26 February 2018
The consultation
The Greater Norwich Local Plan will determine where new housing should be built for the next 20 years, as well as establishing policies on a variety of issues related to land use and building, including design, energy, climate change and transport. The plan-makers are currently consulting on options for the plan, and it’s really important that people respond with their views. The consultation document is long and a bit tricky to navigate, so Norwich Green Party has written these notes to guide you through it. To respond, go to www.gnlp.org.uk and click on ‘have your say’. From here, you can:
1. comment on sites that have been put forward for development, or put a site forward yourself;
2. comment on the main Growth Options document, which includes a series of questions about different policy issues;
3. comment on the interim Sustainability Appraisal, which evaluates the economic, social and environmental sustainability of different policy options;
4. look at the evidence base – there are lots of documents available to download which provide the evidence used in drawing up the plan. These include assessments of housing need and employment land and lots of information about flood risk. These documents are quite long and technical and are probably only worth reading if you’re planning to submit a very detailed response on a particular issue.
You can read the whole document without registering, but if you want to comment you will need to register with an email address and password. If you need consultation documents in large print, audio, Braille, alternative format or a different language, email gnlp@norfolk.gov.uk or phone 01603 306603.
To comment on particular sites:
Click on ‘Comment on sites’. From here you can either download a PDF or view the sites online. There are links you can click on to view sites for each of the three districts (Broadland, Norwich and South Norfolk), organised by location. The sites are listed in a table. Click on the pencil icon on the left to comment, or the globe icon to view a map of the site.
To comment on ‘growth options’ and policies:
From the home page, click on ‘Have Your Say’ in the red bar at the top. Scroll down to section 2 and click on ‘go online here’, then on the section you want to comment on. At the bottom, you can click on ‘Next Chapter’ or ‘Previous Chapter’ to go forward or back.
This section asks for views on six different options for how new housing should be distributed. Inevitably, there are quite a lot of technical terms used in the document, so the glossary at Appendix 4 might be useful!
There are seven chapters. The first two provide context and don’t contain any questions. Chapter 3 has a short question about the objectives of the plan. Chapter 4 has questions about the six ‘growth options’ and about housing numbers, green belt, the city centre, towns and rural areas. Chapter 5 is about the call for sites, and does not contain any questions (you can comment on sites in section 1). Chapter 6 contains lots of questions about different policy issues: employment sites, transport, design, affordable housing, retirement housing, caravans and houseboats, gypsy and traveller accommodation, climate change, air quality, flood risk, nature conservation, landscape, energy, water management, health impact assessments, Neighbourhood Planning, culture, and the Broads.
Chapter 7 is about how the plan will be monitored, and includes two questions about this. At the end of this section, there is also a question where you can raise any other issues relating to the plan.
Unfortunately, the chapters aren’t divided up into smaller parts, and chapter 6 in particular is very long. The best way to find questions on a particular issue is to search for keywords using Ctrl + F.
Key questions
There are 66 questions, and all will be important to different people. Here, we highlight questions where Norwich Green Party has a strong view, and summarise our position. Feel free to use these points as the basis of your own responses, although it’s helpful if you use your own words.
Housing need
Questions 5 and 6: An assessment of housing need has suggested that Greater Norwich needs 38,988 more dwellings between 2015 and 2036 (most of which have already been allocated in the last plan, the Joint Core Strategy (JCS)). Question 5 asks whether the plan should allocate enough land for an extra 10% ‘buffer’ above this figure. Question 6 asks whether ‘windfall’ development (sites which are not allocated in the plan but where development takes place, including small sites and office-to-residential conversions) should be additional to this figure. The alternative would be to calculate an estimate of the likely level of windfall development and include this in the figure.
The growth options are based on the need to provide 7,200 more allocations on top of the sites already allocated in the JCS. This figure includes a 10% buffer and does not include any predicted windfall development.
We are not in favour of a ‘buffer’, particularly not one as high as 10%. Allocating more sites than necessary only encourages developers to cherry-pick the easiest and most profitable sites and risks leaving key brownfield sites vacant. We support the introduction of a ‘reserve list’ of allocations, which would become available for development only when most existing allocations have been built out.
For largely the same reasons, we do not accept that windfall development should be in addition to the agreed number of required allocations. The plan should be encouraging small-scale windfall development (where it is appropriate in planning terms), which can provide homes in places they are needed and support smaller building firms. The document estimates that windfall could provide up to an extra 5,600 dwellings, which is a significant proportion of the number required. This should be taken into account when allocating land, to avoid allocating far more sites than necessary.
How housing is distributed
Questions 9-12: These questions are about the six different ‘growth options’ for how housing allocations should be distributed. Option 1 concentrates growth close to Norwich. Option 2 allocates the most sites in ‘transport corridors’ (close to major roads – the map of this option shows that railway lines are not included). Option 3 focuses on the A11 corridor. Options 4, 5 and 6 all disperse allocations much more widely across rural areas – option 5 combines this with a new settlement, while option 6 combines it with some growth close to Norwich.
It is important to remember that the vast majority of sites have already been allocated through the Joint Core Strategy (JCS). There is a huge amount of growth already planned for the ‘north east growth triangle’ around Rackheath, which was the focus of the JCS, as well as a large amount in Cringleford, Hethersett, Long Stratton and Wymondham
Our priority is to oppose the dispersal options (4, 5 and 6). The local plan should seek to create self-contained communities with shops and services which are close to employment areas and thereby reduce the need to travel. These options would do the opposite – by scattering houses widely across small villages, they would increase dependence on the private car.
Given that the number of sites to be found is relatively small (compared to when the JCS was being drawn up), we do not believe a new settlement can be justified. In order for a new settlement to be well planned and viable, it would require a large amount of funding and political backing, and it is not clear that these are available. A poorly planned new village would be likely to be simply another car-dependent development built on fields. We therefore oppose option 3 on these grounds.
Option 1 (concentration of growth around Norwich) and option 2 (growth in the ‘transport corridors’, which includes a substantial number of new allocations in Wymondham and Diss) are, in our view, acceptable starting points for a growth plan. However, the final decisions must be based on the principles of good planning – notably the principle of reducing the need to travel, particularly by car. Brownfield sites should be prioritised ahead of greenfield sites for development, while taking account of the biodiversity value of brownfield land.
Question 13: this is about green belt. Norwich does not currently have a green belt and there has been some interest in establishing one, notably from the Campaign to Protect Rural England. According to national planning policy, new green belts can only be established in ‘exceptional circumstances’, and the consultation makes clear that the plan makers do not believe a case could be made.
We support the introduction of a green belt in the form of ‘green wedges’. Current policies are not adequately protecting the river valleys and other green corridors, but a full green belt could take years and leave sensitive areas open to destruction in the meantime. Green ‘wedges’ would be a more reasonable way of ensuring that the most important areas of countryside near the city are protected and would therefore offer the best protection at this time.
Questions 23-25: These questions are about the settlement hierarchy, which helps determine how much development can happen in different types of places. It might sound a bit technical, but the implications are huge, so we are really keen for as many people as possible to respond to this.
The current settlement hierarchy has six categories: Norwich urban area; main towns (Aylsham, Diss, Harleston and Wymondham); key service centres; service villages; other villages; and smaller rural communities/countryside. Settlements are placed in the hierarchy based on the level of services and employment opportunities they offer. Places in the bottom two categories will not normally be considered suitable for significant development.
The consultation includes two options. Option SH1 broadly retains the current hierarchy. Option SH2 combines the bottom three categories into a category called ‘Village Groups’, on the basis that services could be ‘shared’ between neighbouring villages or hamlets. This would allow development in villages or hamlets with no services, with the idea that residents would use services in a nearby village.
We strongly oppose option SH2 and any weakening of the settlement hierarchy. Good planning seeks to build communities with good access to employment and services and reduce the need to travel – the settlement hierarchy was developed for this reason. There is a clear difference between a village where residents can walk to the shop (for example) and one where they have to drive to a shop in the next village, and the current hierarchy recognises this. Combining these villages into groups removes this distinction and goes against the principle of reducing car dependency. It risks creating a developers’ free-for-all in rural areas, which would suddenly virtually all be considered suitable for development.
Transport
Questions 34-35: Question 34 asks whether any additional strategic transport improvements should be supported by the plan, in addition to those already listed. Question 35 asks how the plan can support improved sustainable transport and broadband coverage.
We find this section very frustrating as it appears to claim there is only one option for transport policy – the status quo. Yet the status quo is hugely self-contradictory: the stated aim is to improve public transport and walking and cycling infrastructure to reduce reliance on the private car, but almost all the money and strategic priority is given to road-building and road-widening schemes.
We think the plan should support local rail, not just the Norwich-London and Norwich-Cambridge services mentioned (though these are important too). A station at Broadland Business Park is already an aim – we would like to see it made a strategic priority, along with investigation of where new or reopened stations could improve access to the rail network, such as at Cringleford. We also want to see renewed emphasis on the completion of the planned Bus Rapid Transit network, which was promised when the NDR was agreed but which has fallen well behind schedule.
There may well be other schemes you want to suggest as ‘strategic transport improvements’. We strongly object to the plan’s assumption of a new road across the Wensum Valley (the Norwich Western Link), for which no satisfactory case has been made and which would cause massive and irreparable damage to the valley.
Regarding the sustainable transport policy, despite some improvements to cycle infrastructure in Norwich, the current policy is not achieving its aim of reducing car usage – mostly because money keeps being spent on road building. We would like to see every policy in the local plan and every site allocation judged on whether it will reduce car use, and for this to be properly monitored.
Design
Question 36: This question is about design standards and housing density. It asks whether to retain the existing policy or make it stronger.
We support the introduction of a stronger policy on design (option DE2), in particular the introduction of new measures to ensure that walkability and access to public transport are taken into account in new developments. It is important that the plan adopt the updated ‘Building for Life’ criteria, which are mentioned in the background text to the consultation but not in the policy options.
The policy should encourage higher-density development where this is appropriate (i.e. in the city centre and parts of the main towns), while also setting a maximum density and maximum building height (which could differ in different parts of Norwich) to avoid overdevelopment.
Affordable housing
Questions 37-39: These questions are about affordable housing. Question 37 asks whether affordable housing should be provided by developers of sites of five or more dwellings, or of 11 or more. Question 38 asks what the required percentage of affordable housing on these sites should be – 27%, or a higher figure. Question 39 asks how this housing should be split between rented and low-cost home ownership, and recommends an 80:20 split.
Given that, as the document states, not all sites will actually deliver a policy-compliant level of affordable housing, we see no reason to change the current requirement of 33%. Requiring only 27% is unlikely to meet need, which has been identified as 26.5%.
Our priority for this issue is to see the plan take a stronger line on the ‘viability assessments’ used by developers to avoid their affordable housing obligation. While there are some sites that are genuinely very complicated and expensive to develop, using this argument to avoid affordable housing contributions should be the exception. Currently, almost all applications which should be providing affordable housing use viability assessments to argue that they can afford little or none. Shelter has produced an excellent report on how this loophole is pushing up land prices and depriving communities of affordable housing. Ideally, we want to see the ‘viability test’ removed from national planning policy so that failure to provide affordable housing becomes the exception rather than the rule. In the meantime, we want to see a formal process set out in the local plan for how viability assessments will be scrutinised.
Climate change
Question 50: All the question asks is whether the plan should include a policy on climate change “based on the current policy approach”. Given that the current approach is at least 10 years old, and that both the UK’s legal obligations (e.g. under the Paris Agreement) and the urgency of the situation have increased since then, we are arguing for a much stronger policy on climate change.
The lack of leadership on this issue from central government is extremely unhelpful, but there are still things that local plans can do. Crucially, action on climate change should be at the heart of plan-making – on energy, transport, housing distribution, design – and not just an individual add-on policy. There is also a need for clear numerical targets that are in line with the UK’s legally binding carbon budgets, including a baseline against which these will be judged. Without these, the plan’s impact on emissions will be impossible to measure.
The climate change policy must include transport emissions, which were excluded in the previous plan (the Joint Core Strategy). This is vital, as UK transport emissions have been rising for the last three years and now account for 25% of all UK greenhouse gas emissions.
The policy on climate change should also set out the risks and likely costs, including public health risks. It should consider the long-term view beyond 2036, as decisions made now will have a massive impact on the area for many decades to come.
Air quality
Question 51: This question asks whether the plan should include a policy on air quality. We are strongly in favour of option AQ1, which would require air quality impact assessments and mitigation measures for all planning applications which could affect air quality.
Nature conservation
Questions 53-56: These questions are about nature conservation, ‘green infrastructure’ and landscape protection. Question 53 offers two options for dealing with the impact of developments on nature conservation sites: require developers to provide alternative green space, or require them to make payments to help manage the conservation sites in a way that addresses the impact of development.
Neither of these options acknowledges the fact that green spaces, let alone designated conservation sites, are not interchangeable – their loss cannot automatically be ‘offset’ by creating a green space somewhere else. We believe the policy on nature conservation should start by setting out the principle that designated conservation sites are to be protected and that development affecting them will be a last resort. Where development would have a negative impact on these sites, land should not be allocated. Applications to develop such sites, including plans for road schemes or similar, should provide evidence that alternatives have been thoroughly considered. The policy should allow for measures from either of the options listed, but not stick rigidly to one or the other as a solution.
Question 54 offers an opportunity to state any changes you think should be made to the Green Infrastructure network. Question 55 is about approaches to landscape protection, and question 56 is about strategic gaps between settlements.
If the proposal for ‘green wedges’ is not accepted, then policies are needed to protect sensitive areas including the Tud and Tas valleys and the countryside to the north west of Norwich.
Renewable energy
Question 57: The only option listed is to retain the current approach of requiring 10% of a scheme’s energy to be provided by on-site renewable or decentralised sources, and to remove references to energy efficiency and sustainable construction as government policy no longer permits local plans to require these.
We dispute the consultation’s claim that it would be “unreasonable” to require more than 10% on-site renewable energy. In the third quarter of 2017 (the most recent available figures), 30% of UK energy generation was from renewable sources – up 15.4% on the previous year. Since the 10% ‘Merton Rule’ was first introduced in 2003, the picture for renewable energy has completely changed. Other local authorities have introduced higher requirements, and it would show a disastrous lack of ambition to leave the requirement at 10%. It is also possible to have an alternative policy requiring a percentage reduction in CO2 emissions – in London this is 40%. This may be a preferable approach, as it directly promotes energy demand reduction.
The government’s statement that local authorities would no longer be able to set energy efficiency standards for dwellings was an amendment to the Planning and Energy Act 2008. While this amendment was passed in 2015, no start date for its implementation has ever been announced. In the absence of clarity on this area of policy at a national level, we believe the local plan should set requirements equivalent to the Code for Sustainable Homes Level 4 (sadly, legislation does make clear that nothing stricter than this can be required). Whether or not the amendment about energy efficiency standards is ever implemented, standards can still be stipulated for commercial buildings, so we are also calling for a strong policy on this to be incorporated in the plan.
Water management
Question 58: The favoured policy (and the only one suggested) is very vague. The current plan (the JCS) sets a water efficiency standard of 80 litres per person per day (lpppd), but the government changed the rules in 2015 so that the strictest allowable standard is 110 lpppd. This makes planning for growth in Greater Norwich basically impossible, as it is an area of water stress and the need for water efficiency is well documented. We will be calling on the plan-makers to make this situation clear to the government and lobby for stricter water efficiency standards to be permitted.
Monitoring
Question 64: This question is about how the plan will be monitored. The only issue to be specifically covered here is housing land supply. The question asks what should and should not be monitored. This is a good place to mention the need for numerical targets on greenhouse gas emissions. You may also want to mention other related indicators which should be monitored, such as affordable housing, cycling, car usage and air quality.
Further comments?
Question 66:
This asks whether there are any other issues you want to raise regarding the local plan.
More help from Norwich Green Party
The main Green Party councillor contact for issues relating to the local plan is Simeon Jackson: simeon.jackson@norwichgreenparty.org. Please email him if you:
- Have comments or questions about this document
- Think there are important things we have missed out (the Green Party’s response will include more detail, but the main issues we will be responding about are outlined above)
- Want to help promote the petition to only allocate new housing where services can be reached on foot or by public transport
