Policy 0133E

We fully support this allocation as it requires the development to be sited in Flood Zone 1 as we previously requested, and is not allowing less vulnerable in the flood zone as stated in the SFRA.

To ensure the soundness of the policy wording, we would suggest that Point 6 of the Policy GNLP0133-E is revised to read as follows: 'Include an enhanced pedestrian and cycling connection through the site from Bluebell Road to the Broad, and linkages to and along the open river valley landscape to the south and east'.

The deletion of the remainder of this element of policy wording is considered necessary to secure the deliverability of all elements of Policy GNLP0133-E. The Bartram Mowers site is not within the University's land control, so enhancement of linkages to open spaces within this site, and the development as approved through application ref: 19/00911/F, cannot be guaranteed.

In addition, the following changes to policy wording are recommended, to assist in developing the design proposals for the site during the Plan period:

Point 2 to be reworded as follows: 'Generally low-rise development (at least 2-3 storeys) however acknowledging the enclosed nature of the site, the scale/building height of any proposed development will be tested against an assessment of its landscape and visual impact, to consider the impact on adjoining residential properties and established open space'

On behalf of our clients the University of East Anglia, we support the proposed allocation of Policy GNLP0133-E – Land at the UEA Grounds Depot Site, 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 soundness. 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 continued 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
There are no site-specific constraints which could preclude the delivery of student accommodation and a small element of ancillary university related uses. Therefore, student accommodation and a small element of ancillary university related uses 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, the inclusion of the Policy GNLP0133-E cannot be justified, and should be deleted if the GNLP is to be sound.

The Local Plan is unsound in that Policy GNLP0133-E is
A. Not consistent with the National Planning Policy Framework (NPPF) section 15. Conserving and enhancing the natural environment.
B. Not justified by, and inconsistent with, policies in the draft GNLP Strategy.
C. Not justified as an appropriate strategy, taking into account the reasonable alternatives.

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 GNLP0133-E threatens to intrude deeply into the Valley, interrupting the present natural flow of the edge of the Corridor along the south edge of the approved university sites to along the line of the Bluebell Road.

A. The Policy is not consistent with the 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 GNLP0133-E is diametrically opposed to (a) and (b) above for the following reason:
The present Norwich “Adopted polices map south sheet” shows the whole area of Policy GNLP0133-E lies within the DM6 Yare Valley Character Area and the DM8 Green Space policies 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 GNLP0133-E 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 GNLP0133-E is not consistent with 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 GNLP0133-E would have the effect of decreasing the green infrastructure and damaging its network. As such it contradicts the Policies in the GNLP Strategy, and its inclusion in the plan is not justified.
C. Not justified as an appropriate policy, taking into account the reasonable alternatives.
The Development Framework Strategy (DFS) of the University of East Anglia (draft updated June 2019), when considering the “Preferred Sites” for development, admits that “potential development areas for this DFS period are not obvious/clear candidate sites” (p. 68). There seems to be no justification for selecting the site of the Policy in preference to other candidate sites that are within the University development envelope, and which would not involve reducing valuable green space in the Valley Corridor.
In addition, it is surprising that the UEA Main Car Park is not considered, in part at least, as a “Preferred Site”. This is a large undeveloped area in the heart of the Campus with huge development potential. Well-designed development of this site, incorporating teaching facilities, student accommodation, etc, with (if necessary) no loss of parking spaces, could greatly enhance the Campus, and would not involve reducing environmentally valuable green space in the Valley Corridor.
(UEA DFS is at
https://gnlp.oc2.uk/docfiles/46/DFS%202019%20reduced%20file%20size.pdf )

Summary
If Policy GNLP0133-E were enacted it would damage the existing green infrastructure and increase pressure on the remaining green infrastructure. Such development would not be consistent with the NPPF, is not justified by the Polices in the draft GNLP Strategy, and is not justified taking into account reasonable alternatives.
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, the inclusion of the Policy GNLP0133-E cannot be justified, and should be deleted if the GNLP is to be sound.