view of not allowing developments which destroy natural habitats whether, woodland, wetlands, heaths etc. As well as protecting species, this also has financial rewards in terms of visitors who enjoy the natural elements of the county.

• The consultation does not appear to be taking due consideration to the response of the Norfolk Wildlife Trust - EDP 11/3/2020 page7 - an organisation with people who have appropriate knowledge and many years of protecting our wildlife – which states the GNLP should be much more nature-led.

Overall, whilst it is accepted that while there is a continued population growth there will be a need for more development, at some point, Councils must limit the grown to prevent ‘over’ development within the county. The attached article by Keith Skipper (please read!), sums up excellently the choices to be made.

General
1.I would like to see more development of new towns (with commercial, social and recreational facilities, services etc including transport links) than large additions on the edge of towns/villages.
2. If a village is going to substantially increased in size, again facilities as above need to be mandated.
3. Where large additions (including previous phases) are made on the edge of towns, facilities as above need to be mandated to avoid overloading the existing infrastructure in towns. Facilities should come in early phases not at the back end. Sub-dividing developments to keep under these kind of thresholds is unacceptable.
4. The environmental standard of all new houses such be extremely high so that we move rapidly towards net zero emissions. Doing this at the new-build stage is much cheaper than retro-fit AND passes substantial amounts of the cost onto the land-owner and property developer, avoiding future private costs or the need for grant grants.
5. Ensure committed levels of social and low cost housing ARE built with no wriggling out on quasi-economic grounds or through salami slicing developments to stay below thresholds. It is unacceptable that landowners and developers make windfall profits and walk away without meeting social and environmental commitments.
Aylsham Specific:
1. The benefit of the additional facilities at Aylsham High School was already committed as part of the Bure Meadows development now in place. It is not honest to imply that they are somehow linked to future development.
2. With population growth at Aylsham, particularly with family homes being planned, the following benefits should be considered/enabled/mandated:
High school to have a sixth form
New supermarket/doctor+dentist surgery/social hall/facilities, sports facilities (gym/squash etc).
Refurbishment of Pavillion on nearby recreation ground.
Water/sewerage proivision is adequately managed together with consideration of Eco=projects such as communal heat and power.
Bus stop on A140 for the Sanders X40 fast coach link to Norwich with foot bridge over the main road.
3. Review of Aylsham traffic plan, including making Burgh Road/Sir Williams Lane one way before we have a fatality. The existing Bure Meadows development and new roundabout/petrol station development at the junction of Burgh Rd/A140 (which provides a short-cut into town from the North) has already overloaded these two narrow roads. Buses use Burgh Road, forcing vehicles coming in the opposite direction to drive on the pavements, often at speed, past domestic gateways.
4. Review of the parking and action in the centre of Aylsham. Provision of well-lit footpaths and cycle ways to allow people to get to the town centre without using vehicles.
5. Ensure guidelines on social housing and reduced cost homes for local people are met and that developers do not wriggle out of commitments. The argument that it is not economic to provide these is FALSE. It should simply be reflected in the price paid for the land in the first place.
6. Build to high environmental standards, not allowing developers to wriggle out of commitments.
7. As the South East side of the town is developed between the traditional town boundary and the A140, this must be considered IN TOTAL (including the existing Bure Meadows development) and facilities provided accordingly. A decision needs to be made whether residents in the new estates are routed into the existing centre for (improved) shopping, healthcare etc or if those are provided within this overall 1000 home development as a planning gain. I favour the latter.
8. Properly finish the developments. The wait at Willow park for recreational facilities and even properly paved roads was unacceptable and showed inadequate management of the development.
9. There is a decision to be made between the site adjacent to Burgh Road or the site adjacent to the Cromer Road. I do not object to the Burgh Road development provided the above considerations are taken into account. Safe vehicle ingress/eggress is absolutely key for both, into town and onto the A140. Long term, I have little doubt both will be developed and this should be done in a joined up way rather than salami slicing so that developers commitments are minimised.

From Chris Dingle

1. My reply is in the form of an overview from the point of an environmental campaigner whose main interest is in REFORESTATION in order to help mitigate the generation of CO2. In this case the GNLP should include from the outset a policy reference to the decision taken by N.C.C to be carbon neutral by 2030. This should then be discussed in all of the relevant sections of the plan.
2. As it stands the plan risks being out of date before the adoption date of September 2022 either by default or conception.
3. In order to avoid this pitfall perhaps an interim guidance section should be given at the beginning on actions which should be taken before the plan reaches the adoption point of 2022. I assume that under national planning guidance the programme for the G.N.L.P itself cannot be shortened.
4. An example of item 2 above can be found on p62, last paragraph---LOCAL ENERGY EFFICIENCY POLICY---. Then considering the N.C.C resolution this improvement should be recommended for actioning now and implemented at Jan 21. This would give the building industry time to adjust. Considering 3 above then this could be an item to be included in an interim guidance.
5. Page 23 paragraph 82. ‘Mitigating the effects of climate change’. Reforestation should be highlighted here with the importance of planting trees shown. The G.N.L.P quotes “while we cannot introduce the green belt under ‘NATIONAL POLICY’. This being the case then I think that text should include something like ‘other measures may become necessary in the future.’
6. Policy 2 page 56. Table 8 item 3. This is perhaps another area which could be part of an interim guidance 3 above.
7. Policy 3 page 64. Item 184 to 187 should be related to the 2030 aim of NCC and included in the interim guidance 3 above.
8. Page 66 paragraph 193. Reference to the draft Norfolk Strategic Planning Framework could be seen to have a negative effect on the G.N.L.P in terms of one plan being more advanced that the other. Clearly this is another area where the decision of N.C.C. to be carbon neutral by 2030 should take precedence in realising that ‘PLANNING’ must move more quickly or be sub-divided into actions which can be concluded to remove uncertainty and redundancy of that planning item.
9. Policy 3 page 68 THE NATURAL ENVIRONMENT
This section should include an expanded reference to the importance of REFORESTATION which is needed to mitigate climate change. It should include the recommendations of the government’s select committee on climate change.
The section should support the work currently being undertaken by N.C.C. in seeking to develop a portfolio or register of landowners who are willing to plant more trees now.
10. Note. It is perhaps of interest to reflect that the Woodland Trust planted 3.3 million new trees in 2018.

Then together with this figure and those figures on tree planting targets referenced by the select committee on climate change I would expect to see future tree planting figures in the draft Norfolk Strategic Planning Framework.

11. Question. When is the N.S.P.F. programmed to be adopted?

Please see attached for full submission

Full representations (with appendices) submitted in response to the current Regulation 18 consultation of the Greater Norwich Local Plan on behalf of Landstock Estates Ltd and Landowners Group Ltd.

I attach the feedback from Broadland Green Party members on the GNLP Consultation.

Each section is identified but not all questions have been answered. However, all questions are included to maintain the numbering.

See attached

For full representation, please refer to attached documents

For full representation, please refer to attached documents

On behalf of M Scott Properties Ltd we are instructed to submit representations to the Greater Norwich Local Plan Regulation 18 (c) consultation. The representations are split into two, reflecting the two parts of the Greater Norwich Local Plan; the Strategy Document and the Sites Plan, in respect of GNLP0337.

The attached document provides a complete record of the representations made on behalf of M Scott Properties Ltd.

The various technical studies referred to in the Representation and the Delivery Statement can be accessed in the attachments also.

Saxlingham Nethergate Parish Council met last week and considered their response to the current consultation.

They noted, considered and decided to fully endorse the response produced by CPRE in full (attached).

Q1 Please comment on or highlight any inaccuracies within the introduction

Please see our more detailed responses to the questions below, which make our concerns clear. In particular we have a major concern with the Draft Strategy as it makes no mention of using phasing for the delivery of new housing. We consider that any new sites allocated in the GNLP should be phased by being placed on a reserve list, and under phased development only built out when most of the existing JCS sites have been used. Inclusion of all the sites for immediate development will lead to developers “cherry-picking” the most profitable sites and newly allocated green field sites in less sustainable locations will be developed first, with even more land banking of currently allocated sites. In short, deliver the already allocated 82% of the 44,500 new homes, before giving permissions on the remaining 18%.

The current Local Plan, the Joint Core Strategy (JCS) was adopted in March 2011 with amendments adopted in January 2014: it has been in place for just over 6 years. When adopted, it was considered to be the blueprint for development in Norwich, Broadland and South Norfolk until 2026, and in doing so provided clear signals about where growth should and should not take place. In the introduction to the current consultation document it is stated that housing, jobs, services and infrastructure needs to be provided at the right time ‘and in the right places’. CPRE Norfolk questions how the response to this has changed so markedly since adoption of the JCS and well before that Local Plan was due to expire. In particular, the construction of the Broadland Northway (NDR) (noted in paragraph 7 of the introduction) was largely intended to help the distribution of traffic to and from new housing built inside its length and in the northeast growth triangle. Moreover, there was a clear focus for housing and other growth to be in and close to Norwich, with minimal new development to be permitted in the rural policy areas of Broadland and South Norfolk. The GNLP strategy seems to be contradicting the direction of travel envisaged in the JCS and appears to undermine the planning process. A great strength of the JCS is the protection it gave to the rural areas: this seems to be sacrificed in the GNLP Draft Plan.

Paragraph 6 of the Introduction is clear that ‘the GNLP must also assist the move to a post-carbon economy and protect and enhance our many environmental assets.’ It will be difficult if not impossible to meet these targets if new housing to the scale proposed in the draft strategy is dispersed across the rural areas of Broadland and South Norfolk. The main justification for this appears to be the availability of primary school places in the “village clusters”, whereas there are more important measures for sustainability which should be taken into account, including the number of car journeys and journeys by delivery vehicles to new housing, along with the associated congestion such vehicles will result in.

The introduction mentions in paragraph 25 that South Norfolk District Council will draw up its own South Norfolk Village Clusters Housing Site Allocations document. CPRE Norfolk is very concerned that by adopting such an approach this allocations document will not receive the same level of scrutiny as the main draft strategy document. We are also very concerned that the number of additional dwellings on top of the existing commitment of 1,349 houses is given as ‘a minimum of 1,200’. The use of the word ‘minimum’ is unnecessary and potentially very alarming, as in effect this gives no limit to the maximum number of houses which could be allocated in those “village clusters”. Given the draft plan provides enough committed sites ‘to accommodate 9% more homes than “need”, along with two “contingency” locations for growth’ (page 37) and does not include windfall developments in its housing totals, the word “minimum” should be replaced with “maximum” or “up to” as is the case with the figures for Broadland’s “village clusters”. Why is there this discrepancy in language between two authorities which are part of the same Local Plan: it appears to be inconsistent and illogical.

Q3 Please comment on or highlight any inaccuracies within the spatial profile.

Paragraph 41 states that ‘this GNLP needs to plan for additional housing needs above and beyond existing commitments based on the most up-to date evidence’. However, the calculations of housing need are based on the 2014 National Household Projections, which are not the most up-to date statistics, nor are they sufficiently robust to be used for such an important and far-reaching strategy. CPRE Norfolk admits that the 2014 figures are those which central Government expects to be used. However, several Local Planning Authorities, including North Norfolk District Council, are challenging the use of the 2014 figures, instead suggesting that the more up-to date 2016 National Household Projections should be used. CPRE Norfolk agrees that the GNLP needs to be based on the most up-to date evidence, and therefore requests the GNDP insists on using the 2016 National Household Projections. If the most recent ONS statistics had been used, current commitments are sufficient to cover housing needs to 2038.

Q6 Do you support or object to the vision and objectives for Greater Norwich?

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.

Q9 Do you support, object, or have any comments relating to the approach to Housing set out in the Delivery Statement?

This states that ‘this plan also provides choice and flexibility by ensuring there are enough committed sites to accommodate 9% more homes than “need”.’ CPRE Norfolk disagrees that such a high level of sites should be provided within the GNLP. As a starting point please refer to our response to Q3 where we argue that the insistence of the Government to use the 2014 National Household Projections should be challenged to ensure that the most up-to date figures are used instead. In addition, by proposing not to include windfalls in the buffer the over-allocation of unnecessary housing will be compounded further.

It is very disappointing that there is no mention of phasing as an option within the Draft Plan and Housing Delivery Statement, as this would help to prevent the worst excesses of unnecessary development. 69 Parish and Town Councils in Broadland and South Norfolk (over 38%) have supported CPRE Norfolk on this issue and have signed a pledge to this effect. With this groundswell of grassroots opinion making such a strong case, we urge the GNDP in producing the GNLP to consider phasing seriously as the most reasonable way forward.

Q12 Do you support, object, or have any comments relating to the Climate Change Statement?

Given the stated measures in the Climate Change Statement, it is impossible to see how the proposed additional allocation of sites for housing in “village clusters” can be justified. Furthermore, it is stated that ‘growth in villages is located where there is good access to services to support their retention’, when this is rarely the case beyond providing a primary school with sufficient places or room for expansion. Many services are simply not located within the “village clusters” with many additional vehicle journeys being an inevitable consequence of such housing allocations. Therefore, these would be contrary to measures 2 and 3 of the Climate Change Statement.

By locating additional housing in “village clusters” there would be an increased need to travel, particularly by private car, due to the lack of viable and clean public transport. If Climate Change is seriously going to be addressed then it is unacceptable to allocate additional sites for housing in rural areas which are not at all, or poorly served by public transport. New housing must be located where jobs and a wide range of services are or can be provided.

In addition CPRE Norfolk is concerned by the lack of any detailed policy on the design of new housing in the draft Plan document, other than a brief mention in the ‘Design of development’ in the Climate Change Statement. Detailed requirements to insist that new houses are built to the highest possible environmental standards beyond the Government’s minimum standards are needed, if serious steps are to be taken towards addressing Climate Change issues.

Q13 Do you agree with the proposed Settlement Hierarchy and the proposed distribution of housing within the hierarchy?

We supported the continuation of the settlement hierarchy as defined in the JCS. We wonder why and where the concept of “village clusters” has been introduced into the planning process. For many reasons they appear to be a flawed unsustainable concept. A real strength of the JCS was its inclusion of a Norwich Policy Area and Rural Policy Areas, and therefore we are very disappointed that this distinction has been abolished. The Rural Policy Areas gave real protection to the countryside: this is threatened by the introduction of the village cluster approach. This is another example of how the Draft GNLP contradicts the existing agreed Local Plan.

As noted above in our response to Q1 CPRE Norfolk has serious misgivings about the separation of the sites and allocations for new housing in the South Norfolk Village Clusters from the rest of the GNLP and its current consultation. In addition, we strongly object to the use of the open-ended statement that these South Norfolk “village clusters” will be allocated a ‘minimum’ of 1,200 houses, rather than giving a maximum number as is the case for the Broadland “village clusters”. If the reason for this separation is, as was given at the recent GNDP meeting of 6th January 2020, the lack of suitable sites coming forward in these South Norfolk “village clusters”, then this gives another good reason why the delivery of housing should be phased. Clearly the sites included in the JCS have undergone rigorous assessment and their inclusion in the Local Plan is an acknowledgement of their suitability for development. It makes absolute sense that these suitable sites should be developed first especially given the fact that any new sites coming forward are deemed to be unsuitable.

Paragraph 163d states that the strategy for location of growth ‘focusses reasonable levels of growth in the main towns, key service centres and village clusters to support a vibrant rural economy’, before suggesting that the approach to “village clusters” is ‘innovative’. The claim that providing new housing in such locations will support services is, we contend, largely illusory. Instead, additional new housing will lead to more car and delivery vehicle journeys, with residents travelling longer journeys to access the services they require such as health services and a supermarket. Given that the majority of any such new houses will be larger “family” homes, with children just or more likely to be of secondary or tertiary school or college age than of primary school age. This will have further impacts on carbon reduction due to the additional journeys needed to secondary schools or colleges.

It is clearly demonstrated in the table on page 80 of the 23 June 2017 GNDP Board Papers that the most reasonable option for the distribution of housing in terms of the environment (e.g. minimising air, noise and light pollution; improving well-being; reducing C02 emissions; mitigating the effects of climate change; protecting and enhancing biodiversity and green infrastructure; promoting the efficient use of land; respecting the variety of landscape types in the area; ensuring that everyone has good quality housing of the right size; maintaining and improving the quality of life; reducing deprivation; promoting access to health facilities and healthy lifestyles; reducing crime and the fear of crime; promoting access to education and skills; encouraging economic development covering a range of sectors and skill levels to improve employment opportunities for residents and maintaining and enhancing town centres; reducing the need to travel and promoting the use of sustainable transport modes; conserving and enhancing the historic environment and heritage assets; minimising waste generation; promoting recycling; minimising the use of the best agricultural land; maintaining and enhancing water quality and its efficient use) is Option 1: urban concentration close to Norwich. In terms of all these factors taken together the least desirable option as shown on this chart is Option 4: dispersal. We therefore strongly support urban concentration in and close to Norwich as the way forward, because it is best for the environment, minimising climate change and the well-being of residents.

There is very little economic evidence to suggest that cementing new housing estates on the edges of villages will bring any boost to local services, but rather they will put a strain on these services, where they exist.

We cannot understand why the table showing the same set of factors in the Interim Sustainability Appraisal for the GNLP on page 42 shows some different results from the table on page 80 of the 23 June 2017 GNDP Board Papers. While the most recent table confirms that overall urban concentration is a better option than dispersal, it is even clearer in the earlier version. The table on page 42 shows that urban concentration is better than dispersal in terms of: minimising air, noise and light pollution; improving well-being; reducing C02 emissions; mitigating the effects of climate change; protecting and enhancing biodiversity and green infrastructure; encouraging economic development covering a range of sectors and skill levels to improve employment opportunities for residents and maintaining and enhancing town centres; reducing the need to travel and promoting the use of sustainable transport modes. However, in terms of some of the other factors it seems that changes have been made to the table so that several options appear to be equal in terms of impacts, instead of showing what the earlier table demonstrated, which is that concentration was the best option and dispersal the least reasonable option.

Given the clear benefits and advantages from these documents for the environment, climate change and other areas, as well as other reservations around lack of sustainability and issues of delivery, we strongly urge the GNDP to remove the requirement for additional new sites for housing in the “village clusters” from the GNLP.

Q14 Do you support, object, or wish to comment on the approach for housing numbers and delivery?

Paragraph 145 claims that the strategy ‘is informed by consultation feedback’, yet chooses to ignore much from previous consultations even where such feedback was significantly in favour of a particular approach. An example of this is the position taken towards windfalls. Responses to the Stage A Regulation 18 Site Proposals and Growth Options consultation were significantly against (110 to 45) counting windfalls in addition to the additional (at that point 7,200) housing, and yet this has been ignored in the current draft plan consultation. By not counting windfalls in the calculation for housing numbers in table 6, there will be a resulting over-supply of houses, particularly if the out-of-date 2014 National Housing Projections are used. Windfalls are acknowledged as a reliable source of new housing and many Local Authorities do count them towards their housing targets: their contribution towards housing targets in the GNLP should lead to a reduction in the number of new sites which are allocated.

CPRE Norfolk also has specific concerns about the approach for housing numbers in the South Norfolk Village Clusters, as there is no total figure given for this new housing, but instead an open-ended ‘minimum of 1,200 homes’. This use of the word “minimum” needs to be removed and replaced by a “maximum” total, so that further potential over-supply is avoided. At best, the actual delivery of new housing in the plan area has just exceeded 2,000 dwellings per annum, with 1,500 being more typical. At this build-rate, current commitments cover actual housing need to 2038.

CPRE Norfolk wants to see sites allocated for housing in the existing plan (JCS) developed before any new sites that are likely to be added in to the emerging GNLP are built out. Although we understand that it will not be possible to prevent new sites being included in the plan, we are asking that these extra land allocations for housing are treated as phased development and that building should not occur on these sites until the current JCS sites have been used up. We think this is a sensible approach because not only does it protect the countryside, but also at current rates of house building there is enough land already allocated in the JCS to cater for the building that is likely to occur over the new Plan period.

There is very little evidence to show that increasing the amount of land on which houses can be built actually increases the rate at which they are built. All that happens is that developers ‘cherry-pick’ the most profitable sites, which are likely to be the newly allocated green field sites and that this will lead to even more land banking of currently allocated sites. This will also mean that many less sustainable (or as CPRE Norfolk would argue, unsustainable) sites for housing are developed rather than those with more sustainable locations. This would result in more pollution and congestion, with the negative consequences for the climate and climate change. It also means that expensive infrastructure which has been provided to facilitate new housing in the existing plan, could end up being an irrelevant and embarrassing white elephant.

It is disappointing that there is no mention of phasing as an option within the consultation document, as this would help to prevent the worst excesses of unnecessary development. 69 Parish and Town Councils in Broadland and South Norfolk (over 38%)have supported CPRE Norfolk on this issue and have signed a pledge to this effect, which was included in the previous consultation, but ignored in the current draft Plan. With this groundswell of grassroots opinion making such a strong case, we urge the GNDP in producing the GNLP to consider phasing seriously as the most reasonable way forward. Clearly there is a democratic deficit: meaningful consultation should not ignore this volume of common-sense opinion.

Q18 Do you support, object or have any comments relating to the preferred approach to sustainable communities including the requirement for a sustainability statement?

Commenting on Policy 2 – Sustainable Communities, CPRE Norfolk questions the use of the words “as appropriate” in the policy’s introduction, as this means the requirements would be far too open to interpretation as to what is “appropriate” and therefore opportunities to ensure that ‘mitigating and adapting to climate change, [and] assisting in meeting national greenhouse gas emissions targets’ will be missed.

This concern is particularly relevant when considering how new housing development in the “village clusters” will fulfil the first requirement to ‘ensure safe, convenient and sustainable access to on-site and local services and facilities including schools, health care, shops, leisure/community/faith facilities and libraries.’ The rationale behind these “village clusters” appears to be mainly based on the availability and accessibility of a primary school. However, safe, convenient and sustainable access to the other features on this list are equally important. Adequate health care and shops simply are not available in these ways to many of the preferred new sites for housing in the “village clusters”, therefore giving further reasons why such sites should not be included in the GNLP.

There is a worrying disconnect between the aspirations in point 6 with the need to ‘manage travel demand and promote public transport and active travel within a clearly legible public realm’, and the imposition of additional new housing in “village clusters”. It is difficult if not impossible to see how residents of the majority of this new housing will be able to use active travel or public transport, due to the likely distances from workplaces and the lack of suitable public transport.

If additional new housing is developed in “village clusters” most of the working residents will not have ‘good access to services and local job opportunities’. Instead there will be an unsustainable increase in the number of journeys to and from work using private vehicles, which will not be electric-powered certainly for the majority of the plan period. It is very doubtful if additional housed will provide enough business to keep a village shop open, but they will definitely increase the number of journeys made for delivery and service vehicles, making this housing even more unsustainable.

If communities are to ‘minimise pollution’ as required to do so by point 8, it is imperative that no additional new housing is allocated to “village clusters”, as this would lead to an increase in petrol and diesel-powered vehicle journeys to and from such housing. This, along with the resultant increase in congestion, makes this additional housing highly undesirable.

Q19 Do you support, object or have any comments relating to the specific requirements of the policy?

We comment on various aspects of Table 8 relating to Policy 2.


Point 3, Green Infrastructure. The opening statement is: ‘Developments are required to provide on-site green infrastructure appropriate to their scale and location’. The three main benefits listed are biodiversity gain, promotion of active travel and the reduction of flood risk, which are key NPPF priorities.
The NPPF is also supportive of biodiversity on a more strategic scale, and the importance of ecological networks and Nature Recovery Networks. While Green Infrastructure is useful, and can play a role in these, it clearly has limitations in a wider role across the wider countryside, and in linking high designated nature conservation sites.
Point 5, Landscape, should recognise that valued landscapes often sit with good wildlife habitats. This is particularly the case for river valleys and the Broads. A strong message from the Environment Plan and the recommendations from the recent Landscapes Review is to make links between landscapes and wildlife, and not consider them in isolation. This is covered more fully in our response to Q21.
Point 9, Water. In our view it needs to be recognised that SUDS is not a silver bullet when dealing with flood risk. Areas of low-lying land with a high water-table can present a problem in ‘getting the water way’, and if it does manage to do that existing settlements can be put at risk.
A high level of growth puts a greater pressure on the capacity of Waste Water Treatment Works, both on the discharge of effluent into river systems, and on flood risk with foul water. This will be exacerbated by under or lagging investment in WWTW. Although not the responsibility of the Greater Norwich Authorities, their Annual Monitoring Reports (AMRs) should record and monitor incidents.

The statement in Point 9, Water - Key issues addressed by policy 2 states that: ‘Government policy expects local planning authorities to adopt proactive strategies to adapt to climate change, taking into account water supply and demand considerations. It allows local plans to set a higher standard of water efficiency than the Building Regulations where evidence justifies it. For housing development, only the higher Building Regulations standard for water prescribed by Government (110 litres per person per day) can [be] applied through local plans and more demanding standards cannot be set. If the potential to set more demanding standards locally is established by the Government in the future, these will be applied in Greater Norwich.’ The closing note at the bottom of the wording states: ‘Implementation of the standards for water efficiency will be supported by an updated advice note.’

We comment that it is imperative that Per Capita Consumption (PCC) of water is further reduced below the Government's prescribed 110 litres per person per day in order to deliver the statement made in Section 3, paragraph 129 which 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 local 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.’ East Anglia is the driest region of the UK, our aquifers, rivers and wetlands are already at breaking point, as are many of the regions farmers who are seeing their abstraction licences reduced or revoked. If more demanding standards to reduce PPC water consumption are not set as part of the local plan, this will further adversely impact upon the environment, impacting upon the Broads and wetlands, which in turn will impact the regions aspirational growth for tourism and will severely impact the regional agricultural economy.

These pressures are further evidence as to why the amount of new housing should be tightly controlled.

Q21 Do you support, object or have any comments relating to the approach to the natural environment?

CPRE Norfolk supports further ‘development of a multi-functional green infrastructure network’. However, we have major concerns about how biodiversity net gain will be evaluated, assessed and measured, although it is recognised that at this point it is unclear as to what the legal requirements of this policy will be given the current progress of the Environment Bill.

Paragraphs 183 and 184 talk about the great weight placed on protecting the natural environment in Greater Norwich, but then there are no clear details on how this will be achieved. Provision of a Green Belt on a ‘green wedges’ model would go some way to addressing this.

This draft Plan takes a very narrow view on the NPPF and 25-Year Plan on policies for the natural environment, namely that strategy, aims and policies are restricted to considering only gain as seen through the prism of development. There is a duty to cooperate between Councils, and that should automatically happen. While implementation may be less direct, there should be a wider strategic vision that does support policies of the NNPF. CPRE Norfolk has a proposal for a Nature Recovery Network from the North Norfolk Coast to the east coast (including parts of the Broadland DC area), by the enhancement of the ecological network provided by our river systems, and supported by the environmental land management scheme. This includes a detailed planning and land management document for landscapes and wildlife relating to a Nature Recovery Network, which also include an AONB extension to the Norfolk Coast AONB into the full catchments of the twin North Norfolk rivers Glaven and Stiffkey.

Q22 Are there any topics which have not been covered that you believe should have been?

Yes, the decision to remove a possible green belt for Norwich on the green wedges (or other) model from the draft Local Plan is, in the opinion of CPRE Norfolk, unjustified, particularly bearing in mind the large degree of support it received in the earlier Stage A Regulation 18 Site Proposals and Growth Options consultation.

Q23 Do you support, object or have any comments relating to [the] approach to transport?

CPRE Norfolk supports the provision of new railway stations at Rackheath and especially Dussindale as outlined in paragraph 206.

We note the contradiction in the Transport for Norwich Strategy as reflected in Policy 4 – Strategic Infrastructure, when it aims ‘to promote modal shift’ by having ‘significant improvements to the bus, cycling and walking network’ on the one hand, but promotes ‘delivery of the Norwich Western Link road’ on the other. CPRE Norfolk fully supports the former set of aims while opposing the latter.

CPRE Norfolk supports ‘protection of the function of strategic transport routes (corridors of movement)’, and as part of this strongly suggests that no industrial development should be permitted on unallocated sites along such corridors of movement.

The desire to support ‘the growth and regional significance of Norwich Airport for both leisure and business travel to destinations across the UK and beyond’ surely contradicts the aspirations for addressing climate change stated within Section 4 of the draft GNLP?

Public transport provision needs to be improved and made affordable, not only between main towns and key service centres, but to and from smaller settlements. This is essential even without any further growth of these settlements, as many areas of rural Norfolk have become public transport deserts.

Q27 Do you support, object or have any comments to [the] approach to affordable homes?

CPRE Norfolk supports the affordable housing policy within Policy 5 – Homes. It is essential that the requirements of this policy are followed when progressing applications for housing on sites of 10 dwellings or more. Any policy which encourages the building of a greater proportion of affordable homes should be adopted. It is to be hoped that government policy will change further regarding viability tests so they become more transparent, so that it would be less easy for developers to evade their responsibilities to deliver affordable homes. More central government intervention is required if these needed homes are to be built. Ideally, affordable and social housing should be provided where needed as a stand-alone provision, and not be connected to private developers’ housing targets. Lessons must be learned from the history of poor delivery of affordable homes, to ensure that the policy to provide 28% or 33% affordable houses must be enforced. We support rural exception sites as a means of supplying needed local affordable and social housing. An approach based on the provision of stand-alone sites such as these, in our opinion is a far better method for addressing affordable and social housing needs.

Q34 Do you support, object or have any comments relating to the approach to employment land?

CPRE Norfolk while not agreeing with the allocation of so much green-field land for employment/economic use, it is essential that any such allocated sites are adhered to. This means that no exceptions should be made, particularly for larger businesses, to develop sites outside these allocated areas. If any such un-planned growth were to be permitted this would lead to further erosion of the area’s landscape and environment, along with issues regarding the sustainability of any such sites. A large amount of the land allocated in the JCS for employment use remains for use. The development of these sites should be prioritised before any new sites are added.

Q45 Do you support or object or wish to comment on the overall approach for the village clusters? Please identify particular issues.

“Village Clusters” appear to be an artificial concept, invented to justify the dispersal of housing into the countryside. It is difficult to understand the justification for changing the current settlement hierarchy within the JCS to that proposed in this draft plan, in particular by eliminating the JCS categories of Service Villages, Other Villages, smaller rural communities and the countryside, which provided opportunities for a more nuanced approach to housing allocation, appropriate to each category of community/settlement within their own setting, landscape and context. The “village cluster” approach is a relatively crude one, with much more of a ‘one size fits all’ approach. CPRE Norfolk is particularly disappointed to see that the current JCS settlement hierarchy is not even offered as an ‘alternative approach’ in the draft GNLP, and wishes to see this rectified.

Even if the “village clusters” are adopted it would still be important to limit these to the area within their settlement boundaries and to designate the remaining largely rural areas as “countryside”, which would then require a further policy similar to the current JCS policy 17: smaller rural communities and the countryside. It is a great regret that the Rural Policy Areas of the JCS will be eliminated in the GNLP, as these provided effective protection of the countryside from unnecessary development.

The different approach for “village clusters” in Broadland compared to those in South Norfolk is not acceptable given the emphasis on the GNLP being a strategic plan for the whole of Greater Norwich. The “village clusters” in Broadland and South Norfolk should be treated in the same way if they are to be included in the final GNLP. This means that a maximum number of new housing for both areas should be included in the GNLP rather than the current different approach/wording, by having Broadland’s “village clusters” providing ‘up to 480’ whereas South Norfolk is to provide ‘a minimum of 1,200’: both areas should have the same wording i.e. ‘up to …’. We are concerned that all of the “village clusters” in South Norfolk will not be scrutinised to the same degree as those in Broadland due to the separate South Norfolk Village Clusters Housing Site Allocations document.

CPRE Norfolk is concerned by the use of primary school catchments acting as ‘a proxy for social sustainability’, with apparently no other sustainability measures being taken into account when decided on the amount and location of housing within “village clusters”. This does not make the proposed allocated housing within “village clusters” sustainable as required by the NPPF. Other measures should be taken into account within the social, economic and environmental spheres.

Q46 Do you support or object or wish to comment on the approach for specific village clusters? Please identify particular issues.

We are concerned that all of the “village clusters” in South Norfolk will not be scrutinised to the same degree as those in Broadland due to the separate South Norfolk Village Clusters Housing Site Allocations document.

Q47 Do you support or object or wish to comment on the overall approach for Small Scale Windfall Housing Development? Please identify particular issues.

CPRE Norfolk feels that windfall development should be restricted to sites within settlement boundaries. Housing need is already catered for by other policies in the Plan. Windfall developments should also count towards overall housing targets.

Q48 Do you support or object or wish to comment [on] any other aspect of the draft plan not covered in other questions? This includes the appendices below. Please identify particular issues.

CPRE Norfolk does not understand why there has been a major change in direction and policy as to where new development should be allocated in the GNLP compared to the current JCS. The JCS was only finally fully adopted in January 2014, just over 6 years ago. In the JCS housing concentrated in and close to Norwich was agreed and supported by hugely expensive infrastructure projects, in particular the Northern Distributor Road (now known as the Broadland Northway), which was primarily constructed to distribute traffic form and to new housing developments on the northern fringes of Norwich and in the North-east Growth Triangle. It would be a massive and costly folly to change that policy to one which allowed for the dispersal of much housing across the rural areas of Broadland and South Norfolk, where there is insufficient infrastructure, services and public transport, which would mean such development would be unsustainable. This would only lead to more congestion and pollution, leading to problems in meeting carbon-reduction targets.

CPRE Norfolk wants to see sites allocated for housing in the existing plan (the JCS) developed before any new sites that are likely to be added in to the emerging GNLP are built on. Although we understand that it will not be possible to prevent new sites being included in the plan, we are asking that these extra land allocations for housing are treated as phased development and that building should not occur on these sites until the current JCS sites have been used up.

There is very little evidence to show that increasing the amount of land on which houses can be built actually increases the rate at which they are built. All that happens is that developers ‘cherry-pick’ the most profitable sites, which are likely to be the newly allocated green field sites and that this will lead to even more land banking of currently allocated sites.

It is very disappointing that there is no mention of phasing as an option within the consultation document, as this would help to prevent the worst excesses of unnecessary development. 69 Parish and Town Councils in Broadland and South Norfolk (over 38%) have supported CPRE Norfolk on this issue and have signed a pledge to this effect. With this groundswell of grassroots opinion making such a strong case, we urge the GNDP in producing the GNLP to consider phasing seriously as the most reasonable way forward.

We question the relevance of a plan whose horizon is 2038, which is likely to be reviewed and replaced on at least three occasions before its end-date, and we fear that on each of these occasions more unsustainable housing will be crammed in at the expense of the countryside. What is perhaps most disturbing is that so many people living in the area are not aware of the current JCS let alone the emerging GNLP, and that where citizens are engaged in the process seem to have their views discounted. For example, this is clear where the views of over 38% of the Broadland and South Norfolk Parish and Town Councils regarding the phasing of housing development are apparently ignored. Current consultation processes are not reaching the majority of people: perhaps a Citizens’ Assembly approach would be a means which would enable more people to be involved.

- The references to Net Zero were mostly in regard to current UK legislation for 2050. I would have expected to see this in line with local council policies and other leading city practices to aim for Net Zero within a shorter time frame - not just for Council but for the city. Designing over the long term is a good exercise and allows for the best route to the end goal. This seemed lacking in the following respects:

- Renewable energy (onshore wind/ solar) was described as being supported when outlined in a local or neighbourhood plan. That sounds like it will not be supported unless this takes place. Yet here is a document which sets out the masterplan for the local plan and it doesn't mention any strategic siting for the onshore renewable energy the region could benefit from. Surely a secondary exercise with grading of land on the basis of suitability would be a preferable way forward if the intent was to be encouraging. Without this, it comes across as a way of blocking development without being seen to be doing so. And what about making available or encouraging the local ownership of renewable energy assets to community schemes?

- Sustainable Transport was mentioned throughout the document. Yet there were frequent contradictions in terms of additional road building programs. What are/were the options for alternative low-carbon public transport routes? It is entirely possible that Norwich Airport may not survive coronavirus. What consideration for (e.g. ferry services from Great Yarmouth to Ijmuiden? Electric vehicles are mentioned - but no consistent plan for EV charging infrastructure being rolled out - in particular within the built up areas in Norwich (generally without off street parking). There were mentions of improved train services, but no specific plans in terms of the land that might be required to join up to longer term schemes (such as the HCA plan to develop a train route between Oxford and Cambridge with the potential to extend to Norwich. There were cross references between many different transport plans - but no sense of an over-arching strategy.

- There was much mention of flood risk in relation to considerations of new property. However the broader resilience strategy appeared to be lacking. What was striking is the lack of natural land in the area. Agriculture was mentioned as having a high use of water - but no specific plans to address farming practices in the area towards more regenerative or resilient approaches. There did not appear to be a strategic approach to nature based solutions in the area to be able to protect existing infrastructure. In particular, given the amount of agriculture, any support for specific innovation that could help tackle climate change mitigation but also adaptation (e.g. silvopasture etc).

- With parts of Norfolk being the 'canary in the mine' of climate change, a Resilience framework could be useful to adopt in considering paths forward. For example the experiences from the Rockefeller 100 Resilient Cities project may be helpful in creating a systemic insight on how to integrate resilience into all aspects of planning and operations. In light of coronavirus, Norfolk has a degree of benefits from its local food economy, however this could be bolstered further via local supply networks that enable greater connectivity between food producers and consumers. Likewise, and enhanced investment in broadband (especially in rural areas) is necessary to reduce travel demand and enable home-working - especially when paired with sustainable logistics and delivery mechanisms.

- Green space is not just a matter of environmental protection (especially in city centres with air quality issues) but also social necessity. I have noticed - as a relatively new resident - that there appear to be several problematic situations which sit between insufficient council funding and insufficient community devolution - for example the disused bowls and tennis areas that have been locked up on Heigham Park. Again, at a time where many other public spaces may be closed under a pandemic, quality green space within cities could support mental health in a time of crisis (especially given that there resources available for mental health are overstretched at present).

As a refrain to the opening remarks on the process, I would like to suggest a radical rethink on the means of engagement. I would strongly suggest the use of Citizen's Assemblies in judging some of the decisions as they arise in fine tuning the plan as we head into a period of volatility, uncertainty and disruption. By using process which help to engage the broader population, people become more aware of the part that they can play, bring their own ideas and can help to make desirable transitions quicker and more effective.

I would be happy to expand on any of the points made above.

The draft Greater Norwich Local Plan (GNLP) currently under-going consultation will guide growth planning (land allocation, detailed site briefing and infrastructure prioritisation as well as the channelling of government growth related funding) over the period 2018-2038. As such, the plan is subject to the fundamental Government requirement for sustainable development set out in the National Planning Policy Framework (NPPF) , which should guide all decision making in this area.

The coming years represent a critical moment for us to take responsibility for sustainability and to plan future growth to help repair the mistakes of the past and ensure that the urban footprint and infrastructure decisions we make now enable ‘good growth’ for future generations – such that they can enjoy healthy, sustainable, mutually supportive lives where the benefits of growth can be equitably shared.

We anticipate that, as measures to mitigate climate change are re-prioritised following the many incidents of extreme weather that have been experienced on a global basis over recent years, and recognition of the effects of ill considered growth on biodiversity, soil health and human health grows, the drive towards more sustainable , resilient development patterns will intensify.

The ambition for environmental net gain is embedded in the ambition of the present Environment and Agriculture Bills, and we anticipate that it may also become an embedded requirement of the Government’s anticipated Planning Bill. The Heathrow Airport ruling is a landmark decision, and we anticipate that the Glasgow Climate Change summit this autumn (provided it can go ahead in the face of pandemic) will likely set another. We would therefore suggest that, in order to robustly plan forward 20 years, the GNDP should adopt a strenuous approach to securing sustainable growth in its land use, economic and infrastructure planning. As currently cast, we do not consider that the plan sufficiently meets the challenge of delivering sustainable development.

Furthermore, irrespective of high level government policy, we contend that on the basis of the sustainable development requirement of the current NPPF; the general power of competence vested in the Localism Act; and on the principles of public interest and subsidiarity, the GNDP is empowered to and should subject its planning, via the Greater Norwich Local Plan (GNLP), to the most rigorous test of planning for sustainable growth.

In addition to points made jointly in a separate but linked representation with Create and Others around the need for a sustainable movement infrastructure proposition to underpin the delivery of sustainable development, we make the following additional background points in proposing how genuinely sustainable development might be achieved for Norwich & Norfolk:

In order to plan for the sustainable growth of greater Norwich, we contend that this will require planning for infrastructure, economy and land use at, at least, the county level of scale – through a separate but complementary exercise. While the GNLP area identified widens the scope across which planning for the city and its travel to work catchment takes place, practically, the catchment of Norwich - due to its unique location and geography - is the whole county. Due to the lack of a competing major centre, people across the entire county rely upon Norwich for cultural opportunities, education and training and as the principle regional retail and entertainment centre. There is a very significant disparity moreover in public spend, for instance on culture in Norwich as against the rural areas, and it is vital for reasons of equity and to support social mobility and educational outcomes, that the cultural, educational and commercial amenities of the city centre remain accessible to all. We set out in the joint Create, SGA and Others’ representation the need to interrogate an additional light rail transport proposition for greater Norwich as part of this.

The Building Better Building Beautiful Commission Report ‘Living with Beauty’ proposes at policy proposition 18 p87 the need for county level planning to produce coordinated spatial, infrastructure and economic plans in co-operation with their constituent city/borough/district authorities and the local enterprise partnership. This would support delivery of a coordinated approach to sustainable development that will ensure that water, waste, movement, power networks, energy and digital are planned in a rational and coordinated way, together with a sustainable land release approach in order to support sustainable development and enable public value capture. We consider that this is an essential, complementary step before land allocation can take place on a sustainable basis and propose that a county level spatial plan, coordinating with the LEP economic and infrastructure strategies needs to be urgently taken forward, with the delivery of sustainable, resilient development as an explicit goal.

This has partly been undertaken through the exercise the GNLP partners were involved with to interrogate the potential of the Norwich to Cambridge Tech corridor. This exercise is however inchoate as the brief did not require consideration of the overall growth proposition for the entirety of the county; there was limited public consultation, and as we understand it, the full set of environmental constraints were not interrogated alongside - and in balance with - the economic opportunities. In this way, the combination of the GNLP in its current form, the Norwich-Cambridge Tech corridor strategy and the respective district plans represent a fragmented approach to advancing a sustainable and coordinated growth strategy for the whole county and need to be brought together through the wider county lens in order that sustainable development can be planned for up to 2038.

Before agreeing an infrastructure package and set of land allocations, we suggest that the GNLP need to take a step back and work with Norfolk County Council and New Anglia LEP to first consider an integrated spatial plan for Norfolk. This should build on work started by Richard Bacon MP ‘How should Norfolk Grow?’ , the CPRE’s Vision for Norfolk exercise and report and also work undertaken by Norwich City Council on their 2040 vision.

Through the Building Growth Place, Land and Markets Group I have continued to promote the potential for Norfolk and Norwich to take a lead role in both commissioning and developing an integrated regional infrastructure and spatial model (which might be commercialised and applied elsewhere) and we have made the case for this on an on-going basis to the LEP, County and to MHCLG. The modelling work that underpins the Tech Corridor goes some way towards this however does not consider the whole county due to the limited focus of the commission on the corridor. There remains an opportunity for Norfolk to work with leading edge consultants through a pilot project to pioneer and test the capacity of integrated spatial modelling to support strategic scale planning, and to coordinate planning for growth with the analysis work currently being undertaken for rural interests including Norfolk County Council to support the DEFRA land use pilot.

We therefore suggest that, in order to meet the test of sustainable development embedded in the NPPF, there is an urgent need for the GNDP to work with Norfolk County Council, the LEP and all the constituent district authorities to consider how the whole county should enable sustainable development and resilience, coordinating with the NALEP economic and infrastructure strategies around a place-based spatial vision and strategy. Without this prior exercise the GNLP cannot be demonstrated to represent a robust approach to sustainable development.

I have the greatest admiration for those tasked with producing the Greater Norwich Local Plan. This a truly massive task, as 50,000 new dwellings are required. Also the plan must look forward 18 years.
Climate change is now accepted as a major challenge, so looking ahead 18 years means this is an even bigger risk. On page 38 of the Draft Strategy there is a Climate Change statement. Item 2 states that we should "Reduce the need to travel, particularly by private car."
As a resident of South Norfolk for nearly all of my 78 years, and being born in Trowse, I am particularly concerned by the repercussions of the proposal to provide an additional 1,200 (minimum) dwellings in estates, throughout the village clusters of South Norfolk.
South Norfolk is widespread and remote. Villages as diverse as Toft Monks, Burston and Morley will be required to provide sites. These villages and many others in South Norfolk are a long way from Norwich, and it's services and infrastructure, hospitals for example.
Of course, South Norfolk have withdrawn the plan details for their clusters, for the time being, but the principle remains, how do you justify so many dwellings against the target to reduce travel, particularly private car.
Shaun Vincent acknowledges in an article published by the E.D.P.on 11th March this year that,"the National Policy Agenda on environmental issues is moving rapidly,especially in the light of the recent court decision on Heathrow Expansion."
I would ask that the figure of 1200 dwellings be reduced.Has sufficient attention been paid to the continuing effect of the Internet on the High Street up to 2038?Could more substandard dwellings be brought into use?Is it appropriate that villages,such as Toft Monks,Burston and Morley have any further estate developments,when major services such as hospitals are so far away.
As South Norfolk have withdrawn the Village Clusters Plan from the current consultation,this is the ideal opportunity for the GNLP to reexamine the principle of this part of the plan.Also I understand that South Norfolk are dissatisfied with many of the sites that have been submitted,because they are not suitable.

I enclose a word document with my referenced comments on aspects of this consultation.

Please find attached the following documentation forming a consultation representation for the Greater Norwich Local Plan: Stage C Regulation 18 Draft Strategy and Site Allocations on behalf of my colleague, Adam Davies.

- Completed document for the following documents and questions:
- Draft Greater Norwich Local Plan – Part 1 The Strategy
- Question 6
- Question 9
- Question 11
- Question 12
- Question 13
- Question 14
- Question 16
- Question 17
- Question 18
- Question 25
- Question 29
- Question 32
- Question 41
- Question 42
- Question 48
- Draft Local Plan – Part 2 Site Allocations
- Policy GNLP2136
- Greater Norwich Local Plan Interim Viability Study (November 2019)
- Proving Layout
- Parameter Plan
- Pedestrian Access Plan
- Highways Technical Note
- Vehicular Access Proposals
- Barley Close Pedestrian Link
- Utilities Assessment
- Flood Risk Technical Note
- Infiltration Testing
- Preliminary Surface Water Attenuation Calculations
- Bat Scoping and Activity Survey
- Great Crested Newt and Amphibian Survey
- Reptile Survey
- Arboricultural Survey
- Archaeological and Heritage Assessment
- Noise Assessment

For full representation, please refer to the attached document

Summary of main points

• Some sites in Norwich are on the riverside and we would like them to make the most of their riverside location.
• Reference to the Broads and its various documents would be welcomed in some areas.
• Some policy wording is not defined it seems and it may be useful to do so.
• Improved reference to show on maps and to say that part of the Utilities Site is in the Broads area, but that both LPAs will work together to bring forward East Norwich development sites.
• Consideration relating to peat and carbon rich soils.
• Consistency of wording in some policies.

Main document

General comments:
• Throughout you refer to ‘post-carbon economy’. Is this an obvious enough term? Is it defined well enough? Does it adequately cover climate change, mitigation and adaptation? Also, by referring to ‘carbon’ only, you do not seem to include other greenhouse gases. I wonder if the use of this term, throughout the document, needs checking to see if it is the most appropriate term for what you are trying to say. At the very least, an explanation of what it means would be helpful.
• Throughout you refer to ‘inclusive growth’. I do not know what this is. What is to be included in the growth? The term might be acceptable, but you may want to define it somewhere as what it actually means is not clear or obvious.
• BREEAM references: you refer to single issues of BREAAM (energy and water on their own) in the document. As part of my discussions with BRE, it seems that they do not recognise the use of single issues, but rather a whole scheme needs to meet BREEAM criteria. You may wish to contact BRE about this to ensure any policy approach is deliverable.

Detailed comments:
• Box, page 6, Para 4, last sentence: refers to some aspects being repeated. I don’t understand; what is repeated?
• Page 8, para 1: has the Broads Local Plan and Broads Plan helped influence the document? Should they be mentioned?
• Page 24, para 95: do you mean increases of between the two figures quoted in each bullet point? Adding the word ‘between’ might make it read better.
• Page 28 – you refer to the Broads as a National Character Area, but it has the status equivalent to a National Park and is a Nationally Protected Landscape. Please say those things in this section of the Local Plan.
• Page 29, para 105 – have you thought about addressing peat and other carbon rich soils in the Local Plan?
• Page 32, para 119. You mention houseboats later on in the document, but could that be mentioned here – along the lines of ‘working with the Broads Authority, so too will the needs of houseboats be met’?
Page 34, environment section of the vision – recommend you mention the landscape impact on the Broads and its setting.
• Page 35, Environment objective – what about the setting of these things?
• Page 38, climate change statement – have you thought about carbon rich soils like peat? Have you thought about heat, cooling and extremes of weather (not just the effect of flooding)?
• Page 46, a how does this split fit with what is said at para 132?
• Page 51, Policy 1, bullet 2 – what do you mean when you say ‘local level’?
• Page 51, Policy 1, ‘support vibrant communities’ – do you mean help ensure communities remain or become vibrant?
• Page 52, Policy 1, second para under table: where you refer to negative impact on the character of the settlement, it seems also prudent to refer to the area in general – for example to consider the impact on the Broads and its setting.
• Page 61, policy 2: The first paragraph ends with ‘as appropriate’ – what does that actually mean in terms of applying the policy? What does ‘sustainable access’ actually mean? ‘What are ‘local services’? Point 10 – would that standard be in place until a Government standard is put in place? Is that worth saying in the policy?
• Page 62, footnote 73 – is that policy wording? Or is that policy in the DM documents of the districts? If that is the case, you might want to clarify that.
• Page 66, para 193 – NSPF version 2 is not draft, it is endorsed. The emerging NSPF is version 3.
• Page 72, para 212 – refers to 2019. You might want to update this in the next version of the Local Plan.
• Page 76, policy 4, transport. You talk of non-car developments and high densities in Norwich. Other places like towns have good access to services and public transport – are they going to have non-car developments and high densities?
• Page 79, para 248 – support reference to the Broads Authority and houseboats – please add something like ‘…for residents of houseboats in the area, through policies that enable the delivery of residential moorings.’
• Policy 5 supporting text – is it prudent to say that the Broads Authority will have regard to/defer to the affordable housing policies of the districts and so this policy will also be used, in parts, by the Broads Authority?
• Page 81, Policy 5: The first para uses the term ‘should’ a few times – is that weak wording? Under affordable housing – does it matter that an applicant might say they are sub-dividing a site for another reason and so could do it? Is it more that sub-dividing is not allowed, and that is because some developers may seek to avoid affordable housing obligations? What is ‘good access’?
• Page 81, Policy 5: what is ‘sustainable access’? What are ‘ancillary uses’? Marketed for up to or at least 12 months? How should they be marketed?
• Page 83, para 1: ‘…tenures of homes within…’. Para 3, what are locations with ‘good access’ – we say within a development boundary. Another consideration for location of such facilities is how staff and visitors can access it. Para 5 ‘…encourages new sites…’
• Page 87, policy 6: What are ‘significant residential and commercial developments’?
• Page 95, map 9 – do you include the part of the Utilities Site that is in the Broads – suggest you do and maybe show it in another colour and amend the key accordingly.
• Page 99, para 2 – isn’t office to residential permitted development?
• Page 100 – East Norwich. Is the East Norwich Strategic Growth Area Masterplan SPD in place? How will the Broads Authority be involved in its production? Is that the same thing that is referred to in the next para before the next bullet points? Should you refer to, even if it is as a footnote, that some of the Utilities site is in the Broads and there is a policy in the Local Plan for the Broads for that and that is consistent with this policy and we will work together etc?
• Page 111, Para 346: ‘…as shown in appendix 5…’. What is ‘good access’? What is a ‘safe route’?
• Page 112, policy 7.4, final para above ‘employment’: what about impact on character of the nearby area like the Broads.
• Page 114, policy 7.5 – do you want to say ‘subject to other policies’? Does the approach contradict page 113 ‘..without breaching normal planning criteria and the sustainable site selection process’.
• Page 114 – is another alternative to not allow this approach?

Typo/grammar
• Box, page 6, Para 4, first sentence: ‘documents will be assembled and as part of the next stage…’
• Page 7, para 6: ‘This will ensure that Norwich continues to be both…’
• Page 24, para 91: ‘flood risk in new development, locating development the great majority of development away from…’
• Page 53, end of footnote 62: ‘…based on the feedback and for each site.’
• Page 56, para 173: ‘The Sustainable Communities policy are wide ranging’. ‘Community policies are’ or ‘Community policy is’?
• Page 57, densities row: ‘…for different parts of the area’
• Page 78, para 239 – ‘it also includes minimum…’
• Page 90, para 267, bullet iii: ‘the essential role that of the other parts of the urban area…’
• Page 93, top: ‘…of key city centre..’
• Page 114, para 350: ‘’’through policies other policies in this plan’

Sites Document

General comments
• Suggest bullet points are numbered for ease of reference.
• I have a concern that there is little translation of strategic ecological gain to site policies. For example I could not find any site specific reference to sites that are within the GNLP Green Infrastructure (GI) Corridors, despite some of the sites, for example around Acle, Whitlingham/Trowse etc being in the junction of major adjoining corridors. I would expect that in these major biodiversity intersections opportunities to enhance wildlife corridors would be highlighted on a site basis. When Net Gain requirement is introduced via the Env Bill will this be picked up at this point?
• Some of the allocations/reasonable alternatives are on or close to or on deep peat resource so it is relevant to include the treatment of carbon rich soils and reference to ‘net zero’ targets. Excavation of deep peat is a significant emitter of carbon into the atmosphere and thus should be shown to significantly influence site choice.
• We asked in the past about this, but it is not included in the documents that I can see. We safeguard former rail tracks from development for their potential future use as PROWs. Go to page 211: https://www.broads-authority.gov.uk/__data/assets/pdf_file/0004/1581916/Local-Plan-for-the-Broads.pdf. Here is the map, page 3: https://www.broads-authority.gov.uk/__data/assets/pdf_file/0008/1565837/SSTRACKS_RAILWAYS.pdf. Are you able to/have you included a policy to safeguard the land from development?

GNLP0068
• Could it make the most of its riverside location?
• Bold text uses the word ‘should’ when referring to affordable housing level. But the later bullet points are introduced as ‘will achieve’. The word ‘should’ seems to weaken the requirement. CC4b for example does not mention ‘should’ indeed GNLP0312 is firmer saying ‘will’.
• Bullet point 5 – so will they provide a river side path? Or maybe do it? Part of the bullet says to do it and then the other says potentail future extension – suggest this is clarified. GNLP0401 equivalent bullet points implies the walkway/cycleway will be provided as part of the scheme. Is the scheme expected to provide the walkway/cycleway and to what standard?

GNLP0409R
• Could it make the most of its riverside location?
• Bold text uses the word ‘should’ when referring to affordable housing level. But the later bullet points are introduced as ‘will achieve’. The word should seems to weaken the requirement. CC4b, for example, does not mention ‘should’ indeed GNLP0312 is firmer saying ‘will’.
• Bullet point 1 – where it says the design will be energy and water efficient, is that beyond the 110l/h/d and 20% above Part L requirements set out in the other document?
• Bullet point 7 – so will they provide a river side path? Or maybe do it? Part of the bullet says to do it and then the other says potentail future extension – suggest this is clarified. GNLP0401 equivalent bullet points implies the walkway/cycleway will be provided as part of the scheme. Is the scheme expected to provide the walkway/cycleway and to what standard?
• Page 24, para 2 – so the policy refers to car free or low car usage, but the offices will have a car park; is that contradictory?

GNLP0401
• Bold text uses the word ‘should’ when referring to affordable housing level. But the later bullet points are introduced as ‘will achieve’. The word should seems to weaken the requirement. CC4b, for example, does not mention ‘should’ indeed GNLP0312 is firmer saying ‘will’.
• Bullet point 1 – where it says the design will be energy and water efficient, is that beyond the 110l/h/d and 20% above Part L requirements set out in the other document?
• Where it says ‘respect its riverside location’ what does that mean? Could it make the most of its riverside location?
• Bullet point 2 – so will the development be on the existing car park?
• Bullet point 4 implies the walkway/cycleway/ will be provided as part of the scheme – but other policies are not that clear. Is the scheme expected to provide the walkway/cycleway and to what standard?

R10
• Bold text uses the word ‘should’ when referring to affordable housing level. But the later bullet points are introduced as ‘will achieve’. The word should seems to weaken the requirement. CC4b for example does not mention ‘should’ indeed GNLP0312 is firmer saying ‘will’.
• Could it make the most of its riverside location?
• Bullet point 2 - implies the walkway/cycleway will be provided as part of the scheme – but other policies are not that clear. But then it says ‘should’ (which 0068 equivalent bullet point does not include) link to a future extension? This may need clarifying. Is the scheme expected to provide the walkway/cycleway and to what standard?

GNLP0360
• Bold text uses the word ‘should’ when referring to affordable housing level. But the later bullet points are introduced as ‘will achieve’. The word should seems to weaken the requirement. CC4b, for example, does not mention ‘should’ indeed GNLP0312 is firmer saying ‘will’.
• Could it make the most of its riverside location?
• Bullet point 1 – last part refers to not prejudice future development of or restrict options for the adjoining sites. But the Utilities site is over the river, so not adjoining. Should the policy refer to the Utilities site in this sentence as well?
• Is the scheme expected to provide the walkway/cycleway and to what standard?
• There appears to be no mention of protecting and enhancing designated / non-designated heritage assets. There is a listed lime kiln on the site and I think potentially some locally identified HAs.

GNLP3053
• Bold text uses the word ‘should’ when referring to affordable housing level. But the later bullet points are introduced as ‘will achieve’. The word should seems to weaken the requirement. CC4b, for example, does not mention ‘should’ indeed GNLP0312 is firmer saying ‘will’.
• Could it make the most of its riverside location?
• Bullet point 1 – last part refers to not prejudice future development of or restrict options for the adjoining sites. But the Utilities site is over the river, so not adjoining. Should the policy refer to the Utilities site in this sentence as well?
• Is the scheme expected to provide the walkway/cycleway and to what standard?
• There appears to be little mention of designated heritage assets and there are a number on site / immediately adjacent, including the scheduled and highly graded Carrow Priory, listed former industrial buildings and Carrow House on King Street and the site is within the Bracondale CA.

CC7
• Could it make the most of its riverside location?
• Bold text uses the word ‘should’ when referring to affordable housing level. But the later bullet points are introduced as ‘will achieve’. The word should seems to weaken the requirement. CC4b, for example, does not mention ‘should’ indeed GNLP0312 is firmer saying ‘will’.
• Unlike other policies with a waterside frontage, the following wording is missing. Why is that? Could/should it be added?
o A scale and form which respects and takes advantage of its riverside context,
o High quality landscaping, planting and biodiversity enhancements particularly along the river edge;
o Protection of bankside access for maintenance purposes.

CC16
• Bold text uses the word ‘should’ when referring to affordable housing level. But the later bullet points are introduced as ‘will achieve’. The word should seems to weaken the requirement. CC4b, for example, does not mention ‘should’ indeed GNLP0312 is firmer saying ‘will’.
• Bullet point 1 – where it says the design will be energy and water efficient, is that beyond the 110l/h/d and 20% above Part L requirements set out in the other document?
• Where it says ‘respect its riverside location’ what does that mean? Could it make the most of its riverside location?
• Is the scheme expected to provide the walkway/cycleway and to what standard?
• Reference is made to the Bracondale Conservation Area but there are Heritage Assets in the vicinity, including the schedule Boom Towers and I think listed buildings on the Carrow Works site / Papermills Yard site.

CC8
• Bold text uses the word ‘should’ when referring to affordable housing level. But the later bullet points are introduced as ‘will achieve’. The word should seems to weaken the requirement. CC4b, for example, does not mention ‘should’ indeed GNLP0312 is firmer saying ‘will’.
• Could it make the most of its riverside location?
• Unlike other policies with a waterside frontage, the following wording is missing. Why is that? Could/should it be added?
o A scale and form which respects and takes advantage of its riverside context,
o High quality landscaping, planting and biodiversity enhancements particularly along the river edge;
o Protection of bankside access for maintenance purposes.

CC4b
• Could it make the most of its riverside location?

GNLP2137
• I note this is a reasonable alternative. If this is taken forward then we would welcome wording that covers the issues addressed above.

GNLP1001
• The site is on higher ground, close to our boundary and potential visual receptors: Wherrymans Way, the river, railway, Ferry Road and Reedham Drainage Mill.
• The site might also be visible from the opposite valley side but against a backdrop of existing settlement.
• There is a risk that new built development/housing, if not sensitively handled could have adverse impacts on the setting of the Broads.
• The possible landscape effects could be mitigated by low ridge heights, reduced scale/massing and screen planting.