0133DR Policy

We suggest replacing respect with ‘conserve and enhance the heritage significance. We also suggest inserting a comma after Terraces.

Continue to suggest HIA for campus now ahead of EiP.

Thank you for consulting Historic England on the Greater Norwich Local Plan Regulation 19 Draft including The Strategy and The Sites. As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the conservation and enjoyment of the historic environment.

Our comments below should be read with reference to our previous comments dated 1.2.17, 15.3.18, 4.12.1, 26.4.19 and 16.3.20. Please also see our detailed comments in the attached tables, Appendix A in relation to The Strategy and Appendix B regarding The Sites.

SUMMARY
The Greater Norwich Local Plan covers the Strategy and Site Allocations. While commenting on the plan as a whole, Historic England is particularly concerned, for its implications for Norwich itself. Norwich is one of England’s great historic cities, and its architectural and historic character, and the sense of place associated with that, make a profound and wholly beneficial contribution to the city’s well-being.

In line with paragraph 185 of the National Planning Policy Framework (NPPF) it is important that the Plan should set out a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats.

To ensure the soundness of the policy wording and associated preamble text, we would suggest that Paragraph 2.39 is revised to delete the following text: 'Since the proposal involves the loss of existing open space, any development must include the opening up of new areas for public access as compensation for this loss'

The University campus, and associated University-owned and managed open spaces, are free for the public to access and enjoy. As the vast majority of University-owned open spaces are not impacted by Policy GNLP0133-DR, it is not considered that this wording is justified or necessary.

On behalf of our clients the University of East Anglia, we support the proposed allocation of Policy GNLP0133-DR – Land Between Suffolk Walk and Bluebell Road, within the Pre-Submission (Reg 19) Joint Local Plan.

A modification to policy wording, specified within Section 6 of this document, outlines the amendment we consider is necessary to achieve legal compliance.

Delivery of the site within the Plan period to 2038 is achievable, and the site remains suitable, available, achievable and viable for the following reasons:

Suitable
The identification of the site as a draft allocation will help to support the expansion of the UEA, alongside sustaining and enhancing the valuable role which the UEA holds for Norwich and the wider context. The UEA are fully committed to development on this site, and view it as an integral part of meeting the UEA’s future growth requirements.

Available
The site, in its entirety, is owned by the UEA, and there are no leases or restrictive covenants on the site. Consequently, the site is readily available for development.

Achievable
Based on the suitability assessment above, there are no site-specific constraints which could preclude the delivery of academic and non-academic university related development on the site. Therefore, academic and non-academic development on the site is deemed to be entirely achievable.

Viable
We are confident that the delivery of the site is viable having regard to the policy requirements of the draft GNLP and there are no factors that we are aware of, at this moment in time, that could prevent the delivery of the site.

For the reasons given above, the footprint of Policy GNLP0133DR should be returned to that approved in the 2016 Local Plan, and so make the Policy consistent with the NPPF and with the GNLP Strategy.

The Local Plan is unsound in that Policy GNLP0133DR is A. Contrary to the National Planning Policy Framework (NPPF) section 15. Conserving and enhancing the natural environment. B. Inconsistent with policies in the draft GNLP Strategy.

Evidence

Background on the Yare Valley Corridor
The Policy should be viewed in the context of the Yare Valley Corridor as a whole.
The Yare Valley Corridor is a key Strategic Green Infrastructure Corridor in the Norfolk biodiversity network, and is protected in the present Norwich Local Plan under Open Space Policy DM8 and Yare Valley Character Area Policy DM6.
The Greater Norwich Infrastructure Plan (GNIP) has identified the Yare Valley as a GI priority initiative in the form of a linear Parkway linking Bawburgh in the West through to Whitlingham in the South East to help manage the development pressure in the area. (GNIP para. 3.3 and 3.4). The Valley can also be expected make a major contribution to the Governments “Green Future” Plan (May 2020) in the realisation of a Nature Recovery Network (NRN) and in achieving Biodiversity Net Gain (BNG).
The Corridor is more than the sum of its parts, and needs its green space conserved and enhanced if it is to function effectively in the future in its multiple roles. These roles include:
• Providing a variety of wildlife habitats, for linking them into the local green network for wildlife movement and for promoting biodiversity.
• Providing interesting, visually attractive, and connected public green space - increasing recognised as essential to the well-being of communities.
• Mitigating the effects of climate change by storing water in its wetlands, retaining water in its vegetation, and acting as a carbon sink.
A large and growing residential population on the corridor’s borders is making increasing demands on the Valley with a resulting adverse effect on its ecology. Witness to these demands is the heavily worn paths of the Yare Valley Walk and its linking path network. There is widespread recognition that the on-going Covid19 crisis has created an even wider public enjoyment and appreciation of green open space, and an uplift in its use. If the corridor is to have a sustainable future, any changes to the corridor must be aimed at increasing rather than decreasing its size.
Policy GNLP0133DR envisages development creep into the Valley beyond the present development boundary and reducing the green space of the valley corridor.

A. The Policy is not consistent with national policy (NPPF Section 15)
Section 15. “Conserving and enhancing the natural environment” of the NPPF paragraph 170 states
“Planning policies and decisions should contribute to and enhance the natural and local environment by:
(a) protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils (in a manner commensurate with their statutory status or identified quality in the development plan);
(b) recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services ….”
What is proposed in policy GNLP0133DR is contrary to (a) and (b) above for the following reason:
The present Norwich “Adopted polices map south sheet” shows Policy GNLP0133DR envisages extending the existing allocated development area further into the DM6 Yare Valley Character Area and the DM8 Green Space of the Norwich Development Management Policies.
In particular for DM6:
“Within the Yare Valley character area, as defined on the Policies map, development will only be permitted where it would not damage the environmental quality, biodiversity or character of the area and where it is for
a) agriculture or forestry purposes; or
b) facilities ancillary to outdoor sport and recreation; or
c) the limited extension of or alteration to existing buildings”
Policy GNLP0133DR does not fall into any of these categories and is thus a step back from previous Norwich green space commitments. As regards the NPPF, it does not “contribute to and enhance the natural and local environment" Instead it reduces and degrades it. It is not “protecting and enhancing valued landscapes …” and it fails to recognise “the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services ….”
As such the policy GNLP0133DR is contrary to the NPPF and so renders the local plan unsound.
(Note 1. The GNLP consultation documentation states that Norwich Development Management Policies are “to be carried forward and used in conjunction with the Greater Norwich local plan 2022-2038.”
Note 2 The “Adopted policies map south sheet” can be downloaded at. https://www.norwich.gov.uk/downloads/file/2709/adopted_policies_map_south_sheet )

B. The Policy is not justified by, and is inconsistent with, policies in the draft GNLP Strategy
The importance of green infrastructure is rightly recognised in a number of policies in the “The Strategy” of the draft GNLP. Some relevant policy statements are (italics inserted for emphasis):
POLICY 7.1 – The Norwich Urban Area including the fringe parishes:
“Growth will include …Enhancements to the green infrastructure network which include links to and within the Wensum, Yare, Tud and Tas Valleys, Marriott’s Way and from Mousehold through the north-east growth triangle as set out in maps 8A and B, along with local networks.
POLICY 3 – ENVIRONMENTAL PROTECTION AND ENHANCEMENT “Development proposals will be required to conserve and enhance the natural environment (including valued landscapes, biodiversity including priority habitats, networks and species, ancient trees and woodlands, geodiversity, high quality agricultural land and soils) through: • being designed to respect and retain, and add to, natural assets; taking account of local design and other guidance, and undertaking landscape, biodiversity or other appropriate assessments if significant impacts might arise; • avoiding harm to designated and non-designated assets of the natural environment unless there are overriding benefits from the development and the harm has been minimised. “In addition, development will deliver net biodiversity gain … creating new or enhancing existing green infrastructure networks that have regard to and help to achieve the local green infrastructure strategies.”
More generally:
POLICY 1 – THE SUSTAINABLE GROWTH STRATEGY Sustainable development and inclusive growth are supported by delivery of the following between 2018 and 2038: …… environmental protection and enhancement measures including further improvements to the green infrastructure network will be delivered.”
These Policy items emphasise the importance attached to delivering conservation and enhancement of the green infrastructure habitats and networks, and to delivering net biodiversity gain, Policy 7.1 singles the Yare Valley out for particular attention for green infrastructure enhancement.

In contrast Policy GNLP0133DR would have the effect of decreasing the green infrastructure and reducing the extent of its network. It contradicts the Policies in the GNLP Strategy, and the extension it envisages is not justified.
Summary
If Policy GNLP0133DR were enacted it would reduce the existing green infrastructure and increase pressure on the remaining green infrastructure of the Valley Corridor. Such development would be contrary to NPPF and to Polices in the draft GNLP Strategy.
6.Please set out the modification(s) you consider necessary to make the Local Plan legally compliant and sound, in respect of any legal compliance or soundness matter you have identified at 5 above.
For the reasons given above, the footprint of Policy GNLP0133DR should be returned to that approved in the 2016 Local Plan, and so make the Policy consistent with the NPPF and with the GNLP Strategy.