Draft Greater Norwich Local Plan – Part 1 The Strategy

Support

Representation ID: 22403

Received: 16/03/2020

Respondent: Norwich Green Party

We support the requirement for a sustainability statement.

Green infrastructure: essential to incorporate some element in all but minor developments ('Net Biodiversity Gain'). Green infrastructure should be defined to include a range of features including, trees, hedges, green roofs, green walls, verges, small biodiversity features etc. Removal of verges and trees to construct local active travel initiatives is unacceptable.

Densities: housing densities should not be under-mined by parking standards. Use of land for parking to boost developer profits is unsustainable.

Travel: levels of parking help to determine the level of private car use. Lower ratios of parking to numbers of dwellings are required to make efficient use of land; encourage modal switch and reduce carbon emissions (a switch to electric vehicles will not solve emissions from road transport). Parking standards in new developments should be lowered across Greater Norwich.

Energy: see response to Q19. Meanwhile, MHCLG has indicated an intention to publish a Future Homes Standard which will require up to 80% lower carbon emissions for all new homes from 2025.

Object

Representation ID: 22404

Received: 16/03/2020

Respondent: Norwich Green Party

Policy 10: Minimise Energy Demand does not sufficiently address the role that energy plays in sustainable communities. Communities should aim for zero carbon/low carbon as much as is economically and technically feasible. The 20% reduction against Part L of the 2013 Building Regulations is not ambitious and can be increased to at least match or exceed the 40% reduction target set by London.
Ref. the statement that “Proposals for free standing decentralised, renewable and/or low carbon energy networks, except for wind energy schemes, will be supported subject the acceptability of wider impacts”, this needs to consider the vital importance that clean energy can play in the strategy. This would also address the concern highlighted in the Greater Norwich Energy Infrastructure Study about the lack of energy capacity. Setting an ambitious target of 2030 for zero carbon energy is feasible, with the potential for the GNLP to be a market leader. This can be achieved by various means including smart grids, use of solar PVs, community energy schemes (“co-ops”), heat pumps, and energy storage technologies. For energy storage, the use of electricity for batteries must also come from 100% renewable energy sources.

Please see more detail in accompanying note.

Object

Representation ID: 22412

Received: 16/03/2020

Respondent: Norwich Green Party

We lack confidence in GNLP's desire to protect the natural environment in light of:
- Development of significant green open spaces in Greater Norwich eg Royal Norwich Golf Club for housing, Yare valley on Bluebell Road for housing, Yare valley land off Colney Lane for new Rugy club and parking, redevelopment of Blackdale school and playfields for student housing.
- NDR which has severed a large area of open countryside. Post-evaluation of landscaping showed that a high percentage of trees and shrubs planted along the road have died.
- GNLP policy support for extension of NDR across River Wensum Valley with its complex mosaic wetland and woodland of habitats.
- GNDP Councils' support for A47 dualling, eg North Tuddenham to Easton dualling would adversely impact upon the Tud valley.
Natural green spaces are seen as an easy target for development and the city is expanding further and further outwards into open countryside. The GNLP must take seriously the Biodiversity Emergency and the need to achieve 'Net Biodiversity Gain' at every opportunity.

Comment

Representation ID: 22413

Received: 16/03/2020

Respondent: Norwich Green Party

Although the provision of new informal green open space on the periphery of Norwich is important (eg new country parks), nonetheless, it is essential to retain and enhance existing open space such as sports grounds and golf courses and school playing fields inside the built up area for several reasons: to provide such spaces close to where people lives and accessible on foot and by bike; to support biodiversity, to absorb rainfall, to stop over-heating of the city, to absorb air pollution and reduce carbon. We would therefore welcome a specific commitment to protection of green spaces of all types.

Object

Representation ID: 22416

Received: 16/03/2020

Respondent: Norwich Green Party

We object to the proposed transport strategy. Specifically, we object to road building schemes; to the failure to identify measures for making best use of the transport network; of the GNDP to upgrade the public transport system as part of the JCS and enabling additional road traffic growth; to the lack of alternative sources of funding in place of the Transforming Cities Fund for facilitating modal switch to sustainable transport; to the lack of demand management measures for constraining traffic.
Specifically, we object to:
- delivery of the Norwich Western Link Road
- enhancement of the Major Road Network
- supporting improvements to the A47.
- supporting growth of Norwich Airport.

Along with climate change, transport is the weakest policy area in the GNLP as the priority given to road building schemes as a key driver for growth is inconsistent with other policy objectives, notably climate change mitigation. The aim of reducing road congestion and improve journey times for drivers and goods is unachievable. This is because faster journeys by road make road transport easier, initially, and therefore facilitating growth in car and lorry traffic, but over time, the additional traffic generated creates new congestion and leads to a vicious circle in the call for more road building. Also, speeding up journey times allows people to live further from their workplaces which encourages dispersal of development.
The GNLP relies, firstly, on the transition to electric vehicles to solve the transport sector's rising share of carbon emissions in Norfolk. However, the manufacture of electric vehicles involves considerable carbon as does road construction. Transport's share of carbon emissions is increasing because motorists have been buying larger and heavier vehicles. It will take many decades before all vehicles are zero carbon powered. Also, the widespread take-up of electric vehicles would not address the problems caused by decentralisation of activities as people and jobs move out of the urban areas to the suburbs, green field sites on the periphery of towns and cities and to villages.
Objection to Norwich Western Link
The proposed road would cause large adverse harm to the River Wensum SAC and to the Wensum and Tud valleys with their complex mosaic of habitats and protected wildlife. It would generate traffic across the valley and open up land at Easton and Honningham for major development. It would increase carbon emissions, air pollution and noise.
We consider that the County Council has not made the case for a NWL. Current levels of traffic across the Wensum valley do not justify a four lane road carried on a viaduct and the resultant level of environmental damage. Traffic modelling assumed a substantial number of jobs at Easton Food Hub and a new settlement at Honningham. The latter has been de-prioritised whilst the predicted number of jobs at the Food Hub has been considerably reduced. As a result, the cost benefit ratio is likely to be far lower than calculated.
We consider that the NWL should be removed from the GNLP at this stage, until such time further work has been done. For example, Norfolk County Council's habitat assessment has not picked up the presence of a large colony of Barbestella Bats living in the woods on the line of the Preferred Route.
The Habitats Regulation Appropriate Assessment of Policy 4 ‘Strategic Infrastructure’ (Section 8) states that there is potential for the NWL river crossing to cause harm to the Wensum SAC It recommends amending the policy to reflect the importance of avoiding adverse effect upon the River Wensum SAC. The recommended text for the policy text relating to the road reads:
• ‘Delivery of the Norwich Western Link Road provided that it can be achieved without causing an adverse affect on the integrity of the River Wensum SAC.’
The GNLP Policy 4 should be amended as above. However, just to underline that our preference is to see deletion of the NWL at this stage.

Reasonable alternatives to a NWL have not been considered. The County has assessed a large number of non-road building measures individually, but not a large package of combined measures.

Our Objections to A47 Dualling (including Blofield to North Burlingham, Thickthorn and Easton to North Tuddenham)

We object on a number of grounds: increase in carbon emissions, air pollution and noise, large land take especially in the case of proposed junctions at Thickthorn, Wood Lane and Norwich Road junction; impact on wildlife habitats such as River Tud and protected species (otters, water voles, bats, owls); traffic generation and increase in car commuting. The North Tuddenham to Easton scheme is likely to draw in traffic from north of Norwich and funnel traffic to the south of Norwich via the Thickthorn junction improvements.
The Preliminary Environmental Information Reports accompanying the schemes all acknowledge a probable increase in carbon emissions for both construction and operation. In the light of the Appeal Court ruling on a third runway at Heathrow and failure of the government to consider whether the schemes is consistent with the Paris Agreement and the amended Climate Change Act 2008, a legal challenge over the roads programme is likely.
Alternatives to the A47 Dualling include: small scale safety measures; digital technology to create Smart highways; travel planning to reduce single use car commuting and encourage modal switch to sustainable transport. Also, it is highly likely that the government will need to consider an alternative to fuel duty such as some form of national road pricing and this would dampen demand for travel by private car and lorry.

Norwich Airport
We oppose expansion of the airport on climate change grounds. Expansion of regional airports is not the answer to a third runway at Heathrow. People need to fly less if the UK is to meet it carbon commitments as has been acknowledged by the Committee on Climate Change. The problem is caused by frequent flyers and not by people taking one annual holiday flight.

Non-road Building Parts of the Transport for Norwich Strategy
Norwich Green Party supports:
- significant improvements to the bus, cycling and walking network to promote modal shift.
However, we consider that a more radical package of measures is needed in order to achieve a much large degree of modal shift. Transforming Cities bid for £100million calculated a mere 6% increase in bus passengers as a result of proposed investment in sustainable transport. This level of switch is far too low for dealing with the scale of the problem. Regrettably, the Joint Transforming Cities bid has been unsuccessful and Norwich will share £117million with two other cities. £40million is nowhere near enough to upgrade a public transport system based on three cross-city corridors, when Norfolk County Council costed a bus rapid transit system at £140million in its evidence to the NDR inquiry in 2014. Growth in and around Norwich has been predicated on developing public transport and the failure to secure funding throws delivery of the JCS and GNLP into crisis. Alternative sources of funding must be found otherwise growth in and around Norwich will take place in the absence of major public transport improvements which would be a disaster for Norfolk's carbon emissions. One alternative source of funds is workplace parking charges, but it would take several years to implement.
We do not support:
 Developing the role of the park and ride system.
Rather than extend the network and take up green field sites for more car parking, drivers should be encouraged to leave their cars at home and catch the train/bus where possible. Extension of Postwick park and ride resulted in the County Council leasing the additional car parking spaces to Aviva for their staff at Broadland Business Park as there was insufficient take up of park and ride in this location.
- A cross valley bus link between UEA and Norwich Research Park.
This would be very environmentally damaging.
The above two proposals are somewhat academic at present as they are included in the Transforming Cities bid which hasn't been fully funded.

An Alternative Transport for Norwich Strategy
We would like to see a road traffic reduction strategy for the Greater Norwich area to include:
- make use of existing road capacity and no new major road building;
- substantial package of sustainable transport measures (alternative sources of funding will need to be found such as Workplace Parking Charges);
- traffic demand management measures (such as Workplace Parking Charges) and also land use planning measures, notably, car free developments, much higher parking standards across Greater Norwich, review of public parking tariffs.
- traffic management measures (safe roads and streets such as a zero tolerance strategy to eliminate deaths and serious injuries on the roads);
- enhancement of the local rail network.

Object

Representation ID: 22417

Received: 16/03/2020

Respondent: Norwich Green Party

We object to the 28% affordable housing target for Norwich and want to see it increased to 33%. Indeed, figures in the SHMA give 38.2% overall affordable housing need for Norwich City Council area. Norwich has a substantial waiting list for social housing. The higher costs of developing on brownfield land in the city centre should be off-set by external national government funding such as HIF. In a case such as Anglia Square, where £15m of HIF money has been secured for site preparation, we consider that this has been off-set by the developer wasting money on an expensive glitzy project which includes a 20-storey tower.
The policy of successive governments to provide sufficient affordable housing on the back of market housing has been a failure. There has been long-standing under-delivery of affordable homes in Greater Norwich despite the Councils adopting a higher than necessary housing target in the JCS. Developers have run rings around the Councils in claiming lack of viability as a reason for not meeting the 33% policy requirement. At the same time, they have provided houses on countryside in South Norfolk and Broadland at a price which is out of the reach of many people. Simply increasing the housing target as a means of providing sufficient affordable housing has not worked and has allowed developers to game the system.

Support

Representation ID: 22418

Received: 16/03/2020

Respondent: Norwich Green Party

We support:
 emphasis on needs of small, medium and start-up businesses. A diverse, local economy with short supply chains is much more resilient than one which relies on multi-national companies.
 Expansion of innovation and skills and training. This will help to increase local wages, improve aspirations of school students and prepare residents for changes to the economy including the digital revolution.

Object

Representation ID: 22419

Received: 16/03/2020

Respondent: Norwich Green Party

Object to:
- development of large number of strategic employment areas in locations which are dependent on car/lorry access eg Norwich Airport area, Longwater, Rackheath, Hethel, Food Enterprise Park. Even at Thorpe St Andrew, where such sites have been provided with some level of public transport, they were initially developed with public transport as an after-thought and new rail halts proposed have not materialised.

Comment

Representation ID: 22420

Received: 16/03/2020

Respondent: Norwich Green Party

Employment land which has been allocated but sitting idle for some time should be either de-allocated or re-allocated for other purposes.
Policy 6 (1) , reference to 'in accessible locations' should be refined to read 'in accessible locations served by public transport and or rail, walking and cycling'.
Potential for increasing resilience of local economy and creating a circular economy should be explored eg set up industries which shorten supply chains and use local waste materials. One idea would be to manufacture buildings high energy efficient materials for constructing thousands of local homes rather than importing them.

Support

Representation ID: 22421

Received: 16/03/2020

Respondent: Norwich Green Party

We support such industries which reflect local innovation and support a high quality environment. We would like to see a greater emphasis on tourists and short-stay visitors arriving by rail and public transport opposed to by private car.