Draft Greater Norwich Local Plan – Part 1 The Strategy

Comment

Representation ID: 22503

Received: 16/03/2020

Respondent: Broadland Green Party

The Foreword makes a fundamental assumption regarding economic growth and unfortunately no facility has been provided to question the assumption that the local plan should be based on continued linear economic growth. It must be recognised that continued linear economic growth is unsustainable globally but especially in a county with limited opportunities for growth without permanently damaging the environment and the wellbeing of people who currently live and work in the county.
The Local Plan should provide an opportunity for a sea-change in how we view the economy from “make, use, dispose” to a circular economy focusing on positive society-wide benefits in which waste is designed out of the system. The circular economy is underpinned by a transition to renewable energy sources. It is based on designing out waste and pollution; keeping products and materials in use; and the maintenance and regeneration of natural systems.
It is quite rightly stated that our strengths include the excellent quality of life on offer, our wonderful natural environment, and our heritage. We should plan to maintain these strengths such that any developments do not harm but enhance our quality of life and natural environment.
One of the principles of the NPPF 2019 is that development resulting in the loss or deterioration of irreplaceable habitats should be refused unless there are “wholly exceptional reasons” . Hence, the urgent need to review developments such as the proposed Wensum Valley western link road which would result in the loss of irreplaceable habitats.
We agree that “The GNLP must also assist the move to a post-carbon economy and protect and enhance our many environmental assets.” However, it should not simply “assist the move” but should be at the heart of the plan.

Comment

Representation ID: 22504

Received: 16/03/2020

Respondent: Broadland Green Party

Reflecting on the overall purpose and stated priorities within the plan we do not feel sufficient emphasis has been put on the objectives established within the National Planning Policy Framework (NPPF). Chapter 2, paragraphs 7 & 8 of the NPPF state the “purpose of the planning system is to contribute to the achievement of sustainable development.” This means that the planning system has three overarching interdependent objectives: economic, social and environmental. We are therefore reviewing the plan against these three objectives “to secure net gains across each of the different objectives”.

Comment

Representation ID: 22505

Received: 16/03/2020

Respondent: Broadland Green Party

There is no evidence that the population will grow in the way suggested by the graph as there is a national declining birth rate. The graph is simplistic and lacking evidence. The pie charts show an identical percentage of young people (28% 0-24) in 2018 and 2038 yet there is an astonishing observation that the trend for higher than average young populations is set to continue. This is unsubstantiated and inaccurate information.

Para 35 states there is a declining birth rate which is supported by the Office of National Statistics (ONS) latest report on births in England & Wales (1 August 2019): “The birth rate was the lowest ever recorded, when births are measured as a proportion of the total population. The total fertility rate stood at 1.70 children per woman, lower than all years except 1977 and 1999 to 2002.” It went on: “In 2018, the crude birth rate (CBR) was the lowest since records began, at 11.1 live births per 1,000 population of all ages. ”

Comment

Representation ID: 22506

Received: 16/03/2020

Respondent: Broadland Green Party

How to achieve happiness and wellbeing of the community now and in the future? Continued growth is not the solution. Norfolk Association of Local Councils (NALC) has a “Wellbeing strategy” which shows the way forward for a healthy and happy Norfolk. NALC represents nearly 500 councils and parish meetings across Norfolk with perhaps three or four thousand councillors, clerks, other staff and volunteers – all of whom are working for the well-being of their residents. Themes addressed in the NALC strategy include many issues that are pertinent to the GNLP and could be ideally referenced in the plan including:
• Low carbon economy and towards net zero
• Trees, hedges and wild flowers
• Biodiversity and wild life
• Neighbourliness, inclusive communities & inter-generational issues
• Water, flooding and irrigation
• The built environment, Housing & Planning
• Cars, car parking. park and ride, lift-sharing and public transport
• Services e.g. doctors, dentists, etc.
• Loneliness
• Shopping
• Coming to terms with the new technologies and AI
• Employment, self-employment, small businesses

CPRE expressed strong support for the NALC Well-being initiative and have agreed to work with NALC to achieve the mutually compatible aims.

Comment

Representation ID: 22507

Received: 16/03/2020

Respondent: Broadland Green Party

How is a need for 28% “affordable housing” to be met, simply developing more homes does not make them “affordable”. Affordable housing is an impossibility in the private sector because prices will only drop if the market becomes flooded and if that happens then the number of householders in negative equity will rocket with a very negative impact on social stability. Councils within the GNDP need to develop workable schemes to fund low-carbon social housing on a scale that has not yet been realised.

The rail network – with the Greater Anglia franchise which started in August 2019 more reliable and frequent services should be planned to encourage travel and commuting by rail. Until there is a good weekend rail service it will not be possible to use the train, rather than the car, for leisure commutes within and out of Norfolk in both directions. This one simple change could save very many unnecessary car journeys to and from East Anglia and support a culture change to encourage train use.
The plan suggests Norwich Airport is a catalyst for economic growth but it is growth that is incompatible with a low-carbon economy and minimising the impacts of climate change. The Environmental objective (para 8c) of the NPPF specifically states the need to “mitigate and adapt to climate change, including moving to a low carbon economy.” It further states that “opportunities can be taken to secure net gains across each of the different objectives”. The expansion of Norwich Airport is clearly not compatible with the NPPF environmental objective.
The cycle network - there has been a 40% increase in cycling since 2013 in the Norwich urban area. Whilst there is focus on the city in the plan there is little mention of cycling elsewhere in Greater Norwich. At a recent consultation with Highways England on the dualling of the A47 at North Burlingham it was stated that footpaths and cycle routes will be looked at once the road has been designed. This is old style thinking and is not giving walking and cycling the prominence they deserve for the good reasons of health, sustainable transport and tourism.
Rural transport – little is said in the plan of developing rural bus services. Given the urgent need to reduce car journeys a greater emphasis needs to be put on rural transportation which includes bus, rail and cycling. Greater emphasis and integrated planning is needed with initiatives such as Connecting Norfolk to promote the use of demand responsive transport services and car sharing.
Digital infrastructure is vital to support rural enterprises and home-working. The mobile phone network is notoriously poor and the Better Broadband for Norfolk programme has not been successful in reaching many houses in villages where there has been the roll out of fibre broadband to a central node in a village but not beyond. Digital infrastructure must be given a greater priority in the years to come.
Emissions and climate change
It is stated in para 82 that “Mitigating the effects of climate change within the Greater Norwich area is a cornerstone of the GNLP”. In which case much more needs to be done in curbing carbon emissions through a radical review of the transport policy as explained above, and the building of energy efficient homes. The expansion of Norwich Airport and the road network is not compatible with “mitigating the effects of climate change”. This has a knock on effect on air pollution which it is accepted remains an important issue with more work to be done. To reinforce the need to review transport options it is also stated in para 84: they (CO2 emissions) are above the national average in rural parts of the area, partly due to a greater reliance on car journeys.
Renewable energy
92. Our plan should support further development of decentralised, renewable and low carbon sources of energy.
Greater emphasis needs to be placed on community energy schemes. Councils should consider smart grids, greater efficiency in housing (including retrofit insulation), greater on-site renewable energy production and energy balancing and storage. See later under Policy 2 regarding Part L of the 2013 Building Regulations.

Comment

Representation ID: 22508

Received: 16/03/2020

Respondent: Broadland Green Party

Comment. Para 120: in practice increased housing and population is leading to inner city wilderness NOT “lively and vibrant city and district centres” Norwich and Norfolk have lively and vibrant city & district centres now so please do not seek to “fix what is not broken!”

Comment

Representation ID: 22509

Received: 16/03/2020

Respondent: Broadland Green Party

Para 123: does not reference local rail transport links. need to improve local rail services on the Bittern and Wherry lines to encourage rail use. E.g. more routes between Norwich Brundall Reedham and Gt Yarmouth.

The growth of Norwich Intl Airport is not consistent with reducing carbon emissions.

The Norwich Western Link should focus on improving existing road links rather than building a new road across the Wensum Valley.

Para 126 references ““a radical shift away from the use of the private car”. But this will only happen if there are clear plans on how this can be achieved and there is insufficient detail in the GNLP on this.

Para 129: “…our proactive approach to co-ordinating development providers, organisations and agencies as well as through interventions in cases where the market cannot deliver infrastructure.” Comment: there will need to be much more active intervention and co-ordination of infrastructure development than has hitherto been seen if this ambition is to be realised. It cannot simply be aspirational but clear plans need to be established to achieve this in practice.

Comment

Representation ID: 22510

Received: 16/03/2020

Respondent: Broadland Green Party

Para 130: Good to have the aspiration but where are the practical measures in the GNLP to actually produce greater water and energy efficiency?
Para 131. “Air pollution levels will be reduced through a combination of better design and location of development, supported by technological changes.” Equally, how will reduction of air pollution be achieved with the massive planned road expansion and destruction of woodland and green areas as a consequence?
The plan's objectives
As general aspirational objectives they are fine except for the objective “to achieve net zero greenhouse gas emissions by 2050”. This objective needs to be much more ambitious given the severity of the situation. Norfolk County Council has adopted a target of achieving net zero carbon emissions by 2030 for council owned land and buildings and for travel. In addition, they will work towards carbon neutrality for the county, also by 2030.

Comment

Representation ID: 22511

Received: 16/03/2020

Respondent: Broadland Green Party

Comment: There is no clear target on energy efficiency and the reduction of carbon emissions. Back in 2008 the Climate Change Strategy for Norfolk signed by all seven district councils and the county council stated: ““Most of the houses and infrastructure that we build now will still be standing in 2080, when the impacts of climate change will be much greater. The considerable level of growth planned for the county by 2026 provides an immediate strategic opportunity to plan housing and infrastructure that will be much more resilient to the impacts of climate change. This will reduce long term risks to Norfolk residents and help avoid the potentially major expense of addressing problems at a later stage, after the impacts of climate change have been felt.”
Recent house building has generally been of a poor quality meeting the minimum of required Building Regulations. There needs to be a significant change in the standard of house building. This must be accompanied by strengthened building control departments to carry out adequate building inspections as in the past. All new housing must be carbon neutral or at least built to Passivhaus standards.
There is no provision for allotment space in any of the current developments despite it being a clearly stated Policy 2 objective.

Object

Representation ID: 22512

Received: 16/03/2020

Respondent: Broadland Green Party

Object: Government and local authorities have agreed that we are facing a Climate Emergency. This has been brought on by unsustainable economic growth. We cannot continue with “business as usual”. The assumption that the population of Norfolk must accept continued economic growth “for the good of the county” is flawed. We have indicated elsewhere that population growth is not inevitable and that in fact the growth rate is declining. We do not need economic growth to lead happy and fulfilling lives. We do need an economy however, that serves the population. It needs to be a circular, zero-growth, economy underpinned by a transition to renewable energy sources, based on designing out waste and pollution; keeping products and materials in use; and the maintenance and regeneration of natural systems.
We cannot address climate change without addressing the issue of continued, unsustainable economic growth which is where the GNLP is fundamentally flawed.