Draft Greater Norwich Local Plan – Part 1 The Strategy

Object

Representation ID: 20501

Received: 08/03/2020

Respondent: Marlingford and Colton Parish Council

Phasing for the new housing sites is essential and any new sites should be placed on a reserve list and only used after the existing JCS sites. The current strategy invites land banking and cherry picking by developers.
It is arguable that Norfolk already has an excess of approved sites, many in entirely the wrong locations to allow sustainable and environmentally sound growth. The 'village clusters' concept is unsound and based on erroneous assumptions of existing infrastructure and future use.

Object

Representation ID: 20502

Received: 08/03/2020

Respondent: Marlingford and Colton Parish Council

What seems abundantly clear is that the current strategy favours developers' profits over the real needs of the community. Environmental protection, while given lip service is, in reality, largely ignored. The large number of new vehicle movements that would be generated by the "village clusters" idea, based as it is on false infrastructure assumptions, is a prime example of this conflicted strategy.

Object

Representation ID: 20506

Received: 08/03/2020

Respondent: Marlingford and Colton Parish Council

The strategy seeks "growth [that] will be clean and resource efficient, with significantly reduced emissions", yet much of the growth proposed will inevitably deliver exactly the opposite effect, largely because the (wish-list) infrastructure simply does not exist in the right locations and, for the most part, will not in the foreseeable future. The 'village cluster' concept is particularly flawed in this respect and a handful of primary schools capable of some expansion, which forms much of its cited 'infrastructure', is nowhere near adequate. Prioritising brownfield sites in Norwich and the larger satellite communities would be a more responsible choice.

Object

Representation ID: 20507

Received: 08/03/2020

Respondent: Marlingford and Colton Parish Council

If the objective is, as stated in para 125, to achieve a "radical shift away from...private car and encourage walking, cycling and use of clean public transport", then allocation of housing sites where infrastructure and services already exist is essential.
On this basis a fundamental reappraisal, not only of the current proposals, but of many sites already in the system is required.

Object

Representation ID: 20509

Received: 08/03/2020

Respondent: Marlingford and Colton Parish Council

The "village clusters" concept is entirely unsustainable in that it relies upon accessing small pockets of geographically disparate infrastructure which will result in the need for increasing numbers of private car journeys and, given the decreasing availability of public transport, clean or otherwise, works directly contrary to the plan's stated environmental objectives.
Additionally, SNDC talk of a "minimum of 1, 200 houses" in these clusters. This should, at least, be corrected to 1, 200 MAXIMUM. If they actually do envisage 1,200 minimum then they are creating a sort of uncontrolled, open-ended 'free for all".

Comment

Representation ID: 22235

Received: 15/03/2020

Respondent: Marlingford and Colton Parish Council

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.