Object

Representation ID: 20597

Received: 10/03/2020

Respondent: Climate Friendly Policy and Planning (CFPP)

More detailed comments on Egnida EIS document
29 The comments in this section have been kindly provided by Dr Nigel Hargreaves of
the Norfolk Community Solar, and are reproduced with his permission.
30 The EIS is promising, but we highlight concern to the frequent references to CHP (if
biomass or fossil gas fired), gas boilers and diesel generators. No fossil fuel or burning
technology should be encouraged in the plan in the Climate Emergency and for Air
Quality reasons.
31 The report is “light” on some specifics:
i. Inclusion of energy storage as part of the flexibility solution
ii. No mention of community energy, although despite promoting ESCos. The plan
could significantly support community energy schemes via ESCos, as per EIS
page 47 "The potential for local authorities to be involved within this type of
approach [ESCo] is being explored further in an additional study investigating
appetite for local investment and suitability of public, private or hybrid
investment model approaches.”
iii. No mention of microgrids, although “semi-islanded” developments are
mentioned. The plan could provide pro-active policy support to promote
development of these.
iv. There could have been more specific recommendations such as solar car ports
v. Grid connection ‘capacity bagging’ ahead of building should not be tolerated
beyond a limited period.
vi. The Electricity tariff of 11p/kWh set in the case study (EIS, page 40) is far too
low - making the business case for the proposed scheme appear less viable,
despite a healthy looking 8.3% IRR.
vii. The exclusion of community energy shares, or any non-developer commercial
interests, in any of the discussion, which could substantially change the costs and
look of projects, is a big omission. Denmark, Sweden, Germany and even
Scotland are much more switched on to this – why not Greater Norwich?
32 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.