Draft Greater Norwich Local Plan – Part 1 The Strategy

Object

Representation ID: 22513

Received: 16/03/2020

Respondent: Broadland Green Party

Object: The statement clearly says “Infrastructure priorities benefit existing communities ………. and deliver sustainable and active travel choices to promote modal shift.” Yet the plan tries to have both an expansion of roads whilst throwing in just a few aspirational cycle paths and footpaths. This is just not enough and is the wrong way of going about modernising our transport infrastructure. In a recent Blofield parish council meeting with Highways England on the dualling of the A47 at North Burlingham / Blofield, they were asked about the footpaths, cycle ways and bridleways to cross the A47 which have been in existence for centuries. The answer given was “we design the road first and then we look at the footpaths and cycle ways”!! The problem is they are road builders. What they need to be is transport infrastructure facilitators and innovators. It requires a culture change on the part of Highways England and NCC Highways.
Comment: “Smaller scale and rural employment sites are less likely to be constrained by infrastructure requirements” But the plan needs to recognise there are infrastructure constraints in many rural locations from drainage to public transport options, to broadband and mobile phone coverage.
“Greater Norwich partners will continue to work to coordinate delivery with other providers” – Comment: this is an aspiration. Much more effort needs to be made by the partners to coordinate delivery more effectively than now. Examples include NCC Highways working in a more integrated fashion with Highways England. Anglian Water need to be included in housing and business developments which recognise technical, capacity and funding constraints.

Comment

Representation ID: 22514

Received: 16/03/2020

Respondent: Broadland Green Party

Comment: Good to see reference to and use of the publication “Rising to the Climate Crisis – A Guide for Local Authorities on Planning for Climate Change”. The challenge will be to abide by the guidance. As the guide states, “Although the current National Planning Policy Framework contains strong policy on climate change, delivery on the ground through local plans has been relatively poor. Local plans in England are not dealing with carbon dioxide emissions reduction effectively, nor are they consistently delivering the adaptation actions necessary to secure the long-term resilience of local communities”. As the guide says in its introduction, “climate change is now the greatest challenge facing our society”. The recommendations therefore, need to be taken seriously and be a key reference in the future roll out of the GNLP.

Object and Comment: Bullet point 140 states how the NPPF requires local plans to "Support appropriate measures to ensure the future resilience of communities and infrastructure to climate change impacts" and to set strategic polices which address climate change mitigation and adaptation. The Climate Change Statement does not fulfil this requirement. The statement simply references other policies. It does not provide a comprehensive Climate Change Policy that can be practically applied in, for example, the case of planning applications. Given the climate emergency, a Climate Change Policy should be developed for the GNLP.

In a report to the Sustainable Development Panel, Norwich City Council, 15th January 2020, the Director of Place commented: “There is a disconnect between the vision, objectives and climate change statement and the actual policy substance needed to enable the plan to contribute significantly to the delivery of a low carbon future.”

Table 5 refers to the coverage of climate change issues including having an effective monitoring regime to ensure evidence on reducing carbon dioxide emissions, recorded against the Climate Change Act and other key national statutory and policy frameworks. It further states: “Our ambition is to reduce per capita emissions and thereby contribute to meeting the national target to bring all greenhouse gas emissions to net zero by 2050”.

There has to be more than a simple ambition. There needs to be pro-active measures and the monitoring of trends to ensure the GNLP strategy is working and the targets are met.

The methodology for assessing carbon emissions given in the Sustainability Appraisal is given in Box 2.2 (page 25):

“Development proposals which could potentially increase the Plan area’s
carbon emissions by 1% or more in comparison to the 2017 estimate would
be expected to have a major negative impact for this objective. Development
proposals which may be likely to increase the Plan area’s carbon emissions
by 0.1% or more in comparison to the 2017 estimate would be expected to
have a minor negative impact for this objective.”

Both the above scenarios will still result in an increase in carbon emissions whereas the imperative is to dramatically reduce emissions. The underlying carbon emission footprint must significantly decrease to meet national obligations.

In 2019, carbon budgets were produced for every UK local authority area with the support of the Tyndall Centre at UEA, known as SCATTER models, based on a UK budget calculated using climate equity principles from the Paris Agreement. A summary of the aggregated SCATTER budget for the Greater Norwich local authorities is given below:

[See table in attached document]

A significant step-change in the reduction of emissions is required if we are to reach the stated targets locally, nationally and to meet the Paris obligations. The following graph indicates the magnitude of the task.

[See graph in attached document]

In summary, to meet the UK’s Paris Agreement obligations carbon emissions in the GNDP area need to reduce by an average of 13.4% per year. Continuing at the current rate of emissions will mean using up our remaining carbon budget by 2026/27. These figures are best estimates and are supported by the UEA Tyndall Centre.

The draft GNLP is aspirational with fine sounding statements about combatting climate change but much more is needed than is currently in the draft plan. These are suggestions for serious consideration:

• Zero carbon development through building design to deliver the highest viable energy efficiency. Passivhaus standards, etc.
• Re-use of buildings and recycling of building materials.
• Minimising waste produced.
• Energy recovery.
• Promotion of decentralised energy through encouraging community-led initiatives such as the promotion of decentralised renewable energy.
• Reduce the need to travel, particularly by private car; and secure the highest possible share of trips made by sustainable travel.
• Encouraging development that utilises and promotes the use of sustainable transport.
• Developing a more integrated transport system using new technologies and the promotion of active travel and smarter choices.
• Securing land for local food sourcing and the promotion of allotments.

As stated in Rising to the Climate Crisis: “Action on climate change should be an integral part of the culture of plan-making and should be embedded and integrated into policy preparation. Only by treating climate issues as central to policy formulation will a local authority have effectively discharged its duty under the 2004 Planning and Compulsory Purchase Act. ”

Such policies also support other health and social objectives. Safe active travel, such as cycling, and local food sourcing, supports healthier lifestyles and social interaction at the same time as reducing carbon emissions.

Behaviour Change

There is no clear strategy for the required behaviour change to turn awareness into action. The 2008 Climate Change report for Norfolk recommended:
“Our behaviour change strategy should be unified under a strong, single sustainability brand for Norfolk that is readily recognised and promotes a clear message. We will need to include clear steps for engaging proactively with the wider local community to incentivise and reward behaviour change, working with community groups, schools, businesses and local partners.” (page 38).

“Norfolk is particularly vulnerable to the impacts of climate change, and has a higher carbon footprint per person than the UK average. We need to take action both to reduce our contribution to the problem and minimise our exposure to future risks.” (page 39).

We therefore recommend implementing the “Next steps” as stated in the 2008 report:
• Establish a wider Climate Change Partnership for Norfolk, with Sector Groups to address our strategic priorities, with clear governance and performance management arrangements to ensure we deliver.
• Develop a Behaviour Change Strategy, including detailed plans for community engagement.

Comment

Representation ID: 22515

Received: 16/03/2020

Respondent: Broadland Green Party

We support the view of Professor John Wood, Head of Department of Veterinary Medicine, University of Cambridge that the Cambridge - Norwich high tech link is potentially very positive: “we have very strong links and hope that a lot of biotech will continue”. However, regarding housing needs now and in the future wealthy people will always source housing but there is insufficient housing for the people who most need it to support the biotech sector: the technicians, veterinary nurses and innumerable support staff. Robust and well managed social housing schemes are the best way to provide this. We also caution against increasing our carbon footprint through the linkup. We really need a good cycle route for the electric bikes that should be ubiquitous in 10 years’ time, not further road development.

Comment

Representation ID: 22516

Received: 16/03/2020

Respondent: Broadland Green Party

Comment: We have already questioned the projected rise in the population. No satisfactory evidence has been provided for this increase.
There appears to be a circular argument on house numbers and jobs to be created. What comes first? Is it the jobs or is it the people who need the jobs?
We have already seen that with declining birth rates the only way in which the population is going to rise in the lifetime of the plan is through new people arriving. Given that any further developments are going to increase our carbon footprint and degrade our pleasant environment why would we want to encourage an increase in an unsustainable population? The argument in the plan is to increase economic growth but if this growth is at the expense of healthy living and increased carbon emissions then it is neither a welcome nor sustainable way to plan our future.
The housing that is required should be built to provide affordable housing for those who need it and housing for the elderly as indicated by the population mix in Section 2, para 34.
A significant proportion of such housing will need to be social housing for those who cannot afford to buy.

Comment

Representation ID: 22517

Received: 16/03/2020

Respondent: Broadland Green Party

Policy 2, Bullet point 10 states: “All new development will provide a 20% reduction against Part L of the 2013 Building Regulations (amended 2016)”. This is an inadequate target with cities such as Bristol and London (GLA) having 35% beyond Building Regulations. Reading, for example, states “All housing developments over 10 dwellings / 1000m2 to be designed to achieve zero carbon (subject to viability)”. Given the climate emergency the financial arguments do not stack up.

Comment

Representation ID: 22518

Received: 16/03/2020

Respondent: Broadland Green Party

Cat-exclusion zones in rural and urban-fringe landscapes.
The issue of cat-exclusion zones is a sensitive and complex issue that has not been considered in the GNLP but is a serious aspect of retaining our natural wildlife and biodiversity. In a comprehensive study highlighting the impact of humankind it was found that whilst the human population represents just 0.01% of all living things humanity has caused the loss of 83% of all wild mammals and half of plants, while livestock and pets kept by humans abounds .
Domestic cats (Felis catus) are known predators of native and introduced wildlife occurring in high densities independent of fluctuations in prey species abundance. Because domestic cats are fed by their owners, they do not need to hunt to survive, and household food buffers them from prey population declines, enabling them to hunt birds and small mammals until prey reach very low numbers. The amount of food a cat is fed does not affect its propensity to hunt. Predation pressure is probably higher, given that domestic cats often live for 15 years or more, much longer than feral cats.
The process of urban sprawl brings the human population and their domestic cats in close contact with wildlife in areas that were previously remote, including reserves and conservation areas created to protect populations of vulnerable or threatened species. Various mitigation measures have been proposed, including devices designed to hinder cat hunting ability and regulations governing cat ownership. Such regulations may aim to reduce cat densities by limiting the number of cats per household, or they may define zones around sensitive conservation areas where cat ownership is prohibited.
How large should cat-exclusion zones have to be?
Even though the average home-range size of domestic cats living in low-density residential areas tends to be small, large inter-cat variation in ranging behaviour means that effectively to exclude domestic cats, exclusion zones would need to be wide.
Home ranges are larger at night than day. Sources of cover such as trees and buildings are preferred. Maximum distances moved and large variability between individual cats suggest buffers in rural landscapes would need to be at least 2.4 km wide, whereas those in urban-fringe habitat could be half as large .
We ask that serious consideration be given to the impact of cat predation on wildlife in the vicinity of future developments.

Comment

Representation ID: 22519

Received: 16/03/2020

Respondent: Broadland Green Party

There is very little substance regarding the improvement and expansion of public transport to reduce car use and offer a convenient alternative. We would expect, however, that further funding of the kind that central government has recently announced for the expansion of bus transport will be made available to transform the existing road system to efficiently use any additional bus fleet. Such a pledge needs to be included in the future plan.
The NDR was designed, as the name states, as a “distributor road” and to service the North East Growth Triangle. The quickest route from the NE Growth Triangle to the A47 Westbound is via the Postwick junction and so a “Western link road” is not necessary to accommodate traffic from the North East. The NDR was designed to work without the Western Link. Way back in 2006 a Western Link was not included in the design for environmental reasons. Nothing has changed to alter this view. Before construction of the NDR was started Mott MacDonald were asked to look at upgrading a route from the A47 to the A1067 Fakenham Road “to B-road standard”. In practice we believe this meant wide enough for two trucks to pass each other easily. The route is now classified as the B1535. There has been a problem of “rat running” through areas such as Western Longville, Ringland, Drayton, Costessey and Taverham which has been made worse by the NDR which channels traffic through these areas. The answer to “rat running” is not more roads, and especially not the proposed Wensum link road which will irrevocably damage the environment and biodiversity. The solution is hugely improved public transport and a culture change in traditional forms of commuting and working. The plan should address how this culture change and the improved public transport is to be achieved. Currently, it does not.
There was supposed to be bus priority work in Norwich, reallocating road space freed up by the NDR. This has not happened. If it is not done soon that road space is likely to be taken up by new traffic expanding to fit the space available. Most of the so called “bus priority work”, Bus Rapid Transit (BRT), on Dereham Road, for example, employed measures that helped all traffic, which does not help modal shift.

Comment

Representation ID: 22520

Received: 16/03/2020

Respondent: Broadland Green Party

Renewable energy should be encouraged and supported including schemes to allow and promote community energy projects.
There is a “right to connect” for new developments which means that the utility, Anglian Water, has no option but to connect new housing developments to the water supply and sewerage systems. Currently, they are unable to object to developments on the basis of insufficient infrastructure to cope and yet we see problems of water supply, sewerage capacity and sewage works (water recycling) capacity across the county. This will lead to water shortages and has resulted already in surface water flooding from sewers and regular emergency tankering of sludge from smaller rural sewage works (Reedham village is an example).
There is, therefore, a need to review the way in which utility companies contribute to decisions on planning applications. As a minimum, a higher priority should be given to the views of utilities regarding local capacity. Ofwat also has a role to play in requiring the investment necessary to bring infrastructure up to the required standard. Companies like Anglian Water make significant profits. They should be required to reinvest those profits into the public infrastructure.
Existing water resources cannot support an increased population. In March 2019 the Environment Agency chief executive James Bevan warned that England could face severe water shortages in the next 25 years if action is not taken now (https://www.bbc.co.uk/news/uk-47620228). East Anglia is one of the regions most at risk of experiencing drought and water shortage.
It does not make sense, therefore, to create more jobs and build more houses that cannot be sustained by existing natural resources. As Sir James Bevan stated, “The impact of climate change, combined with population growth, means the country is facing an “existential threat””.

Comment

Representation ID: 22521

Received: 16/03/2020

Respondent: Broadland Green Party

Para 241: Support the policy that “sets a general requirement for on-site affordable housing provision of 33%”. There is no point in relaxing this requirement to enable developers to realise their minimum allowable profit. Schemes must be developed, or national policy modified through LA lobbying, to ensure sufficient affordable homes for those who need it.
As stated in an earlier section: We support the view that the Cambridge - Norwich high tech link is potentially very positive: “we have very strong links and hope that a lot of biotech will continue”. However, regarding housing needs now and in the future wealthy people will always source housing but there is insufficient housing for the people who most need it to support the biotech sector: the technicians, veterinary nurses and innumerable support staff. Robust and well managed social housing schemes are the best way to provide this.

Support

Representation ID: 22522

Received: 16/03/2020

Respondent: Broadland Green Party

Support: the need for additional sites for Gypsy and Traveller accommodation