Draft Greater Norwich Local Plan – Part 1 The Strategy

Comment

Representation ID: 20791

Received: 12/03/2020

Respondent: Norwich Green Party

Updates needed:
1. Government has announced intention of bringing forward deadline to end sale of petrol/diesel cars and vans to 2035. This has implications for clean energy provision and local charging infrastructure.
2. Transforming Cities is likely to secure smaller funds for sustainable travel improvements, with serious implications for developing public transport upon which the Joint Core Strategy was predicated. There are no other sources of funding on the horizon for ensuring that existing and new strategic growth areas will be served by public transport to help encourage modal switch.
3. 'Planning for Future' includes measures to build greener homes.

Object

Representation ID: 20793

Received: 12/03/2020

Respondent: Norwich Green Party

Major conflicts and tensions in the overall plan purpose between growth in homes, jobs and infrastructure and achieving sustainable development. Eg how will plan contribute to net zero carbon by 2050 or moreover to the County Council's environmental policy to achieve carbon neutrality by 2030 and at the same time support road investment programmes?
Joint Core Strategy failed to deliver sustainable development - eg transport's share of carbon has increased; the NDR was delivered but not the bus rapid transit system promised; and inadequate numbers of affordable homes were built. GNLP offers more of the same.

Comment

Representation ID: 22359

Received: 16/03/2020

Respondent: Norwich Green Party

Economy: Need to emphasise importance of moving to low/zero carbon economy.

Infrastructure: Concerns about emphasis on “relatively poor strategic infrastructure links” as key policy driver. There is a well-researched evidence base for not building more major roads. Soft infrastructure delivery (education and skills) is more important and GN historically under-performs on educational attainment. Lack of integration between land use planning and transport – dispersed development; strategic sites in peripheral areas lacking public transport. Lack of consideration of whether an appropriate strategy when considered against reasonable alternatives.

Renewable energy: plan is not sufficiently pro-active and ambitious.

Delivery: must not be simply driven by housing and jobs targets and infrastructure. Climate change and meeting Paris Agreement must be integral to delivery. Plan should aim to secure radical carbon reductions in line with trajectory for authority area, consistent with achieving net zero carbon by 2050. Plan actions do not reflect climate emergency (para 81). Plan will not deliver sustainable development as defined by the Brundtland Report, 'Our Common Future'.

Comment

Representation ID: 22381

Received: 16/03/2020

Respondent: Norwich Green Party

Para 81 refers to 'mitigating effects of climate change' but it is also essential to adapt to climate change (eg address risk of over-heating from rising temperatures) and to build resilience (eg strengthen local economic supply chains, protect agricultural land and green open spaces).
Flood risk: sea level rise and rising water levels in Broads and river systems have implications for flood risk in Greater Norwich.

Natural environment: reference needed to biodiversity emergency and nature-depleted state of UK. In order to enhance biodiversity, reduce urban over-heating, provide access to natural environments, reduce noise and air pollution and improve the quality of life: there is a need to: create new wildlife habitats as well as protect and enhance existing ones; substantially increase tree coverage and hedgerows in rural and urban areas; protect urban green open spaces from development eg sports grounds and not replace grass with hard surfaces.

Historic assets: (92) add 'medieval street pattern' as having shaped historic development of Norwich and line of city wall. See attached briefing paragraph 5. Norfolk Structure Plans referred to medieval street pattern which gave added protection to Norwich historic city centre.

Comment

Representation ID: 22382

Received: 16/03/2020

Respondent: Norwich Green Party

Delivery: exclude 'delivery' as factor to weigh against objectives in the interim sustainability appraisal. EG 'delivery' skews distribution of housing allocations in favour of dispersal options. Delivery is not an objective in the SA and should be disregarded for purpose of weighing up policies on sustainability grounds.

Para 83, per capita emissions underestimate carbon emission levels as they exclude, consumption, production, aviation, shipping and hence and hence reductions necessary is under-stated.

Para 84 needs to explain implications of hotter drier summers and warmer wetter winters for region and policy making. Need to refer to sea level rise, rise in river levels and possible implications for Norwich area.

Object

Representation ID: 22384

Received: 16/03/2020

Respondent: Norwich Green Party

Economy: We object to: concept of 'growth axis along Cambridge Norwich Tech Corridor'. We are concerned about land use, transport and environmental implications of dispersing development along A11 corridor in open countryside such as Snetterton Heath, in small towns and on strategic employment sites on periphery of Norwich. A wide corridor 100kms in length has been progressed without policy testing, SEA and prior public consultation.

Infrastructure: We oppose 'improve connectivity' in relation to major road building schemes. Add reference to reduce the need to travel and manage demand for private car travel.

Delivery: Oppose statement at it stands. Delivery must not be driven by numbers of homes, jobs and by infrastructure alone. Integral to delivery is also the need to set climate change targets.

Support

Representation ID: 22386

Received: 16/03/2020

Respondent: Norwich Green Party

Communities: support

Comment

Representation ID: 22387

Received: 16/03/2020

Respondent: Norwich Green Party

Homes: add ' zero carbon' after 'high quality'.

Environment: Environment policy would benefit from re-wording, “......and to significantly reduce emissions to ensure that Greater Norwich plays a full part in meeting national commitments to achieve net zero GHG emissions by 2050 as well as implementing adaptations to climate change”.

Need to clarify what is meant by 'clean growth'. We have concerns about this term which derives from the Government's 'Clean Growth Strategy' (and reflected in the New Anglia LEP Clean Growth strategy). Firstly, 'clean growth' doesn't go far enough in cutting carbon emissions consistent with net zero carbon by 2050 and secondly, it includes programmes which are inconsistent with net zero carbon, notably improving road links to cut congestion and support economic growth.

Comment

Representation ID: 22388

Received: 16/03/2020

Respondent: Norwich Green Party

Economy: plan target to build thousands of new homes should act as a stimulus to developing local manufacture of zero carbon construction materials;

Homes: include requirement to build to maximum energy efficiency standards such as Passivhaus. For example, the Reading Local Plan is making zero carbon housing mandatory for major residential developments unless demonstrated as unviable. On-site renewable energy standards should be set as well as carbon offsetting scheme to secure off-site carbon reductions.

Infrastructure: urgent need to address smaller Transforming Cities grant than anticipated. If funds can't be identified for sustainable transport required to serve thousands of new homes and jobs, quantum of development should be reduced, to prevent car-dependency.

Environment: need for Green Belt/wedges to prevent coalescence of communities eg Hethersett and Wymondham; protect river valley settings and protect setting of NDR similar to Southern Bypass.

Comment

Representation ID: 22390

Received: 16/03/2020

Respondent: Norwich Green Party

Environment policy would benefit from re-wording, “......and to significantly reduce emissions to ensure that Greater Norwich plays a full part in meeting national commitments to achieve net zero GHG emissions by 2050 as well as implementing adaptations to climate change”.

Need to clarify what is meant by 'clean growth'. We have concerns about this term which derives from the Government's 'Clean Growth Strategy' (and reflected in the New Anglia LEP Clean Growth strategy). Firstly, 'clean growth' doesn't go far enough in cutting carbon emissions consistent with net zero carbon by 2050 and secondly, it includes programmes which are inconsistent with net zero carbon, notably improving road links to cut congestion and support economic growth.