Object

Representation ID: 20593

Received: 10/03/2020

Respondent: Climate Friendly Policy and Planning (CFPP)

Climate Change Statement
3 We welcome the Climate Change Statement at CONS page 38 as, for the first time in the
GNLP process, issues relating to Climate Change have been brought together in one
place. This is helpful.
4 However, the statement serves only as a set of pointers into other policies. It does not
provide a Climate Change (CC) policy. As such, it is not effective in providing an
overarching policy on CC that can have effective weight at later planning application
stages which is required by the legislation.
5 Despite, bullet CONS 140 immediately above the statement stating how the NPPF
requires local plans to set strategic policies which address CC mitigation and adaptation,
the statement does not fulfil this requirement.
6 However, the statement, with its different limbs, forms that basis of material that could
be converted into the skeleton of an overarching GNLP Climate Change policy. Such a
policy would be a very positive step for GNDP to take considering the Climate
emergency. However, we emphasise the word skeletal, as there would be additional
work to take the skeletal structure provided by the statement and turn it into a robust
policy, as we outline below. We posit strongly that this is done for the next draft of the
plan.
We note that the Director of Place, Norwich City Council, has commented that there is a
disconnect between the Climate Change statement and the policy substance needed for
the plan to “contribute significantly to delivery of a low carbon future”.
Overall, we submit that a dedicated CC policy is required. As a recent example of good
practice in please see Stroud District Local Plan Review, Draft Plan, in which a new
Core Policy on Climate Change mitigation has been included.

Trend based baseline carbon emissions, budgets and targets
Overall there has been a 28% reduction in emissions over this period. The figure above
shows that in Greater Norwich area, Industry and Domestic emissions have reduced
whilst Transport emissions are rising and are at the same levels as in 2005. In general,
national trends in the decarbonisation of electricity has enabled significant reductions for
industrial and domestic carbon footprints. A robust climate change policy in the GNLP
could have further significant impact locally on bringing down Industry and Domestic
emissions.
12 Road transport emissions have made no significant reductions in over 14 years,
indicating a major policy failure, both nationally and locally. This may only be
remedied by a very tough set of policy interventions in transport for modal shift away
from private car use; electric vehicles may only play a small part in decarbonising
transport for reasons we give elsewhere. The GNLP Climate Change and Transport
policies should have reducing transport emissions as their number one objective.

Policy 4: Transport
22 Policies 2 and 4 are mentioned at CONS, page 39 (the Climate Change Statement table).
The DEFRA Clean Growth Strategy objective to meet a 30% reduction in carbon
emissions from road transport by 2032 should be included here as a footnote (before
footnote 49). As above, the SA states that this objective will not be met by the plan.

More detailed comments on Egnida EIS document
Throw away comments in the CONS document eg: CONS, page 39 (Climate Change
statement) “Encourage community-led initiatives such as the promotion of decentralised,
renewable and low carbon energy use or securing land for local food sourcing”, and
CONS, page 101, Policy 7.1 “providing for sustainable energy generation, including a
local energy network serving the area as a whole” need much more development within
the plan.