Object

Representation ID: 21981

Received: 16/03/2020

Respondent: Ms Carol Sharp

We cannot see how the proposed additional allocation of sites for housing in “village clusters” can be justified with regard to Climate change targets. You say there will be ‘Growth in villages is located where there is good access to services to support their retention’ Many services are simply not located within these “village clusters” and the additional journeys needed to access them would be contrary to measures 2 and 3 of the Climate Change Statement.

There is little detailed policy on the design of new housing in the draft Plan document, other than a
brief mention in the ‘Design of development’ in the Climate Change Statement. Detailed requirements to insist that new houses include a detailed carbon assessment and are built to the highest possible environmental standards beyond the Government’s minimum standards are needed, if serious steps are to be taken towards addressing Climate Change issues.

We welcome the guidance of the Town and Country Planning Association Climate document which
states :
‘4.5.1 Local development plans must contain policies which, taken as whole, secure radical reductions in carbon dioxide emissions and that Local authorities must have an effective monitoring regime to ensure that there is clear evidence of progress on reducing carbon dioxide emissions, and this progress must be clearly recorded in their annual monitoring reports.’
The methodology to ensure this is not mentioned. As well as CO2, particulate matter (PM) (PM2.5 and PM10) that come off tyres and exhaust or nitrogen dioxide (NO2) gas are both major components of urban air pollution, long-term exposure them increases cardiovascular and respiratory diseases. Currently, there is no clear evidence of a safe level of exposure to PM below which there is no risk of adverse health effects.
The online air monitor at Castle Meadow shows significant increases in pollution levels in the last 2
months on last year’s figures.

Apart from vague statements about developments needing ‘to improve green infrastructure’ there is no mention of any urban tree planting, or any urban planting to help mitigate the increasing pollution in the city and help reach carbon targets.
Some more specifics would be useful, for example from the City of London’s current best practice, informed by scientific evidence, for using green infrastructure to reduce public exposure to road transport pollution.
https://www.london.gov.uk/sites/default/files/green_infrastruture_air_pollution_may_19.pdf
and the University of Surrey’s guide - Implementing Green Infrastructure for Air Pollution Abatement: General Recommendations for Management and Plant Species Selection
https://figshare.com/articles/Considerations_regarding_green_infrastructure_implementation_for_improved_air_quality/8198261/3
Tree planting throughout Norfolk must be encouraged. NNDC has pledged to plant 110,000 trees but
can find nothing proposed for the other councils.

We would like to see a timeline and specific targets for schemes. For example for all public buses and taxis in Norwich to be electric and a charging system similar to London for polluting vehicles using a LEZ (low emission zone) in the city. FOE say South Norfolk should aim to improve the current 16% commuter journeys by public transport, cycling, walking to 40%, and give Norwich a target of 70% of people commuting by public transport, cycling, and walking by 2030.

When cars are needed, they should be shared as much as possible. Only 11% of commuters share their car when commuting in the Norwich area. According to social enterprise Liftshare, best in class
employers have 40% of their staff sharing journeys to work.

Targets for for renewable energy generation are not mentioned. Currently the Norwich area has 7MW of renewable power and the South Norfolk area has 63MW matched with the best of similar local authority areas they would have 29MW and 251MW respectively. This is a minimum target to be achieved rapidly, and all local authorities should look to exceed it.

FOE recommend all councils identify both a councillor at cabinet level and a lead officer as Climate and Nature Champions who are required to publish a bi-annual independent and audited report to the public on progress in meeting climate change and nature targets.

Lastly please consider implementing the Friends of the Earth recommendations to secure sufficient resources to invest in the changes needed to restore nature and meet climate goals:
• Use legal and planning mechanisms such as Section 106 agreements, Community Infrastructure Levy and other mechanisms to fund climate actions and nature restoration projects.
• Raise money from the UK Municipal Bonds Agency for low carbon infrastructure.
• The Workplace Parking Levy (WPL) places a modest charge on employers providing 11 or more parking places, and invests the revenue in sustainable transport measures such as new tram routes, electric buses, cycling and public transport smartcards.