NS&OC OPA Sustainability Statement

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3. SUSTAINABILITY STATEMENT NORTH SPROWSTON AND OLD CATTON OUTLINE PLANNING APPLICATION OCTOBER 2012


1. INTRODUCTION Beyond Green Developments intends that North Sprowston & Old Catton (NS&OC) will be a place that offers a high quality of life with a very low environmental footprint. Very few large-scale developments achieve the ‘exemplary’ sustainability to which many state an aspiration: this statement – which is in part a summary and synthesis of other statements submitted with the scheme application – explains how Beyond Green’s proposals will enable the delivery of an authentically and holistically sustainable place. The statement is effectively in two parts. The first part, comprising sections 2 and 3, explains the sustainability principles behind the plans for NS&OC and summarises how these are manifested in the proposals, focusing in particular on how they work in aggregate to reduce the environmental footprint of the development. The second part, contained in section 4, explains how the proposals for NS&OC have been considered in light of the potential for wider development in the Old Catton, Sprowston and Thorpe St Andrew ‘Growth Triangle’ in order to present proposals that would be consistent with the sustainable planning of this wider area through a future Area Action Plan. Note: Following a legal challenge, parts of the text of the adopted GNDP Joint Core Strategy were remitted by High Court Order and reverted to the pre-submission stage of the plan process, to be treated as not having been subject to examination and adoption. Following further work to address the High Court ruling, a version of the Joint Core Strategy containing proposed submission text was published for consultation on 10th August 2012.

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2. SUSTAINABILITY PRINCIPLES The National Planning Policy Framework states that “[t]he purpose of the planning system is to contribute to the achievement of sustainable development” (paragraph 6). Whilst noting that “Resolution 42/187 of the United Nations General Assembly defined sustainable development as meeting the needs of the present without compromising the ability of future generations to meet their own needs” – known as the Brundtland definition – the NPPF further states that “[t]he policies in paragraphs 18 to 219, taken as a whole, constitute the Government’s view of what sustainable development in England means in practice for the planning system”. In other words, development taking place under the NPPF is, by definition, sustainable. At the heart of Beyond Green’s philosophy and conception of sustainability is the understanding that human behaviour is profoundly influenced by the environment in which we live; as Winston Churchill said, “We shape our buildings and afterwards they shape us”. As a company which came to the development business to promote sustainability, rather than vice versa, and which has sustainability outcomes written into its Memorandum and Articles – as well as the formal agreements with its landowner and financial partners in this project – Beyond Green is driven by a mission to create places that make it easy and attractive to live prosperously within environmental limits. This is a somewhat more demanding conception of sustainable development than that embodied by the NPPF, and it gives rise to the following principles: • 80% less carbon is the overarching target. Although having no formal status within the planning system, by far the most comprehensive and demanding sustainable development target – which is also enshrined in primary legislation – is the obligation on the UK Government to reduce carbon emissions by 80% by 2050 on 2005 levels. This would stabilise UK carbon emissions at a level beyond which, if mirrored elsewhere, the risks and costs of climate change are deemed to reach unacceptable proportions. There is a robust economic case that by embracing and adopting a low glide-path toward this target, rather than leaving essential technological and – especially – behavioural changes as late as possible, the costs of transition will be minimised and the competitive opportunities from building a new, low-carbon economy exploited. Carbon is far from the only environmental issue about which to be concerned, but provides a robust and – importantly – measurable currency in which to think about and measure true environmental impact. • People, not buildings, use energy and cause carbon emissions. Most efforts to improve the environmental sustainability of the built environment, such as the BRE Environmental Assessment Methodology and the Code for Sustainable Homes, focus on improving the overall resource-efficiency of the building. Although there is some acknowledgement of accessibility and other placed-based factors in some of these methodologies, the strategic challenge remains of people living otherwise unaltered environmentally impactful lifestyles in somewhat greener homes. True sustainability requires a focus on all aspects of people’s lives, not just their houses or workplaces. Beyond Green advocates a ‘total footprint’ approach to conceptualising and measuring whole-life environmental impacts, enabling domestic resource use to be put into its proper context and addressed accordingly (see Box 1). • Sustainability is about economic and social development, not only environmental protection. With the publication of the NPPF, there is a stronger than ever recognition that economic, social and environmental goals must be achieved together. However, this cannot be taken to pretend that established patterns of economic growth and social behaviour are conducive to or even compatible with environmental protection. Fortunately, many of the outcomes that characterise more environmentally sustainable places are also vital to economic and social wellbeing: from the greater proximity, face-to-face contact and creativity that comes to genuinely walkable, compact, mixed-use places to the localisation of supply chains of foodstuffs, materials and labour (and the economic multipliers they provide), authentic sustainable development offers a much more credible socioeconomic model than the ‘decarbonised’ business-as-usual to which conventional thinking clings.

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Box 1: The total footprint approach to measuring environmental impact Total footprinting is a way of measuring the overall impacts of human activity on the environment, typically at the level of the average individual lifestyle. Total carbon footprint is a measure of the total amount of carbon dioxide emissions that are directly and indirectly caused in the servicing of the average lifestyle, measured in tonnes of carbon dioxide emissions per person per annum. Total ecological footprint measures the area in global hectares of bioproductive land required to support the average lifestyle per annum. Total footprinting has many in-principle benefits as a way of measuring and communicating environmental sustainability outcomes: •

it encompasses all aspects of a person’s lifestyle choices, not just resource use in the home, and not just those impacts that arise directly (including, for example, embodied carbon in the manufacture of consumer goods);

it gives due weight to factors that cannot be influenced by the project or issue at hand – for example, the carbonintensity of grid electricity or the resource-intensity of industrial agriculture. It thus emphasises changes in the wider economy and in personal behaviours, and does not over-claim for any individual project’s impact;

while supported by appropriately complex methodologies and datasets, footprint models typically count impacts in simple and communicable terms through the prism of consumption and lifestyle choice;

it can be readily compared with accepted benchmarks for national and global ‘fair shares’ and targets; and

it does not differentiate the value of carbon or ecological impact savings from particular sources, supporting an efficient ‘least cost first’ approach to impact reduction and avoiding perverse incentives.

Total footprinting also has limitations: it deals in averages and like all models has limits to its accuracy and specificity; and it does not directly address economic and social aspects of sustainability. But, overall, it provides a more comprehensive assessment of impact that any other environmental accounting method in current use. Through its Resources and Energy Analysis Programme (REAP, www.resource-accounting.org.uk), the Stockholm Environment Institute at York University publishes consumption-based environmental accounts for every local authority area in the UK. The chart below shows the per-capita ecological and carbon footprints for the average Broadland resident in 2006 (latest available data). As can be seen, on this basis housing accounts for a relatively small share of the total footprint (20% of ecological and 28% of carbon footprints); food accounts the single largest share of ecological impact (28%) and transport of carbon impacts (31%). Broadland total footprints, 2006 (REAP) 14.00 12.00 Other

10.00

Capital Investment 8.00

Public Services Private Services

6.00

Consumables 4.00

Food Transport

2.00

Housing 0.00 ECOLOGICAL FOOTPRINT (GHA/CAPITA)

CARBON FOOTPRINT (TONNES CO2/CAPITA)

With an ecological footprint of 4.94gha/capita, compared with 4.64 for the UK, and a carbon footprint of 12.87tCO2/capita, compared with 12.10 nationally, Broadland residents have relatively high environmental footprints. Generally, higher footprints are associated with areas that have higher incomes (because richer people have bigger environmental footprints) and lower population densities (because people in these areas use private cars more and are less likely to live in more energy-efficient attached dwellings). The lowest footprints in the East of England are in cities such as Cambridge (4.42gha/cap and 11.60tCO2/cap) and Norwich (4.54gha/cap and 11.85tCO2/cap). A globally sustainable fair-share carbon footprint is 1.2 tonnes per capita.

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• Place-making at scale enabling integrated sustainability at every level. By designing and making places at scale, planning and development can influence every aspect of lifestyle choice and make living sustainably natural and attractive. In particular, adopting the compact ‘walkable neighbourhood’ as the primary unit of urban planning (and assuming a sensible location for development) enables vital issues such as access to work and community facilities, and patterns of production and consumption of food and materials, to be influenced. An infrastructure platform providing low-impact means of supplying and managing energy, water and other needs can be established with relatively few constraints. Within this type of sustainable urban framework, designing thermally and resource-efficient built form is both a much easier and a more meaningful task. • Sustainability through, not at the cost of, good urbanism. So-called ‘zero-carbon’ developments often make for strange urban environments, with buildings uniformly oriented north-south for ideal solar gain, and ostentatious ‘green’ features such as renewable energy generators visually dominant. Whilst sustainable design should be celebrated and not hidden, if it is achieved at the expense of good urbanism and an attractive, walkable townscape it will have perverse consequences. Only by subsuming sustainable design into the creation of a place that has intrinsic appeal for its character and amenity – even if this entails some modest engineering compromises – can it be genuinely suffused into all aspects of the life of a place. • A focus on the movement economy. At outline stage, the key focus for sustainability outcomes is the ‘movement economy’ – how much, what for and how people move about. Strategic land-use planning exerts greater influence than any other factor in place-making on travel demand, and once determined cannot later be readily altered (contrary to the view sometimes put that travel behaviour change is necessarily a ‘longer term’ priority). This is why layout, scale, massing and land-use mix and distribution on-site and connections and relationships off-site are the primary focus of this outline application. • There are limits to the role of place-making; behaviour change has to be actively encouraged. In the context of a glide-path to a 90%-less-carbon society by 2050, even such mammoth tasks as greening the National Grid essentially represent low-hanging fruit, and even in places that are set up to make smallfootprint living easy and natural – as at NS&OC – the necessary depth of change will not be achieved without conscious changes in lifestyle choice. Actively encouraging people to drive a lot less, cycle a lot more, alter their diets, consider the sourcing of consumables and the impacts of leisure activities (including how often they fly) are inescapably part of enabling a truly sustainable community.

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3. SUSTAINABILITY AT NORTH SPROWSTON & OLD CATTON 3.1 Major features The key features of the NS&OC scheme that will contribute to creating a culture of sustainability are: • the layout: a permeable network of streets and blocks creating a safe and legible urban environment conducive to walking and cycling, as well as improved east west connectivity; • the transect and street hierarchy: rules for the proportioning an composition of streets and buildings that will compel human scale and fine-grained urbanism through detailed design, allowing variety within an overall cogence that will draw people into the public realm and privilege pedestrians and cyclists over cars; • a mixture of land-uses, with sufficient community facilities, shops and services and workplaces concentrated in new and expanded local and neighbourhood centres to reduce the need to travel significantly and, alongside the proposed transport strategy, support a steady reduction in dependence on the private car; • new and extended bus services which will improve public transport accessibility not just within the development but on key movement corridors serving existing homes, supporting area-wide travel planning and eventual traffic neutrality, together with an on-site car club; • small business incubators, home-working units and an enterprise hub to encourage and enable entrepreneurship and alternative working patterns; • a wide choice of housing which will create and sustain a social mix, but with all homes built to high standards of thermal performance as the basis for a universal target of Code for Sustainable Homes Level 4 or better; • a comprehensive green infrastructure network including the dedication of Beeston Park as a major new public park, plus two new recreation grounds, local parks and play spaces, space for allotments and food production, wildlife corridors, green roofs and new and retained habitat areas – bringing people closer to nature; • extensive food growing areas including allotments, community gardens and food production within parks, acting as the basis of a local food culture; • a very low carbon decentralised energy network, initially fired by natural gas but capable of being retrofitted to use other fuel sources, as the basis of a 60% reduction in building carbon emission across the site; • water and drainage infrastructure supporting a significant reduction in potable water consumption and capable of delivering non-potable water supplies to all buildings, including from rainwater harvested on site; • a Site-Wide Design and Sustainability Code to be developed prior to detailed design submission to set comprehensive targets for buildings and construction including with regard to materials, fit-out and building-integrated technologies; • ongoing management through an Estate Management Company, which will provide ongoing support for participatory sustainable lifestyle change as well practical management of service such as green infrastructure maintenance, parking management, and the attraction of sustainable businesses to locate and operate within N&OC.

3.2 Towards environmental footprinting As discussed above, Beyond Green proposes to take a ‘total footprint’ approach to analysing and measuring environmental sustainability outcomes at NS&OC. If outline planning permission is granted, Beyond Green intends to develop a bespoke footprint model which will enable the impact of the application of the principles described above to be measured and monitored, providing information which will enable the scheme to be 5


evaluated and contribute to ongoing management initiatives, including the provision of information, advice and incentives to residents and users of the development. Preliminary discussions have taken place with potential technical partners in this exercise and a detailed scoping exercise will be undertaken prior to the submission of reserved matters applications. However, at this outline stage it is possible to identify a wide range of direct and indirect impacts that will accrue from the proposals and explain the magnitude of measurable carbon and ecological footprint reductions they could achieve if implemented as proposed. Table 1 below maps the issues and impacts on different components of residents’ environmental footprints as follows: • scope – summary of the impacts included within the footprint component; • baseline footprints – the baseline per-capita impacts of the average Broadland resident lifestyle as measured on the Stockholm Environment Institute REAP methodology; • key scheme proposals – summary of the main features of the proposals for NS&OC impacting on the baseline footprint; • direct impacts – likely magnitude and nature of footprint component reductions as a direct outcome of the NS&OC proposals (i.e. ‘designed-in’ impacts not reliant on behaviour change or off-site impacts); • indirect impacts – potential magnitude and nature of footprint component reductions as a result of change enabled or encouraged by or complementary to NS&OC proposals (e.g. behaviour change, off-site impacts) – over and above direct impacts; • residual impacts – potential magnitude and nature of footprint component reductions as a result of change that cannot be directly or indirectly affected by the scheme; and • further information – where in the suite of application documents more detailed information on the relevant scheme proposals can be found.

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Footprint

Scope

component

Housing

Baseline

Key scheme proposals

Direct impacts

footprint gha/

tCO2/

cap

cap

Include impacts

0.99

3.60

embodied by

(20%)

(28%)

materials production

Additional indirect

Additional

Further

impacts

residual impacts

information

Thermally-efficient homes and

High – major

Medium – scope for

Medium –

Housing

buildings constructed using low-

direct carbon

regulated emissions

upstream energy

Statement;

impact materials (min CfSH Level 4)

reductions in

to be further

decarbonisation

Energy statement

and construction

Target zero construction waste

construction and

reduced by future

processes, domestic

Local sourcing of materials and

use

change in fuel

energy use, •

maintenance and repair, and the

labour wherever possible

supplies;

Very low carbon energy strategy

opportunities for

reducing CO2 emissions by 60%

further demand

administration of

reductions through

housing services.

individual building design and resident behaviour change

Transport

High quality streets and permeable

Medium –

Medium –

High – market &

Design and

layout to encourage walking and

realistic aim is to

contribution via

fiscal impacts on

Access

cycling

achieve a 50%

CIL/S106 to

fuel energy

Statement;

Walkable neighbourhood -

mode share for

sustainable

prices,

Transport

the operation of all

Integrated, highly accessible

car use for travel

transport

electrification of

Assessment

public and private

community facilities, shops and

to work;

measures;

vehicles,

transport modes, the

workplaces, reducing the need to

negligible use of

incentives to reduce

investment in

use of vehicles

travel

the car for travel

car ownership (e.g.

sustainable

High-quality ICT connections to all

to primary

transparent parking

transport

properties and workplaces

schools and

pricing) and

infrastructure in

Frequent, rapid low-carbon bus

extensive

improve take-up of

Greater Norwich

services to Norwich City Centre

localised

sustainable modes

and beyond

Progressive parking strategy phasing

employment

on and around site

Transport impacts

1.07

3.95

include the

(22%)

(31%)

manufacture and purchase of vehicles,

abroad and those

embodied by capital investment in

transport infrastructure.

out private car-reliance and

(Area-Wide Travel

promoting take-up of car clubs and

Planning)

EVs

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Footprint

Scope

component

Food

Baseline

Key scheme proposals

Direct impacts

footprint gha/

tCO2/

cap

cap •

Area-wide travel planning

Additional indirect

Additional

Further

impacts

residual impacts

information

Food impacts include

1.37

1.22

Allotments and community gardens

Low – impact of

Medium – potential

High – wider

Green

the impacts of the

(28%)

(9%)

Local food hub at Red Hall Farm and

proposals on food

for greater

societal/market

Infrastructure

production,

locally-sourcing suppliers among

economy will be

consciousness

changes

Statement; Social

processing,

high street food retailers, cafes and

exemplary rather

leading to changed

and Economic

transportation and

restaurants

than systemic

consumer

Development

behaviour

Statement;

consumption of all foodstuffs and

beverages plus

Food-growing in parks and public spaces

Delivery

Residents will be encouraged to

Statement

catering services and

make use of food delivery services

impacts embodied by

and an on-site delivery consolidation

capital investment in

scheme will be explored.

food infrastructure and services. Consumer

Consumer impacts

0.63

1.26

items

include those in the

(13%)

(10%)

Retail and leisure opportunities

Low –

Medium – potential

High – wider

Social and

within the development will be

development will

for culture of

societal/market

Economic

production,

actively marketed to partners and

have minimal

sustainability to

changes; global

Development

manufacture,

occupiers providing locally and

impact on

increase

reductions in

Statement;

transportation and

sustainably sourced goods

production of

consciousness of

carbon intensity

Delivery Statement

All retailers and craftspeople on-site

consumer goods;

and demand for

of embedded

consumer items (e.g.

will benefit from thermally efficient

waste recovery &

sustainable

energy

clothing, furniture,

buildings, very-low-carbon energy

gasification would

consumption

appliances, tools,

supply and other resource-efficient

reduce whole-life

choices

infrastructure

carbon emissions

consumption of

books, personal care, tobacco and impacts

High rates of recycling of all forms of

embodied by all

waste will be encouraged in

associated capital

partnership with the Waste

investment.

Authority and service providers

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Footprint

Scope

component

Baseline

Key scheme proposals

Direct impacts

footprint gha/

tCO2/

cap

cap

Private

Private service

0.28

0.84

services

impacts include

(6%)

(7%)

water supply, private •

Additional indirect

Additional

Further

impacts

residual impacts

information

On-site, accessible provision of key

Medium –

Medium – potential

High – gradual

Social and

‘high street’ services meeting

services sourced

for further building

grid

Economic

everyday needs

from mixed-use

emissions

decarbonisation

Development

All commercial premises on-site will

environment on-

reductions on-site;

reducing

Statement;

services, telecoms,

benefit from thermally efficient

site will have less

emerging culture of

embodied

Delivery

package holidays,

buildings, very-low-carbon energy

carbon embodied

‘local’ increasing

emissions in off-

Statement

hotels, insurance,

supply and other resource-efficient

in their supply

on-site

site services

infrastructure

because of low-

consumption;

Potential for location of ‘tradable’

carbon premises.

possible supply-

health and education

financial services, •

postal services and impacts embodied by

service-sector employers on site, all

chain measures by

all associated capital

benefiting from thermally efficient

service providers

investment.

buildings, very-low-carbon energy supply and other resource-efficient infrastructure •

All non-residential buildings constructed to BREEAM ‘Excellent’ or better

Proposed dual supply of water and natural foul water treatment, moving towards water neutrality

On-site, accessible provision of

Medium –

Medium – potential

High – gradual

High – gradual

nursery, primary school and primary

services sourced

for further building

grid

grid

health services

on-site will have

emissions

decarbonisation

decarbonisation

All public service premises on-site

less carbon

reductions on-site;

reducing

reducing

health, education

will benefit from thermally efficient

embodied in their

emerging culture of

embodied

embodied

services, recreational

buildings, very-low-carbon energy

supply because of

‘local’ increasing

emissions in off-

emissions in off-

services, social work,

supply and other resource-efficient

low-carbon

on-site

site services

site services

waste and sanitary

infrastructure

premises.

consumption;

Public

Public service

0.51

1.61

Services

impacts include

(10%)

(13%)

central and local administration,

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Footprint

Scope

component

Baseline

Key scheme proposals

footprint gha/

tCO2/

cap

cap •

Direct impacts

Additional indirect

Additional

Further

impacts

residual impacts

information

Potential for location of public-sector

possible supply-

embodied by all

employers on site, all benefiting from

chain measures by

associated capital

thermally efficient buildings, very-

service providers

investment.

low-carbon energy supply and other

services and impacts

resource-efficient infrastructure •

All non-residential buildings constructed to BREEAM ‘Excellent’ or better

Capital

Capital investment

0.09

0.31

Investment

impacts not included

(2%)

(2%)

Impacts not included

-0.01

0.07

in other categories

(0%)

(1%)

4.94

12.87

Impacts unlikely to be directly affected by development

in other categories Other

Total

Table 1: Impact of NS&OC proposals on total ecological and carbon footprints

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3.2.1 Towards a lower environmental footprint On the REAP methodology, which assigns all footprint impacts to the final consumer1, only about 18-20% of a person’s footprint comes directly from the use of energy in heating and powering the home in occupation (about 10-11%) and the consumption of fuel for personal travel (about 8-9%). The remaining four-fifths of impacts are ‘embedded’ in the upstream production of things people use, including the home they live in and the car or bus they use. This powerfully shows the limitations of ‘zero carbon homes’ as a strategy for sustainability and reinforces the importance of both ‘upstream’ infrastructural change (such as to grid energy sources, both in the UK and, especially, in countries from which the UK is an importer of goods) and consumer choice; the latter being especially important because only so much ‘decarbonisation’ of inputs is possible before the question becomes not how to consume differently, but how to consume less. However, because of the scale of NS&OC, additional factors come into play. To the extent that life in NS&OC is ‘localised’ – in particular, that people who live on-site work there, shop there or take leisure there – the scheme can also influence ‘upstream’ impacts. All shops, workplaces and public and private services in NS&OC will benefit from the same platform of thermally efficient buildings, low-carbon energy supply and efficiently-managed water services as homes, significantly reducing the impacts embedded in those components, and thus residents’ footprints. To the extent that people living off-site use these facilities, they too will have reduced footprints. To the extent that people on- and off-site walk to use these services, there will be a further multiplier. Furthermore, Beyond Green believe that, because NS&OC will have the hallmarks of an authentically sustainable place, everyday experience of and participation in less impactful lifestyles (reinforced by information and advice) will feed back into wider consumption and lifestyle choices – such as greater consciousness about the provenance of fresh food, resource conservation, dietary change and less frequent use of cars and planes. Government research has found that people are much more likely to change particular behaviours when doing so would fit into a wider system of “attitudes, values, aspirations and sense of self-efficacy” and that “there is an important feedback loop from behaviour into underlying, attitudes, values and aspirations”2. If a culture of sustainability can be inculcated at NS&OC, very substantial reductions in environmental footprints notwithstanding change in the wider economy could be obtained. Benchmarks for environmental impact reduction based on a total footprint methodology will be set as part of the proposed modelling exercise, and used to inform the monitoring and management of the development, including what and how information, advice and incentives are provided to residents and users. It is likely that a research programme will also be designed alongside the footprinting methodology to enable learning and understanding from the use of this approach at NS&OC to inform a wider debate and understanding about applied sustainability in place.

REAP is an input-output model which, in much the way that Value-Added Tax works on the basis of value-added at each stage in the production process and the liability ultimately washes through to the final consumer, works on ‘carbon-added’ (or bioproductive landadded) the final incidence of which falls on the consumer. The percentages given are based on estimates in A Consumption Approach for Emissions Accounting – the REAP Tool and REAP Date for 2006 (SEI, 2010).

1

2

“Achieving culture change: a policy framework”, Prime Minister’s Strategy Unit, July 2007, pp7-8

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4. SUSTAINABLE PLANNING OF THE WIDER GROWTH TRIANGLE Following a legal challenge, parts of the text of the adopted Joint Core Strategy – including those pertaining to the ‘Growth Triangle’ – were remitted by High Court Order and reverted to the pre-submission stage of the plan process, to be treated as not having been subject to examination and adoption. Following further work to address the High Court ruling, a version of the Joint Core Strategy containing proposed submission text was published for consultation on 10th August 2012. The published draft pre-submission text proposes the development of an Area Action Plan to guide development in the Old Catton, Sprowston and Thorpe St Andrew ‘Growth Triangle’ and produce “a single co-ordinated approach” across the area. An Area Action Plan (AAP) is a Development Plan Document focused on a specific location or an area subject to conservation or significant change. As such, it is covered by The Planning System: General Principles and in particular the statement at paragraph1 7 that “[i]n some circumstances, it may be justifiable to refuse planning permission on grounds of prematurity where a DPD is being prepared or is under review, but it has not yet been adopted. This may be appropriate where a proposed development is so substantial, or where the cumulative effect would be so significant, that granting permission could prejudice the DPD by predetermining decisions about the scale, location or phasing of new development which are being addressed in the policy in the DPD.” At the time of submission of this planning application, work on the proposed Growth Triangle AAP is not well advanced and so little or no weight can be given to it as a material consideration. However, it is equally the case that the application scheme is a substantial development whose scale is such that some predetermination of matters that would otherwise be decided in the AAP appears inevitable. Pre-application discussions with Broadland District Council officers have indicated that, other material considerations notwithstanding, such predetermination could be deemed acceptable if the proposals are in accordance with the adopted development plan, consistent with the sustainable planning of the wider area, if an early grant of planning consent would provide benefits which outweigh any disadvantages that might accrue prior to the AAP process being advanced. This section sets out the applicants’ understanding of the likely objectives of an Area Action Plan, explains how the scheme proposals meet those objectives, and where appropriate identifies the ways in which a grant of outline planning consent for the proposed scheme could constrain the discretion of a future AAP to decide how best to meet those objectives across the Growth Triangle. Together with the planning, design and environmental information presented across the suite of application documents, it aims to present information and analysis sufficient to inform a judgement about the merits of the scheme in the context of the wider Growth Triangle.

4.1 Objectives for the Growth Triangle Broadland District Council’s Growth Triangle Guide (June 2011, p5) summarises what development within the Growth Triangle should seek to achieve: • • • • • • • •

7,000 new homes by 2026 rising to 10,000; a new District Centre including a ‘high street’, library, education and health facilities; new Local Centres for access to day-to-day shops and services; up to six new primary schools and a new secondary school, opened during early stages of development; provide land for employment use, including expansion of Rackheath Industrial Estate; conserve important green spaces and landscapes such as historic parklands and ancient woodland; link habitats and green spaces into a ‘network’ to promote biodiversity; maintain a ‘buffer zone’ north of Rackheath to protect the Norfolk Broads;

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• a swift, efficient and frequent Bus Rapid Transit service between the Growth Triangle and Norwich City Centre; • a choice of safe and direct cycle and pedestrian routes throughout the Growth Triangle to connect to services, employment areas, adjoining fringe parishes and Norwich City Centre; • orbital bus services to Broadland Business park, Rackheath Industrial Estate, Airport employment areas and to the countryside; • new rail halts at Rackheath and Broadland Business Park; • cohesion between new and existing communities; • a household waste recycling centre; and • renewable energy technologies. The AAP will support delivery of these objectives. Development of the AAP was at an early stage when the High Court ordered the remission of the supporting aspects of the Joint Core Strategy, and is understood to be suspended pending the re-examination of the submission draft, but the Growth Triangle Guide published by Broadland District Council in June 2011 to inform the public about plans for the Growth Triangle indicates that it will have three main parts: • a Framework Plan: a map showing the distribution of land uses and how they will relate to one another • strategic policies, to set out the main requirements for new development which will be needed to achieve the objectives for development in the area, deliver infrastructure and manage land uses; and • area-specific policies, to explain what development in different parts of the Growth Triangle should be like. The Council has also produced a Framework Plan Study (September 2011) which provides a range of planning and environmental background information on the Growth Triangle and sets out four illustrative examples of possible distributions of development within. This indicates that: • of the 1,865 hectares of land within the Growth Triangle, around 660 hectares will be required to deliver the proposed growth. Approximately 385ha of this “land budget” are required for residential development, with a further 145 for open space, 50 for employment, and the balance for other uses; • taking into account relevant opportunities and constraints, there are three “core areas” of moderate or high development potential: the applicants’ land; the former Rackheath airfield where the Rackheath ecotown is proposed; and land either side of the Salhouse Road3; • in the four illustrative “framework plan examples”4 given, some development is envisaged in each of these three core areas, with the amount varying according to the emphasis of the example (e.g. Rail TransitOriented Development vs Urban Extension); and • significant information gaps remain including on ecological impact, the water cycle, transport and archaeology which will inform both the AAP and individual planning decisions. As part of this study, a plan is provided analysing the development potential of different land parcels within the Growth Triangle. This is reproduced as Figure 1 below. Although the Study does not itself give figures, Beyond Green estimate that the area of land identified as having ‘high’ or ‘moderate’ development potential amounts to approximately 40% of the area of the overall Growth Triangle, or around 750ha. Given the estimated need for around 660ha to deliver the proposed growth, and assuming that the land of greatest development potential is likely to be favoured for site allocations, this would suggest that some, and indeed a substantial level, of development will be required on the application site under any scenario. This is borne out by the four framework plan examples, all of which indicate a significant amount of development on the application site. 3

Framework Plan Study, p36. There is also a number of smaller sites, for example at New Rackheath close to the route of the Northern Distributor Road 4

Pp40-47

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Figure 1: Development potential of land within the Growth Triangle (Growth Triangle Framework Plan Study, Broadland District Council, September 2011)

4.2 Impact of the scheme proposals The scheme proposals can impact on the discretion of the AAP, and thus the overall planning of the Growth Triangle, at two principal levels: the distribution of development – what land within the Triangle is used for development; and the form of development – what is included within the scheme and the spatial relationships that will thus emerge. Broadly, the former has implications for the AAP’s framework plan and the latter for its strategic and area-specific policies. 4.2.1 Distribution and framework planning As stated above, it is apparent from the preliminary analysis published by Broadland District Council that there is only limited surplus capacity in land identified as being of greater (i.e. ‘high’ or ‘moderate’) development potential compared with the estimated land budget required. Clearly, it is possible that some

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land of lower development potential may, with appropriate mitigation, be able to be developed – indeed NS&OC proposes a small extent of development on some such land north of Beeston Lane at Red Hall Farm. But, given the extent of permanent constraints such as ancient woodland and recreational land uses, which cause significant fragmentation particularly in the central area of the Triangle, the ability to achieve a coherent spatial form from development on much of the land identified as lower-potential must be in question. Prior any further masterplanning work it therefore seems clear that, as the four scenarios in the Framework Planning Study illustratively identify, some development on the applicants’ land is likely to be essential if the objectives of the Growth Triangle are to be delivered. This concurs with the findings of Beyond Green’s own early-stage framework planning work (see Design and Access Statement Chapter 4 for an overview of design evolution), which highlighted some factors that have influenced the design proposals for NS&OC and will inevitably influence the AAP framework plan in due course. These include: • the relatively coherent and continuous shape and size of the land in the control of the applicants, and in particularly the ability through the formation of the consortium to plan cogently across multiple land ownerships; • the weak physical connectivity and integration between the three “core areas” of higher development potential. The Beyond Green consortium land is separated from the land around Salhouse Road by Sprowston Manor Golf Club and the bulky, barrier-like land uses around Sprowston Tesco. Rackheath is separated from the land around Salhouse Road by the route of the Norwich Northern Distributor Road; • the increased importance, therefore, of connectivity north-south with existing communities, facilities and transport routes (and of social as well as physical connectivity with the existing communities of Sprowston and Old Catton), and of development in each core area being of the right scale to sustain its own local services to some extent; and • the very limited choice of possible routes for an inner east-west orbital street (particularly given existing consents for development at Home Farm, White House Farm and Brook Farm). This framework planning exercised supported the judgement that the Beyond Green land is a relatively straightforward area within which to achieve an internally coherent development at a scale capable of sustaining integrated facilities such as shops, primary schools, workplaces and community facilities regardless of what takes place in other parts of the Growth Triangle. An integrated pattern of walkable neighbourhoods can be achieved which may not be possible on other land. Therefore, whilst it is clearly the case that the proposals would run in advance of the AAP in deciding that a substantial level of development would take place in the westernmost of the three “core areas” of the Growth Triangle, Beyond Green conclude both (i) that some development on this land is inevitable given the constraints on land across the wider area and (ii) that its combination of scale and geography and connections argue for a substantial rather than de minimis level of development to be located within this core area. The application is for up to 3,520 homes to be delivered over a 15-20 year period according to market conditions; this equates to 35% or slightly over a third of the eventual level of development envisaged in the Joint Core Strategy. It may be that a higher level of provision in this sector is appropriate or required, as the AAP may determine. 4.2.2 Form To analyse the implications of the form and content of the NS&OC proposals for the AAP, such as might be reflected in strategic and area-specific policies, the objectives for the Growth Triangle described in the Growth Triangle Guide have been reproduced in Table 2 below (Column 1). A summary is given of the impact of the scheme proposals on the objective (Column 2), and of the implications for the future flexibility of the AAP to plan sustainably for the wider area (Column 3).

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What is the impact of the NS&OC proposals?

What are the implications for discretion of the Area Action Plan?

7,000 new homes by

NS&OC would deliver up to 3,520 new homes, approximately 2,400 by

See ‘distribution’ above. Housing targets laid down in the Joint Core

2026 rising to 10,000

2026. This amounts to approximately one-third of the target for 2026

Strategy are minima, not maxima, and the proposals would contribute

and slightly over one-third of the subsequent target. Further details are

early and reliable delivery of housing without precluding substantial

set out in the Housing Statement.

levels of housing development in other parts of the Growth Triangle.

What does the Growth Triangle seek to achieve?

Land within the applicants’ control remains available for additional allocations in the western part of the Triangle if considered appropriate. A new District Centre

NS&OC proposes an east-west high street and square with library,

The Area Action Plan will be able to identify a location for a District

including a ‘high

health and education facilities plus shops and other services as a Local

Centre either around the NS&OC main square or in a suitable location

street’, library,

Centre, located and designed in such a way as to have the capacity to

on other land within the Growth Triangle. The geography of the

education and health

grow into a District-scale centre should the AAP require. Further

Triangle is such that any choice of location will be more accessible to

facilities

details are set out in the Social and Economic Development Statement.

some parts of the Triangle than others but the NS&OC main square is optimally located to serve new and existing development in the western part of the area. Based on the GNDP Infrastructure Needs Study 2009, Beyond Green calculates a need for a library, education and health facilities on site even if the main District Centre is located elsewhere.

New Local Centres for

In addition to the centre described above a secondary Local Centre is

Because of the geography of the Growth Triangle, and particularly the

access to day-to-day

proposed at Wroxham Road square with other, smaller Neighbourhood

fact that the applicants’ land is largely separated from other

shops and services

Centres proposed at Red Hall Farm, Church Lane South and Old Catton.

developable parts of the Triangle by areas of undevelopable land such

These have been located to maximise accessibility on foot, by bike and

as Sprowston Manor Golf Club, the choice of location of centres within

on public transport for those living within, and in existing communities

the scheme has negligible knock-on effect on the appropriate

close to, the site on the ‘walkable neighbourhoods’ principle. Further

distribution of centres elsewhere.

information is set out in the Social and Economic Development Statement.

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What does the Growth

What is the impact of the NS&OC proposals?

What are the implications for discretion of the Area Action Plan?

Up to six new primary

In accordance with pre-application discussions with the Local

Proposed primary school provision meets need arising from the

schools and a new

Education Authority, NS&OC provides sites for two two-form entry

scheme calculated in accordance with the methodology used in the

secondary school,

(420 place) primary schools, as well as nurseries. Further information

GNDP Infrastructure Needs Study. It has been assumed, in

opened during early

is set out in the Social and Economic Development Statement.

accordance with guidance given by the Local Education Authority,

Triangle seek to achieve?

that the probable location for a secondary school will be at Rackheath

stages of development

eco-town. The proposals do not provide land for a secondary school, but this could be considered at a later date if the AAP decides a location in the western part of the Triangle is to be preferred. Provide land for

As part of the provision of a mixed-use environment, the scheme 16,800m2

The proposals for employment space are sufficient to meet the

employment use,

incorporates up to

of employment space fully integrated into

requirement to create a genuinely mixed-use environment whilst

including expansion of

the proposed Local Centres, aimed primarily at SMEs in the high-value

respecting the primacy of Norwich city centre as an employment

Rackheath Industrial

service sector. Further information is set out in the Social and

destination. They are modest compared with, and will have negligible

Estate

Economic Development Statement.

impact on, the proposed allocations of 25ha of new employment land each at Rackheath Industrial Estate and Broadland Business Park or the creation of mixed-use places on other primarily residential development sites.

Conserve important

The two outstanding green spaces and pieces of landscape within the

As locally designated historic parkland, it is highly unlikely that the

green spaces and

applicants’ control, Beeston Park and the meadow south of Red Hall

AAP would seek to allocate Beeston Park for development; more

landscapes such as

Farm, will be conserved and enhanced for public amenity as part of the

probable is that Beeston Park might be designated part of a strategic

historic parklands and

scheme. Further information is set out in the Green Infrastructure

green infrastructure network serving the wider Growth Triangle and

ancient woodlands

Statement.

beyond. To this extent, the scheme proposals would not prejudice, and may actively facilitate, the aims of the AAP.

Link habitats and

A comprehensive network of connected, multifunctional green

The landscape and green infrastructure design principles adopted and

green spaces into a

infrastructure is proposed for NS&OC which mitigates the impact of

applied to NS&OC reflect aims expressed by stakeholders and the

‘network’ to promote

development on local ecology and provides enhancements. This

public during pre-application engagement, and are likely to

biodiversity

includes proposed off-site connections, particularly to the countryside

implement and exemplify the strategy the AAP will seek across the

to the north. Further information is set out in the Green Infrastructure

Growth Triangle.

Statement.

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What does the Growth

What is the impact of the NS&OC proposals?

What are the implications for discretion of the Area Action Plan?

Maintain a ‘buffer

Lying in the western part of the Growth Triangle, NS&OC has no impact

No impact on ‘buffer zone’

zone’ north of

on Rackheath or a potential buffer zone to its north. Issues of

Rackheath to protect

cumulative impact of development on the Broads will be addressed by

the Norfolk Broads

the provision of information to enable Appropriate Assessment to be

Triangle seek to achieve?

carried out by the competent authority. A swift, efficient and

NS&OC does not lie on the prospective BRT corridor; however bus

There is a theoretical potential indirect impact if the approval of

frequent Bus Rapid

improvements will be secured as part of the scheme which deliver swift,

NS&OC were to result in lower allocations along the proposed BRT

Transit service between

efficient and frequent services between NS&OC and Norwich city centre.

route such as to affect its viability. However, approval of NS&OC

the Growth Triangle

Further information is set out in the Design and Access Statement and

would not of itself preclude a level of development along the BRT

and Norwich City

Transport Assessment.

corridor necessary to support its viability.

A choice of safe and

NS&OC will provide segregated cycle tracks on primary routes and a

The development is in accordance with the objective for the Growth

direct cycle and

permeable secondary and tertiary street network offering cyclists a wide

Triangle and will make a significant contribution to a wider cycle

pedestrian routes

choice of safe, direct routes connecting to off-site infrastructure, to

network serving the area.

throughout the Growth

which improvements will be sought and made via a S106 agreement and

Triangle to connect to

the implementation of the Norwich Area Transport Strategy.

services, employment

Connections to off-site leisure routes into the countrywide are also

areas, adjoining fringe

proposed. Further information is set out in the Design and Access

parishes and Norwich

Statement, Green Infrastructure Statement and Transport Assessment.

Centre

City Centre Orbital bus services to

NS&OC proposes an east-west orbital street running between St Faiths

Development of NS&OC would actively facilitate the objective of the

Broadland Business

Road and Wroxham Road via Spixworth Road, North Walsham Road

AAP by delivering a major section of the proposed east-west route as

park, Rackheath

and the proposed Main Square, connecting to sections to be delivered

an integrated part of the development, without the need for public

Industrial Estate,

by other developments and ultimately provide a direct route between

funding and/or separate negotiations with the landowners over whose

Airport employment

the Airport employment areas and Rackheath/Broadland Business Park

land the route passes. The location and form of the proposed

areas and to the

to the east. A scheduled orbital bus service is envisaged in later stages

development also places a substantial population – around 8,000

countryside

of development once the necessary infrastructure and a viable level of

people – within a 10-minute walk of this route, contributing to the

demand are in place. Further information is set out in Public Transport

basis for a viable service to be introduced in due course.

Statement.

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What does the Growth

What is the impact of the NS&OC proposals?

What are the implications for discretion of the Area Action Plan?

NS&OC does not lie on or near the railway line.

No impact.

Cohesion between new

Every effort has been made, working closely with stakeholders including

The proposals deliver the objective to the fullest possible extent on

and existing

the parish councils, in the design of NS&OC to maximise physical and

land within the applicants’ control, and given the challenges to

communities

socioeconomic connectivity with the existing communities of Sprowston

integration posed by neighbouring land uses and the form of adjacent

and Old Catton to which the site is proximate. This includes integrating

past development. The approach taken to pre-application

principles for the design of the Church Lane connection developed as

consultation has also made a contribution to creating connections

part of the Sprowston Neighbourhood Plan process. Further

with the existing community, and this contributes to the context in

information is set out in the Design and Access Statement and

which the AAP will be developed.

Triangle seek to achieve? New rail halts at Rackheath and Broadland Business Park

Statement of Community Involvement. A household waste

The proposals for NS&OC do not incorporate a household waste

The proposals recognise the need for a HWRC and identify a suitable

recycling centre

recycling centre (HWRC); however, should such a facility be deemed

site within the scheme, located close to complementary uses and

through the AAP to be necessary on the application site the necessary

accessible from the main highway network, thereby facilitating at least

consents would be obtained through a separate process. This could be

one suitable choice for the AAP process to weight.

on land adjacent to the application site, or within the site close to the proposed Energy Centre. Renewable energy

The preferred energy strategy for NS&OC envisages minimising energy

The proposals are consistent with the objectives of the AAP. As the

technologies

demand through the use of very thermally efficient buildings, such that

energy infrastructure for the scheme is scalable, the proposals could

the residual energy demand is mainly for electricity, and then meeting

have an enabling effect by allowing other developments within the

this need through a decentralised natural gas-fired electricity network

Triangle to connect to the NS&OC decentralised network.

with biomass boilers to supply water and building-integrated groundsource heat pumps to supply residual heat. At least 10% of energy supply to the scheme will be from renewable sources, with the potential to increase this further by switching the gas supply from natural to biogas. Table 2: NS&OC proposals and Growth Triangle objectives

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Overall, it can be concluded from the table above that, apart from the obvious implications for the distribution of development, the proposals for NS&OC would have a limited impact on the discretion of the AAP to decide how and where the stated objectives for development in the Growth Triangle are met, and that the effects would be a mixture of constraining and enabling. The main constraining impacts are: • determination of the location of local centres (and community and public services within them) and primary school sites; • alignment and form of the east-west link road and other primary routes; and • permanent conservation from development of Beeston Park. In Beyond Green’s view it is very difficult to envisage that these constraints would, in practice, harm the ability of the AAP to plan sustainably for the area as a whole. The main enabling impacts, conversely, are: • flexibility to establish a district centre on the NS&OC High Street or as part of another scheme elsewhere in the Growth Triangle as appropriate; • provision for small scale employment uses likely to be complementary (and harmless) to the largerfloorplate, less integrated offers of dedicated employment areas; • opportunity, with a supportive planning consent, to co-locate public and community services within clear focal places within NS&OC, or elsewhere, as decisions by service providers determine; • conservation of Beeston Park as a country park with the potential for enhancement to allow it to become a sub-regional resource, potentially reducing the need for such a resource to be identified from developable land elsewhere; • contributions to the on- and off-site transport networks which will help to prime investment and make it easier for other developments to come forward; • maximal connectivity with Sprowston and Old Catton, which it seems unlikely could be improved upon in an alternative planning exercise.

4.3 Conclusion Notwithstanding the very limited weight to be given to the AAP in its current status, it is Beyond Green’s concluding view that granting permission to this development in advance of the preparation of the AAP, whilst inevitably predetermining some matters that, in its absence, could be addressed by the AAP, would not cause any significant harm to the sustainable planning of the wider area and would, rather, make a strongly positive contribution to the delivery of the stated objectives for the Triangle. The clearest potential factor is the allocation of a substantial level of housing to the application site; however all the available evidence indicates that an allocation is likely to need to be made anyway, and the aims of sustainable development would therefore entail that it has the scale and critical mass to sustain the necessary local infrastructure and services. The application as a whole demonstrates how this will be achieved.

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