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Greater Norwich Local plan

Mike Burrell, Greater Norwich Planning Policy Team Manager has just announced the next phase of consultation:

“The GNLP will go forward for a six week Regulation 19 publication period, which will start at 09.00 on Monday 1 February 2021 and close at 17.00 on Monday 15 March 2021. No representations will be accepted outside of this period. You can find the proposed submission documents on our website at www.gnlp.org.uk

The publication period allows for any concerns to be formally raised as a ‘representation’ regarding the soundness or legal compliance of the GNLP. Representations must be received by GNLP by 17.00 on Monday 15 March 2021.

There are two ways to make comments on this plan: by submitting them online or in writing. Ideally, please submit comments online at www.gnlp.org.uk. However, written responses can also be made on a response form, which can be downloaded from www.gnlp.org.uk, or requested by phoning 01603 306603 or emailing gnlp@norfolk.gov.uk.

Written representation forms should then be emailed to: gnlp@norfolk.gov.uk

Or sent via post to: Greater Norwich Local Plan Team, County Hall, Martineau Lane, Norwich NR1 2DH

All representations must be received by 17.00 on Monday 15 March 2021.

The GNLP comprises two key elements: the Greater Norwich Local Plan (GNLP) Strategy which is the planning strategy for growth in Greater Norwich from 2018 to 2038 together with supporting thematic policies; and a GNLP Sites document which contains the policies for sites we propose to allocate for development to help deliver the GNLP. There are also supporting and evidence base documents available for inspection, including: the Sustainability Appraisal, the Habitats Regulations Assessment, the Equalities Impact Assessment. …“

It is important to be aware that “Representations at this stage should only be made on the legal compliance and soundness of the GNLP, that is: has the plan been prepared in accordance with all legal and procedural requirements; and does the plan meet the prescribed tests of soundness”. This is explained in more detail, together with advice, on the Representation Form that can be downloaded as a pdf.

Friends of the Earth in “Local Plans: A Campaigner’s Guide” gives its view on how to respond to Local Plan Consultations. See for example p 49 “The Natural Environment”

The Yare Valley Society Response

The Yare Valley Society is objecting to the GNLP on the grounds of the Plan being unsound in respect of two of its policies:

Policy GNLP0133DR: Land between Suffolk Walk and Bluebell Road

Policy GNLP0133-E: Land at the UEA Grounds Depot Site, Bluebell Road University of East Anglia

Both of these policies would result in a reduction of green space in the Valley, with Policy GNLP0133-E making the most brutal intrusion into the Yare Valley green envelope.

Both of these policies are a step back from the commitments to the green infrastructure of the Yare Valley contained in previous local plans. See for example the “Adopted policies map south sheet” for Norwich, which can be downloaded here.

The YVS holds that both of these policies are

contrary to the National Planning Policy Framework (NPPF) section 15 Conserving and enhancing the natural environment.
contrary to the declared policies contained in other parts the GNLP Draft. See for example YVS 2020 GNLP submission section D

The YVS will present evidence to the Local Plan Inspector to support its view.

Planning for the Future – Government Consultation

The government plans to sweep away many of our planning controls as part of their “Build Build Build” strategy. Papers for the Consultation are here. The closing date is 29 October 2020.

Environmental bodies have expressed deep concern over the proposals. The Wildlife Trusts claim the new proposals will fail to protect nature. This is at a time when the National Biodiversity Network is recording a devastating wildlife loss in the UK. Nikki Williams, Director of Campaigning and Policy at The Wildlife Trusts writes:

“We live in one of the most nature-depleted countries in the world. The White Paper proposes a planning system with three categories of land – earmarked for growth, renewal and protection – but this simplification brings the risk of creating a disconnected landscape, one in which wildlife continues to decline because nature doesn’t slot into neat little boxes. Protecting isolated fragments of land is not enough to help wildlife recover, nor will it put nature into people’s lives – something that is now recognised as vital for our health and well-being.”

The Council for the Protection of Rural England is concerned local people will lose a say on individual developments and on the future of their green space. Tom Fyans, CPRE deputy chief executive writes:

“The key acid test for the planning reforms is community involvement and on first reading, it’s still not clear how this will work under a zoning system.

Although we welcome the government’s commitment to all areas having a local plan in place, we also need robust legal guarantees that the public are consulted regarding new development. Red lines on a map are not going to build trust in the planning system.’

How do we handle this one – the big one!?

Are we prepared to lose our previous rights to respond to individual planning applications? Are we happy about the reduction in local government influence? Should Local Plans be restricted to a much-reduced form of a government template? Will the zoning proposed destroy rather than promote interconnected green space for wildlife and leisure?

The Yare Valley Society committee has studied the documentation and formulated a response. Do not leave it to the Society alone. We all, as individuals, must respond to the consultation, highlighting the importance of expanding and enhancing interconnected green space; and emphasising its role in countering climate change, promoting biodiversity, and contributing to the well-being of our communities.

Having thoughts about how you might respond to the consultation? Below is the response of the Yare Valley Society Committee. The committee responded only to questions within its remit. You may wish to respond on other questions as well.

Please submit your response – do not leave it to the Society alone. You do not have to respond to all the questions.

The committee found the Friends of the Earth suggested responses of great help in framing its own. Friends of the Earth also provide a responses template for use if you do not wish to respond online.

Yare Valley Society Response

Q1. What three words do you associate most with the planning system in England?

Valuable; Consultation; Representation

Q2(a). Do you get involved with planning decisions in your local area?

Yes

Q3. Our proposals will make it much easier to access plans and contribute your views to planning decisions. How would you like to find out about plans and planning proposals in the future?

By email.

It is hard to see how these proposals will make it easier for people to contribute their views to planning decisions, since the reforms propose to omit or curtail key stages of the planning process, namely when a planning application is submitted, it is subject to public consultation and is decided by the local planning authority. Only ‘protected areas’ would appear to retain a planning system along these lines.

Q4. What are your top three priorities for planning in your local area?

Protection and enhancement of green space for wildlife and informal recreation

Democratic, accountable, transparent local decision making.

The environment, biodiversity and action on climate change

Q5. Do you agree that Local Plans should be simplified in line with our proposals?

No. To deliver new homes and other development while meeting broader objectives, such as healthy, resilient communities, the UK net zero carbon 2050 target and protection of green space, wildlife and the natural environment, Local Plan policies must be sufficiently detailed and tailored to local circumstances, challenges and opportunities.

It is essential to continue to allow local authorities at least the same level of flexibility to set development management policies as under the current Local Plans system. They should not be restricted in this as the consultation paper proposes. This in turn should be supported by a strengthened NPPF which empowers, rather than restricts, planning authorities and communities to manage development in their area in line with local aspirations and needs, and in a way which responds effectively to the climate and ecological crises.

Q6. Do you agree with our proposals for streamlining the development management content of Local Plans, and setting out general development management policies nationally?

No. These proposals would take away control from local communities and the councils who serve them. Local Plan policies must be sufficiently detailed and tailored to local circumstances, challenges and opportunities if we are to meet wider aspirations and objectives, such as on climate change, the natural environment, green space, local economy and affordable housing.

The White Paper proposals for paring down the development management function and stripping planning authorities of their ability to decide development proposals (or placing restrictions on this) outside protected areas will mean local people and elected councillors who serve them will have less say over what development can or cannot go ahead. The Proposals severely curtail local democracy.

Q7(a). Do you agree with our proposals to replace existing legal and policy tests for Local Plans with a consolidated test of “sustainable development”, which would include consideration of environmental impact?

There is insufficient information in the consultation documentation to answer this question. For example, it is not at all clear what form a consolidated test of “sustainable development” could take. There are many types of sustainability, environmental, economic, social etc., etc., Any consolidated test is likely to be very complex if it is to deal with the relevant issues. If it is not complex, it will be ineffectual in rooting out unsustainable and so undesirable proposals.

As at present the answer must be No.

Q7(b). How could strategic, cross-boundary issues be best planned for in the absence of a formal Duty to Cooperate?

No justification or reasoning is given for removal of Duty to Cooperate. Co-operation between authorities at their interfaces is essential if coherent planning is to take place.

Where appropriate, there should be a locally accountable, democratic, strategic planning tier. For example, in the Greater Norwich Area Broadland District Council, Norfolk County Council, Norwich City Council and South Norfolk Council co-operate with one another to produce a Local Plan for Greater Norwich. If one of these authorities decided it did not want to participate it would be difficult to plan for the future prosperity of the Greater Norwich community as a whole. Green biodiversity networks, sustainable transport networks, provision of green space could become disjointed and be damaged.

Q9(a). Do you agree that there should be automatic outline permission for areas for substantial development (Growth areas) with faster routes for detailed consent?

No. There should be no automatic permission granted. Development proposals should be decided by way of a planning application. The planning application process provides for public, democratic scrutiny. This is a prerequisite for robust, fair planning outcomes. Under an automatic permission in principle this stage would be omitted and therefore the procedure for approval would be less fair, potentially less rigorous, and undemocratic.

Q9(b). Do you agree with our proposals above for the consent arrangements for Renewal and Protected areas?

No. The planning application process provides for public democratic scrutiny. This stage needs to be retained and enhanced to ensure at least the existing level of scrutiny and public participation remains. Without these safeguards, procedures risk being less fair and less rigorous.

Q9(c). Do you think there is a case for allowing new settlements to be brought forward under the Nationally Significant Infrastructure Projects regime?

No. New settlements should be seen as a last resort after all other options, such as redevelopment and urban extensions have been considered and exhausted first.

Planning should remain in the hands of democratically elected authorities.

Q10. Do you agree with our proposals to make decision-making faster and more certain?

The proposal that applicants will be entitled to an automatic rebate of their planning application fee if they are successful at appeal is unfair. It will deter cash-strapped local authorities from refusing to grant permission for an application they consider to be poor. When reaching a planning decision often many factors need to be considered and balanced. A rebate should be required only where a council’s planning decision is deemed unreasonable by an Inspector on material planning grounds.

Q11. Do you agree with our proposals for accessible, web-based Local Plans?

Not sure. While increased use of digital technologies is welcomed, it does need to be supplemented by in person events to ensure a wide engagement of the community, and to enable discussion of detail. Both face-to-face communication and digital modes of communication are required.

Q12. Do you agree with our proposals for a 30-month statutory timescale for the production of Local Plans?

Not sure. Everything will depend on the level of resourcing made available to planning departments and the Planning Inspectorate.

Q13(a). Do you agree that Neighbourhood Plans should be retained in the reformed planning system?

Yes. Neighbourhood Plans should be continued and enhanced. They play an important role in setting local policies tailored to the needs of their neighbourhood, and foster community ownership of and engagement with planning.

Q13(b). How can the neighbourhood planning process be developed to meet our objectives, such as in the use of digital tools and reflecting community preferences about design?

The digital planning process should not be such as to constrain communities by an overly rigid format. They should be able to incorporate a range of policies which include the environment, biodiversity, action on climate change, and the protection of green space for wildlife and informal recreation.

Q14. Do you agree there should be a stronger emphasis on the build out of developments? And if so, what further measures would you support?

Yes. Already too much of the land that has been allocated for housing development has not been built on. The current practice of land hoarding by certain developers awaiting suitable “market conditions” contributes to the present unacceptable cost of housing, patchy development, and unnecessary demands for release of further land for development; the latter encroaching on green space. Rigorous measures need to be in place to discourage land hoarding.

Suggested measure: Councils should be given the power to purchase undeveloped land (scheduled for development) for pre-set common multiple times its existing use value; this should aim to make it viable for more affordable housing to be built. In addition, the council should be given the power, after a set time, to require the developer to put undeveloped land (scheduled for development) up for public auction (with no reserve price), with a view to encouraging other developers to make use of the land.

Q15 What do you think about new development that has happened recently in your area?

In the Greater Norwich Area, there have been repeated attempts by developers to encroach on the designated Yare Valley Character Area. This area makes an important contribution as a corridor in the biodiversity network, as a flood water storage area, as a mitigator of climate change, and as a green space for the informal recreation that is so important for the well-being of the community. With the help of the LPAs most of the attempts have been resisted, but there have been some notable exceptions. Each development intrusion impacts on the ability of the Character Area to perform its important roles

Q16. Sustainability is at the heart of our proposals. What is your priority for sustainability in your area?

Creating a national biodiversity network, climate change mitigation, green space for community well-being.

Q21. When new development happens in your area, what is your priority for what comes with it?

Green space that enhances the biodiversity network, mitigates climate change, and promotes community well-being.

Q22. (c) Should the Infrastructure Levy aim to capture the same amount of value overall, or more value, to support greater investment in infrastructure, affordable housing and local communities?

More value.

The overall aim should be to secure a greater proportion of the uplift in land value in order to support greater investment in creating a national biodiversity network, climate change mitigation, green space for community well-being.

Q23. Do you agree that the scope of the reformed Infrastructure Levy should capture changes of use through permitted development rights?

Yes. It is unfair that development delivered as a result of exercising permitted development rights is able to sidestep local policy requirements, development impacts and community needs.

Give the government and your MP your views on these proposals

Greater Norwich Local Plan (GNLP) Consultation 29 January-16 March 2020 (Draft Strategy and Site Allocations)

We now have another chance to respond to a consultation on the GNLP.

The existing GNLP runs until 2026, and the new GNLP will be expected to plan for up to 2038.

The consultation has two parts. The first part is The Strategy which proposes the policies that need to be in place to plan for the future. The second part is the Sites Plan a list of sites that are seen to be suitable and necessary for development in order to implement the policies.

Links have been given to relevant documents. You can respond online, or at one of the Roadshows, or in writing. If you have any difficult in responding there is a helpline at 01603 306 603. To make a response on line you will need to register. There will be a local Consultation Roadshow at the Forum, Norwich. on 26 February and 5 March 2 – 8 pm.

The Strategy

The draft Greater Norwich Local Plan Strategy recognises in many of its policies the important role of green infrastructure. Most specific is Policy 3 Environmental Protection and Enhancement. In the draft Policy 3 follows the explanatory Natural Environment paragraphs 184 to 194 and Map 8 of Green Infrastructure Corridors: Of particular interest is para 191:

“The Joint Core Strategy identified the potential to create a new country park at Bawburgh Lakes to the west of Norwich. It would complement the existing country park to the east of the city at Whitlingham, with the parks linked by the Yare Valley green corridor. Its establishment remains desirable. However, the policy is not site specific as other opportunities … may be identified …”

There has long been talk of a Country Park at Bawburgh, but progress on this seems to have stalled. At present the lakes are popular with the fishing community, but there is no public right of access. There is a suggestion in para 191 that any possible funding for Bawburgh Lakes might go elsewhere. Details of the site are here. (The reference on the map to Retail/Commercial Allocation is said to be an error – but worth commenting.)

Please respond to give your support to a Country Park at Bawburgh Lakes

Draw attention to the urgent to extend access to green space in the Valley to avoid further degradation by increasing use. There is growing demand from the population of new residential developments taking place in Bowthorpe, Cringleford, Little Melton and elsewhere. The existing green space in the Valley is already under severe pressure from informal recreation (evidenced by the over worn footpaths), and this, in turn, impacts on the viability of wildlife habitats.

Ask for high priority to be given to establish a Country Park at Bawburgh Lakes, and in the interim for a policy be put in place for an extension of the Yare Valley Walk, and the management of the lakes and their surroundings to safeguard habitats and increase biodiversity.

Give it your own personal slant.

Sites plan

Success in the previous consultation

The response of our members to the previous site allocation consultations has borne fruit. Almost all the proposed sites for development in the Yare Valley Green Infrastructure Corridor have been classified as “unsuitable”.

A big thank you to all who wrote in objecting to the sites. A big success for the championing of our green environment!

A threat remains

Unfortunately, in the new draft of the GNLP there remains a site allocation that rings alarm bells:

Site GNLP0133-E

UEA – Land at the Grounds Depot Site

Student Accommodation (400 beds student beds) 1.60 ha

The Yare Valley Society strongly opposes the inclusion of this site.

If you too are unhappy about the inclusion of the site respond by making your own objection, with your own personal slant and reasons. You can make a difference!

The Yare Valley Society opposes the inclusion of the site because its development would:

A Have a damaging impact on the effectiveness of Yare Valley Green Infrastructure (GI) Corridor

The proposed site is a damaging intrusion into the Yare Valley Character Area which forms an important part of the GI Corridor. The present natural flow of the edge of the Character Area along the south edge of approved university sites to along the line of the Bluebell Road is brutally interrupted by the proposed site. The site intrudes deeply into the GI Corridor.

The GI Corridor performs three important green infrastructure roles:

Provides a variety of wildlife habitats and is a key part of the local green network for wildlife movement and promoting biodiversity.
Provides interesting, visually attractive, and connected green space, recognised widely as essential to the well-being of communities.
Mitigates climate change and the effects of climate change by storing water on its wetlands, retaining water in its vegetation, and acting as a carbon sink.

The Corridor is more than the sum of its parts. Any reduction in the corridor impacts on its ability to function effectively in its roles.

B Increase the existing pressure on the Yare Valley Green Infrastructure Corridor.

In all of the green infrastructure roles above the corridor is already under great pressure

Role 1: Research shows nationally that biodiversity in, and abundance of, wildlife is decreasing (see State of Nature 2019 Report) and anecdotal evidence suggests this is reflected locally.

Role 2 Many over-worn paths demonstrate the demand for informal recreation, which will only increase with the planned increases in local population (e.g. new homes at Cringleford)

Role 3 Combating and mitigating climate change is assuming ever greater importance for the well-being of future generations.

This is not the time to be damaging existing key infrastructure networks, but a time to be extending them.

C Contradict Norwich Development Management Policy

(The GNLP consultation documentation states that Norwich Development Management Policies are “to be carried forward and used in conjunction with the Greater Norwich local plan.2022-2038.”)

The site lies wholly within the Yare Valley Character Area, as defined on the Norwich Local Plan Policies Map – South, Adopted December 2014, and is accorded special status in the Norwich Local Plan Policy DM6:

“Within the Yare Valley character area, as defined on the Policies map, development will only be permitted where it would not damage the environmental quality, biodiversity or character of the area and where it is for

agriculture or forestry purposes; or
facilities ancillary to outdoor sport and recreation; or
the limited extension of or alteration to existing buildings”

The inclusion of the site marks a step back from upholding the existing Norwich Local Plan Policy

D Contradict the policies of the Draft Greater Norwich Local Plan – Part 1 The Strategy

The importance of green infrastructure is rightly recognised in a number of policies in the draft GNLP Part 1 The Strategy. The policies seek to conserve and enhance the green infrastructure, the policies do not seek to destroy or degrade it.

Relevant policy statements are:

POLICY 1 – THE SUSTAINABLE GROWTH STRATEGY

“environmental protection and enhancement measures including further improvements to the green infrastructure will be delivered.”

The sustainable growth strategy will be supported by improvements to … green infrastructure…”

POLICY 2 – SUSTAINABLE COMMUNITIES

“Development must be of high quality, … contributing to mitigating and adapting to climate change, assisting in meeting national greenhouse gas emission targets.”

POLICY 3 – ENVIRONMENTAL PROTECTION AND ENHANCEMENT

“Development proposals will be required to conserve and enhance the natural environment. Key elements of the natural environment include valued landscapes, biodiversity including priority habitats, networks and species, geodiversity, …”

“Development should deliver biodiversity net gain wherever possible”.

“To enhance the natural capital of Greater Norwich, the natural assets and connections between them which form the Green Infrastructure Network illustrated in map 8 will be protected and enhanced. Protection will be achieved through effective management of development in accordance with the policies of the development plan.”

POLICY 6 – THE ECONOMY:

“Tourism, leisure, environmental and cultural industries will be promoted and assisted by … implementation of the green infrastructure network”

POLICY 7.1 – The Norwich Urban Area including the fringe parishes:

“Growth will include …Enhancements to the green infrastructure network which include links to and within the Wensum, Yare, Tud and Tas Valleys, Marriott’s Way and from Mousehold through the north-east growth triangle as set out in map 8, along with local networks.

The inclusion of the site would suggest that Greater Norwich will not be serious about implementing its declared green infrastructure policy.

Conclusion on Sites Plan

If building development were to take place on this site it would damage the existing green infrastructure and increase pressure on the remaining green infrastructure. Such development would be completely contrary to the stated aims of the Norwich Local Plan and the draft GNLP Strategy. It would be a clear signal to developers, and the general public that Greater Norwich is not prepared to stand by its green infrastructure commitments.

Site GNLP0133-E, UEA – Land at the Grounds Depot Site, Student Accommodation (400 beds student beds) 1.60 ha should not be developed, and should be classified as “unsuitable”

Thank you for reading so far, now