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Representation ID: 20592

Received: 10/03/2020

Respondent: Climate Friendly Policy and Planning (CFPP)

Please see attached for full representation

CONS bullet 84 introduces per capita CO2 footprints, whilst SA 2.11 (page 25)
introduced the population-wide footprint (from the DBEIS data for UK local
authority and regional carbon dioxide emissions national statistics). Whilst
both ways of looking at the data (per capita or population-wide) are valid, it
would be preferable to use just one. The population-wide footprint is the most
appropriate as that relates directly to the overall CO2 budget available.

Need for baseline carbon emissions, budgets and targets
17 The draft plan contains quite a few statements on Climate Change that sound promising
(for example, bullet CONS 82 “Mitigating the effects of climate change within the
Greater Norwich area is a cornerstone of the GNLP”) but which lack substance and any
clear demonstration of a route to their deliverability.
18 We have made the case, many times previously (please refer back to previous
consultations responses from NGP, CEPP and Dr Andrew Boswell) that the gap between
warm words and deliverability can only be achieved by fully understanding baseline
carbon emissions, setting a GNLP carbon budget that is aligned to national and
international obligations, and with measurable targets for achieving it. None of this
exists in the draft plan.
19 Again, we refer to the Stroud Draft plan as an example of good practice. Here the
Council declared a target to become carbon neutral by 2030, ahead of the current
Government target. This target has been brought into the local plan, joining up political
will with strategic planning3.
20 The situation in Greater Norwich is less clear politically with the County Council stating
in its Environmental Policy that it will work towards carbon neutrality by 2030, the City
Council having a 2050 target. And Broadland and South Norfolk apparently working
towards positions. There is a clear need for a unified target across the area, and for it
then to be embedded into the GNLP with the necessary policies to help deliver it through
the strategic planning system. No work appears to have been done on this, although the
time before the Regulation 19 consultation and subsequent process, gives space for
related political decisions to be progressed.