REPRESENTATION
FROM
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
CONTENTS
Page
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. INTRODUCTION
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[1]. 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[2].
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. PROCESS
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. ENVIRONMENT
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).[3] 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 )[4],
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[5]
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[6] 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. SUSTAINABILITY
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[7].
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[8].
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’[9],
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[10]:
“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[11], 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[12]
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 Petition
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[13]
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[14]
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)[15]
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[16]
have been breached as public money has been provided to Barratt Homes[17]
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[18],
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[19]
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.[20]
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[21]
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”[22] 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. JUSTIFICATION
8.1 Housing
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[23] (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.
Population density
|
Affordable housing delivered
|
Affordable housing needed
(Experts' estimates)
|
Proportion of affordable need
delivered %
|
Overall rank in England
|
|
South Norfolk
|
131
|
313
|
121
|
259
|
1
|
Broadland
|
223
|
110
|
98
|
112
|
7
|
Norwich City
|
3481
|
410
|
624
|
66
|
23
|
Definitions:
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 Employment
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[24].
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[25]. 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[26]. 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[27]. 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[28]
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 Population
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[29]
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[30]
“The single biggest issue facing the farming
community is meeting the challenge of producing more food while impacting less
on the environment.”
10. INFRASTRUCTURE
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”[31]. 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[32].
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[33]. 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 Railway
10.3.1 There
has been much speculation about the use of the existing Bittern Line[34]
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[35]
(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. PLANNING
11.1 The Norwich Society[36]
call the JCS the most important planning decision to be taken in the county for
decades, whilst Civic Voice[37]
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[38]. "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[39]
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[40]
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[41])
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.
11.11.1Developers
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. ALTERNATIVES
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)[43]
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[44]
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)[45]
have developed a discussion document[46]
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[47].
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 Dispersal
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[48]:
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[49]
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[50]. Their Chief Executive, Jon Clemo has
gone on record to say the following[51]:
“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
·
Housing
·
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. CONFLICTS
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[52].
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[53],
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.[54]
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[55].
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[56]
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. POLITICS
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[57] 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[58] 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.[59] 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[60]. 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. ECONOMICS
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[61]
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[62]
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[63],
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 Education
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[64]
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.[65]
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.[66]
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.[67]
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 Qualifications
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.[68] We expect it to continue to widen should
there be additional strains placed on the current education and training system
in Broadland.
20. TOURISM
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 Coltishall
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[69],
“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. CONCLUSION
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!
Stephen Heard
Chair Stop Norwich Urbanisation (SNUB) 2nd
Nov 2012
END
ENDNOTES
[1] Para 18; Page 9 of The Audit Commission Inspection Report 2010 at:
http://www.audit-commission.gov.uk/SiteCollectionDocuments/InspectionOutput/InspectionReports/2010/greaternorwichdevelopmentpartnershipinspection26mar2010REP.pdf
[2] http://www.broadland.gov.uk/PDF/Rural_Living_Broadland.pdf
[4]
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=
[6] Victoria Slingsby, Principal Officer – climate change,
Strategic Environmental Planning at the Environment Agency.
[7]
http://www.broadland.gov.uk/housing_and_planning/618.asp
[8]
http://www.woodlandtrust.presscentre.com/News-Releases/Is-England-becoming-deforested-c81.aspx
[9] 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/
[10] In June 2011, the government
released the Natural Environment White Paper, setting out their environmental
priorities for the next 50 years
[12] 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.
[13] 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/
[14] Full details of this
campaign can be found at http://www.cprenorfolk.org.uk/alliance-on-housing-2/.
[16] 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.
[17] Barratt Homes is a brand
name of Barratt Developments as shown at:
http://www.barrattdevelopments.co.uk/barratt/en/home
[18] 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.
[20] Health Service Journal 18th
October 2012
[21]
http://www.norfolkcommunityhealthandcare.nhs.uk/uploads/downloads/board_papers/August%202012/Enclosure%20H%20Board%20QR%20July%20report.pdf
[23]
http://england.shelter.org.uk/professional_resources/housing_databank
[24] Greater Norwich Development
Partnership (July 2010) An Economic Assessment of Greater Norwich – a companion
document to the Greater Norwich Economic Strategy 2009-2014
[25] 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”.
[26] 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.
[28] 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.
[30] From an article in the EDP
Farm and Country section (Saturday 13th August 2011) entitled “What
is the greatest challenge that rural areas face?”
[31]
http://bettertransport.org.uk/campaigns/roads-to-nowhere/local-schemes/norwich
[32] 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.
[33]
http://www.persona.uk.com/a47postwick/index.htm
[34] 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.
[36] http://www.thenorwichsociety.co.uk/
[37]
http://www.civicvoice.org.uk/
[38] Full details of the plans can be found at: http://www.snubcampaign.org/norfolk-hub.html
[39] 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.
[42] Broadland Planning
Application No: 20121516
[44] 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
[45] 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.
[46] Better Places for Living –
June 2012
[47] 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/
[48] In an article in the EDP
Farm and Country section (Saturday 13th August 2011) entitled “What
is the greatest challenge that rural areas face?”
[49]
http://www.housing.org.uk/policy/rural_housing/rural_housing_week.aspx
[50]
http://www.norfolkrcc.org.uk/wiki/index.php/Affordable_Rural_Housing
[51] In an article in the EDP
Farm and Country section (Saturday 13th August 2011) entitled “What
is the greatest challenge that rural areas face?”
[52] 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.
[53] http://www.planningofficers.org.uk/POS-Enterprises/About-POS-Enterprises/
[54] 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.
[57] 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.
[58] 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.
[59] http://www.planningresource.co.uk/go/news/article/1155616/planning-bill-hands-power-pickles/?utm_source=twitterfeed&utm_medium=twitter
[60] http://www.planningportal.gov.uk/general/news/stories/2012/oct12/251012/251012_1
[61] EDP, Friday 26th
Oct 2012
[62] 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).
[63]
http://www.architecture.com/HomeWise/FutureHomesCommission/FutureHomesCommission.aspx
[64] Colleges and Sixth Form
Schools providing Further Education courses
[65] Norfolk
County Council, Children’s Services, Data and Statistics intranet
[66] Norfolk
County Council, Children’s Services, Data and Statistics intranet
[67]
http://www.ippr.org/publication/55/9468/the-future-of-higher-education-in-england-call-for-evidence
[68] 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
[69] 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.
·
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.
. 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
