STOP NORWICH URBANISATION (SNUB)
Stephen Heard has a Post Graduate Certificate in Sustainable Business from the University of Cambridge and is a member of their Programme for Sustainable Leadership
National short listed finalist for the SMK Campaigner Awards 2010 in the Local Campaigner category
SNUB supported by Esmée Fairbairn Foundation Grass Roots Programme of small grants to support grass roots campaigners with administration costs.
SNUB Patron: Martin Shaw
1. INTRODUCTION ……………………………………………………….. 4
2. PROCESS ………………………………………………………………. 5
3. ENVIRONMENT ……………………………………………………….. 6
3.1 Strategic Environment Assessment ……………………. 6
3.2 Water Stress …………………………………………….. . 7
3.3 Surface Water Flood Risk ……………………………… 8
3.4 Campaign for the Protection of Rural England (CPRE).. 9
4. SUSTAINABILITY ……………………………………………………… 10
4.1 Natural Environment ……………………………………… 10
4.2 Climate Change and Carbon Footprint …………………. 12
4.3 Sustainable code for house construction ………………. 14
5. DEMOCRACY (Duty to Cooperate) …………………………………. 15
5.1 Introduction ………………………………………………… 15
5.2 Public Meetings …………………………………………… 15
5.3 Aarhus Convention ……………………………………. 16
5.4 Petition ……………………………………………………. 17
5.5 Community Involvement ……………………………….. 17
5.6 CPRE Alliance ………………………………………….. 17
5.7 GNDP Closed Meetings ………………………………….. 17
5.8 Broadland District Council Elections ……………………. 17
5.9 Salhouse Parish Council Election ……………………….. 17
6. PROCUREMENT AND COMMISSIONING …………………………. 17
7. HEALTH AND SOCIAL CARE …………………………………………. 18
7.1 Introduction ………………………………………………….. 18
7.6 Primary Care …………………………………………………. 20
7.7 Secondary Care ……………………………………………… 20
7.8 Community Care …………………………………………….. 20
7.9 Mental Health Services ……………………………………… 21
7.10 Out-of-Hours GP Service …………………………………… 21
7.11 Ambulance Service …………………………………………. 22
7.12 Dental and Other Clinical Services ………………………… 22
8. JUSTIFICATION ………………………………………………………… 22
8.1 Housing ………………………………………………………. 22
8.2 Employment ………………………………………………….. 26
8.3 Population ……………………………………………………. 27
9. FOOD CHAIN and AGRICULTURE …………………………………… 28
10 INFRASTRUCTURE ……………………………………………………. 30
10.1 Norwich Northern Distributor Road ………………………. 30
10.2 A47 Trunk Road (Postwick Interchange Slip Roads) Order 31
10.3 Railway ………………………………………………………. 32
10.4 Bus System …………………………………………………. 33
11. PLANNING ……………………………………………………………… 33
11.1 Introduction ………………………………………………… 33
11.4 Community Planning ……………………………………… 34
11.5 Current Approved Planning Applications ……………….. 34
11.6 Norfolk Hub Entertainment Complex ……………………. 34
11.7 Wroxham Planning ……………………………………….. 35
11.8 Salhouse Conservation Area …………………………….. 36
11.9 National Planning Policy Framework …………………… 36
11.10 Empty Homes …………………………………………….. 37
11.11 Beyond Green Application ………………………………. 37
12. ALTERNATIVES ……………………………………………………… 37
12.1 Introduction ………………………………………………. 37
12.2 The Norwich Society ……………………………………. 37
12.3 Relocation of Norwich International Airport (NIA) …….. 38
12.4 Drayton Road ……………………………………………… 39
12.5 Acle Hub ………………………………………………….. 39
12.6 Dispersal ………………………………………………….. 40
13. LOCALISM ACT 2011 ………………………………………………… 41
14. NORWICH POLICY AREA …………………………………………. . 43
15. CONFLICTS …………………………………………………………… 44
16. AIR SAFETY ……………………………………………………………. 45
17. POLITICS ………………………………………………………………... 46
18. ECONOMICS …………………………………………………………… 48
18.1 Introduction ………………………………………………… 48
18.2 Community Infrastructure Levy (CIL) ……………………. 49
18.3 New Homes Bonus ………………………………………. 49
18.4 Residual Land Values ……………………………………. 50
18.5 Cuts to Front Line Services ………………………………. 51
18.6 Propensity to Buy …………………………………………. 51
19. EDUCATION AND QUALIFICATIONS ………………………………. 51
19.1 Education …………………………………………………… 51
19.2 Qualifications ……………………………………………… 52
20. TOURISM ……………………………………………………………… 53
20.1 Norfolk Broads …………………………………………… 53
20.2 Coltishall …………………………………………………. 53
20.3 Independent Verification ………………………………. 54
21. CONCLUSION ……………………………………………………… 55
END NOTES ………………………………………………………… 56
My thanks to all contributors from local Parish Councils, Community Campaign Groups and the core team of Stop Norwich Urbanisation (SNUB). Special thanks to PL and MF for proof reading and sense checking.
JOINT CORE STRATEGY PROPOSED SUBMISSION RESPONSE
1.1 This representation is made on behalf of Stop Norwich Urbanisation (SNUB) a community campaign group covering the geographic footprint of the North East Growth Triangle (NEGT). This representation is made on behalf of the 3,600 followers and supporters of SNUB as measured by various democratic measures including a petition and numerous open public meetings, the latest being in 2012. It is made under Regulation 20 of the Town and Country (Local Planning) (England) Regulations 2012.
1.2 We do not believe that it is appropriate or proportionate that our representation should be restricted to the remitted elements of the Joint Core Strategy (JCS) as the plans for the development of the NEGT are intertwined in the JCS and to restrict our comments to this element only would be counterproductive and not living up to the ideals of localism as defined by this government. Our representation therefore whilst concentrating on the remitted elements of the JCS does by the very nature of the complexity of the JCS stray into other relevant and pertinent areas. The picture would be incomplete if we were not to do this and we would be failing to give any subsequent independent inspection a flavour of the strength of feeling about the whole JCS.
1.3 In making these representations we would like to reiterate our original concerns when we found at the original pre-court hearing the JCS failed the soundness test on a number of fronts. We still find this to be the case further expanded and amplified by the findings in this representation.
1.4 The overall view of the 3,600 local residents is that they do not wish to see the construction of 10,000 new homes in the NEGT as proposed by Broadland District Council (BDC) through its agent the Greater Norwich Development Partnership (GNDP) in their JCS. This view is strengthened by their belief that they believe that the JCS is not sound for a variety of reasons as detailed in this representation.
1.5 We, as the representatives of local residents, therefore do not support any of the three options put forward by GNDP on behalf of BDC and would like to see the JCS cancelled with the GNDP disbanded thus saving the annual administrative costs of £500k. The GNDP was set up to produce a mechanism for planning and managing the large-scale growth proposed for the Norwich area in the East of England Plan. The suspension and eventual cancellation of this regional housing strategy removes the need for an unelected body such as the GNDP.
1.6 We would like to see each constituent local authority developing their own local housing strategy, via their existing Local Development Framework (LDF) taking the views of Parish Councils into consideration through Parish Plans and Neighbourhood Plans, as they have in North Norfolk, thus representing true local opinion and a bottom up sustainable housing strategy. We are however aware of the controversy surrounding Neighbourhood Plans and the oblique endorsement they give to superior plans like the JCS and our views on this initiative are tempered by this circuitous attempt to involve the community and then promptly ignore their wishes if they do not fit with the local authorities view.
1.7 We believe that the results of a bottom up approach would see a reduced number of houses to meet real local “housing need”, rather then the current inflated “housing want”, built in the communities that require inward investment to ensure the sustainability of local amenities. This overall reduction of houses is in accordance with the campaign conducted by the Norfolk branch of the CPRE (see more details under Democracy) and the Save Our Villages campaign conducted by The National Housing Federation that is supported by BDC.
1.8 We submit the following commentary to support this view and to demonstrate why we believe that this revised JCS is NOT sound:
2.1 This additional JCS consultation is necessary due to the successful legal challenge brought by SNUB where BDC and other members of the GNDP were deemed to have acted unlawfully. This ruling came about due to the absence of the necessary Strategic Environmental Assessments (SEA) for all of the necessary options as required by EU legislation.
2.2 An independent study commissioned by BDC found that the process used for the first iteration of the JCS (before the High Court case) was “infected”. Indeed the High Court Judge when deliberating on the legal challenge stated that the consultation papers were like “wading through treacle” and he questioned the Defendants as to why they did not make the process simple in order for local residents to be able to see the options.
2.3 Even this current round of consultation seems infected with the 100 plus page document entitled Joint Core Strategy for Broadland, Norwich and South Norfolk (Ref No: PSJCS2) having no page numbers making it difficult if not impossible to navigate through. The document entitled Regulation 19 Publication and Sustainability Appraisal Consultation (Document ref: PSJCS 1) has a loose-leaf amendment to paragraph 6.3 on Page 5 where reference to the NPPF Compatibility Self Assessment Checklist has been omitted. These errors and omissions do not provide the necessary confidence that lessons have been learnt from this study and that the process is still infected.
2.4 We do not believe that the process for this consultation has improved and that it is difficult for the layperson to be able to understand the various options and therefore pass an opinion. The over reliance of tricky to locate online soft copy material and the difficulty in obtaining hard copies of the documentation upon request has been a barrier to full consultation especially among those residents who are not IT literate. The safe receipt of the documentation package results in a pile of impenetrable documents 7cm thick. It is presumptuous to assume that local residents who cannot access the documents online would go to a library or to the offices of BDC.
2.5 The original plan for the remitted JCS proposed submission content was for it to be published for a period of 8 weeks from 10th August 2012 until 5pm on 8th October 2012. However, due to an omission error by GNDP, the deadline for consultation had to be extended until 2nd November 2012.
2.6 Whilst this extension is welcomed it is worth noting that BDC refused a legitimate request for an extension from Great and Little Plumstead Parish Council (a SNUB supporter) to have a consultation lasting three months. They used in their justification, among other reasons, the perfectly sound logic that both the Plumsteads and Rackheath have their Parish Council meetings in July (9th and 16th respectively) and then do not meet again until September (10th and 17th respectively). Thus the opportunity for discussion and debate with the community, on a matter that would have lasting impact over the following decades, was lessened even further.
2.7 It seems that it is acceptable for an extension to cover up an error by full time professionals but not satisfactory to allow time for part time unpaid volunteers to organise a sensible debate and consultation within the communities most affected by these proposals. This arrogance is systematic throughout the whole process thus reinforcing the view that there is a democratic deficit here in Broadland.
2.8 The process for reworking the remitted parts of the JCS has merely regurgitated the original conclusion that the most appropriate option is, in fact, the same text as remitted and remains the best option for strategic growth in the Broadland part of the Norwich Policy Area (NPA).
2.9 We therefore conclude that this proposal is unsound as there is no tangible evidence that BDC and GNDP have re-engineered their infected process and the end result looks very similar to the conclusions reached before the successful High Court challenge.
3.1 Strategic Environment Assessment (SEA)[i]
3.1.1 There is no evidence that ALL options that were reviewed have been subjected to a full SEA as required by EU legislation. The process examined, in detail, 11 potential growth locations at three different scales of strategic growth and 7 potential combinations of those locations. However this revised JCS does not include a full and equitable SEA for every single option and only the three options put before the public in this consultation have had the benefit of a full SEA. Our contention is that this omission is the very same omission that led to the original high court challenge and the BDC and GNDP have not taken on board lessons learnt from the Judge’s declaration. For this reason alone this revised JCS is unsound.
3.1.2 This obligation is spelt out in the URS Sustainability Appraisal (PSJCS 3(2)) where it highlights the need to appraise all reasonable alternatives. The very same document includes the statement that all of the alternatives are fairly finely balanced. SEA’s of other reasonable alternatives, as set out in the Alternatives Section of our submission, would have highlighted the environmental impacts of the alternatives thus providing a much more balanced strategy.
3.2 Water Stress
3.2.1 The East of England is the driest region in the UK, experiencing an average of 600 mm of rainfall annually in contrast to an average of 900 mm for England and Wales. In an average year only a quarter of the rainfall is available as a water resource after evaporation and use by plants. Consequently water availability and water quality are key issues for Anglian Water and their Water Resource Management Plan (WRMP). Every water authority in the UK has to have one of these plans and the Anglia Water plan, states, among other things, the following:
§ Chemical and biological river water quality has improved over the last three years. However, both biological and chemical water quality for the region are below the national average, significantly below the national average in the case of chemical water quality where only 46% of rivers are considered to be of ‘good’ quality as opposed to the national average of 64%.
§ In areas of the Anglian Water region surface waters are already fully committed during summer months, whilst some winter abstractions are no longer reliable. Likewise, groundwater is considered to be over-licensed or over-abstracted in some areas. The Anglian Water region has been classified as in serious water stress by the Environment Agency.
3.2.2 The Environment Agency identified the Anglian Water region as an area of moderate water stress in its 2007 consultation on water stressed areas. This was revised to one of serious water stress in the final designation. The Anglian Water region’s water resources are highly utilised. The predictions for growth in the region means water resources are going to need to be carefully managed to provide additional water supplies and manage customer demand to ensure a secure supply of water without damaging the natural environment.
3.2.3 We share the concerns of the Broadland Agricultural Water Abstractors’ Group (BAWAG ), the National Farmers Union (NFU) and a number of substantial landowners who farm thousands of local acres that the completion of this number of proposed new homes would have a detrimental impact on the supply and disposal of water to the local farming community. The immediate cap in abstractions to historic levels in 2010 magnified their concerns.
3.2.4 Indeed Anglia Water, in undertaking an SEA of the Draft WRMP, highlight the potential for significant environmental effects in some schemes in some areas. For the most part, the risks of significant effects are a result of the lack of detailed information available for individual schemes at the planning stage.
3.2.5 We believe that this element of the JCS falls into this category for significant environmental effects, and that the rather naive view put forward in this strategy is that the water supply and disposal of wastewater will benefit from future innovation yet to be identified, as quoted in the Growth Triangle Guide of Spring 201. Here it states:
“Innovative solutions informed by a Water Cycle Study will be implemented…”
There is as yet no evidence of this innovative solution. Instead the Habitat Regulation Assessment (PSJCS 5) from 2010 has appended unconvincingly to it a letter dated 12th July 2012 where it states:
“Under the circumstances, all parties agree that the conclusion of the Habitats Regulations Assessment dated February 2010 remains unchanged, subject to the progress noted above in working towards a resolution of the longer term water resource requirement”
The lack of progress from Feb 2010 to Jul 2012 on sourcing the necessary innovation is worrying for the future as the forecast technical solutions do not seem to have manifested themselves in the manner predicted in 2010.
3.3 Surface Water Flood Risk
3.3.1 Flood and Water Management Act 2010 Section 27 requires flood and coastal erosion risk management authorities, including lead local flood authorities and district councils, to make a contribution towards achieving sustainable development when exercising their flood and coastal erosion risk management functions. Section 32 and Schedule 3 are among the provisions of interest to local authorities with regard to their decision-making role in sustainable drainage systems (SUDS).
3.3.2 The National Audit Office reports that giving greater responsibility and discretion to local authorities to identify flood risk and target investment raises significant challenges, especially during a time of budget cuts and other newly devolved responsibilities. Whilst the NAO considers that greater value for money can be achieved through these reforms, key elements of what is required are not yet in place.
3.3.3 Local knowledge of surface water flood risk is far less advanced than national information on risk of flooding from rivers and the sea. There is no evidence that BDC has the appropriately qualified staff with the required technical expertise and their local decision-making is hampered by the need to cross-refer between numerous different complex plans that affect local flood risk management. It is not yet clear how DEFRA and the Environment Agency will provide assurance nationally that arrangements are working let alone here locally.
3.3.4 Flood risk is, according to local water supply organisation Anglia Water, considered to be a potential problem at locations where additions to existing or new treatment facilities are being proposed as they are in this proposal. They go on to say that appropriate flood control measures will need to be incorporated into the detailed design of new facilities. In addition over the next 100 years, sea levels could rise by up to 1 metre, causing thousands more properties to flood including those that are contained within this proposal
3.3.5 We do not believe that the appropriate flood control measures have been put into place in this proposal, particularly for surface water flooding, best illustrated around the Sprowston Park and Ride site and other localized flooding areas in the proposed NEGT. The inability for excess surface water to drain away from prime agricultural sites within the NEGT is already a prime consideration for BAWAG; urbanisation of these will add hugely to the problems.
3.3.6 The present sewage situation is also under stress particularly during periods of heavy and sustained precipitation, and the outflow from the Whitlingham Wastewater Treatment Works into the River Yare at Trowse cannot cope, resulting in the potential for untreated sewage being pumped into the river. In order to attempt to overcome this, treated sewage water is pumped back in to the river below the water outlet causing distress to water users and wildlife as large and unplanned volumes of water are placed back in natural waterways.
3.3.7 A quick look at the whole water strategy including abstraction, flood, surface water drain off, rainwater harvesting and all other aspects of water management leave a lot to be desired with a great emphasis on future expensive innovation. We find it difficult to comprehend how in times of economic stress the necessary improvements will be funded. The description of Best Available Technology Not Entailing Excessive Costs used throughout the water industry is very apt here in Broadland as we attempt to build thousands of houses in one of the driest parts of the country.
3.4 Campaign to Protect Rural England (CPRE)
3.4.1 The local Norfolk branch of the Campaign to Protect Rural England (CPRE) has gone on record to voice their concerns about the over-development of Norwich and its surrounding catchments areas. They report the concerns of their members, a number of which are SNUB followers, about the creeping urbanisation of Norwich with the real risk that the conurbation will eventually equal the urban sprawl found in Nottingham and Bristol which BDC has advocated as being advantageous without spelling out how this would be a positive factor.
3.4.2 CPRE consider that this level of development will be unacceptable to the current environment bringing irreversible damage to a fragile ecosystem approaching the Norfolk Broads. What is disturbing is that BDC has advocated making Norwich as large as these cities as being advantageous without any reference to the negative impact this urban sprawl would have on the rural countryside that currently surrounds Norwich city. Both the Leader and the Chief Executive of BDC seem to be on a personal crusade to make this happen without compromise. The CPRE Policy Statement is here: http://www.cprenorfolk.org.uk/wp-content/uploads/2012/05/JCS-statement.pdf.
3.4.3 Details of the other organisations, such as SNUB and other campaign groups plus a large number of Parish Councils who are part of this Alliance, can be found at: http://www.cprenorfolk.org.uk/alliance-on-housing-2/. These organisations have all agreed with the following CPRE declaration:
“………… support(s) the aims of the CPRE Norfolk Alliance campaign to reduce the current housing targets set under the Joint Core Strategy. We urge the Greater Norwich Development Partnership to begin an immediate review of the housing targets, including opportunities for effective public participation, as provided for under the localism agenda.”
4.1 Natural Environment
4.1.1 BDC is currently undertaking a public consultation on the Landscape Character Assessment Supplementary Planning Document (SPD) as it relates to the Landscape Character Assessment Review. The Study covers the District, excluding the Broads Authority Executive Area, for which the Broads Authority is the local planning authority, and the more built up parts of the district close to Norwich because of their urban nature. Furthermore, it updates the previous Landscape Character Assessment (LCA) of 1999 accordance with the current guidance. Nevertheless the previous LCA will continue to provide informal guidance on Areas of Landscape under Local Plan Policy ENV 8.
4.1.2 It is intended that the SPD will be supplementary to Policy 1 Addressing Climate Change and Protecting Environmental Assets in the Joint Core Strategy Development Plan Document (DPD), which forms part of Broadland’s Local Development Framework. The SPD is expected to be adopted in 2012 following public consultation.
The Landscape Character Areas in Broadland are:
River Valley: Rivers Wensum and Bure
Woodland Heath Mosaic: Horsford
Plateau Farmland: Foulsham and Reepham, Freethorpe
Tributary Farmland: Cawston, Weston green, Coltishall, Blofield
Wooded Estatelands: Blickling and Oulton, Marsham and Hainford, Spixworth, Rackheath and Salhouse
Marshes Fringe: Wroxham to Ranworth, South Walsham to Reedham, Reedham to Thorpe
4.1.3 It is our view that the adoption of the SPD would bring considerable strain on these landscape characters, the majority being located in the NEGT, and in some cases they will be changed beyond all recognition and these changes will be irreversible, removing them forever. The current LCA is intuitively the very opposite to large scale development planned for in the JCS, as the LCA seems to be recommending more wooded areas and open spaces, which is difficult to reconcile with the 10,000 houses planted in the middle of the landscape as the JCS intends. Indeed the Woodland Trust has gone on record as saying that the East Anglia region is under-forested.
4.1.4 There is also scant regard paid to the natural environment as demonstrated by Mott MacDonald, who sent two naturalists to discover what wildlife existed in the ancient woods adjoining Beeston Park in the NEGT footprint in circa 2009. The owners of the wood were promised a full report of what the naturalists found but never heard anything until they received a letter from Mott MacDonald in April 2012 asking to carry out another survey.
4.1.5 The owners informed Mott MacDonald that they were not happy to cooperate any further because no effort had been made to furnish them with the initial report as promised some two years before. Once the report had been seen the owners would consider further requests for entry into the wood. After chasing this report the owners reminded Mott MacDonald that nobody was to enter the wood to carry out any research until they had provided the report. Prior to that a letter was received by the owners, confirming that the Great Crested Newt inhabits the natural pond in the woods.
4.1.6 In addition to the presence of these newts the “Big Norwich Bat Project’, a novel study which has been set up in the summer of 2012, has been established to try and improve the knowledge and understanding of bats across the city of Norwich and the surrounding countryside. Whilst surveys have been on going, by the end of August 2012 133 of the 196 1km2 squares had been surveyed, resulting in 32,249 bat passes being recorded. This included Common Pipistrelle (Pipistrellus pipistrellus) at 92% of sites and Soprano Pipistrelle (Pipistrelles pygmaeus) at 79% of sites. Several scarcer species were recorded throughout the survey, including Nathusius’ Pipistrelle (Pipistrellus nathusii) and Barbastelle (Barbastella barbastellus), Daubenton’s (Myotis daubentonii), Natterer’s (Myotis nattererii) and Brown Long-eared (Plecotus auritus). In total 9 of the 13 bat species recorded ever recorded in Norfolk, were found in the Norwich area this year with the strong possibility that their habitats will be found in the NEGT area.
4.1.6 This is an overview of the Government’s Natural Environment White Paper:
“A strong, vibrant natural environment is vital to the protection of the nation’s health, economy and security. Society benefits from the natural environment through ecosystem services, such as the production of food and drinking water, the extraction of minerals for commercial use and natural flood defences. However, as man-made demands on the environment grow, new, more advanced systems of utilising land must be found.
4.1.7 Alongside the Natural Environment White Paper, the Government also published its response to Professor Sir John Lawton’s Review – Making Space for Nature. This review sets out 24 recommendations to achieve a ‘coherent and resilient ecological network.' The Government has built on these findings in the White Paper, announcing plans to create an independent National Capital Committee that will measure the value of the natural environment and how it contributes to the wider economy.
4.1.8 We see no evidence of these important policy-defining documents being used in these proposals, as the rework of the remitted elements of the JCS seem to have ignored any new thinking, particularly around the environment.
4.2 Climate Change and Carbon Footprint
4.2.1 Much of the discussion on climate change is about reducing carbon dioxide emissions, but preparing for the effects of climate change is just as important. This is called adaptation.
4.2.2 The Intergovernmental Panel on Climate Change (IPCC) Special Report of November 2011, Managing the Risks of Extreme Events and Disasters to Advance Climate Change Adaptation, explains the impact that effective land use planning for adaptation can have in preparing economies and societies for the effects of climate change. The UK’s Adaptation Sub-Committee also identifies the importance of the land use planning system in adaptation.
4.2.3 Changes in rainfall, rising temperatures and erosion of the coastline all call for more adaptation measures to reduce the impact of humans on the climate system, particularly in relation to reducing greenhouse gas emissions. Recent key changes to environmental legislation have impacted on local Broadland policies on climate change. Planning plays a key role in helping to secure reductions in greenhouse gas emissions and providing resilience to the impacts of climate change and supporting the delivery of renewable and low-carbon energy and associated infrastructure. Nor do we believe that BDC has considered the likely impacts of climate change and, using the available evidence and the aforementioned key changes, positively and proactively planned for these impacts when considering their plans for growth in the NEGT.
4.2.4 The UK has a unique Climate Change Act (CCA) that should influence genuine low-carbon policy. The Act sets a legal requirement to achieve carbon reductions of 34% by 2020 and 80% by 2050.
4.2.5 In 2010, the Climate Change Committee (CCC) optimistically estimated that Integrated land use and transport planning could generate emissions reductions of up to 2 MtCO2 by 2020 “through designing new residential and commercial developments to minimise additional car miles.” Such emissions reductions are necessary to lay the foundations for deep cuts in transport emissions required through the 2020s.
4.2.6 Optimism turned to pessimism in June 2012 when the CCC stated concern as to whether such appropriate land-use planning decisions would actually be made locally. CCC proposes that the risk needs to be monitored. In reality, the difficulties in obtaining climate-friendly strategic planning decisions result from deep systemic issues. Much more is needed than “monitoring”.
4.2.7 Squeezing out carbon needs to be central in local strategic planning for any chance in meeting the CCA objectives of deep, national, emission reductions. Future proofing Local Development Framework’s (LDF), to truly comply with national policy and the CCA, requires so much more: real numerical and quantifiable reductions in total carbon emissions across the whole plan area by each sector. Current practice of “postponing” detailed consideration of emissions is untenable - if the carbon footprint is not evaluated at the LDF stage when considering the overall strategy, it will be impossible to fix it downstream.
4.2.8 Nor is it practical to use offsetting strategies between sectors when this year (2012) CCC advises that carbon reduction measures need to increase four-fold to meet CCA budgets. To suppose that some low-carbon home building can offset a carbon-intensive road scheme (as they have done in this strategy) is unreasonable.
4.2.9 Meeting the requirements of the CCA is essentially a numbers game, not currently understood by Inspectors who may see carbon emissions as just another air quality management issue. Carbon has to become a planning issue. SNUB believes that Planning Inspectors need to rigorously review every carbon assessment for its realism, measurability and monitor-ability throughout the planning period. The audit trail of supporting documents needs to be shaken up to make such quantitative appraisal possible. For example, it is an anachronism in the age of climate legislation that sustainability appraisals can be accepted without any meaningful evaluation of carbon emissions. This is making a mockery of the Act even before the end of its first 2008 - 2012 carbon budget period.
4.2.10 We believe that the whole JCS (particularly the development planned for the NEGT and the construction of the NDR) will see a positive increase in the
carbon footprint of the geographical area. The NDR will, if built, produce 25,000 tonnes of CO2 per year in addition to current levels – equivalent to 6% of Norwich’s current transport emissions. This reason alone is enough for us to say that the strategy is unsound.
4.2.11 Indeed a recent edition of the Lancet made clear the links between climate change and health. New studies published in the Lancet highlight climate change as a global health issue. They also point out that carbon reduction strategies can improve health in other ways besides mitigating against climate change. It refers to these additional, independent health benefits as ‘co-benefits’ for health arising from action on climate change.
The main points it makes are around the links between health and:
· Household energy emissions
· Urban land transport
· Food and agriculture
· Short-lived greenhouse pollutants
4.2.12 We believe that the increased in carbon emissions generated by this strategy will have a detrimental impact on residents’ health and well being and provide even more strains on the local health system.
4.2.13 To top it all the developers involved in the strategy have publically stated that they have to build garages to sell houses! So much for a sustainable development with potential residents using public transport and not having garages built. Remember this is a strategy that planned to implement a charge for on site parking to discourage car ownership!
4.3 Sustainable code for house construction
4.3.1 The original JCS proposal included the provision of 4,000 houses built to Sustainable Code 6 standard, which was part of the original Eco Town initiative proposed, by the previous Government. However it has become apparent that the challenges of building a large settlement to this level of sustainability are numerous. In addition the economic modelling does not work as building to this standard increases the costs by circa £36,000. As a consequence, the plans for the Eco town element of this proposal have been downgraded to what is now called a “low-carbon development” with houses built to no more than sustainable level code 4 standard. BDC has also developed what is called the “Rackheath sustainability level” for the construction of these houses without defining what this entails.
4.3.2 We are therefore of the opinion that this proposal is not sound as the sustainability level of the proposed houses will be no different to current national house building standards. Evidence has highlighted that the use of electrical appliances and normal day-to-day living will actually increase the carbon footprint of this area and any sustainability gains from construction will be lost in the process.
4.3.3 The current occupiers of the 12 code 6 houses built in Stracey Close at Rackheath are all complaining of high utility bills as they are not in receipt of the “feed in tariff” to offset the high cost of renewable energy from ground source pumps and solar panels on east-facing roofs which are proving to be ineffective. They are also experiencing operational difficulties with the rain-water harvesting systems as is the flagship and BDC sponsored Centre for Eco and Business Training at Rackheath Industrial site.
4.3.4 Wherry Housing Association is to build a further 14 houses in this small development but only to sustainability code level 4. A portion of the existing gardens of the code 6 houses will be used to build these additional homes.
4.3.5 The County Council promotes strategies to mitigate and adapt to climate change taking full account of flood risk, coastal change and water supply and demand considerations. Local planning authorities like Broadland should be planning for new development in locations and in ways that reduce greenhouse gas emissions. They should also actively support energy efficiency improvements to existing buildings in a way consistent with the Government’s zero carbon buildings policy, and should comply with policies on local requirements for decentralised energy supply and to minimise energy consumption.
4.3.6 Our contention is that, whilst new homes maybe zero carbon rated, this does not make them attractive for either renting (as energy bills are too high) or sale (as market price is inflated to cover the additional costs of £36k to build a zero carbon rated house).
5. DEMOCRACY (Duty to Cooperate)
5.1 It may appear that the Duty to Cooperate has been discharged, however we are of the opinion that this has been a “tick box” exercise and that the views of respondents have not been listened to or acted upon. We can see no real evidence that this submission has been noticeably altered and that public opinion has been ignored. The list of organisations consulted in the Duty To Cooperate document (August 2012 – PSJCS 8) does not include any local community groups like SNUB, and the absence of any of the usual utility companies and the LEP makes the cooperation incomplete. We feel that there has been a serious democratic deficit here in BDC for the reasons shown below from 5.2 through to 5.9.
5.2 Public meetings
5.2.1 There have been over the past three years a number of public meetings within the NEGT where local residents from across the area have been able to express their views and opinions on the scale of the proposed development. These meetings were well attended with the last one being in Sept 2012 and on each and every occasion the residents let it be known that they were not in favour of the proposals. There has, over the past five years, been no overwhelming opposing view that this level of development is welcomed even by the commercial organisations within the NEGT. Indeed a number of locally owned Small to Medium sized Enterprises (SME’s) have the contrary view that their business would be under threat from the potential entry of large multi national organisations.
5.2.2 The latest occasion (Sept 2012) was a drop in session at Rackheath held over two evenings where only 3.7% of the respondents stated that they wanted large-scale development in the NEGT area. Just fewer than 50% stated that they wanted no development at all and the remainder were split between wishing some small-scale development and medium size development. This reinforces the view that local residents recognise the need for new houses and are willing to accommodate some in their community however they are opposed to the urbanisation of Norwich with 10,000 houses proposed in the NEGT.
5.2.3 Indeed a survey conducted by BDC itself at the Rackheath 2011 summer fete resulted in 87.5% of local residents saying they were totally against the Exemplar and only 5% actually were in favour of it; the remaining 7.5% had expressed no opinion. If you calculate it on the basis of a plain yes or no and disregard those "sitting on the fence" then it works out to be 92.3% opposed and 7.7% supporting it.
5.3 Aarhus Convention
5.3.1 The United Nations Economic Commission for Europe (UNECE) Convention on Access to Information, Public Participation in Decision-Making and Access to Justice in Environmental Matters was adopted on 25 June 1998 in the Danish city of Aarhus (Aarhus) at the Fourth Ministerial Conference as part of the "Environment for Europe" process. It entered into force on 30 October 2001.
5.3.2 The Aarhus Convention establishes a number of rights of the public (individuals and their associations) with regard to the environment. The Parties to the Convention are required to make the necessary provisions so that public authorities (at national, regional or local level) will contribute to these rights to becoming effective[ii].
5.3.3 We believe that the residents of the NEGT and BDC have been denied their access to justice as provided for in this ruling and that the JCS is unlawful due to this failure of human rights enshrined in EU law.
5.4.1 A petition organised by SNUB collected 3,567 signatures against the proposed development. This petition was ignored by BDC denying the democratic wishes of thousands of local residents.
5.5 Community Involvement
5.5.1 There has been no attempt by BDC, either its Officers or Councillors, to hold talks with SNUB since the successful legal challenge to the JCS. This is despite the Judge recommending such endeavours and we feel that this failure to demonstrate cooperation with opposition groups means that the duty to cooperate has not been discharged.
5.5.2 The consultation documents contain a Statement for Compliance with the Statement of Community Involvement (PSJCS 7 dated August 2012). The document states:
“The councils consider that there have not been any significant changes that would reflect in an update to the Statement for Compliance with Statement of Community Involvement”
This rather arrogant view reinforces our feeling that indeed nothing has changed and that this consultation is merely window dressing to satisfy the direction of Mr Justice Ousley. This contemptuous behaviour is rife throughout this process.
5.5.3 In addition the public consultations, including this one, have been set during times of traditional holiday periods as follows:
· Issues and Options Consultations 19th Nov 2007 to 8th Feb 2008
· Regulation 25 Technical Consultation 4th Aug 2008 to 26th Sep 2008
This process has not benefited from feedback, as there has been no sample feedback on consultations and evaluations of public consultation events in order to help assess consultative methods. This goes against best practice and demonstrates the lack of community involvement.
5.5.4 We also acknowledge that there has been no attempt by the GNDP and BDC to use the services of Planning Aid as operated by the Royal Town Planning Institute in order to facilitate the necessary community involvement. Indeed the refusal by BDC to cover all the legal costs of SNUB following their successful legal challenge has done the community involvement a disservice as the very limited resources of SNUB have been diverted into fund raising to the detriment of community involvement.
5.6 CPRE alliance
5.6.1 The local CPRE group in Norwich has organised an Alliance of local campaign groups and Parish Councils to campaign for an overall reduction in the number of new houses planned for Norwich and the surrounding communities.
5.7 GNDP Closed Meetings
5.7.1 The Greater Norwich Development Partnership (GNDP) had until Dec 2011 held all of their meetings, since their beginning in 2006, behind closed doors thus denying access to members of the public and elected officials who were not part of the GNDP Board. This secrecy was a serious and unsustainable breach of local democracy and local campaigners had to force them to open up the meetings. As a consequence local opinion was not given the opportunity to be heard and we therefore believe that the soundness of this strategy has been compromised by the lack of public participation.
5.8 Broadland District Council Election
5.8.1 There was an election for Broadland District Council in May 2011 and one of the incumbent district councillors for the Wroxham ward campaigned as being in favour of the JCS and the plans for the NEGT. This Councillor lost his seat to a new councillor who campaigned against the JCS thereby demonstrating the wishes of the majority of voters in this ward.
5.9 Salhouse Parish Council Election
5.9.1 The Chair of SNUB and author of this submission was democratically elected onto Salhouse Parish Council in August 2012. He stood on a SNUB ticket and won by a 25% margin thus demonstrating the strength of support for this campaign among the voters of Salhouse.
6. PROCUREMENT AND COMMISSIONING
6.1 We are of the opinion that a number of EU Public Procurement Regulations have been breached during the commissioning of services paid for by the Programme of Development (POD) money provided to BDC for the original Rackheath Eco Town project. These rules are designed to demonstrate Best Value and Most Economical Advantageous tender (MEAT) through the open competition of all opportunities where public money is being spent. There is also a drive to use public money to support local small and medium size enterprises (SME). A number of these contracts have been provided to out of county organisations despite the availability of Norfolk based enterprises.
6.2 In particular we believe that the rules around State Aid have been breached as public money has been provided to Barratt Homes in the establishment of the Rackheath Community Trust. Barratt Homes have entered into a formal agreement with BDC and the owners of land earmarked for the construction of the 200-exemplar homes that are intended to showcase innovative building techniques for use across the proposed NEGT build. Our view is that this involvement gives Barratt Homes an unfair advantage against other potential developers thus breaking the rules around State Aid, particularly as there was no widely advertised open tender process in line with the Public Contracts Regulations. Selecting Barratt Homes negated the State Aid requirement for an open and transparent competition avoiding any potential market distortion.
6.3 Under the Public Services (Social Value) Act which passed into statute in February 2012, all public bodies in England and Wales are required to consider how the services they commission and procure might improve the economic, social and environmental well-being of the area. We see no evidence that the requirements of this legislation have been taken into consideration in these proposals or how the need to achieve triple line reporting (Social, Economic and Environment) will be met.
6.4 There is also a requirement to measure the Social Return on Investment (SROI) in all future public sector purchasing, as this new legislation calls for the concept of making social value more relevant and important in the placement and provision of public services. This is highly relevant to the changing landscape of public services in England, with a need for systems that support good local decisions, involvement of service users and other stakeholders.
6.5 We find that these considerations have not been taken into consideration in this proposal, which is therefore not sound.
7 HEALTH AND SOCIAL CARE
7.1 The NHS must deal with an increasingly complex set of issues that influence health and the continuity of services across the UK. Here are just two of these national issues that are just as relevant here in the NEGT and in particular the first one:
· Ageing and growing population – we all know our population is getting older. Current projections also indicate that our population is also going to grow from 61 million today to 77 million by 2050.
· New diseases of affluence and lifestyle – like diabetes, obesity and depression are on an unprecedented rise.
7.2 These issues are compounded by this proposal to build a new town in the NEGT for the following reasons as predicated on the impact of the Health and Social Care Act, visit: http://www.dh.gov.uk/health/2012/02/bill-factsheets/. The only reference to this in any planning document for health and social care is the following reference to the proposed eco community (now called low-carbon development) that only relates to a maximum of 4,000 houses:
“The Rackheath eco-community is a pioneering new development that will use renewable energy technologies to offer new housing, employment, day-to-day services and public transport, to achieve a low-carbon way of life. The eco-community is currently at the planning stage.”
7.3 The mere fact that the local health strategy is still referring to the Eco town demonstrates disconnection between that strategy and the present JCS housing strategy thus reinforcing our opinion that the two are not joined up. We believe that this is a result of the lack of meetings between NHS organisations and GNDP with only two being listed in the Duty to Cooperate document (NHS and Norfolk and Suffolk NHS FT being listed with no explanation as to who the NHS organisation actually was i.e. Primary Care Trust or Strategic Health Authority or one of the other providers?).
7.4 We also cannot find any reference to these development plans in the forming strategy of the proposed Health and Wellbeing Boards which are charged with bridging the divide between health and social (including housing) care.
7.5 Locally here in Norfolk we are soon, within the next three years according to the Health Secretary on a ministerial visit to the county in Oct 2012, to become the oldest county in the UK in terms of the number of elderly residents. This will bring additional stresses to an already stretched health and social care system.
7.6 When the projected changes in broad age groups are compared with Norfolk and with England looking at the shares of the total, older people would account for almost 32% of Broadland’s population by 2030. This is marginally above the Norfolk percentage (31%) but well above England (25%). We see no plans for housing to cope with this aging population, no sign of planners developing “over 50’s housing” nor of initiatives such as: dementia housing/management, affordable housing options, new business models for care/nursing homes, long term care and independent living. This lack of diversity planning is potentially discriminatory against an aging population and leaves the authorities open to a future charge of ageism as they ignore the needs of this critical element of future proofing and adaptation.
7.7 Primary Care
7.7.1 The Health and Social Care Act 2010 contains major changes to the delivery of primary health care with the formation of new Clinical Commissioning Groups (CCG). It is not known at this stage whether the geographical area within the NEGT will fall under the auspices of the existing North Norfolk CCG. If this were the case then the population serviced by this CCG would more than double through inorganic growth and they are likely to struggle to cope. It is envisaged that there would need to be the formation of a new CCG to serve the estimated population residing in the proposed new conurbation. There has been no mention of this in the local or regional NHS strategy and we believe that the lack of strategic planning to deliver primary care to a much larger and demanding population makes this strategy unsound.
7.8 Secondary Care
7.8.1 The local acute hospital for the NEGT area is the Norfolk and Norwich University NHS Foundation Trust (NNUHFT) hospital. The hospital is currently suffering stress as patient activity increases over and above planned activity and the current commissioners for this area (NHS Norfolk and Waveney Primary Care Trust) has asked the Centre for Effective Dispute Resolution to step in after it could not reach agreement with NNUHFT over two elements of the proposed contract for 2012/13.
7.8.2 At issue are how quickly the Trust can start to achieve an 18 week referral to treatment time for orthopaedic patients and how it should be penalised for missing this. There is also disagreement about what penalties the hospital should face when ambulance turnaround is delayed at the Accident and Emergency Department, ambulances being kept waiting longer than the planned 15 mins and patients having to wait longer than the targeted 4 hour wait for treatment. Details here: http://www.hsj.co.uk/hsj-local/pcts/great-yarmouth-and-waveney-pct/mediation-sought-in-norfolk-over-performance-and-penalties-dispute/5049939.article
7.8.3 There would need to be a major investment in the provision of acute services which is highly unlikely when the NHS has to find £20bn savings by 2015 and the forecast for central government funding after that period will result in a negative increase in comparison to today’s settlement. We believe that the stresses on the provision of secondary care for the current NHS hospital with no forward plans for a new hospital make this housing strategy unsound.
7.8.4 This view is confirmed by the latest survey of hospital chief executives where four out of five believe that their Trust will see a rise in activities as the predicted move of activity from the acute sector to the community has not materialised.
7.9 Community Care
7.9.1 One of the major thrusts in the Health and Social Care Act is to move secondary care into the community with clinical services provided by Norfolk Community Health and Care NHS Trust in tandem with the local CCG. Part of the rationale for this is to relieve pressure on the already stretched secondary care provided by the NNUNHS. This is likely to move the pressure to the primary care providers and they will need facilities from which to provide this care.
7.9.2 Whilst it is noted that the JCS makes provision for additional primary and community care centres it is not clear who would fund the construction of these new premises. It is clear however that the money from Community Investment Levy or the New Homes Bonus will not be used for this purpose and the NHS will be expected to fund this expansion.
7.9.3 The Trust is also experiencing real challenges in the provision of community care as reported in its August 2012 Board Report and has already exceeded its MRSA target for 2012/13 with one case in April, taking it to the limit for the whole financial year and reported a second in July. The Trust also had an increased number of falls in July (78 up from 56 in June) two of which resulted in moderate harm and one in serious harm. In addition the number of pressure ulcers increased.
7.9.4 We therefore believe that the lack of funding for the outdated strategy to construct new health and social care premises and the current performance at the existing Community Trust with no firm plans for new investment in this critical area makes this strategy unsound. This is particularly relevant as the local community services provider is vulnerable to merger and acquisition activity thus allowing commercial organisations to “cherry pick” the most lucrative services leaving the loss making rump to be serviced by the NHS.
7.10 Mental Health Services
7.10.1 Norfolk and Suffolk NHS Foundation Trust provides child and adult mental health services, alcohol treatment, learning disability and eating disorder services across Norfolk and Suffolk. With one of the diseases of affluence and modern lifestyle being depression, which is on an unprecedented rise, then there is real concern about how this already over stretched service can cope with the increased demand that a new town of this size would bring.
7.10.2 They have recently, Oct 2012, announced their Cost Improvement Plan (CIP) that shows that they will be transiting through a “radical redesign of services” from 2012 to 2016 with over 500 job losses and a reduction of in patient beds from 225 to 172. It is difficult to comprehend how this CIP strategy would be able to cope with the planned increases in their services were this proposal to go ahead.
7.11 Out of Hours GP Service
7.11.1 The current contract to provide Out of Hours GP service in Norfolk is with the
The East of England Ambulance Service NHS Trust who were awarded a new three-year contract to provide the service, beginning on 29th August 2012. There is no provision made in this contract for the provision of this service to any large-scale new development such as planned in this strategy. We would suggest that this lack of provision sets a dangerous precedent and our conclusion is that this strategy is unsound due to this lack of forward planning in the provision of such a critical and key service.
7.12 Ambulance Service
7.12.1 There is a current countywide campaign organised by the Eastern Daily Press (EDP- England’s biggest regional selling morning newspaper) to highlight the poor response times for ambulances provided by the East of England Ambulance Service. The campaign, called “EDP Ambulance Watch” was launched due to concerns about rural response times in Norfolk, back up ambulance delays, poor turnaround times for ambulances at hospitals and a controversial staff and vehicle rota redesign. Our contention is that these proposals will amplify an already tense and difficult situation with no real solution on the immediate horizon.
7.13 Dental and other clinical services
7.13.1 The following map http://www.norfolk.nhs.uk/node/994 highlights that there are, in the NR13 postcode area that covers the NEGT footprint, no available NHS dentists and all list are full. There are no forward plans or indeed NHS budgets available for the provision of new NHS dentists in the foreseeable future and any new and large influx of people will create genuine strain on existing resources.
7.13.2 There are similar capacity gaps in the provision of services such as physiotherapy, podiatry, dietician, speech and language therapy and other critical services. A community consultation, undertaken in 2007 by the Broadland Community Partnership, included questions about residents’ views of local health provision. Local residents identified the following:
· A lack of support for people returning home after being in hospital.
· Concern about access to a range of services including GP Surgeries, hospitals and specialist care including physiotherapy
Our contention is that these concerns would become worse with the planned increase in population.
7.13.3 There seems to be no acknowledgement of the “Nicholson Challenge” that the NHS faces which is to generate savings of £20bn by 2015 with the East of England region having to deliver £8bn as their overall contribution. Difficult to see how a population explosion planned for in this housing strategy will help achieve this.
8.1.1 The primary justification for the proposed level of houses is the need to provide housing and employment opportunities for local residents. The JCS requires 37,000 homes and 27,000 jobs to be delivered to 2026. This strategy was born out of the previous Government’s call for growth points, which Norwich City, in tandem with South Norfolk and Broadland District, responded to, achieving the necessary permissions to be a growth point. This previous Labour Government then sanctioned Regional Spatial Strategies (RSS) that called for hundreds of thousands of homes to be built including the 37,000 now being promoted by the JCS that has been adopted by the local authorities that make up the GNDP.
8.1.2 Nevertheless the total number of applicants on the housing registers of Broadland, Norwich and South Norfolk councils are approximately 14,000 but only around 30% are defined as inadequately housed - just over 4,000. Local housing registers have been discredited by South Norfolk’s KPMG study that found that 70% of the people on the list should not be on it! We have every reason to believe that the same conclusion would be made for Broadland’s housing register.
8.1.3 Indeed Broadland are so unsure of their own housing needs they have commenced a housing needs survey for Blofield, a few miles south of Salhouse, which they trumpet as; “ A comprehensive analysis of people’s housing needs is to be rolled out in Broadland – starting with the parish of Blofield”. Details at: http://www.broadland.gov.uk/PDF/Rural_Living_Broadland.pdf
8.1.5 League tables provided by Shelter (reproduced below) show that these councils, including Broadland, are in total currently providing a more than adequate supply of affordable houses. The reality is the JCS is not about local housing need. The GNDP has admitted it is a plan based on inward migration. The 37,000 extra houses planned for the Norwich Policy Area are mainly to facilitate a population expansion of 50,000 people. We have seen advertisements placed in and around London boroughs encouraging local residents to relocate to Norwich highlighting that it is a nice place to live.
Affordable housing delivered
Affordable housing needed (Experts' estimates)
Proportion of affordable need delivered %
Overall rank in England
Population density: The number of people per square kilometre in the area, Office for National Statistics, Regional trends, Regional data table 1.2.
Affordable housing delivered: Annual average (using last three years of data available) of additional affordable homes provided by local authority area where homes located, 2006/07 to 2008/09: CLG live table 1008
Affordable housing needed (Experts' estimates): As laid out in the latest available Strategic Housing Market Assessment (SHMA) or Housing Needs Study (HNS) for the area.
Proportion of affordable need delivered %: Calculated by expressing the number of affordable homes delivered as a percentage of annual requirements for affordable housing.
Overall rank in England: Ranking on the proportion of affordable housing need delivered.
8.1.6 However, the present Government has decided to scrap strict house-building targets as called for in the RSS in England as they “antagonised communities” and generated “thousands of objections”. The Department for Communities and Local Government (DCLG) has gone on record as saying that the regional strategies were prepared by “unelected bodies” and were “highly controversial”. “This resulted in long delays and meant that regional strategies did not provide certainty for communities or investors,” it added.
8.1.7 The Government said, “Rather than unaccountable and remote bodies, the Government believes that it is local authorities and communities that should decide the level and distribution of growth in their areas”. Indeed Local Government Secretary Eric Pickles said:
“The evidence is clear – top down targets simply haven’t worked.”
8.1.8 We would concur with all of these sentiments and fail to see why the JCS is still promoting these discredited regional top down targets set by the previous administration.
8.1.9 We believe that the real justification for building this number of houses is not housing need but the need to use revenue from New Homes Bonus, additional Council Tax and Business rates plus the Community Investment Levy to replenish the finances of BDC. We have this believe based on the fact that they are artificially suppressing local Council Tax in the hope that they will be able to use these new revenues to replenish their financial reserves.
8.1.10 We also believe that this strategy is reinforced by comments of the leader of Norfolk County Council (NCC) in the EDP (Weds 24th Oct 2012) when he attempts to justify the purchase of the old RAF Coltishall site by stating that it is his job to turn a previous revenue spending council into a revenue generating council. It appears that BDC is mirroring that approach and this strategy is as much a revenue generating strategy as anything else.
8.1.11 This view is further reinforced when considering the misleading and varying total of affordable houses. The regional strategy first mooted 30% that the GNDP generously inflated to 40%. The Planning Inspector then dropped back to 30%. However two independent studies indicated that 18% would be viable. The reality is that these plans would probably result in something around 15% thus belittling the much-vaulted need for houses for the young generation who were sofa surfing. The housing need was not evaluated properly at the original Examination in Public of the JCS and in truth all three local authorities should have been made to answer this criticism after the High Court hearing.
8.1.12 We also believe that the communications and consultation from BDC and the GNDP have not adequately explained affordable housing and spelt out that it means three different types of housing as follows:
§ Social rented (usually through a Housing Association).
§ Shared ownership where the house is purchase by a Social Landlord and then part of that is sold with the other part being rented from the landlord.
§ Discounted market value where the house is sold at anything from 80% to 90% of value with the balance retained by the developer.
8.1.13 BDC have stated, when pressed by SNUB, that they wish to see 40% of the proposed houses provided as affordable broken down as follows:
§ Social Rented 24%
§ Shared Ownership 12%
§ Discounted Market 4%
The reality however is that the quantity of affordable housing will likely to be no more than 20% due to the economics (see Economics section later in this paper) and could be as low as 15%.
8.1.14 The social rented houses are then provided in the following types of houses:
§ 1 bed 15%
§ 2 bed 31%
§ 3 bed 35%
§ 4 bed 19%
The net delivery of social rented properties i.e. those built to meet real housing need for those who will not be able to afford shared ownership or to purchase a discounted house, for the planned 10,000 proposed houses will be as follows:
§ 1 bed 360
§ 2 bed 744
§ 3 bed 840
§ 4 bed 456
8.1.15 We believe that this paucity of real social housing to rent to vulnerable residents reinforces the view that the main drive to build these houses is as an income generator for BDC and to generate substantial profits for the proposed developer. The proposals before Parliament at the moment, to allow prospective developers to negotiate a further reduction of affordable housing, should this be a barrier to commencing large-scale developments is a worrying trend that is deployed in the NEGT would see a further erosion of the supply of affordable housing. Any altruistic ideals are not found and therefore this proposal is unsound.
8.2.1 The other major justification is the 27,000 new employment opportunities that are planned to be delivered in the NEGT footprint thus making it easier, using public transport or zero carbon travel, for residents to travel to work.
8.2.2 The largest industrial sectors in Broadland are health (employing 14.4% of the workforce before the announced staff cuts); manufacturing (employing 13.2% of the workforce), including a cluster of businesses within the Rackheath and Hellesdon Park Industrial Estates; business and professional services (employing 10.7% of the workforce); construction (employing 10.7% of the workforce); and retail (employing 10.6% of the workforce). A significant proportion of employees (7%) are in the tourism sector. Broadland accounts for around one-sixth of Norfolk’s employees within the food-processing sector, mainly accounted for by Bernard Matthews in Gt. Witchingham. Employment in the agriculture sector has remained reasonably steady in Broadland over recent years, employing three per cent of the district’s workforce, which is higher than the regional and national average.
8.2.3 The major employment opportunities, as actually defined in the JCS, are in the South West and South of the city based on the success of the Norwich Research Park, John Innes Centre, Hethel Engineering centre, University of East Anglia (UEA) and the Norwich and Norfolk University Foundation Trust hospital. Indeed during the period of rework of this remitted element of the JCS there have been several announcements about major investments in these areas including £26m secured by the Norwich Research Park and the generation of thousands of new jobs. There have been NO such announcements for any employment opportunities in the NEGT.
8.2.4 It therefore makes sense economically for any funds to be allocated to the dualling of the A11 and bypassing the market town of Long Stratton on the A140 link south of Norwich to the A12 and A14 with the latter linking to the New Anglia Enterprise Zone. This Zone will cover 121 hectares in Great Yarmouth and Lowestoft, including land around the two ports and key industrial estates in both towns. In addition, being included as one of five new Centres of Offshore Renewable Engineering that the Government has created, as well as recently submitting a bid to be part of the Rural Growth Network, has boosted the Zone further.
8.2.5 It has been reported that, after Aberdeen, the East of England is the second largest centre for the UK energy industry and there is enormous investment potential in the field of energy that could realistically bring 10-15,000 new skilled jobs to the region. Indeed the new Zone aims to create up to 2,000 jobs and 80 businesses by 2015 and 13,500 jobs and 200 businesses over the 25-year lifetime of the zone. It is envisaged that a large majority of these will be in the aforementioned energy industry and houses will be needed in the Zone area to accommodate these employees.
8.2.6 The other dimensions are that the development of the NEGT and the linked NDR may well distract investors from investing in the Great Yarmouth area, and that the planned jobs in support of the burgeoning off shore industries may not be realised. These concerns were expressed by the Great Yarmouth representative at the Duty to Cooperate meeting held by the GNDP in May 2012 when the following minute was recorded:
“Great Yarmouth Borough Council expressed concerns that if the NDR were to go ahead the Broadland Business Park may capture growth that would have gone to Great Yarmouth.”
The minute goes on to record that there will be a need to investigate the impact of this through the countywide Economic Strategy. We can find no reference to this strategy in the documents that we are asked to consult on. In addition the very public spat between BDC and New Anglia LEP does not bode well for the future.
8.2.7 West Norfolk will also benefit from a similar Local Enterprise Partnership (LEP) in Greater Cambridgeshire and Greater Peterborough. Indeed we also see the planned improvements of the A47, as an integral part of the European TEN-T network, providing the main east-west road connection and route to the Midlands and North of England. We would support funding of improvements to the A47 Acle Straight in the East and further improvements towards Kings Lynn and on to Peterborough in the West linking both LEP areas.
8.2.8 It would therefore stand to reason and pass any sense of logic that any future large-scale housing would need to be in these areas and not on prime agricultural land.
8.3.1 The 2008-based population projections from the Office for National Statistics (ONS) indicate an increase in Broadland’s population from 124,400 in mid-2010 to 149,000 in mid-2030, a rise of around 24,600 or just fewer than 20%. Over this twenty year period older people (men aged 65+ and women aged 60+) would increase significantly in number, by around 15,300. Children and the working age population would increase less significantly.
8.3.2 A recent population survey suggests that the population change since 2001 for the three areas covered by the GNDP is as follows:
· South Norfolk - 12%
· Norwich - 8%
· Broadland - 5%
8.3.3 This survey demonstrates that the recent historic population increase for this area is lower than the forecasts that the JCS is predicated on and as a consequence these plans are deemed not to be sound. Increase in Norfolk is lower than some other areas in UK e.g. 17% increase in Peterborough.
8.3.4 We can also report that National Insurance Number (NINo) registrations to overseas nationals entering the UK in the 2009/2010 financial year indicate fewer than 200 coming to Broadland, the main nationalities being Polish and Filipino, but with around 12 different nationalities in all. For an alternative view of migration, Broadland has received very few foreign nationals under the Worker Registration Scheme for EU Accession 8 countries. The only significant nationality represented in the 2009/10 financial year was Polish. They are typically younger adults aged 25-34. As with the NINo registrations, these figures exclude dependants. Broadland may also have a small number of foreign nationals who are here as students.
8.3.5 There is therefore no natural predilection for overseas nationals to come and live and work in Broadland even when taking into account foreign students or seasonal agricultural workers. We believe that the only viable alternative to ensure an adequate population to occupy these planned new houses is to encourage mass inward migration into Norwich and the surrounding area.
8.3.6 Our view is that this approach is foolhardy and represents a huge gamble particularly if house prices are high and affordable houses are not viable due to high running costs.
9. FOOD CHAIN and AGRICULTURE
9.2 The proposal to build 200 exemplar homes to show case low carbon development is to build these on current Grade 2 agricultural land on land skirting the settlement limit of the existing Rackheath settlement. The proposals for the remainder of the area purport to use the brown field site that was once, for 14 years only, an old RAF airfield at Rackheath that borders up to and encroaches onto the settlement limit for Salhouse. Our view is that the definition of this land as brown field is tenuous to say the least.[iii]
9.3 Indeed the potato crops grown on this site are used to produce the renowned Kettle Chips, which proudly proclaims to be “made in Norfolk” and reduces their food miles considerably. There are also new grain silos under construction on the adjoining industrial site providing employment in the area for existing residents. It is also ironic that Norfolk County Council are seeking to provide new smallholdings for tenanted farmers and are proposing to dig up the old runway at the former RAF Coltishall site to return it to agriculture whilst concreting over perfectly suitable food producing land for this proposed development.
9.4 We are therefore of the view that this land has been producing food for hundreds of years except for a very small period of 14 years, of which only three were active, during the national emergency that was WWII. We challenge the definition of brown field and surmise that this strategy is not sound due to the need to secure the UK food chain production within these islands and cut our over reliance on food imports.
9.5 There is also no mention of the need to use agricultural land to grow biofuel crops for such biogas plants like the one at Taverham. This will be supplied by specially grown “energy maize” to power the generators which will provide the output to the national grid as renewable energy. We learn that contracts have been signed with local farmers to grow these crops over 1,000 acres! If we continue to land grab for additional housing and energy crop production where does the locally sourced food get grown?
9.6 If you then add in the predicted coastal erosion over the next 50 years that also takes outs acres of food producing land where does it leave us? Do we eventually have to import 100% of our food from countries that are busily protecting their food producing land in order to supply their home markets and not the export market?
9.7 Recently a regional MP, Dr Therese Coffey MP for Suffolk Coast, highlighted these concerns when she stated in a parliamentary debate in Oct 2012, that she was increasingly worried about the amount of good grade farmland starting to be used for other purposes. In addition she went on to say that the loss of land for agricultural use would lead to less produce being grown, forcing up prices and impacting on food security.
9.8 A senior agricultural advisor to the government, Professor Tim Benton, expanded on this view when he spoke at a recent public lecture hosted by the East of England Co-operative Society (Oct 2012) when he put forward the view that current farm land had to be farmed hard in order to protect areas like the Norfolk Broads.
9.9 We would concur and agree that agricultural land should remain and be farmed to ensure that this part of the country remains the breadbasket of the UK. This sentiment is supported by the following statement from Francis Ulrych, Norfolk county chairman of the National Farmers Union who stated
“The single biggest issue facing the farming community is meeting the challenge of producing more food while impacting less on the environment.”
10.1 Norwich Northern Distributor Road (NDR)
10.1.1 There is no doubt that this proposed large scale development depends on the construction of the proposed Norwich Northern Distributor Road (NDR) which has its roots in 1940s planning and dubbed locally and the Campaign for Better Transport as “The Road to Nowhere”. The strategy states that the housing development is not reliant on the NDR but admits that development would have to be reviewed if the NDR were not to go ahead.
10.1.2 Indeed we were told at one of the many SNUB public meetings in 2009 by the then leader of Broadland District Council that if the NDR was not built then there would be no large scale development of houses in the NEGT. This proved to us and the hundreds of local residents present at the meeting that the real reason for the NDR was to provide infrastructure for the 10,000+ houses to be built in the growth triangle and nothing to do with easing congestion.
10.1.3 At the very same meeting a highways official from Norfolk County Council admitted in answering a question from the floor that they had no “magic bullet” solution to the traffic congestion at the narrow road bridge on the A1151 Wroxham Road over the River Bure which would, if the NDR was to be built, see an increase in traffic exiting the NDR to make its way to the Norfolk Broads.
10.1.4 The GNDP as agents for Norfolk County Council (NCC) may well point to the fact that the consultation in 2003 showed residents in favour of the NDR, NCC’s proposals have changed significantly since then as the 2003 NDR was a full length route from the A47 West of Norwich to the A47 East of Norwich, and did not involve the major ‘Postwick Hub’ gyratory at Postwick. The NDR proposed in the 2003 Norwich Area Traffic Study (NATS) consultation was a full Norwich northern by-pass from the A47 East anti-clockwise to the A47 West – this would have linked the proposed road to the A47 Southern by-pass in a full ring road. The ring road to the West was seen by many consultees to the far West of the City in villages, like Costessey and Hellesdon, as providing relief to their villages and local lanes. It therefore received considerable support on this basis.
10.1.5 The current proposals however are for a half-length route that is linked to much greater growth as defined in the JCS, and including the major ‘Postwick Hub’ gyratory, a route that has never been subjected to any consultation. If this proposed shorter NDR were to proceed, the aforementioned villages would see considerable “rat running” as traffic would be forced onto minor roads at the end of the proposed NDR in order to connect to the western side of Norwich to join the A47 en route to the Midlands and the North. These residents have not had the opportunity to be consulted on this scenario and we suspect that one of the reasons why NCC and others have not consulted is that the probable result would be a resounding NO to this proposal. Any plans for the rest of the NDR to be funded locally, as being promoted by the unelected GNDP in their closed to the public meetings, by local councils, commercial borrowing and the use of the Community Infrastructure Levy are short sighted and not practicable in this time of economic prudence.
10.1.6 In fact, the only public opinion on this shorter version of the NDR was during a public poll held by the Eastern Daily Press (the country’s biggest selling regional morning newspaper) in 2012 and the overwhelming result was a resounding NO vote by members of the public against the NDR.
10.1.7 Despite slashing bus support (see paragraph 10.4.3), Norfolk County Council has found £1.7 million to spend next year to push through road building around the north-east of the city; a road which has no guarantee of central Government funding and may never get built.
10.2 A47 Trunk Road (Postwick Interchange Slip Roads) Order
10.2.1 The proposed public inquiry into the above Order has been indefinitely delayed due to the absence of the necessary traffic assessment from Norfolk County Council. This Order was in our opinion fatally flawed from the outset, as it should not have been an Interchange Slips Road Order. It is the start of the NDR and should therefore been under the jurisdiction of the Highways Agency as part of the UK trunk road transport system.
10.2.2 We are also aware that there are a number of alternative proposals already put forward for link roads and this planned development of the Postwick Interchange is inextricably linked to the plans for the development of the Joint Core Strategy (JCS) and in particular the plans for the North East Growth Triangle (NEGT). Alternative plans for the additional development of the Broadland Business Park have been submitted by Lothbury Investments, which negate the need for major re-development of the Postwick Hub as required by this proposed Order.
10.2.3 The alternative proposals for Postwick junction can also link to a developer funded single carriageway inner orbital road link between A47 Postwick Interchange and A1151 Wroxham. This is shown on the map on the right: all elements of the route are already in the Broadland plan except for short and easily closed gap between Salhouse Road and Plumstead Road East, alongside Racecourse Plantation.
10.2.4 The proposal to reduce the overall number of houses and then see them dispersed is a viable alternative to the 10,000 houses in the NEGT adjacent to the NDR. If this alternative was to be favoured then the planned NDR would not be needed and therefore there would be no need to develop the Postwick Interchange and huge amounts of public money could be saved.
10.3.1 There has been much speculation about the use of the existing Bittern Line railway throughout these proposals and the construction a new railway station at Rackheath and a small goods yard to support the rail delivery of bio fuels into the centre of the NEGT develoment. There is however little mention of this in the new regional rail strategy with a passing comment about the possibility of a new railway halt at Rackheath.
10.3.2 There has however been an increasing number of ticketing problems on the Bittern Line causing delays, anxieties and possible extra costs for passengers and are losing National Express “large amounts of revenue” according to Norfolk County Councillor Paul Morse (EDP News Sept 2011).
10.3.3 There have been a growing number of occasions when the on board conductor fails to get round all the passengers needing to buy tickets before the train arrives in Norwich. This is the same line that is meant to take all of the extra passengers from the proposed Eco town from Salhouse station into Norwich which will give the conducter a whole 10 mins to get around all of the passengers from Salhouse and from the proposed new station at Rackheath!
Extra carriages would be ideal but then again they wouldn’t fit on the platforms at some of the stations on the Bittern Line.
10.3.4 There has been no evaluation of the impact of opening up the existing rail link between Dereham and Norwich which has recently seen a regular passenger train traverse between these two stations. Whilst the line is currently operated by a railway preservation group (The Mid Norfolk Railway) the possibility of any future train operating company running regular commuter trains between Dereham and Norwich has not been evaluated. Our contention is that this presents a greater opportunity for the distribution of houses to the south and south west of the city.
10.4 Bus System
10.4.1 The so-called rapid bus system to transport residents from the proposed new development is merely a traditional “bus lane” that would stop at the top of Mousehold Heath forcing a bottleneck at Gurney Road. This would cut off one of the main access routes for residents in the NEGT to the city and cause large tailbacks along Heartsease Lane.
10.4.2 It is not similar to the Cambridgeshire Guided Busway or similar to other forms of rapid public transport using trams or similar vehicles.
10.4.3 We also find it incongruous that there is a reliance on the use of public transport buses when Norfolk County Council has reduced its budget for buses from £41m in 2010/11 to £25m in 2011/12, and 31 buses have already been reduced or withdrawn. As one local resident says:
"I live in a rural area and there are no buses after 6pm. If you need to go out in the evening you have to take a car. I would love to see bus services run more often, especially in these small villages."
Almost 200 bus routes were reviewed and, following discussions with public transport providers the number of bus services that received subsidies in 2010/11 was 178 or 30% of the network. The council has been driving forward a campaign because of an £4.5m shortfall in funding for the concessionary pass scheme - which allows pass holders to travel free on buses. The lack of adequate funds from the Government is putting huge pressure on maintaining rural bus services at a time when there is a big push to persuade local residents to give up using their cars and these plans are littered with examples and calculations that are predicated on this wholesale move to public transport that we contend is highly unlikely due to the lack of rural buses and the inability of people to change behaviours.
11.1 The Norwich Society call the JCS the most important planning decision to be taken in the county for decades, whilst Civic Voice is an enthusiastic supporter of the new “right to plan” provided for communities by the Localism Act 2011. We share these views believing this presents an important new opportunity for neighbourhoods to take the lead in shaping the future of the county for decades to come. It is imperative that all stakeholders get it right.
11.2 We start from an assumption that the regulations governing neighbourhood planning should be as enabling and encouraging as possible. We welcome the guiding principle that they should place a minimum of requirements on communities and take a de minimis approach. In a number of areas, however, we believe the regulations need to go further to minimise the risk of delay and even obstruction by local authorities like BDC. Neighbourhood planning requires a significant shift in the culture and attitude of many local authorities as it is based on a participatory and not representative approach to democratic involvement.
11.3 We are not confident that BDC will be able to accommodate the behavioural change that is needed in the final regulations that should help establish neighbourhood planning as a right to be enjoyed by all communities regardless of the attitude of their local council.
11.4 Community Planning
11.4.1 In June 2011 SNUB, along with Parish Councillors from 14 other Parish Councils, attended a training session hosted by BDC to explain Community Planning[iv]. As part of the process the attendees had to look at photographs of Broadland and say which pictures most sum up Broadland and why? These were some of the answers:
· Lots of open spaces and footpaths.
· Open countryside.
· Quiet and peaceful surroundings.
· Rural tranquillity.
· Quiet roads.
· Lovely countryside.
11.4.2 Our contention therefore is that BDC have ignored the elected representatives of a large number of Parish Councils as demonstrated at this event, which was called to ensure the communities’ views were taken into consideration in future planning strategies.
11.5 Current Approved Planning Applications
11.5.1 There is also evidence that there is within the GDNP area a large number, thought to be in the region of 10,000 across Norfolk, of applications for house building that have been approved but not yet started. We would like to see these applications included in the overall analysis of the mix of housing needs for the future with details provided.
11.6 Norfolk Hub Entertainment Complex
11.6.1 We believe that BDC are still in discussions with Wintersgill LLP, a London based architect, about a proposal to develop the Norfolk Hub, a vast development on the edge of Salhouse. The proposals include the following:
· 11 hotels, ranging from two to five stars, with a total of 8,000 rooms
· Convention Centre providing three large halls of 12,000 sq feet and 6,000 square feet and 50 meeting rooms
· New Dual Carriageway link to national road network
· Outdoors stage for large-scale open air events such as Glastonbury
· Indoor sports centre
· New ultra light rail connection to the city and airport
· Small monorail running on a loop track inside the site
· Lorry parks for event organisers
· Shopping Mall and floating restaurants
· New lake and canals
· Two 18-hole golf courses
· All weather tropical water park under a glass enclosure
11.6.2 Despite verbal confirmation from BDC that these plans would never materialise we are aware of an email from Wintersgill in October 2009 stating:
"Norfolk Hub is still a possibility but the timescale for commencement is not yet known. The next stage in the development of the project is the commissioning and completion of an Outline Feasibility Study, which we are currently discussing the funding. This study will help to narrow the various options for the project with regard to the site location and the size and content of the development".
11.6.3 This was confirmed by a second email in November 2009 stating, "The Norfolk Hub project is still under active consideration. "It is our contention that this development is designed to provide the major employment opportunities in the NEGT in order to justify the 10,000 houses in this proposal, and that the absence of any other firm employment opportunity is due to this development waiting in the wings to be renewed at the appropriate time. Duplicity at its worst!
11.7 Wroxham Planning
11.7.1 Wroxham and Hoveton St. John are two connected villages, split by the River Bure. Most of the village facilities are actually in Hoveton, but are generally known as Wroxham - the capital of the Norfolk Broads. This community is located to the east of Rackheath and Salhouse and the Parish of Wroxham adjoins Salhouse whilst the parish of Hoveton St John is in the North Norfolk District Council adminstration area.
11.7.2 There were plans to construct 200 new homes in the Parish of Wroxham adjacent to the Norwich Road (Trunk Road A1151). The Parish Council objected to these plans on the basis that the additional traffic generated by this development would be detrimental to air quality and increase the risk of traffic accidents along the A1151. In order to prove this point North Norfolk District Council installed an air quality measurement device on the A1151 in Hoveton just over the single carriageway historic road bridge over the River Bure. As a consequence of the results of this measurement the plans were reduced to potentially provide 100 new homes.
11.7.3 Our contention is that the additional traffic generated by thousands of new homes in close proximity to the capital of the Norfolk Broads would result in major traffic congestion, an increase in CO2 carbon emissions and poor air quality plus an increase in the risk of road traffic accidents as residents decide to use the A1151 to travel to the Norfolk Broads or the North Norfolk coast.
11.7.4 We therefore believe that theses plans are not sound as all traffic surveys associated with these plans have not taken the movement of vehicles along the A1151 into consideration.
11.8 Salhouse Conservation Area
11.8.1 Part of the Salhouse village is currently a Conservation Area and there is a current proposal to extend this to other parts of the village as defined in http://www.salhousevillage.org.uk/PP%20Final%20Report%20Conservation%20Appraisal.pdf.
11.8.2 The decision on whether this extension is approved is still outstanding and it is our view that if this approval were to be accepted then the proposals to construct thousands of houses adjoining this potential Conservation Area would jeopardise the very area that is to be conserved and be contradictory to the principle that a conservation area should have strict control of new development.
11.9 National Planning Policy Framework
11.9.1 The National Planning Policy Framework (NPPF) has now replaced the previous planning guidance documents. Section 10 is the most relevant to Norfolk, entitled Meeting the Challenge of Climate Change, Flooding and Coastal Change.
11.9.2 Sustainable development contributes to protecting and enhancing the natural environment, helping to improve biodiversity, use natural resources prudently, minimise waste and pollution and mitigate and adapt to climate change including moving to a low carbon economy. Planning plays a key role in helping to secure reductions in greenhouse gas emissions and providing resilience to the impacts of climate change and supporting the delivery of renewable and low carbon energy and associated infrastructure. We do not believe that these revised plans help to secure the necessary reduction in greenhouse gases, as there are no calculations to show how this will happen.
11.9.3 The Planning Advisory Service (PAS) has this to say on its Blog about the new National Planning Policy Framework (NPPF):
This is still a plan-led system, and plans should be evidence-led. That evidence starts with the vision and objectives you are trying to achieve. You understand where these have come from because your communities have told you. There is empirical evidence that tells those communities that there are some issues that will have to be tackled head-on by the plan. There is then a conversation between you and your communities, including key people who hold other information that you need, and who own sites you are going to have to look at.
You develop policies that will help deliver the aspirations, the needs and demands of the place. You refine them through conversations with the community and you produce a plan, which will deliver the change needed to meet the vision for the place.
Today, this is called a ‘Core Strategy’. Some time next year, it will be called a ‘Local Plan’. Call it ‘Brian’. Call it whatever you like. Just make sure it has been prepared with the involvement of the community, using evidence they understand, and containing policies you are certain will turn the place you are planning into the place that everyone wants to see.
We see no evidence of this involvement to the standard expected by the NPPF.
11.10 Empty Homes
11.10.1 The Empty Homes Agency (EHA) submitted a Freedom of Information request that has revealed that around 12,000 empty homes are hidden from official national figures because they are earmarked for demolition. We contend that a proportion of these empty homes are in the NEGT area and that these have not been taken into consideration in the determination of housing need. We would also like to include in these hidden figures the number of multi bedroomed social housing units that are occupied by single occupants that could be released with a managed house swop to allow downsizing and upsizing to occurr.
11.11 Beyond Green Application
11.11.1Developers Beyond Green have submitted a planning application for the development of land North of Sprowston and Old Catton[v] which is within the NEGT and presupposes that either Option 1 or Option 2 in these proposals go ahead once again showing a staggering disregard for public opinion.
12.1 We do not believe that these proposals are sound, as the reasonable alternatives have not been explored using new thinking and up to date forecasts particularly around the future economy of UK plc. We have, in putting forward these alternatives, taken a compromise position that whilst SNUB have always advocated the dispersal option we concede that there maybe a small number of single growth points that MAYBE viable. Our point here is that these, along with the dispersal option, have not been fully explored.
In particular the following are, in the local communities’ opinion, viable bottom up alternatives (rather than top down dictates) that require further exploration:
12.2 The Norwich Society
12.2.1 The view of the Norwich Society which has not been considered is the possibility of a more dense “satellite” conurbation, a Single Growth Point for 15,000 to 16,000 homes, somewhere on the preferred axis for both rail and road transport between the Ipswich and Cambridge railway lines and the A11 and the A140. This would place a new community somewhere in the triangle between the A11 and the A140, bounded to the South by the A1066 Diss to Thetford road.
12.2.2 Uncertainties over the final construction of the Norwich Northern Distributor Road (NDR) and the lack of any timetable for improvements to the A47 on the East and West make this area to the South and West of the City the only possible location for a new settlement of this size.
12.2.3 It would also offer excellent transport and accessibility to the southern arc of Norwich, with its concentration of important facilities and employers ranging from Norwich Union and Marsh, through Chapelfield Shopping Centre, Norwich City College and UEA to the Norwich Research Park (with over 10,000 jobs), County Hall and the Norfolk and Norwich University Hospital. It would also complement the dualling of the A11, due for completion by winter 2014, and add credibility to the economic revitalisation of the area.
12.2.4 The Norwich-Cambridge economic axis would be strengthened, linking Norwich City’s embryo hi-tech firms and thriving financial sector with the other university city’s booming science-based research parks. In support of this the Norwich-Cambridge railway line is already a thriving commuter route, travelling via the cluster of small but vibrant motor research companies that exist around Hethel and Snetterton.
12.3 Relocation of Norwich International Airport (NIA)
12.3.1 Revisit the alternative of moving Norwich International Airport (NIA) from St Faiths to the previous RAF Coltishall site thus releasing land adjacent to the city for housing development. This was looked at seriously in 2009/2010 but Omniport (the owners of NIA) requested that the potential developers should enter into a non-disclosure agreement (i.e. keep it all secret) and then promptly mothballed the idea, as did Norfolk County Council and North Norfolk District Council. Subsequent Freedom of Information requests have been refused.
12.3.2 We are aware that Marshall Aerospace of Cambridge had a viable business proposition to use the old RAF Coltishall site to expand their aircraft maintenance business due to the length of the runway, with the use of existing facilities. This would have brought much needed employment into the area.
12.3.3 The Ministry of Justice, the owners of the site, in Jan 2011 confirmed TAG Aviation (Stansted) Ltd. as the preferred bidder for the ex RAF Coltishall site. We now hear (after Tag Aviation pulled out) that Norfolk County Council (NCC) are planning to buy the Coltishall site using public money to provide aggregate, from breaking up the runway and old buildings, for the construction of the proposed Northern Distributor Road (NDR).
12.3.4 Indeed there is a current commercial proposal on the table from the Hans House Group of Companies that is fully funded by private equity money, without recourse to third party debt or public subsidy. Artemis/Hans House has publically announced its bid, which has the following elements:
· £4.1m cash to pay for all costs associated with the separation and reconnection of all main services to HMP Bure, estimated at £1.5m.
· A substantial budget to fit out and refurbish all key buildings to tenant’s specific requirements.
· The gift of free accommodation to the Spirit of Coltishall Association, sufficient for it to create a Heritage Centre.
· The provision of “green” electricity sufficient for 100% requirement of HMP Bure for the next 20 years at the same price or less than the MoJ is currently paying.
12.3.5 The present site of NIA is suffering from growth restrictions and the current threat that a major employer (KLM UK Engineering) located at NIA may well close down if revised plans for a new engine testing bed located (on the eastern side of the airport in Horsham-St-Faith) is not approved. KLM UK Engineering employs 341 full-time jobs at the company plus 100 contract jobs and those in the supply chain.
12.3.6 We believe that the development of the NIA site would provide all of the benefits of a low carbon development and provide much need carbon footprint reductions. We also believe that the relocation of NIA to Coltishall would deliver thousands of job opportunties with ready made commercial solutions ready to use this facilty.
12.4 Drayton Road
12.4.1 Develop the land along the Drayton Road utilising the Royal Norfolk Golf Club land and the Hellesdon hospital land on a ribbon development along this main road into the city. This would enable the golf club to relocate to their preferred site at Weston Park and for the Norfolk and Suffolk NHS FT to commission a new build facility. This would make an ideal low carbon site.
12.4.2 This new build could attract international funding and allow a state of the art facility providing new employment opportunities during its construction and safeguard future employment of NHS staff whilst reducing the current costs of running an unsuitable carbon intensive site. It is possible that the aforementioned planned reductions in beds and staff may be reduced if the Trust were able to take advantage of this potential new investment.
12.5 Acle Hub
12.5.1 The Norfolk Association of Architects (NAA) have developed a discussion document that puts forward an alternative development site using Acle as a hub linking the LEP footprint area through Acle and the Yare valley into Norwich. This issue of the single growth location as an alternative to sprawl was submitted by the NAA as a response to the “Issues and Options” document of the GNDP in 2009. It took the form of a ‘priming paper’ for discussion with the title, (“Acle a town in waiting“). This paper has since been redrafted in a more consolidated form, (“Do different and do better”) and was put forward at an open public meeting in 2010 where it was well received. The more recent revision, under a new title, “Better Places for Living” has a greater focus on transport, emphasising the considerable benefit of providing for a better and less diffuse transport solution.
12.5.2 We believe that this alternative has many merits and provides a real possibility of linking the high employment opportunity areas on the east coast through to the county city of Norwich via a housing hub at Acle using a sustainable public transport tram system. This alternative represents new thinking and the adaptation of new technology rather than the regurgitation of old thinking dressed up as modernisation.
12.6.1 There has been a long held view and a formidable body of opinion that the rural landscape needs to be protected and the population who live in rural isolation should be given the opportunity to live and work in the areas that they see as home. The construction of thousands of new homes in one large “new town” in the NEGT will have the unintended consequence of forcing young families away from their birthplace and into a brand new community leaving existing communities even more exposed.
12.6.2 These proposals will attract large national retail and entertainment chains (Tesco, Weatherspoons etc) into the NEGT, bringing added pressures to local businesses including those currently located in the NEGT that may well see the additional population as attractive. It is our view that this attraction will be short lived whereas a genuine dispersal of proportionate housing into existing villages and market towns will generate sustainable economic value.
12.6.3 James Parry, Chairman of the Campaign to Protect Rural England (CPRE) sums this up succinctly when he says:
The lack of affordable homes makes it difficult to maintain the viability and sustainability of services in smaller villages, be they the local post office, the school, the village pub or public transport connections.”
12.6.4 The National Housing Federation, supported by Broadland District Council, has recently (Sept 2012) run a Save our Villages campaign that espouses the very need to encourage inward investment into rural communities.
12.6.5 The Norfolk Rural Community Council, an independent charity founded in 1986 to support communities across Norfolk, promotes the provision of affordable housing for local people in rural communities across Norfolk. Their Chief Executive, Jon Clemo has gone on record to say the following:
“We need more affordable homes to allow people to live in areas where they grew up, keep our communities vibrant and importantly provide labour into local businesses and services.”
12.6.6 The concept of large developments is, in our opinion, taking a lazy approach to economic regneration as it makes it easier for large corporations to build and serve large chunks of population that would otherwise be unattractive to them if they were to be dispersed. We believe that it was an error, in the dispersal v concentration deliberations, not to consider dispersal outside of the Norwich Policy Area (NPA) and not to consider the impact of this level of development across the whole county and region.
13. LOCALISM ACT 2011
13.1 The decentralisation agenda encapsulated in both the Localism Act 2011 and the National Planning Policy Framework (NPPF) will place much more emphasis and responsibility on local authority planners and elected members in meeting both local needs and nationally important goals on climate change. There are key areas of opportunity and threat in the East of England and therefore proportionally in Broadland and the NEGT footprint as outlined below:
· The removal of the East of England Plan means more than just removal of housing allocations: positive strategic planning policies on green infrastructure and water resources and infrastructure will be removed too. We see no evidence of these policies being delivered by means other than through the Regional Strategy from BDC or GNDP.
· Although climate change is not a core planning principle in the consultation draft NPPF, climate change adaptation is a strategic policy in plan-making, and informs a key chapter on climate change, flooding and coastal change.
· The presumption in favour of sustainable development provides a proactive approach to both plan making and development management.
· The duty to co-operate is a requirement and opportunity for joint working between local authorities, and a list of prescribed public bodies on strategic priorities is given in the NPPF, including climate change adaptation. Once again very little evidence that this is being implemented by BDC.
· Neighbourhood development planning is a voluntary process of neighbourhood level plan making but it will form part of the statutory development plan. Local communities can be encouraged to think about what to do about the effects of climate change, such as how more parks or gardens could help to reduce the risk of flooding.
13.2 We do not believe that this proposal is sound, as it does not fully deliver on the promises made by the current government in the five key measures laid out in the Localism Act intended to decentralise power as follows:
· Community Rights
· Neighbourhood planning
· General power of competence
· Empowering cities and other local areas
According to Government, the effect of the Act will be to:
· Give more freedom and flexibility to local government.
· Give new rights and powers to local communities, making it easier for them to improve local services and save important local facilities.
· Reform the planning system, putting more power in local peoples' hands.
· Ensure that housing decisions are taken locally.
In setting out the intent of the Localism Act the previous Housing Minister Grant Shapps said in June this year:
“I want communities of all shapes and sizes, living in the smallest of villages and the largest of cities, to have the chance to drive forward their own plans for the future of their neighbourhoods without being hindered by bureaucracy and red tape.
13.3 The view of our followers is that they are disenfranchised from the planning process with very little rights and powers, unable to improve local services (bus routes cut this year) and save important local facilities. Housing decisions are being taken by an unelected local government quango, the GNDP, who until recently held meeting in secret with no input from locals at all.
13.4 Indeed the very first consultation in 2008 on the outline plans for the JCS, when the local residents delivered a resounding NO to the proposals, was mysteriously lost. The whereabouts of these responses has been sought by many individuals and organisations without a satisfactory resolution. Most telling was the fact that It was raised at the Examination in Public directly to the senior BDC planning officer who refused to provide a satisfactory explanation. This lack of an explanation for the 2008 consultation and the problems with the incorrect translation of further consultees (see 13.5) has resulted in the community feeling that they cannot trust BDC and GNDP to honestly report the findings particularly when they produce a result that is in opposition to formulated plans.
13.5 Those residents who participated in further consultations post 2008 via hard copy letter, primarily due to them being unable to access a computer and who are predominantly IT illiterate, found that BDC had taken their comments, which in the main were negative, and paraphrased them to the extent that they became a positive or at best a neutral comment which was then taken as a positive. Officers at BDC, when challenged, replaced their précis with the exact iteration, admitting this highly dubious practice. We believe however that this was only carried out for the relatively small number of respondents who had noticed the considerable change in emphasis and then complained. If residents did not notice or complain then the abridged version, in favour of the proposals, was left on record thus distorting the true responses. This duplicity invalidates the Statement of Consultation (PSJCS 6 dated August 2012) contained in the current consultation bundle and confirms the view of the Ipsos Mori poll highlighting that 82% of the general public do not trust politicians.
13.6 An example of the duplicity that we have seen and the lack of transparency came when, at a recent CPRE and Sustains Feeding the Future conference, there was an outline of local solutions to global food crisis. Hidden in the EDP article reporting on this conference was this comment:
"Other speakers included Norfolk County Council planner, Phil Morris, who said 66,000 new houses were proposed for Norfolk between 2010-2026, and that new development could be seen as an opportunity for food-growing initiatives"
"Other speakers included Norfolk County Council planner, Phil Morris, who said 66,000 new houses were proposed for Norfolk between 2010-2026, and that new development could be seen as an opportunity for food-growing initiatives"
This was the first reference that any local Parish Council, campaign group or local resident had seen of this huge number of houses which almost doubles the initial plans of 37,000 houses. Not very empowering.
14. NORWICH POLICY AREA
14.1 Salhouse Parish Council were surprised to see that the village had miraculously been included in the Norwich Policy Area (NPA) since the original Issues and Options consultation document of 2007. Since that period the Parish has subsequently been included as an Appendum to the NPA in later drafts of the JCS.
14.2 This inclusion in the NPA appeared without any notice to the Parish Council or without any consultation with local residents. Furthermore research shows that Salhouse was not part of the NPA in the Norfolk Structure Plan (199 – 2007), the East of England Plan or the Broadland Local Plan (2006 – 2011). This error was highlighted in a letter to GNDP in May 2012 where the Parish Council formally requested the removal of Salhouse from the NPA.
14.3 A response to this letter was sent in June 2012 by the Leader of BDC, who also happens to be at the time of writing the Chair of the GNDP acknowledging the anxieties of the Parish Council. However it falls short in acquiescing to the request for the removal of Salhouse from the NPA or apologising for what we see as an obvious oversight. His view is that we will have to wait and see the outcome of this current consultation and inspection when the Parish Council can put forward an argument to be removed from the NPA.
14.4 We are therefore of the strong opinion that this current proposal is not sound due to the erroneous admission of Salhouse parish into the NPA. We reiterate the request from Salhouse Parish Council for it to be removed from the NPA.
15.1 It is our contention that there has been a number of conflicting interests surrounding the whole proposal for development in the NEGT. We believe that these prejudicial interests may contravine the principles of openess and transperency on personal interests as outlined in the Localsim Act 2011 and may also be unlawful under The Bribery Act 2010.
15.2 Even professional planners are unsure about the distinction between an incentive and a bribe. The Planning Advisory Service, designed to provide advice to local authorty planning departments has this to say about the use of Community Infrastructure Levy and New Homes Bonus:
Incentives – where there is development, there could be money for infrastructure. Have you developed your approach to spending the Community Infrastructure Levy and New Homes Bonus? Be mindful of how these incentives are perceived by the community. Some will see them as bribes.
15.3 We are of the opinion that the close relationships between third parties and the formation of the Racklheath Community Trust (an unelected group of local residents part funded by Barratt Homes, the legal 'joint venture agreements ' partner with BDC and the German landowner of Manor Farms Rackheath Limited) beggars legality and probity.
15.4 This practice was highlighted on the BBC East Inside Out programme on Monday 31st Oct 2011 that investigated why cash-strapped councils are refunding money to developers. The programme was highlighted as follows:
“New developments aren't often popular with residents, so one way that councils can sweeten that pill of controversial development is to demand community facilities in return. Developers give money to the council to build the facilities, but Inside Out has discovered that councils don't always spend the money, some have millions of pounds in unspent money, and some have handed it back to the developers.”
15.5 There has been in the last 18 months a considerable amount of public money spent in the neighbouring village of Rackheath, the centre of the North East Growth Triangle where BDC are trying to build 10,000 homes, as follows:
· Two new pedestrain crossings (signalised Puffin crossing and a refuge island crossing) at a cost of £140,000. This is despite a fairly new refuge crossing having been built on the site of the Puffin crossing. This nearly new crossing had to be dismantled to make way for the Puffin crossing.
· BDC have spent £300,000 to date on retro fitting energy saving schemes to existing homes in Rackheath.
· The construction of an Eco Community Education Centre on Rackheath Industrial Estate which cost £500,000.
15.6 We also have some reservations about the role of the Chief Executive of BDC who is also listed as a Director of the Planning Officers Society Enterprises, the trading arm of The Planning Officers Society. The Society is the professional organisation for local governent Planning Officers and operates both as a limited company and as a charity. The enterprise is a trading arm used to fund the activities of the charity. It is accepted that the Directors act in an unpaid capacity.
15.7 However the POS Enterprises acted as a critical friend for the review work of the remitted element of the JCS following the successful legal challenge. This by definition was work carried out by BDC and we question the wisdom of using, and paying, an organisation to critque work carried out by one of its Directors particulalry as Mr Kirby was the main artichect of the JCS when he was Deputy Chief Executive and Head of Planning at BDC.
16. AIR SAFETY
16.1 The NEGT lies under the flight path of Runway 27/09 at Norwich International Airport (NIA) and has a Non Directional Beacon (NDB) in the centre of the planned development site. Whilst this beacon has been switched off, the proposed development lies directly under the flight path to runway 27 where aircraft using the ILS approach would be at 1200 feet.
16.2 The responsibility for civil aerodromes airport safeguarding[vi] was transferred from the Civil Air Aviation (CAA) to airport operators by the ODPM Circular 01/2003.
16.3 In transferring this responsibility local authorities are meant to hold a safeguarding map. We have not seen such a map for NIA and there are implications for the safety of flights in and out of this single runway airport both during the construction (large cranes etc) and post construction. London City Airport's Consultative Committee has a really good page on safeguarding and we would expect to see a similar plan in these proposals.
16.4 We also question the commerciality of constructing a new town under the flight path of an existing runway of an established international airport and the propensity of purchasers to buy in those circumstances particularly as a number of the proposed houses have three floors. The NIA is also the hub for offshore helicopter flights and as a consequence handles an excessive amount of low flying helicopter traffic thus increasing the risk of accidents and noise pollution.
17.1 We believe that the decision to build 10,000 new homes in the NEGT is a politically driven decision rather than one that is based on real need. The inherent risk of the Cabinet system of local government, placing decision-making in the hands of small number of councillors and council officers, has been evident throughout this process. The risk has been compounded further by the disproportionate number of times that full Council has devolved decision making to a small and powerful cabal of councillors and council officers particularly in relationship to the JCS. This has poor checks and balances, and councillors elected to change the status quo are excluded from decision-making bodies and prevented from engaging in proper debate. The very real prospect of personal agendas being played out makes it even more difficult to challenge through the normal democratic process.
17.2 Pseudo-public bodies, formed to evade transparency, may also develop plans as is the case with GNDP, which met behind closed doors whilst developing its Core Strategy and refused to publish minutes and agenda papers. Self-appointed Local Enterprise Partnerships (LEP’s) will make this worse as they operate with limited public accountability and can bid for private sector development funding.
17.3 Having heard Ms Spelman’s explanation, when Secretary of State for Environment, Food and Rural Affairs (May 2010 - Sept 2012), of her decision, to release PFI credits for the proposed incinerator at Saddlebow in Kings Lynn, fellow Tory minister and North West Norfolk MP Henry Bellingham said:
“We are in government to listen to the public and to our constituents and to take decisions for the greater good of the community. In a case where the opposition is so overwhelming it’s no good that it looks like the public are being ignored.”
17.4 Indeed the Prime Minister himself when responding to a recent planning question in the house stated:
“…..and the second thing of course is under our plans residents can write Neighbourhood Plans which gives far greater control to residents about the shape of their future communities….”
17.5 We contend that the opposition to these development plans is overwhelming, and that the three line whip from the ruling political party on BDC, usually applied during closed political meetings immediately prior to full Council meetings, restricts elected members from exercising a free vote during critical debates. This makes the public participation, particularly when restricted to three minutes only, whilst ill informed politicians can waffle on for hours, null and void. Request for an extension to the three minutes are seldom granted and there is no opportunity for public speaking at the GNDP meetings.
17.6 There are good grounds for believing that the JCS was rushed through to circumvent the Localism Act and that, in their haste to approve the JCS, the ruling party ignored the warnings from eminent Barristers that the JCS was legally unsound. As a consequence the JCS did not meet with legal approval on environmental grounds and did not include any alternatives even though participants in the Public Consultation exercise had submitted alternative strategies and ideas. If they knew it was unsound why was it not repaired prior to submission thus avoiding all of the legal costs and rectification by a cash strapped local authority?
17.7 The massive opposition to GNDP and BDC is focussed upon the arrogantly determined Conservative Councillors bent on getting their own way and satisfying personal agendas. This must not happen because it is perpetuating permanent public resentment and alienation. This is not merely a matter of passing some application that a sector of the population is unhappy with and will through time forget. This is sheer resentment and grievance about democratic deficiency in local government where the views of the public were purposely disregarded from the outset. There has to be reconciliation but it seems that the Conservative Councillors cannot see this, even though other councillors have been highly vocal and much more aligned with their electorate.
17.8 The political interference has been seen with the leader of the ruling party calling in selected members of local Parish Councils to clandestine meetings to warn them of the unintended consequences of opposition to the JCS. Indeed we have the evidence of a District Councillor in the neighbouring South Norfolk council taking the unprecedented step of writing to all of his constituents and telling them that they should vote for Option 1 in this consultation and they had better be careful what they wish for! The clear indication is that Option 3 would see the transfer of thousands of new homes to their area rather then here in the NEGT.
17.9 We have also seen the late notice cancellation of BDC meetings (June and Sept 2012) on the pretext that there was nothing to discuss even though the district is facing its most challenging decision for decades. There was however, at short notice, an extraordinary meeting of the Council on Thursday 2 August 2012 to discuss the legal challenge to the JCS. We believe that was a deliberate political attempt to stifle debate and to deny opposition parties and members of the public the opportunity to have their say.
17.10 There is also the politically driven attempt to rush through the Examination in Public (EiP) of these changes, scheduled for March 2013, before the purdah period for the May county council elections. Our contention is that the EiP should come after the purdah period so that any new executive at Norfolk County Council (a key player in the GNDP) can voice their opinion on the whole JCS.
17.11 We also have the possibility of the Communities Secretary allowing planning applicants to bypass local authorities by applying directly to him as outlined in the new Growth and Infrastructure Bill. In making this announcement on 18th Oct 2012 Planning Minister Nick Boles said the bill would "boost investment and local economic growth" followed by:.
"It removes confusing and overlapping red tape, whilst ensuring democratic checks and balances and environmental safeguards remain in place.
17.12 However, Shadow Communities Secretary Hillary Benn tweeted:
“Eric Pickles' extraordinary plan to nationalise planning permission - he will be able to cut out local communities at the stroke of a pen."
He also said that the clause allowing direct applications to the government "should be called the ‘You can't trust local people to take the right decisions’ clause". We emphathise with this view as we have felt untrusted and labelled as troublesome NIMBY’s from the outset.
17.13 The political aspect of these plans have been further confirmed by the latest bid by the greater Norwich collaboration to submit a bid for the newly announced City Deal. Once again we face the prospect, as happened with the original Growth Point deliberation, of an unelected body representing a large proportion of local residents bidding for central government funding without any consultation or mandate to do so. The effect of this, as we have seen with the JCS, could be detrimental to the wellbeing of the local population and infrastructure.
17.14 We also face the prospect of central government interference as a raft of planning reforms has been proposed in The Growth and Infrastructure Bill. The Bill sets out the measures which will allow the reconsideration of economically unviable 'section 106' agreements, would mean some commercial and industrial schemes could be treated like nationally significant infrastructure projects (NSIPs) and provides an opportunity for projects to be decided by the Planning Inspectorate where local planning authorities have a poor record in deciding decisions. We are concerned that due to the inability of BDC and the GNDP to “get it right” that the plans set out in the JCS will be treated as a NSIP thereby negating all of the intended consequences of the Localism Bill.
18.1 The economic decisions that surround the financing of new housing supply are numerous and complex and we do not believe that BDC has taken into consideration all of the comments and recommendations in the Communities and Local Government Committee’s Report on Financing of New Housing Supply presented to Parliament by the Secretary of State for Communities and Local Government in July 2012. We are also unaware of the countywide Economic Strategy and the impact that these JCS proposals will have on other parts of Norfolk by diverting potential investment from deprived areas (Great Yarmouth and Kings Lynn in particular) into a more affluent area of the county.
18.2 Community Infrastructure Levy (CIL)
18.2.1 As an example, the new Community Infrastructure Levy (CIL) has an important role to play in negotiating development and land use change for the widest possible public benefit. We welcome the added clarity and transparency that the CIL will provide over Section 106 obligations. We remain uncertain, however, about the overall impact of the CIL given that its role will be limited in significant areas of regeneration, especially those such as the NEGT with negative land values.
18.2.2 In particular we are concerned that the commitment to ensure that a “meaningful proportion” should be for communities to determine its use is not genuine. Our understanding is that all of the CIL generated by the JCS will be pooled by the GNDP and used to fund such projects as the Long Stratton bypass or to top up the NDR funds thereby preventing any real local investment of the CIL in the NEGT.
18.2.3 Any future residents of the NEGT homes would be faced with a CIL of circa £15,000 per house with no assurances that they will benefit from this additional taxation. We find this to be extremely misleading.
18.3 New Homes Bonus
18.3.1 The Government’s £1 billion New Homes Bonus, which began in April 2011, replacing the RSS, is a powerful, simple and transparent incentive that means that BDC and other GNDP member local authorities which promote and welcome growth can share in the economic benefits
18.3.2 The Government provides additional funding or a 'bonus' for new homes by match funding the additional council tax raised for new homes and empty properties brought back into use, with an additional amount for affordable homes, for the following six years. The bonus is based on past increases in housing supply. It's a powerful incentive for housing growth, because it ensures that growing areas have the resources to meet the needs of their new residents and existing communities.
18.3.3 Whitehall promises to match council tax raised from new homes for six years in order to provide money that can be used to cut council tax or invest in front line services to overcome local opposition. We are not sure how this sits with the previously mentioned Bribery Act or the rules surrounding State Aid.
18.3.4 Notwithstanding any potential conflict with legislation here in Broadland, the leader of the Council has openly admitted that they have raided the reserves of the council in anticipation of receiving this bonus in the years to follow. As a consequence the financial planning for future years shows a perilous position that relies on this bonus, particularly as council tax has not risen over the last few years. There appears to be no contingency plan if these houses are not built and the bonus does not materialise other than a considerable hike (estimated at 27%) in council tax.
18.3.5 Indeed the Leader confirms this view when discussing the proposed reforms to business rates as he says, “The days of the support grant are gone and council finance is going to be about business rates and things like the New Homes bonus”. We contend that the new homes bonus is merely seen as a prime revenue source and that the drive to build thousands of homes is to generate income.
18.3.6 This financial situation reinforces our view that this plan is not sound and that the drive for new houses is a financial necessity and not driven by housing need.
18.4 Residual Land Value
18.4.1 At the first GNDP meeting open to the public there was a discussion around the financial viability of the JCS. This was demonstrated by an example of a hypothetical 250-house development. The discussion was based on the forecast of the Residual Land Value for the JCS development. The national benchmark agreed by all key stakeholders is £500,000 per hectare.
18.4.2 The GNDP use figures from the Homes and Community Association (HCA), which show that the JCS has a residual land value of £725,053 per hectare once all of the costs and CIL are taken into consideration. This clearly ought to make it viable and attractive for the developers. For and example of 250 houses there should be the following affordable houses:
1 Bed Flat 18
2 Bed Flat 13
2 Bed House 30
3 Bed House 15
4 Bed House 7
TOTAL 83 units representing 33%
18.4.3 However 13 of these houses (5 x 2bed, 5 x 3bed and 3 x 4bed) will be for intermediate use that is sold on an equity share basis and not real social housing. This makes real affordable social housing for rent at 28%.
18.4.4 However the developer’s figures show that with this level of affordable housing and their own estimate of costs (much higher than the HCA estimate) the Residual Land Value would equate to £312,968 per hectare and therefore not viable. This means that no developer would build these houses unless there was a drop of the affordable housing to 18% that would result in the following housing mix:
1 Bed Flat 11
2 Bed Flat 8
2 Bed House 13
3 Bed House 9
4 Bed House 4
TOTAL 45 units representing 18%
18.4.5 If you then apply the same ratio of intermediate use as above the real number of affordable social housing for rent stands at 34 units that is 14% of the total build. The developers are therefore saying that they would only build these houses with 33% affordable housing if there were an increase in house values of circa 7%. The latest forecast from the Royal Charted Institute of Surveyors (RICS) is for at best an increase of 2.5%! There was an admission that there would be severe cash flow challenges as the JCS was front-loaded with costs before the CIL starts to become income.
18.4.6 We therefore contend that this proposal is not economically sound.
18.4.7 We would also query the economic sense of NCC planning to use public money to buy Coltishall when there is a viable bid on the table using private money and providing employment opportunities?
18.5 Cuts to front line services
18.5.1 We find it perverse that the greater Norwich collaboration is prepared to fund the planned expansion as detailed in the JCS during these austere times and in particular when all local authorities are cutting front line services quoting the lack of money to continue with these. This is despite sitting, in case of NCC, on large financial reserves that have been earmarked for investment in the JCS and NDR.
18.5.2 This is difficult to explain to local residents when they see cuts to youth services, meals on wheels and a shake up of services to the elderly. The drive at County Hall to save £135m over the next three years yet spend public money on unwanted and unnecessary infrastructure and houses seems to be the economics of a madhouse.
18.6 Propensity to Buy
18.6.1 Only one in four consumers would choose to buy a home built in the last 10 years says a survye from the Future Homes Commission. They conclude that even if the shortage of mortgages can be solved and the undersupply of homes can be tackled, there may remain an acute shortage of potential buyers. Too few people want to buy one according to the latest research from the Future Homes Commission, shows the reasons why loud and clear. Not enough space in the rooms. Not enough storage. Not enough natural light. And not enough flexible spaces for communal and private living or changes in the household over time. In other words, they don't think new homes are built for the needs of modern families in the ways that Victorian and Edwardian houses were. Add to this the additional build costs for a zero carbon dwelling (estimated to be circa £36k) and the BDC CIL (£16k) and these houses will appear to extremely expensive and the propensity to buy will be reduced consideribly.
19. EDUCATION AND QUALIFICATIONS
19.1.1 In Norfolk there are 3 nursery schools, 358 primary schools, 28 secondary schools, 11 special schools, 2 all-through schools, and 1 short stay school. There are now 24 academies and 1 free school with approximately 35 higher education establishments within reasonable commute of potential residents in the NEGT[vii].
19.1.2 In 2011, the proportion of Norfolk pupils reaching Government targets at Key Stage 1 (KS1), defined as reaching Level 2 in Mathematics, reading and writing, was similar to the 2010 figures. However, gender inequalities exist: in each of the three subjects, girls outperformed boys. In 2011, by the end of KS2 (age 11), the proportion of Norfolk children reaching Level 4 in English and Mathematics was broadly in line with the national average.
19.1.3 At KS4 the proportion of Norfolk pupils achieving five or more GCSEs at grades A*-C including English and Mathematics has improved every year between 2007 (45.2%) and 2011 (55.4%) although the 2011 figure is worse than the national figure of 58.2% for Local Authority maintained schools and academies.
19.1.4 The Commission on the Future of Higher Education has been established to address the key challenges facing the higher education sector over the next 20 years and to produce a policy framework that will safeguard and strengthen the position of our higher education institutions in the long term. This consultation is open until the end of October 2012.
19.1.5 Our view is that the education system in England with the move towards Academies and Free Schools along with the current consultation on higher education is in a state of flux that will not be able to cope with the immigration of thousands of new students. Our contention is that the worsening of KS4 results seen in 2011 will continue due to the overcrowding of existing secondary schools.
19.2.1 In general, the qualification levels of Norfolk residents’ aged 16-64 are lower than regional and national figures. At National Vocational Qualification (NVQ) level 4 and above, the national figure is 31.3% whereas the figure for Norfolk is significantly lower at 26.0%. For lower level qualifications, especially NVQ level 1, the gap is less marked: the national figure is 80.2% compared with 78.9% for Norfolk. The proportion of people in Norfolk with no qualifications is 13.0% (or 68,100 individuals) that is worse than the national figure of 11.3% - this gap is widening. We expect it to continue to widen should there be additional strains placed on the current education and training system in Broadland.
20.1 Norfolk Broads
20.1.1 Tourism is important in Broadland district and the prosperity of towns such as Acle, Blofield, Brundall and Wroxham is dependant to a large extent on links with the Norfolk Broads. The Broads is Britain’s largest wetland covering an area of 303km2, and is recognised for its distinctive landscape, consisting of rivers, broads (shallow lakes), marshes and fens, rich in rare habitats, supporting a myriad of plants and animals.
20.1.2 Along with the Broads and Sites of Special Scientific Interest (SSSI), within Broadland there are 22 nationally important archaeological sites; 50 Grade I, 79 Grade II* and 843 Grade II listed buildings; four historically designated landscapes; and many historical market towns and villages.
20.1.3 A significant proportion of employees (seven per cent) are in the tourism sector, which is forecast to grow by 38% from £700m to just under £1bn. We believe that the absence of a traffic survey to gauge the impact of additional traffic from the NEGT travelling to and/or through Wroxham and Hoveton will have a disastrous impact on local tourism as visitors will soon tire of queuing and find alternatives. The impact of this to the local economy has not been factored into any of the impact analyses. This view was confirmed by the Norfolk County Council representative at the Duty to Cooperate meeting held on the 17th May 2012 where the minutes of this meeting recorded the following:
“North Norfolk highlighted the possible implications for the road bridge from additional traffic resulting from growth in the NEGT. The impact will need to be considered.”
20.1.4 The Sustainability Appraisal carried out by URS concludes that both Option 1 and 2 could potentially have adverse implications to the Broads. We believe that the risk to tourism, and the negative impact on the local economy should visitors to the Broads start to decline are big risks that are not fully understood.
20.2.1 The alternative plans for the commercial development of the RAF Coltishall site include the provision for a Heritage Centre and Aircraft Museum.
20.2.2 The plans to dig up the old, and contaminated, runway at Coltishall in an attempt to bring contaminated land back into agricultural use whereby an old WWII airfield, that has been producing food for the last 60 years, is to be dug up to provide thousands of unnecessary houses is sheer and utter madness
20.2.3 Local residents now face the prospect of two ruined landscapes, with hectares of food producing land removed from the food chain, thousands of houses built that no one will buy, years of construction traffic in and around the Broads and a road to nowhere that will increase the amount of carbon in the atmosphere! This will blight the area for decades and tourists will stop coming when they experience this disruption.
20.3 Independent Verification
20.3.1 The supporters of SNUB share the view of George Freeman, Mid Norfolk MP when he says,
“We should be able to have the new businesses, houses and facilities we need without destroying the identity, heritage and beauty of our county.”
He goes on to say in another lead EDP article entitled “Keep Norfolk Norfolk”
“We need development based on a vibrant local economy with small businesses and ‘organic’ housing back in the villages and in towns where people want to live.”
20.3.2 The Bishop of Norwich calls for a similar dispersal strategy when it comes to providing new and affordable housing. He has asked that the church play an active role in securing sites in existing communities for affordable houses in order to protect the rural way of life and to keep generations of families together, rather then forcing them to split up and migrate to large anonymous housing estates as called for by the JCS.
20.3.3 Even the local regional newspaper, the EDP, has a campaign that advocates this approach by appealing for their readers to support their local economy.
21.1 The original Joint Core Strategy Consultation Report notes in its opening words:
"The next 20 years will change the face of Broadland, Norwich and South Norfolk".
21.2 Given this arduous remit, we fear that this current consultation has to be seen in party with the whole JCS and not just restricted to the remitted part of the strategy as defined by Justice Ousley in his High Court deliberation and subsequent judgement.
21.3 This consultation has been produced with, apparently, insufficient local knowledge of the area, its history and landscape. It overlooks difficult issues, makes too many meaninglessly bland statements of good intent, and puts a set of options that are either unarguable or invite a particular set of answers. It does not allow local residents to reaffirm their opposition to these plans other than “voting” for Hobson’s choice!
21.4 In the pages above we have set out our response to why we believe that this proposed submission content is unsound and why it has not been prepared in accordance with the duty to cooperate, and with legal and procedural requirements. The comments, fact and logic erode the case being pushed by BDC and GNDP because everything they have stood for is alien to the concept of Localism.
21.5 We have also set out what changes we consider necessary however our conclusion is that the JCS should be scrapped as we believe that the following key issues have not been confronted but are central to any proposals:
· Population expansion: the implications if predictions slow or prove inaccurate in the mid-term.
· Transport network: the failure to deliver a proper level of investment would jeopardise the whole plan.
· Location for expansion: a single Growth Point close to existing infrastructure and employment should be considered and the advantages of such a strategy developed.
· Dispersal option: the reduction of the overall housing supply demanded by a discredited regional strategy and the dispersal of a reduced quantity to existing communities thus providing much need inward investment.
21.6 We would hope that BDC has the courage, as did Rochdale Borough Council (RBC), to withdraw its Joint Core Strategy from the examination. RBC withdrew theirs after an inspector raised concerns over the "soundness" of the document in April this year.
Planning officers at the Council have concluded that the "best course of action" is to withdraw the Core Strategy completely and to draw up a new one "as a matter of urgency", the Council said.
If not then we fear that the NEGT will become like Pios, a new town in the Guadalajara province of Castilla-La Mancha, Spain which, will take over 7,000 years to pay back as local residents have no wish to live where there are no jobs and no infrastructure!
Chair Stop Norwich Urbanisation (SNUB) 2nd Nov 2012
 Para 18; Page 9 of The Audit Commission Inspection Report 2010 at: http://www.audit-commission.gov.uk/SiteCollectionDocuments/InspectionOutput/InspectionReports/2010/greaternorwichdevelopmentpartnershipinspection26mar2010REP.pdf
 BAWAG is an association of 170 agricultural and horticultural abstractors based around Norfolk Broads in East Anglia. BAWAG was formed in 1997 in response to the 1994 Habitat Directive. BAWAG represents abstractors’ interests in North Norfolk CAMS and Broadland CAMS. http://www.norfolkfarm.co.uk/default.asp?page_id=34&pg=
 Victoria Slingsby, Principal Officer – climate change, Strategic Environmental Planning at the Environment Agency.
 To find out more about the project and findings go to http://www.norwichbatgroup.org.uk/project.html
To find out more about British bats go to http://www.bats.org.uk/
 In June 2011, the government released the Natural Environment White Paper, setting out their environmental priorities for the next 50 years
 The Exemplar is the plan to construct 200 houses to the so-called Rackheath carbon standard as a pilot for the whole low carbon development that used to be called the Eco town. It would be the first construction of the 10,000 houses that this consultation is all about.
 The Royal Town Planning Institute is the UK's leading planning body for spatial, sustainable and inclusive planning and is the largest planning institute in Europe with over 23,000 members. http://www.rtpi.org.uk/planning-aid/what-we-do/
 Full details of this campaign can be found at http://www.cprenorfolk.org.uk/alliance-on-housing-2/.
 The Council has received some £10.2m of funding for the Rackheath Programme of Development.
 State Aid refers to forms of assistance from a public body, or publicly-funded body, given to selected undertakings (any entity which puts goods or services on the given market), which has the potential to distort competition and affect trade between member states of the European Union.
 Barratt Homes is a brand name of Barratt Developments as shown at: http://www.barrattdevelopments.co.uk/barratt/en/home
 EDP Front page headline dated 20th Oct 2012 “Dementia Timebomb” as number of elderly residents with dementia living in Norfolk as the county sets to become the largest group of dementia sufferers in any county in the UK.
 Broadland District Health Picture – August 2011
 Health Service Journal 18th October 2012
 Greater Norwich Development Partnership (July 2010) An Economic Assessment of Greater Norwich – a companion document to the Greater Norwich Economic Strategy 2009-2014
 31st Oct 2011 The Government announces it is going to invest taxpayers’ money into local regions in order to kick-start the economy. Locally Lotus will benefit to the tune of £10.4m from the regional growth fund with the prediction that this will generate 800 new jobs in the local supply chain and according to a Lotus spokesperson “considerable number of new jobs at Lotus itself over the next 6 to 8 years”.
 The four authorities of Norfolk and Suffolk County Councils, Great Yarmouth and Waveney Borough Councils produced a successful bid for an Enterprise Zone for Great Yarmouth and Lowestoft. The Enterprise Zone will help boost the local economy by attracting businesses and start-ups through the provision of simplified planning and business rate discounts.
 The Broadland Business Park is adjacent to the NEGT area and one of the intended sources of employment to support the proposed level of housing.
 From an article in the EDP Farm and Country section (Saturday 13th August 2011) entitled “What is the greatest challenge that rural areas face?”
 Development beyond the pre-NDR threshold established through the AAP process will not be possible without a commitment to the NDR. If it becomes clear that there is no possibility of the timely construction of the NDR, a review of the JCS proposals for the NEGT and the implications for the strategy as a whole would be triggered.
 The Bittern Line is a Community Railway Partnership that supports and publicises the railway from Norwich to Cromer and Sheringham. The railway forms part of the National Rail system. Norfolk County Council and Anglia Railways formed the Partnership in 1997, additional funding partners have joined and funds raised are used to promote the railway and the surrounding area to develop economic and environmental benefits for residents, visitors and tourists. They are supported by The Department for Transport and the National Community Rail organisation ACoRP.
 EDP News Sept 2011
 Areas of special architectural or historic interest, the character of which is desirable to preserve or enhance, through strict control of new development, and protection of trees, and the need for demolition of buildings or walls to be subject to Conservation Area Consent.
 Broadland Planning Application No: 20121516
 The NCC Cabinet paper is here: http://www.norfolk.gov.uk/view/cabinet110612item8pdf
 Despite a reduction in the availability of high-value contracts, the UK will become an increasingly popular market for healthcare infrastructure investment over the next few years, industry commentators are predicting. http://www.buildingbetterhealthcare.co.uk/news/article_page/UK_health_construction_market_sparks_interest_from_overseas/81462/cn41586?dm_i=8EU,10C22,6N7KVP,32KDY,1
 At the onset of the ‘consultations relating to the joint Core Strategy, the Norfolk Association of Architects formed a small working party to discuss the planning system, but in no way is it an official view of the Norfolk Association of Architects nor of the parent RIBA. The Council of the NAA sees this as a proper document for the purposes of public debate.
 Better Places for Living – June 2012
 Copies of, “Acle a town in waiting“ (2009); “Do different and do better”(2010) are available, and a copy of the as yet unpublished, “Better Places for Living” (2012) is attached as part of this representation. Copies can also be found at the NAA website: http://www.norfolkarchitects.org.uk/
 In an article in the EDP Farm and Country section (Saturday 13th August 2011) entitled “What is the greatest challenge that rural areas face?”
 In an article in the EDP Farm and Country section (Saturday 13th August 2011) entitled “What is the greatest challenge that rural areas face?”
 From 1st July 2011 businesses (which includes local authorities) must have “adequate procedures” to prevent bribery in their organisations, under a new law to combat corruption. The Bribery Act 2010 creates four new criminal offences – in essence bribing someone, being bribed, bribing a foreign official and, for commercial organisations, failing to prevent bribery.
 Mr Kirby was promoted to Chief executive of BDC in October 2011 after an in house competition following the early retirement of the incumbent Chief Executive.
 House of Commons on 17th October 2012 at Prime Ministers Question time when Nadine Norries MP for Mid-Bedfordshire put a question to David Cameron.
 The purdah period typically begins six weeks before the scheduled election, in each authority on the day the notice of election is published. Purdah in local government ends at the annual meeting of the council in the new municipal year (usually the first full council meeting after the election) when the appointment of a new executive by the leader occurs.
 EDP, Friday 26th Oct 2012
 Residual valuation is the process of valuing land with development potential. The sum of money available for the purchase of land can be calculated from the value of the completed development minus the costs of development (including profit).
 Colleges and Sixth Form Schools providing Further Education courses
 Norfolk County Council, Children’s Services, Data and Statistics intranet
 Norfolk County Council, Children’s Services, Data and Statistics intranet
 Office for National Statistics NOMIS Official Labour Market Statistics – Qualifications Jan-Dec 2010 http://www.nomisweb.co.uk/reports/lmp/la/1967128599/report.aspx#tabquals
 In an article in the EDP Farm and Country section (Saturday 13th August 2011) entitled “What is the greatest challenge that rural areas face?”
[i] Requirement for Strategic Environmental Assessment:
European Directive 2001/42/EC ‘on the assessment of effects of certain plans and programmes on the environment’ (the SEA Directive), was transposed into English Law via the Environment Assessment of Plans and Programmes Regulations 2004, Statutory Instrument 2004 No.1633, (the SEA Regulations). The SEA Directive applies to a wide range of plans and programmes and the overarching aim is to “provide for a high level of protection of the environment and to contribute to the integration of environmental considerations into the preparation and adoption of plans and programmes with a view to promoting sustainable development” (Article 1).
The SEA Directive defines ‘environmental assessment’ (Article 2(b)) as a procedure comprising:
· preparing an Environmental Report on the likely significant effects of the draft plan or programme and reasonable alternatives;
· carrying out consultation on the draft plan or programme and the accompanying Environmental Report;
· taking into account the Environmental Report and the results of consultation in decision making; and
· providing information when the plan or programme is adopted and showing how the results of the environmental assessment have been taken into account.
[ii] The Aarhus Convention provides for:
· The right of everyone to receive environmental information that is held by public authorities ("access to environmental information"). This can include information on the state of the environment, but also on policies or measures taken, or on the state of human health and safety where this can be affected by the state of the environment. Applicants are entitled to obtain this information within one month of the request and without having to say why they require it. In addition, public authorities are obliged, under the Convention, to actively disseminate environmental information in their possession;
· The right to participate in environmental decision-making. Arrangements are to be made by public authorities to enable the public affected and environmental non-governmental organisations to comment on, for example, proposals for projects affecting the environment, or plans and programmes relating to the environment, these comments to be taken into due account in decision-making, and information to be provided on the final decisions and the reasons for them ("public participation in environmental decision-making");
· The right to review procedures to challenge public decisions that have been made without respecting the two aforementioned rights or environmental law in general ("access to justice").
[iii] Brief History of RAF Rackheath
Racheia (now called Rackheath) is mentioned in Doomsday book as tenanted farming land. However in August 1942 the land was requisitioned and construction started of RAF Rackheath as a heavy bomber airfield for use of the USAAF. The airfield site consisted of 40 to 50 fields as shown in the 1801 enclosure Award Map.
Most of the flying and technical area was on Dakenham farmland consisting of 276 acres, Beech Tree Farm (223 acres) Mousehold Farm (30 acres) and Green Farm (33 acres). The accommodation consisted of 130 acres, in all a total of approximately 692 acres. Construction started on 7th Sept 1942 and the last USAAF aircraft left in May 1945. The Airfield was taken over by the RAF, on a care and maintenance basis, in June 1945 and left in 1959. Crop spraying aircraft used the runway during 1960 and light industry moved into technical areas with the runway broken up in the autumn of 1960. Since then this land has been returned to agricultural use and produces much of the cash crops need by the UK economy and plays it part in securing the UK food chain as demanded by DEFRA.
Indeed East Anglian Film Archive of footage taken by the BBC Look East programme depicts film archive of Rackheath Airfield filmed in 1960 being readied for return to agricultural land from its previous War time role. It can be seen at http://www.eafa.org.uk/catalogue/5510 for this short silent footage of around 46 seconds.
[iv] Community Led Planning June 2011
. The attendees were from the following:
- Acle PC
- Aylsham Neighbourhood Plan Working Group
- Aylsham Town Council
- Blofield PC
- BDC (Councillors)
- Broads Authority
- Brundall PC
- Buxton with Lamas PC
- Hainford PC
- Hevingham PC
- Lingwood and Burlingham PC
- Norfolk Association of Local Councils
- Ringland PC
- Salhouse PC
- Spixworth PC
- Sprowston PC
- Western Longville PC
· Wherry Housing Association
[v] Beyond Green Development
Proposal to provide up to 3,520 dwellings up to 16,800 square metres of employment space up to 3,800 square metres of space for Shops, Services, Cafes, Restaurants and Drinking Establishments; up to 1,000 square Metres of Hotel Accommodation; Primary Schools; up to 2,000 square metres of Community space including a Health Centre Library and Community Halls; an Energy Centre; Cycle and Vehicle Parking for Residents, Visitors and Staff; Landscaping and Public Open Space for Amenity Recreation and Food-Growing; Ecological Mitigation and Enhancement; Utilities and Sustainable and rain drainage Infrastructure and Pedestrian Cycle and Vehicular Accesses.
[vi] Airport Safeguarding
This is the process by which development in the vicinity of airports (and specified en-route technical sites operated by NATS or the MoD) is controlled in order to ensure the continuity of safe operations. It is primarily concerned with:
- The maintenance of airspace sufficiently free of obstacles to ensure the safety of airborne aircraft, known as physical safeguarding.
- The control of developments, including wind farms, which may interfere with aircraft/airport navigational aids such as the Instrument Landing System (ILS), Distance Measuring Equipment (DME) and radio navigational beacons, known as technical safeguarding.
- The control of developments likely to attract birds, or introduce distractions that may compromise the safety of aircraft.
· Obstacles include not just buildings but also other structures such as transmitter towers and tall cranes used on construction sites, which can present real problems.
[vii] Colleges and Sixth Form Schools
Attleborough High School, Attleborough
Bungay High School, Bungay
City of Norwich School, Norwich
Costessey High School, Norwich
Diss High School, Diss
Earlham School, Norwich
East Norfolk Sixth Form College, Great Yarmouth
Easton College, Norwich
Great Yarmouth College, Great Yarmouth
Gresham's School, Holt
Heartsease High School, Norwich
Hellesdon High School, Norwich
Hethersett Old Hall School, Norwich
Kirkley Community High School, Lowestoft
Langley School, Norwich
Lowestoft College, Lowestoft
Neatherd High School, Dereham
Northgate High School, Dereham
Norwich City College of Further and Higher Education, Norwich
Norwich High School for Girls GDST, Norwich
Norwich School, Norwich
Notre Dame High School, Norwich
Paston College, North Walsham
Sheringham High School and Sixth Form Centre, Sheringham
Sir John Leman High School, Beccles
Sprowston High School, Norwich
The Benjamin Britten High School, Lowestoft
The Blyth-Jex School, Norwich
The Denes High School, Lowestoft
The Hewett School, Norwich Thorpe St Andrew School - a Specialist Sports College, Norwich
Wymondham College, Wymondham
Wymondham High School, Wymondham