Sustainability Appraisal Report

Object

Representation ID: 23258

Received: 24/02/2021

Respondent: Mr Clive Boyd

Legally compliant? No

Sound? No

Duty to co-operate? No

Sustainability Appraisal
The Sustainability Appraisal is flawed in its assessment of reasonable alternatives, environmental objectives, and social objectives.

Reasonable Alternatives
Many of the local residents chose their homes because of their location. Repeatedly, local authority told us that the field designated as Site No GNLP0463R was outside the building line, and that any future development would take place in the field immediately to the south of Big Back Lane, with access via Beauchamp Road and Proctor Road. Indeed, the ends of these two roads have been left open whereby they could be extended to service any new development. We feel betrayed that the traditional building line is being ignored, as is the original proposed site for development.
Environmental
The proposed development and possible widening of local roads will severely impact on this beautiful area in an adverse way. The villagers are aghast at its potential loss which would hardly engender good feeling towards the new estate. It would be a mistake to tally the residents of Chedgrave without taking into account Langley School, situated on the edge of the village. The capacity of the schools is for over 800 persons; teachers, pupils, and support staff; this compares with just over 1,000 residents of Chedgrave. The daily movement of personnel connected to the school already makes the volume of traffic an issue in the area, which would
be exacerbated by the proposed development.
Social
The local facilities to service the new development are
already fully utilised, with little capacity to accommodate
more residents, especially when it is also proposed to have an even bigger development (GNLP0312) in this same area.

The Sustainability Appraisal is jaundiced in that it concentrates on the requirements of the new residents
without giving consideration to the impact on the current
residents. We cannot find a single resident who is in favour of this development, and are struggling to
understand why it is being foisted upon us against our wishes. We cannot believe that our green habitat needs to be taken before the GNLP can achieve its building targets.

Object

Representation ID: 23569

Received: 15/03/2021

Respondent: Noble Foods Ltd

Agent: Carter Jonas LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

.

Object

Representation ID: 24247

Received: 22/03/2021

Respondent: Climate Friendly Policy and Planning (CFPP)

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Please find the consultation response from Climate Emergency Planning and Policy to the Reg 19 Pre-Publication Draft GNLP attached.

Object

Representation ID: 24350

Received: 22/03/2021

Respondent: Jarrold and Sons Ltd

Agent: CODE Development Planners Ltd

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Please see attachment for details of full representation.

These representations are submitted on behalf of Jarrolds & Sons the owners of land to the rear of Heath Crescent (identified in the Greater Norwich Local Plan (GNLP) evidence base documents as site GNLP2173). The site is bound to the north by Fifers Lane, an industrial
estate to the east and residential dwellings along Heath Crescent and Prince Andrew’s Road to the west, and Prince Andrew’s Close to the south.

The site at Heath Crescent has been assessed in the GNLP Site Assessment: Norwich and Urban Fringe - Hellesdon Booklet as a reasonable alternative site for residential development (reference GNLP2173).

4 Conclusions
4.1 Jarrold & Sons also considers the GNLP fails the test of soundness when assessing whether it is justified. In order to be justified the plan should be an appropriate strategy, taking into account the reasonable alternatives and based on proportionate evidence. There is insufficient evidence to justify decisions in the GNLP. Decisions that have been made are based on
inaccurate and misleading information.
4.2 These representations demonstrate that the GNLP is not legally compliant and fails the tests of soundness.
4.3 Currently the GNLP seeks in part to delegate decisions regarding the spatial representation of
the infrastructure requirements to support growth, principally sport, recreation and open space designations, to the development management DPDs. However, this fails the tests of soundness as it has impacted the GNLPs policy justifications and effectiveness. Furthermore,
it does not provide a strategy which seeks to meet the areas needs consistent with achieving sustainable development; the residential allocations are not supported by an up to date assessment of the need for sport, recreation and open space. The GNLP is therefore not positively prepared.
4.4 In order to remedy this the SA needs to be amended and reassess strategy and site allocation policies. The GNLP Site Assessment Booklets should be amended to follow and reference the SA assessment. These amendments will lead to amendments to the policies and supporting text contained in the GNLP. Consequently, further formal public consultation will be required.

Object

Representation ID: 24408

Received: 22/03/2021

Respondent: ClientEarth

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Since the Regulation 18 consultation, the UK Climate Change Committee (CCC) has issued a standalone report providing recommended actions for local authorities, with a view to enabling the achievement of the 6th Carbon Budget and the 2050 net zero target.(https://www.theccc.org.uk/publication/local-authorities-and-the-sixth-carbon-budget/) The report includes a number of specific recommendations in respect of local planning policy, which they say should “lay the foundations towards net zero”. The CCC advises that:
 “Net Zero housing and commercial developments, connected to sustainable transport infrastructure, walking and cycling and public transport need to become the norm, not the exception”, and
 “[n]ew planning policy needs to align more widely with spatial planning for sustainable transport and energy systems – to support decarbonised heat as a norm – based on appropriately sited, highly energy efficient buildings.” In this context, they further advise: “Zero carbon developments avoid future retrofit costs for councils, landlords and residents. … Local planning authorities currently developing Local Plans should gather evidence to support policies that require developments to exceed current building standards. This should include evidence that shows that higher energy performance and low-carbon heating systems will add value to the sale or rental price and reduce energy costs for householders. This evidence can feed into the determination of the value of the development. … Local Plans and Transport Plans should deliver modal shift from cars to walking, cycling and public transport. New developments should prioritise walking and cycling infrastructure at the masterplanning stage and should be well-linked to viable public transport routes. Planning policy can set maximum (rather than minimum) car parking spaces for developments or even car-free development. … Constraining the growth in vehicle mileage is vital to reducing emissions, even as EVs replace petrol and diesel cars. Car and van mileage can be reduced by 7-16% by 2030 and 12-34% by 2050 against today’s levels. There should be: … Shifting 33-35% of trips to walking, cycling and public transport such as shorter trips, for cities this can be higher … Local Plans should support renewable energy and low-carbon heat. Local Planning Authorities should review Local Plans. These should include an energy policy that takes a positive and proactive approach to renewable energy generation and storage. … Local authorities should include new onshore wind in discussions with communities about climate change and land-use planning.”
The Norfolk Strategic Planning Member Forum (NSPMF), of which the Greater Norwich authorities are part, has also recently issued a research paper on ‘climate change and the planning system’.(https://www.norfolk.gov.uk/what-we-do-and-how-we-work/policy-performance-and-partnerships/partnerships/norfolk-strategic-planning-member-forum) The paper includes a number of recommendations regarding plan-making:
 On the overall approach: “Action on climate change should be an integral part of the culture of plan-making and should be embedded and integrated in policy preparation. … Local Planning Authorities are therefore likely to need to evaluate planning applications through a climate change lens and ensure future local plans clearly set out the decision-making framework, with particular emphasis on the following, for example:
o Placing more emphasis on co-locating uses and planning development near public transport links to reduce car travel.
o Setting more ambitious targets on energy efficiency in buildings.
o Encouraging the greater use of renewable energy.
o Embedding and prioritising climate change in local plan-making and when determining planning applications, including ensuring resilience to climate impacts such as flooding.
o Requiring travel plans with increased sustainable transport obligations - prioritising walking, cycling and public transport over reliance on the car.
o Increasingly plan and help facilitate for the switch to electrified transport.”
 On co-benefits: “It is important to be aware that whilst these recommendations relating to topic areas may address climate change adaptation and mitigation, or sequestration of greenhouse gases, that is not the only benefit. It is often wise to do what is recommended, regardless of climate change, because of the many other benefits of which doing so brings. The elements of climate change are also woven into many policy areas with much cross-over, e.g. growth distribution, transport policies, environmental policies as well as specific polices on adaptation and mitigation as all have a role to plan in addressing Climate change. For example:
o Walking and cycling rather than driving a motor vehicle can reduce greenhouse gas emissions from burning fuel. Adopting a more active lifestyle can lead to improved health and well-being as well as saving individuals money.
o An energy efficient home requires less energy and therefore reduces the amount of emissions associated with producing energy, but it also reduces money a household or business spends on energy bills.
o Green infrastructure can help sequester carbon dioxide but it can also help biodiversity and increase access to the countryside and other greenspaces, which can in turn support mental and physical well-being.
o Tackling climate change is part of facilitating and enabling clean growth. It can help economic recovery and provide job opportunities such as retrofitting of properties,
technology development e.g., EVs and electrification of transport and the renewable energy sector.”
 On sustainable travel: “Local planning authorities should consider the following through appropriate plans, policies and processes: Better alignment of plans and decisions with identified local and national strategic infrastructure priorities for walking and cycling. Ensure proposals seek enhanced connectivity to open space and seek to provide connections to, enhancement and maintenance of nearby existing walking and cycling networks. … The aim is to better promote active forms of travel, particularly walking and cycling to reduce unnecessary car use. Evidence clearly points to shorter trips (i.e. 1-5 miles) where walking and cycling can most effectively increase, and conversely reduce, travel by private car. There needs to be a much more joined up approach, with more collaboration and clear advice on how to realise the multiple aspirations. … Car Free Housing policies: Transport is now the biggest contributor to carbon emissions in the UK and within this sector, passenger cars are by far the biggest contributor. It is clear from the Department for Transport’s research that a modal shift away from the private passenger car would have the most significant impact in reducing greenhouse gases, such an approach could be encouraged through planning policy.”
 On sustainability appraisal: “Strong/prominent climate change objectives in the Sustainability Appraisal and Local Plan … These policies are then assessed against sustainability appraisal objectives whereby potential positives are maximised and any negative effects identified mitigated.”
 On national planning reforms: “[W]hilst changes may well be made to the planning system in future, recommendations within the report are relevant for the current local plans in production and could be ‘in the meantime’ policy approaches – in place until the national system is changed.”
However, despite the Greater Norwich and other NSPMF authorities having committed to implementing these recommendations, they do not appear to be reflected in the current draft of the Greater Norwich plan. In addition to the issues previously raised at the Regulation 18 stage, we have identified the following matters that suggest a failure to comply with the applicable statutory and policy requirements.
In response to the previous criticisms of the approach taken to emissions reduction in the Sustainability Appraisal, the updated report accepts (at p. 14 of Volume 2) the “restricted” nature of the assessment, which is said to fall short of an “in-depth analysis”, with such an analysis requiring “further detail from additional research”. Moreover, in its overall conclusions the report continues to disregard the key question in this context: that is, the extent to which the proposed policies maximise the plan’s potential positive effects on emissions. Rather than simply assessing the relative size of individual policies and sites’ emissions impacts, the appraisal must assess the consistency of all proposed policies and sites with wider climate policy, including whether they fully support the achievement of the national net zero target – itself stated to be a core objective of the plan.(See, e.g., p. 38 of the draft plan: “… to significantly reduce emissions to ensure that Greater Norwich is adapted to climate change and plays a full part in meeting national commitments to achieve net zero greenhouse gas emissions by 2050.”)
Nonetheless, taking the Sustainability Appraisal on its own terms, the following headline conclusions (set out in the Non-Technical Summary) point to the plan having significant adverse effects on this objective:
 “A total of 85 allocated sites are located on previously undeveloped land in the open countryside of Greater Norwich. The proposed development within the GNLP in these locations would be expected to increase the risk of urbanisation of the countryside and coalescence. The proposed development of 49,492 dwellings across Greater Norwich, with a number of developments located within rural Broadland and South Norfolk, would be likely to result in a loss of tranquillity of the rural landscape as a consequence of increases in noise and light pollution.”
 “The majority of new residents would be located in areas with good access to services and facilities, including convenience stores and bus services. Nevertheless, large areas of Broadland and South Norfolk have limited access to rail services.”
 “Approximately 1,019ha of development allocated within the GNLP is located on previously undeveloped land. This would be expected to result in the permanent and irreversible loss of ecologically, and potentially agriculturally, important soil resources. … Soil provides a range of essential services to the local area, including nutrient cycling, abating flood risk, filtering water, filtering air, carbon storage and providing the basis for vegetation to flourish. The scale of development proposed within the GNLP would be expected to increase pressure on essential ecosystem services.”
In response, the GNLP authorities appear to accept these conclusions and, while pointing to attempts to “limit” these impacts in the plan, fall short of suggesting that a lower emissions approach to allocating development was not possible.(GNLP Authorities’ Response to Sustainability Appraisal Residual Effects from the Reg 19 GNLP, January 2021.) Indeed, it would appear that these adverse effects have been exacerbated by the decision to plan for a level of housing that exceeds the assessed need by some 20% / 10,000 houses, and which therefore unnecessarily provides for development on greenfield land and in unsustainable locations.
The impact of this decision is clear from looking at a few examples of the Sustainability Appraisal’s assessment of allocations made in the plan:
 In respect of the Key Service Centre allocations (at C.9.12.2): “It is assumed that this policy would be in conformity with the requirements of other polices, such as Policy 4, to promote sustainable transport. This could potentially help to improve access to workplaces and social infrastructure. However, as these Key Service Areas are located in primarily rural areas across Greater Norwich, improvements to transport infrastructure set out in Policy 4 would be unlikely to provide all site end users with sustainable connections to Norwich city centre, Norfolk and nationally.”
 In respect of the Village Clusters allocations:
o “There is a vast network of [Public Rights of Way] across Greater Norwich. This would be likely to provide good pedestrian access within and around these settlements. However, many of the Village Clusters are situated in remote areas within Greater Norwich, with limited access to railway stations, which are primarily located within Norwich and the east of the Plan area, with some stations also located to the west of South Norfolk. Site end users in more rural locations would also be expected to have limited access to regular bus services, despite some expected transport improvements in line with Policy 4. It is likely that a large proportion of site end users would be situated outside the target distance of public transport links. The rural location of development proposals under this policy would be expected to contribute to a relatively high reliance on personal car use…” (C.10.12.1)
o “Under this policy, it is likely that development will occur at a number of greenfield sites, which would be expected to result in a net loss of agriculturally and ecologically valuable soils. As the significant majority of soils in the Plan area are Grade 3 land, it is likely that this policy would result in a net loss of BMV land. This impact would be permanent and non-reversible and would also reduce the carbon sink capacity of soils across the Plan area.” (C.10.14.1)
 In respect of site GNLP4054 – for provision of 400 dwellings:
o “Sites GNLP4052 and GNLP4054 comprise previously undeveloped land and are located outside the existing settlement of Hethersett. Therefore, the proposed development at these two sites could potentially contribute towards the urbanisation of the countryside.” (D.17.4.4)
o “The nearest convenience stores, Park Drive Stores and Tesco Express, are located in the centre of Hethersett. Sites GNLP4052 and GNLP4054 are located outside the target distance to these shops.” (D.17.6.1)
o “Hethersett Surgery is located in the centre of Hethersett. Sites GNLP4052 and GNLP4054 are located wholly or partially outside the target distance to this GP surgery.” (D.17.8.5)
o “Hethersett Woodside Infant and Nursery School and Hethersett Voluntary Controlled Junior School are located in the south of Hethersett village. Little Melton Primary School is located to the north of the cluster. Both sites in this cluster are situated wholly or partially outside the target distance to these schools.” (D.17.10.1)
o “Sites GNLP4052 and GNLP4054 are located wholly or partially outside the target distance to a bus stop providing regular services. … The closest railway station to Hethersett is Wymondham Railway Station, located approximately 6km to the south west of the cluster. This is outside the target distance …” (D.17.12.1 and D.17.12.2)
o “The proposed development at Sites GNLP4052 and GNLP4054 would be likely to result in a major negative impact on natural resources due to the loss of 20ha or more of previously undeveloped land. These negative impacts would be associated with an inefficient use of land and the permanent and irreversible loss of ecologically valuable soils.” (D.17.14.2)
 In respect of site GNLP0581R – for provision of more than 600 dwellings:
o “Sites GNLP0581R and GNLP4045 comprise previously undeveloped land and are located outside the existing settlements of Costessey and Bowthorpe. Therefore, the proposed development at these two sites could potentially contribute towards the urbanisation of the countryside.” (D.8.4.4)
o “The nearest local services, Co-op, Stafford Stores and Post Office, and Sainsbury’s, are located in and around Costessey. Sites GNLP0581R and GNLP4045 are located outside the target distance to these services.” (D.8.6.1)
o “The closest GP surgeries to this cluster are The Roundwell Medical Centre in Costessey and Taverham Surgery in Taverham. Sites GNLP0581R and GNLP4045 are located outside the target distance to these GP surgeries.” (D.8.8.5)
o “The closest leisure facility to Costessey is Riverside Leisure Centre, located approximately 8km south east of the cluster. Both sites in this cluster are located outside the target distance to this leisure facility …” (D.8.8.6)
o “The closest primary schools to this cluster include Chapel Break Infant School, St Michael’s Church of England Voluntary Aided Junior School and Queen’s Hill Primary and Nursery School. Sites GNLP0581R and GNLP4045 are situated outside the target distance to these schools.” (D.8.10.1)
o “Sites GNLP0581R and GNLP4045 are located outside the target distance to a bus stop providing regular services. … The closest railway station to Costessey is Norwich Railway Station, located approximately 8km to the south east of the cluster. This is outside the target distance … Site GNLP0581R currently has poor access to the surrounding footpath network.” (D.8.12.1-3)
o “The proposed development at Site GNLP0581R would be likely to result in a major negative impact on natural resources due to the loss of more than 20ha of previously undeveloped land. These negative impacts would be associated with an inefficient use of land and the permanent and irreversible loss of ecologically valuable soils.” (D.8.14.2)
Accordingly, on its own terms, the Sustainability Appraisal’s findings would appear to support a quite different approach to site allocation – one that avoids as far as possible new development on greenfield land and in unsustainable locations. The above allocations are an illustrative but not exhaustive list of instances of this problem in the plan.

Object

Representation ID: 24432

Received: 22/03/2021

Respondent: Trustees of First Viscount Mackintosh of Halifax and Trustees of CM Watt Residual Trust

Agent: La Ronde Wright

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Regarding the GNLPs response to point 6: 6 Increased risk of urbanisation of the open countryside and coalescence. A total of 84 allocated sites are located on previously developed land in the open countryside of Greater Norwich. The proposed development within the GNLP in these locations would be expected to increase the risk of urbanisation of the countryside and coalescence.

It is important to undertake a new review of the strategic gaps and other areas between settlements at risk of coalescence to provide an up-to-date evidence base to inform new allocations. As such, with a lack of a review regarding the Strategic Gap, especially in light of the new strategic infrastructure works, it is considered that the GNLP is not justified regarding an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence and therefore conflicting with paragraph 35 of the NPPF.

Object

Representation ID: 24441

Received: 22/04/2021

Respondent: Trustees of First Viscount Mackintosh of Halifax and Trustees of CM Watt Residual Trust

Agent: La Ronde Wright

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Regarding the GNLPs response to point 6: 6 Increased risk of urbanisation of the open countryside and coalescence. A total of 84 allocated sites are located on previously developed land in the open countryside of Greater Norwich. The proposed development within the GNLP in these locations would be expected to increase the risk of urbanisation of the countryside and coalescence.

It is important to undertake a new review of the strategic gaps and other areas between settlements at risk of coalescence to provide an up-to-date evidence base to inform new allocations. As such, with a lack of a review regarding the Strategic Gap, especially in light of the new strategic infrastructure works, it is considered that the GNLP is not justified regarding an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence and therefore conflicting with paragraph 35 of the NPPF.

Object

Representation ID: 24516

Received: 22/03/2021

Respondent: Orbit Homes

Agent: David Lock Associates

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The SA incorrectly assesses the SGV (Site Reference: GNLP4057A) against some of the sustainability objectives and the SA could benefit from an expanded assessment of the new settlement proposals which is outlined in the attachment. SEE FULL REP IN ATTACHMENT.

Object

Representation ID: 24542

Received: 22/03/2021

Respondent: Rosconn Group

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

RSL considers the spatial strategy of the GNLP to be unsound for want of justification as it has not been underpinned by a sufficiently robust SA process. Reasonable alternatives to the preferred spatial strategy have not been adequately appraised in the same detail or on the same basis.

See attachment for full representation (section 5)