Draft Greater Norwich Local Plan – Part 1 The Strategy

Comment

Representation ID: 22422

Received: 16/03/2020

Respondent: Norwich Green Party

Sequential approach: We wish to see car parking standards lowered and made consistent across the Greater Norwich urban area so that existing and new employers are less tempted to move out of the city centre to green field locations where parking is more plentiful. Sustainable transport modes must be improved alongside so that people can access with ease all locations by bus, foot, cycle and where possible, by local rail across Norwich and not rely on the private car as at present. The existing array of out-of town strategic developments around Norwich, such as Longwater and Broadland Business Park are a climate disaster, as well as consuming large amounts of land. Less car parking would enable more efficient use of land. We also consider that city centre brownfield sites allocated for employment uses eg Barrack Street should be developed before approving out of town locations.
Other main town centre uses: need to move away from providing more or as much car parking and instead reduce the amount of car parking and re-develop valuable land for housing. Norwich City Council needs to find an alternative to public car parking for raising revenue funds. Also, need to encourage short-stay users such as shoppers to catch park and ride rather than drive into the city centre and park, by making park and ride more attractive vis-a vis parking in the city centre.

Support

Representation ID: 22423

Received: 16/03/2020

Respondent: Norwich Green Party

We generally support the approach for the city centre. In order to support and protect the city centre, we consider that it is necessary to limit the temptation of businesses to move to peripheral locations by constraining the amount of parking allowed for new developments across the Greater Norwich area and introducing workplace parking charges in and around Norwich. Parking charges would provide an income for investing in a public transport system.
As the opportunities arise, we would like to see redevelopment at Riverside with higher densities and far fewer parking spaces. Riverside is a badly planned site where land has been squandered on surface car parking and a major access road

Object

Representation ID: 22424

Received: 16/03/2020

Respondent: Norwich Green Party

We object to a Northern City Centre Strategic Regeneration Area based around a large district centre/mixed use development at Anglia Square. We objected to the Anglia Square scheme and participated in the recent public inquiry. We recognise that the Anglia Square site provides the most sustainable and accessible in the city centre. However, in our view and many others, the scheme called in by the Secretary of State is not consistent with sustainable development.
If the scheme is rejected by the Secretary of State, we advocate a low rise high density mixed use development comprising mixed housing, (with a higher percentage of affordable housing), local retail, employment, cultural and community facilities built to high sustainability standards.
Support for a lower number of dwellings than the 1,250 envisaged for Anglia Square, would require new sites to be identified elsewhere. Windfall sites are highly likely.

Support

Representation ID: 22425

Received: 16/03/2020

Respondent: Norwich Green Party

We broadly support the proposals in principle. There is a need to reference the requirement to protect the Carrow Abbey County Wildlife Site in the policy wording.

Comment

Representation ID: 22426

Received: 16/03/2020

Respondent: Norwich Green Party

Ref. the interim sustainability appraisal which assesses policy options against the 15 sustainability objectives established by the scoping report. We are very concerned that the interim sustainability appraisal undermines its whole purpose by also considering ‘delivery’ as a factor to weigh against the objectives. This is summed up by p52 of the appraisal: after a table presenting the six options for distribution of housing allocations (p42), in which it is absolutely clear that options 1, 2 and 3 perform better than the dispersal options (4, 5 and 6), the “summary of significant effects” starts: “Options 1, 2 and 3 may be harder to deliver”, goes on to observe that 1,2 and 3 perform better on everything else, then concludes “in sustainability terms the choice between alternatives appears finely balanced, with no alternative clearly better than another in SA terms”.
This is dishonest. The only objective on which 4, 5 and 6 are deemed to perform better is SA5, “Ensure that everyone has good quality housing of the right size and tenure to meet their needs”. In the ‘analysis’ of this objective on p45, there is no mention of meeting need (which surely relates to providing affordable housing in places where there are jobs and where people therefore want to live); instead, this becomes “diversity, choice and competition in the market for land” and “least risk of delay”, and judges dispersal the best option – ignoring the fact that this will result in unaffordable housing in unsustainable non-communities with no employment, so not actually meeting need at all. SA5, therefore, is first twisted to have a completely different meaning in order to support dispersal, then considered to outweigh all the other objectives put together (there’s no hierarchy of objectives in the SA) to the extent that the dispersal options become equally sustainable to options that would concentrate growth where infrastructure and services are.
“Delivery” is not an objective in the Sustainability Assessment and should be disregarded for the purpose of weighing up policies on sustainability grounds.

Object

Representation ID: 22427

Received: 16/03/2020

Respondent: Norwich Green Party

We object to the proposal for a new urban extension at Taverham (1,400). A new strategic community in this location would be reliant on car use and therefore increase carbon emissions, air pollution and traffic pressures in the Wensum Valley area and increase different types of run-off including silt to the River Wensum SAC. Major development on land between the NDR and city edge would see further loss of countryside. As indicated, we believe that existing allocations should be developed before any new allocations.
The SA/SEA (Jan 2020) for Taverham and Ringland (B.47) confirms that the proposed Taverham and Ringland development cluster would have a major negative impact on Air Quality and Noise, Climate Change Mitigation and Adaptation, Education and Natural Resources and Waste. By way of mitigation, the SA/SEA recommends that focus on improving public transport, walking and cycling would be likely to help reduce carbon emissions emitted within Norwich.
However, the likelihood that high quality public transport can be provided from the outset of the development is unclear because the Transforming Cities bid has not been successful. In any case, the Fakenham Road and Reepham Road were not identified as among the six radial road corridors for upgrades to public transport infrastructure by the joint application. Therefore, unless alternative sources of funding can be obtained for developing a high quality public transport system for Norwich, a strategic development at Taverham is likely yo be car-dependent in much the same way that Thorpe Marriott has evolved.
Overall, we are concerned by the extent of car-based urban sprawl of Norwich as development has spread out into the open countryside, facilitated by road building. . Norwich is now strangled and its unique rural setting has been eroded by the Southern Bypass and NDR and a string of business parks, retail parks and other major developments clustering around land hungry junctions.

Comment

Representation ID: 22481

Received: 16/03/2020

Respondent: Norwich Green Party

Energy: a number of City Council car parks have electrical load restrictions which limit the provision of additional chargers for electric vehicles especially rapid chargers. UK Power Networks might require grid improvements for the city centre area to enable new chargers to be connected to the network.

Green Infrastructure: Policy 1 Infrastructure refers to green infrastructure. We would like to see a step change in the provision of green infrastructure. The latter should be in addition to and not a replacement for the ongoing loss of informal green spaces such as sports grounds and playing fields to housing and other development. Green infrastructure relating to active travel has in several instances involved the removal of greenery to the detriment of urban heating and biodiversity; for example grass verges have been removed in order to widen shared pedestrian/cycle paths. All green infrastructure should involve the enhancement or new addition of green soft landscaping

Object

Representation ID: 22482

Received: 16/03/2020

Respondent: Norwich Green Party

We object to the GNLP reliance on individual private car use for accessing essential infrastructure, notably:

Health Care Requirements (ref Appendix 1): Parking is referred to in relation to 'Additional need resulting from growth' for the categories of 'Hospital' (NNUH) and Mental Health' (Julian Hospital). The expansion of car parking at NNUH is a major concern which needs addressing. Firstly, additional car parking facilitates the growth in car travel to the hospital and leads to an increase in carbon emissions and in air pollution. The NNUH has the largest car park in Norfolk which is more a policy failure than a proud record. The climate change emergency and the air pollution crisis have major public health implications and yet the NNUH and GNDP reliance on car travel is making public health worse. Secondly, there is a social equity problem because public transport provision serving the NNUH is unaffordable and second rate for many low income households and those without a car. Catering for car access to the NNUH has been a higher priority for policy makers whilst the provision of public transport to the NNUH has largely been left to the market. Money will need to be found for improving public transport infrastructure for serving the NNUH (such as re-organising the rather chaotic dropping off/picking up public transport arrangements outside the main entrance) in view of the smaller than anticipated Transforming Cities grant.

Waste Management (ref Appendix 1) we are concerned about the out-of-town locations of the planned recycling centres which will increase reliance on car-borne access. The increase in carbon emissions from additional car mileage could potentially negate any energy savings benefits from recycling. It would be helpful to calculate the net environmental costs and benefits of this recycling model (users take by car and van a range of materials to central location for recycling) to inform decision making, otherwise the local authorities could end up creating a net disbenefit and increasing the use of energy and carbon emissions.

High quality public transport infrastructure is referred to in Section 5 Policy 1 (para 168) and the Key Diagram shows eight Strategic Bus Corridors. We wish to reiterate our point that the GNDP authorities' Transforming Cities application was unsuccessful and Norwich, Portsmouth and Stoke will have to share a £117m pot.
As a consequence, the draft plan is not deliverable due to uncertainty around the ability to develop a city-wide public transport system for serving growth (including the level of growth to 2026 envisaged by the JCS). There are no other large sources of funding on the horizon which can make up for the deficiency. A lack of funding means that the draft GNLP fails the NPPF 'Effectiveness' test.

Comment

Representation ID: 22817

Received: 16/03/2020

Respondent: Norwich Green Party

Energy: a number of City Council car parks have electrical load restrictions which limit the provision of additional chargers for electric vehicles especially rapid chargers. UK Power Networks might require grid improvements for the city centre area to enable new chargers to be connected to the network.
Green Infrastructure: Policy 1 Infrastructure refers to green infrastructure. We would like to see a step change in the provision of green infrastructure. The latter should be in addition to and not a replacement for the ongoing loss of informal green spaces such as sports grounds and playing fields to housing and other development. Green infrastructure relating to active travel has in several instances involved the removal of greenery to the detriment of urban heating and biodiversity; for example grass verges have been removed in order to widen shared pedestrian/cycle paths. All green infrastructure should involve the enhancement or new addition of green soft landscaping,
We object to the GNLP reliance on individual private car use for accessing essential infrastructure, notably:
Health Care Requirements (ref Appendix 1): Parking is referred to in relation to 'Additional need resulting from growth' for the categories of 'Hospital' (NNUH) and Mental Health' (Julian Hospital). The expansion of car parking at NNUH is a major concern which needs addressing. Firstly, additional car parking facilitates the growth in car travel to the hospital and leads to an increase in carbon emissions and in air pollution. The NNUH has the largest car park in Norfolk which is more a policy failure than a proud record. The climate change emergency and the air pollution crisis have major public health implications and yet the NNUH and GNDP reliance on car travel is making public health worse. Secondly, there is a social equity problem because public transport provision serving the NNUH is unaffordable and second rate for many low income households and those without a car. Catering for car access to the NNUH has been a higher priority for policy makers whilst the provision of public transport to the NNUH has largely been left to the market. Money will need to be found for improving public transport infrastructure for serving the NNUH (such as re-organising the rather chaotic dropping off/picking up public transport arrangements outside the main entrance) in view of the smaller than anticipated Transforming Cities grant.
Waste Management (ref Appendix 1) we are concerned about the out-of-town locations of the planned recycling centres which will increase reliance on car-borne access. The increase in carbon emissions from additional car mileage could potentially negate any energy savings benefits from recycling. It would be helpful to calculate the net environmental costs and benefits of this recycling model (users take by car and van a range of materials to central location for recycling) to inform decision making, otherwise the local authorities could end up creating a net disbenefit and increasing the use of energy and carbon emissions.
High quality public transport infrastructure is referred to in Section 5 Policy 1 (para 168) and the Key Diagram shows eight Strategic Bus Corridors. We wish to reiterate our point that the GNDP authorities' Transforming Cities application was unsuccessful and Norwich, Portsmouth and Stoke will have to share a £117m pot.
As a consequence, the draft plan is not deliverable due to uncertainty around the ability to develop a city-wide public transport system for serving growth (including the level of growth to 2026 envisaged by the JCS). There are no other large sources of funding on the horizon which can make up for the deficiency. A lack of funding means that the draft GNLP fails the NPPF 'Effectiveness' test.