Comment
Stage C Evidence Base
Representation ID: 22240
Received: 16/03/2020
Respondent: ClientEarth
1. In respect of energy efficiency, we welcome the statement that “the evidence and justification establish a clear need to set a local energy efficiency policy which goes beyond 2013 Building Regulations” (p. 62). However, the accompanying statement that going further than a 20% improvement on Part L would not be viable would not appear to be supported by the Interim Viability Assessment (November 2019). In particular, it is not clear from the viability assessment that higher standards have been assessed. In this context, a zero carbon standard should be the starting point that is worked back from to the extent that any viability constraints are identified. Where there are viability constraints affecting a particular category of dwelling or scale of development, then standards should be reduced for that category or development size only, avoiding a ‘lowest common denominator’ approach. It is also not clear where the £15,000 cost per dwelling figure for higher efficiency standards (cited at page 63 of the draft strategy) is derived from or to what standard this figure relates.
2. The Energy Infrastructure report prepared in May 2019 – i.e. before the introduction of the UK’s net zero target – concluded in the planning policies section and in the context of climate mitigation that “these policies represent a medium level of ambition within the context of the existing constraints and wider national policy goals.” (p. 44). This indicates that a higher level of policy ambition is possible, including in respect of renewable and low carbon energy generation, and that the proposed policies should be reviewed accordingly.
In September 2019, we wrote to the Greater Norwich planning authorities about the need to integrate emissions reduction objectives throughout local plan policy. We are therefore pleased to see a commitment in the draft strategy to ensure policies in the GNLP “contribute to meeting the national target to bring all greenhouse gas emissions to net zero by 2050, as well as helping to meet local targets, statements and plans” (p. 40). We also welcome the statement that “policies in the GNLP will need to contribute to national targets to reduce emissions [and] plan for transition to a post-carbon economy” and that mitigating climate change is “a cornerstone of the GNLP” (paras 82 and 86).
However, we are concerned that these commitments have not in fact been met in the development of the proposed plan policies. It is not sufficient that the plan merely includes policies “which address climate change mitigation” (as suggested at para 140). Plan policies taken as a whole must be “designed to secure that the development and use of land in the local planning authority's area contribute to the mitigation of climate change”.1 In this context, they must “contribute to radical reductions in greenhouse gas emissions” and “take a proactive approach” to mitigating climate change “in line with the objectives and provisions of the Climate Change Act 2008.”2
To comply with this obligation and the other law and policy requirements described in September letter, local planning authorities need to demonstrate that the proposed plan policies are expected to contribute to the mitigation of climate change. At a minimum, this means showing that the policies contribute to the delivery of the national 2050 target under the Climate Change Act 2008, which is a reduction in net greenhouse gas emissions of “at least 100%”.