Object

Representation ID: 20594

Received: 10/03/2020

Respondent: Climate Friendly Policy and Planning (CFPP)

Policy 4: Transport
CONS, page 61, Policy 2, bullet 6. This is a very weak, bland statement and contains no
reference to modal shift and targets for modal shift.
We note that the Director of Place, Norwich City Council, has commented that Policy 4
is “insufficiently ambitious in supporting the transition to a low carbon future by
achieving significant modal shift” 6.
We would agree and suggest a modal shift hierarchy needs to be developed and made
central to Policy 4, Transport section. Road building, known to increase traffic, lock-in
car dependence, congestion and carbon emissions, should be the option of last resort.
Currently Policy 4 places various road building projects as options of high priority; these should be removed as below.

Policy 2: Energy section
26 EIS, Table 1, page 5. This essentially showed the lights going to go off in most of
Norwich with the planned developments and without any intervention. This risk to the
existing network is an argument for a much more creative, visionary approach to energy
which would facilitate significant carbon reduction too. The GNDP councils should be
thinking of smart grids, much greater efficiency in housing (including retrofit insulation
programs), greater on-site renewables and energy balancing and storage. The Egnida
EIS document does make some good suggestions toward this (see more detailed critique
below), for example “semi-islanded development” in chapter 5.
27 However, CONS, Page 61, Policy 2, bullet 10 (Energy policy) does not pick up on this
and embed it into policy. The statement needs to be much more pro-active. It also
needs to be factored through into the site appraisals which does not appear to have be
done.
28 Further on CONS, Page 61, Policy 2, bullet 10 – “All new development will provide a
20% reduction against Part L of the 2013 Building Regulations (amended 2016)”. This
is a weak target with other areas doing better. For example, Bristol and London (GLA) have 35% beyond Building Regulations, and Reading “All housing developments over
10 dwellings / 1000m2 to be designed to achieve zero carbon (subject to viability)”. The
financial arguments against more than 20% at the top of CONS, page 63, need to be
revisited.