Interim Sustainability Appraisal

We acknowledge that this is an interim sustainability appraisal, and note that presumably more detailed appraisal of policy options will be carried out prior to the Regulation 19 consultation.

1. Appraisal of objectives
It is difficult to carry out a meaningful appraisal of such broad objectives. However, one point we wish to make in relation to the economy objective is that "an enterprising, creative, broad based economy with high productivity and a skilled workforce" is not necessarily incompatible with reducing carbon emissions and adapting to climate change. The transition to a zero-carbon society actually brings many opportunities for skilled and useful work in renewable energy, construction, repair and recycling, etc. If steps are taken to promote this 'green economy' in Greater Norwich, economic prosperity will actually help with regard to SA2. It is true, however, that the current economy, based on ever-greater consumption of resources, is harmful to objectives on climate change.
On the 'homes' objective, there should be a mention of how good design for energy and water efficiency can minimise the negative impact on reducing carbon emissions and preserving water supply.
A theme running through this section is the self-contradictory assertion that several of the objectives will have a negative impact on conservation, air quality, reducing emissions, and water supply, but a positive impact on 'quality of life' and 'deprivation'. Any meaningful measure of quality of life presumably includes breathable air and sufficient potable water. The way these outcomes are weighed up against each other perpetuates an artificial separation of economic, social and environmental issues - how can you have social justice or economic prosperity if your air and water are poisoned and your home under threat from extreme weather?

2. Assumptions
The interim SA lists several assumptions that have been made. We understand that a number of factors make a certain degree of assumption necessary. However, there is a crucial difference between an assumption based on available evidence (where the evidence is used to come up with a 'best guess' in the absence of certainty) and an unevidenced assumption based on received wisdom or someone's opinion.
To give three significant examples: firstly, it is stated that "within the limits of this assessment it is assumed that a higher release of land for housing would result in high delivery rates and overall build out levels." However, no evidence is cited for this assumption, despite the previous sentence having essentially acknowledged that it is in fact likely to be false. For an issue of such central importance to the plan, evidence should be sought based on current unbuilt planning permissions in Greater Norwich, past allocation levels and build-out rates, and comparisons from elsewhere in the country. As it is, the assumption that 'more allocations = more housing' is used to prop up arguments for a high delivery buffer, which would be likely to result in significant unnecessary development of land with valuable agricultural and/or biodiversity value (which developers will tend to favour over more complicated brownfield sites).
Secondly, the SA goes on to say that "A wide dispersal and mixture of development sites is assumed to provide more choice and competition in the housing market, which has benefit in terms of housing delivery." We have two major concerns about this claim. One, there is again no evidence for an assumption which is subsequently used to skew the SA heavily towards the dispersal options (which are unacceptable according to almost all the SA criteria). Two, the phrase "choice and competition in the market" is used repeatedly in the consultation document. However, here it is "the housing market", while in several instances elsewhere it is "the market for land". These are two different things. "Choice and competition in the housing market" would seem to refer to choice for homebuyers and competition among builders/sellers for their custom. "Choice and competition in the market for land", on the other hand, is an extremely woolly phrase. Who is competing with whom for what? Choice and competition in the marketplace are generally two sides of the same coin: if there are lots of cake stalls at the market, I as a purchaser have choice, while the cake vendors have competition. In the case of the 'market for land', whether the landowners have competition and the developers have choice or vice versa, it is not at all clear why this 'competition' is increased by the choice of dispersed rural sites over urban ones, nor how it will speed up housing delivery, which is in any case quite another matter from simply obtaining land or planning permission.
Finally, it is also "assumed that larger sites [...] are less likely to be able to provide higher proportions of affordable housing" - again with no supporting evidence (and certainly no evidence that lack of affordable housing is due to higher site costs, rather than simply a greater willingness on the part of large developers to hire consultants to write viability assessments which allow them to escape their affordable housing obligations).

3. Appraisal of growth distribution options
The appraisal gives a useful overview of the impacts of different options. There is less differentiation than might at first be expected, but we appreciate that at this stage, it may not yet be possible to make finer distinctions between some of the options. However, we take issue with the conclusion ('Summary of significant effects') and the way it has been reached. Looking at the colour-coded table and the detailed commentary, the most obvious conclusion to be drawn is that options 4, 5 and 6 perform significantly worse. Yet the concluding remarks open with "Options 1, 2 and 3 may be significantly harder to deliver" - skating over everything the SA has said, and choosing instead to comment on something that it is not best placed to evaluate. 'Delivery' is not a criterion of the SA - indeed, delivery of a bad plan could hardly be said to be a sustainable outcome.
7.6.2 acknowledges that options 1, 2 and 3 outperform the dispersal options on "objectives that seek to improve air quality, reduce the impact of traffic, address climate change issues, increase active travel and support economic development". Once again, the conclusion appears overwhelmingly obvious. Yet the overall conclusion reached is a total non-sequitur: "in sustainability terms the choice between alternatives [...] appears finely balanced, with no alternative clearly better than another". This blatantly flies in the face of everything the SA says - it is not a legitimate conclusion in any sense. This use of the vague and unevidenced claim about 'delivery' (which apparently weighs equally with every single SA criterion put together) cannot go unchallenged. If the next iteration of the SA remains at this shockingly poor level of 'analysis', it risks rendering the plan unsound.

4. Appraisal of policy options
We consider the logic to be flawed in the appraisal of option SH2. 7.13.1 states that "if villages are clustered in such a way that higher growth is only allocated where the levels of accessibility to services is good then the impact of this approach could also be positive in respect of SA1, SA2, SA6, SA7, SA8, and SA12." But ensuring "higher growth is only allocated where the levels of accessibility to services is good" is the purpose of the existing settlement hierarchy. Merging several categories, whatever the detail of how it is done, unavoidably undermines this - the purpose of option SH2 is precisely to allow growth to be allocated further from services. "It's too early to tell" is an unacceptable cop-out position for the SA to take on a proposal that would clearly have a significant negative impact on several of the plan objectives and SA criteria.
The section on policy options underlines how unsatisfactory it is to have only one option on major issues such as climate change and energy - they can only be appraised against a 'no plan' scenario, which is an extremely low bar. The SA ought to be evaluating a range of policy options so that well-informed decisions can be made.

5. Monitoring
Please see our response to Q. 50 and Q. 64 of the Growth Options consultation.


N.B. The GNLP objective on climate change has changed to 'mitigate against' rather than 'minimise contributors to' - in the SA (4.5), this has not been updated.