Policy 2 - Sustainable Communities

Introduction

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The Sustainable Communities policy is wide ranging. It aims to ensure that the design of development is high quality, contributes to the establishment and maintenance of resilient and inclusive communities, promotes low carbon development and helps to address climate change. It is a key strategic policy, covering many aspects of the vision and objectives of the plan. Together with policy 3, which focuses on the design of development reflecting local character and sense of place using local design guidance, the policy promotes well-designed places as required by section 12 of the NPPF.

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The policy covers ten key social, economic and environmental issues which all developments must address through their design. These are set out in table 8 below. The table also references other relevant plan policies and supporting supplementary planning documents. 

Table 8 - Key issues addressed by policy 2

Issue number in policy 2

Requirement and justification

  1. Access to services and facilities

Developments are required to provide convenient, safe and sustainable access to new on-site services and facilities or to existing facilities as appropriate. This reduces the need to travel and provides local access to services and facilities, supporting their viability. The provision of safe and accessible green infrastructure, sports facilities, local shops, access to healthier food, allotments and layouts that encourage walking and cycling also helps to support healthy lifestyles.  In this respect, regard should be had to Sport England’s Active Design document. Strategic infrastructure is provided for through policy 4.

  1. New technologies

The policy requires development to make provision for the delivery of new technologies. Such a strategic approach is important for economic growth and will have environmental and social benefits, such as assisting in home working. The policy encourages developers to work with service providers on the delivery of a broad range of existing, developing and future technologies, with broadband and mobile phone networks a current focus.

Developers must therefore ensure broadband infrastructure is provided for new developments. To do this, they should register new sites with broadband infrastructure providers.  The preference is that all residential developments over 10 dwellings and all employment developments will provide Fibre to the Premises (FTTP) for high connection speeds. For smaller schemes, the expectation is that FTTP will be provided where practical. Where this is not possible, then non-Next Generation Access (NGA) technologies that can provide speeds more than 24Mbps should be delivered.

The policy also provides the basis for more detailed supplementary planning documents for measures to support new technologies in times of rapid change, including modern construction techniques and the use of electric and possibly hydrogen vehicles. 

  1. Green infrastructure

Developments are required to provide on-site green infrastructure appropriate to their scale and location. The three main benefits of green infrastructure: biodiversity gain; the promotion of active travel and the reduction of flood risk, are key NPPF priorities. On-site provision will link and contribute to the further development of an area-wide green infrastructure network, promoted through policies 3 and 4, which has now been in development in Greater Norwich for over a decade in accordance with the Greater Norwich Green Infrastructure Strategy and delivery plans, and other documents such as the River Wensum Strategy. 

  1. Densities

In line with the NPPF, developments are required through this policy to make effective use of land. To do this, the policy establishes minimum net densities for different parts of the area.  It requires higher densities in the most sustainable locations. These are mainly in Norwich and in the city centre where, dependent on design issues, high densities have and can be delivered. It also establishes a minimum density elsewhere to ensure the effective use of land. In determining the appropriate density for a development, regard will need to be had to the type and size of housing; for example, a greater number of 1- bedroom properties can be accommodated compared to 5-bedroom properties. The policy will be used with policy 3 which focuses on design creating a distinct sense of place and reflecting local character.

  1. Local character (including landscape, townscape, heritage )

The NPPF requires local plans to recognise the intrinsic character and beauty of the countryside, and respect local character and the historic environment  Accordingly, the policy requires development to respect local character, based on existing and any future landscape, townscape or historic character assessments, and avoids harm to locally valued landscapes and the historic environment from inappropriate development. It continues the well-established approach in Greater Norwich of having strong landscape protection policies. To do this, it provides the continued strategic policy basis for more detailed, location specific development management policies covering the strategic gaps and landscape settings including river valleys, undeveloped approaches to Norwich and the setting of the Broads. This is the most suitable approach to landscape protection locally given that Greater Norwich does not have the exceptional circumstances required by Government to establish a Green Belt.  

  1. Travel

The policy requires appropriate development to be designed to manage travel demand, promote active and sustainable travel and to ensure parking is addressed effectively. The design of development, as well as its location67, and the local availability of services addressed in point 1 of this policy, play an important role in determining how much and how people travel. This is particularly the case on larger sites where good design can significantly influence travel habits. In addition, the policy requires sites to be designed to accommodate parking without impacting on the amenity of residents or over dominating the site. 

  1. Inclusive and safe communities

In line with the NPPF, this element of the policy covers social aspects of the design of development. The requirement focuses firstly on ensuring services are accessible either within or from new developments. Secondly, the policy covers the creation and maintenance of resilient, safe and inclusive communities in which all members of society can interact. Thirdly, the design of development is required to promote healthy and active lifestyles.

  1. Resource efficiency and pollution

This part of the policy covers a range of the environmental issues that new development must focus on, most of which have an impact on addressing climate change. In terms of maintaining air quality, particular regard to this will be expected of developments within or near identified Air Quality Management Areas or main roads.  Point 8 provides the strategic basis for any more detailed guidance on resource efficiency, pollution, overheating and ground conditions. 

  1. Water

Point 9 of the policy covers the range of issues related to water affecting new development, including flood risk, water quality, sustainable drainage (SUDS) and water efficiency. As evidenced by the Strategic Flood Risk Assessment, the great majority of development promoted through this plan avoids areas at risk of flood. Any mitigation required, mainly in parts of Norwich city centre and East Norwich, will come forward as part of specific developments and will be guided by the level 2 Strategic Flood Risk Assessment.

Government policy expects local planning authorities to adopt proactive strategies to adapt to climate change, taking account of water supply and demand considerations. It allows local plans to set a higher standard of water efficiency than the Building Regulations where evidence justifies it. For housing development, only the higher Building Regulations standard for water prescribed by Government (110 litres per person per day) can be applied through local plans and more demanding standards cannot be set.  If the potential to set more demanding standards locally is established by the Government in the future, these will be applied in Greater Norwich. For non-housing development, broadly equivalent standards can be required using BREEAM assessments.

In Greater Norwich, evidence and justification on the need for water efficiency measures includes:

  • The Environment Agency (EA) has identified Greater Norwich as water stressed in its ‘Water Stress Area Final Classification (2013), the primary source of evidence which supports a tighter water efficiency standard;
  • The need for water efficiency is particularly significant in Greater Norwich given its proximity to internationally protected water environments, including the River Wensum and the Broads;
  • Anglian Water’s strategic approach68 to providing water supplies to meet growth needs includes a major focus on water efficiency measures;
  • The Norfolk Strategic Planning Framework and the key relevant organisations, the Environment Agency and Natural England, all support retaining this approach which has been in place in Greater Norwich since 2011;
  • The cost of such a policy, implemented using water efficient fixtures and fittings, is negligible69. It can be easily achieved through a flexible variety of measures to suit different types of homes and buildings. The cheapest approach is the use of water efficient fixtures and fittings. Solutions can also include the use of greywater recycling and rainwater capture. It will have no effect on development viability and will lead to financial savings for householders and users of other developments, along with carbon emissions reductions.

Implementation of the standards for water efficiency will be supported by an updated advice note.

  1. Energy

Point 10 of the policy requires development to be designed and orientated to minimise energy use, an easily achievable and cost-effective means of promoting low carbon development. It also supports decarbonised energy supplies locally by promoting measures such as decentralised, renewable and low carbon energy generation, co-locating potential heat customer and suppliers, and battery storage, as well as energy efficiency in new developments.

This approach to energy in new developments is required as:

  • Evidence70 shows that a positive approach to promoting energy efficiency and locally generated sustainable sources of energy, as well as promotion of the use of battery storage, is required to address local energy network capacity constraints and to ensure the timely delivery of growth;
  • The NPPF requires a positive approach to be taken to promoting energy efficiency. In doing so, policy 2 anticipates the Government’s “Future Homes Standard” currently scheduled to be introduced by 2025, which will require all new build homes to have low carbon heating and high levels of energy efficiency.  When the Government implements the Future Homes Standard it will strengthen (or replace) the GNLP policy approach by providing further measures. The NPPF also requires a positive approach to large scale renewable energy generation except for onshore wind energy development.  No suitable sites for onshore wind energy development have been submitted to the GNLP. The best ways to display local support, as required by the NPPF, for onshore wind energy are through a neighbourhood plan which requires a local referendum or through any other future local plan documents which may consider suitable sites71;
  • The LEP strategy72 identifies energy as one of five high impact sectors with the potential for growth;
  • Policy 2 makes necessary updates to existing development management policies to address the above.

Policy 2 therefore establishes standards for energy efficiency in new housing and non-housing development. If required, further detail on how this will be achieved will be set out in a future Energy Policy Implementation Note or SPD. This approach is deliberately flexible as:

  • The defined standards are not prescriptive. They allow for either a “fabric first” approach to reducing energy use, which on many types of site tends to be cheaper, or the use of on-site sustainable energy, or a mixture of both;
  • Implementation notes or SPDs can be amended to reflect rapid changes technologies and other changes of circumstance such as changes to national policy, such as Government’s indication through a ministerial statement that national policy will change in 2025 to prevent the use of fossil fuels to heat new homes.

Evidence shows the policy is viable73.  Investment in energy efficiency in new development will have the significant additional benefits of reducing energy costs for the users of new development, as well as carbon savings.

The policy also requires larger developments (100 dwellings plus or 10,000 square metres plus for non-residential development) to maximise opportunities for the use of sustainable local energy networks. This requirement is also set in line with the recommendations of the Greater Norwich Energy Infrastructure Study.

The study sets out that there are likely to be constraints on the electricity grid and recommends ways to avoid or reduce the costs of improved network connection which are relevant to all larger sites, and to those sites affected by grid constraints named in appendix 1. Measures to implement point 6 of the policy, to be evidenced on a site by site basis through the Sustainability Statement, could include:

  • Semi-islanded approaches including high levels of on-site, renewable or low carbon generation and batteries;
  • Demand side responses, where on-site generation could be turned up or load reduced in response to network signals;
  • Investment in infrastructure delivered through an Energy Services Company, which can then provide a steady revenue stream for those involved.

Footnotes

67Addressed through policy 1 of this plan.

68Anglian Water - Water Resources Management Plan December 2019

69Estimated by the Government at £6-9 per dwelling  (The Housing Standards Review, 2014)

70The Greater Norwich Energy Infrastructure Study (March 2019)

71Neighbourhood Plans proposing wind turbine development in South Norfolk should take account of its Wind Turbine Landscape Sensitivity Study

72New Anglia Local Enterprise Partnership’s Norfolk and Suffolk Economic Strategy

73GNLP Viability Assessment (NPS, September 2019) – updates will inform the cabinet version of the plan in January 2021