Comment

Representation ID: 22514

Received: 16/03/2020

Respondent: Broadland Green Party

Comment: Good to see reference to and use of the publication “Rising to the Climate Crisis – A Guide for Local Authorities on Planning for Climate Change”. The challenge will be to abide by the guidance. As the guide states, “Although the current National Planning Policy Framework contains strong policy on climate change, delivery on the ground through local plans has been relatively poor. Local plans in England are not dealing with carbon dioxide emissions reduction effectively, nor are they consistently delivering the adaptation actions necessary to secure the long-term resilience of local communities”. As the guide says in its introduction, “climate change is now the greatest challenge facing our society”. The recommendations therefore, need to be taken seriously and be a key reference in the future roll out of the GNLP.

Object and Comment: Bullet point 140 states how the NPPF requires local plans to "Support appropriate measures to ensure the future resilience of communities and infrastructure to climate change impacts" and to set strategic polices which address climate change mitigation and adaptation. The Climate Change Statement does not fulfil this requirement. The statement simply references other policies. It does not provide a comprehensive Climate Change Policy that can be practically applied in, for example, the case of planning applications. Given the climate emergency, a Climate Change Policy should be developed for the GNLP.

In a report to the Sustainable Development Panel, Norwich City Council, 15th January 2020, the Director of Place commented: “There is a disconnect between the vision, objectives and climate change statement and the actual policy substance needed to enable the plan to contribute significantly to the delivery of a low carbon future.”

Table 5 refers to the coverage of climate change issues including having an effective monitoring regime to ensure evidence on reducing carbon dioxide emissions, recorded against the Climate Change Act and other key national statutory and policy frameworks. It further states: “Our ambition is to reduce per capita emissions and thereby contribute to meeting the national target to bring all greenhouse gas emissions to net zero by 2050”.

There has to be more than a simple ambition. There needs to be pro-active measures and the monitoring of trends to ensure the GNLP strategy is working and the targets are met.

The methodology for assessing carbon emissions given in the Sustainability Appraisal is given in Box 2.2 (page 25):

“Development proposals which could potentially increase the Plan area’s
carbon emissions by 1% or more in comparison to the 2017 estimate would
be expected to have a major negative impact for this objective. Development
proposals which may be likely to increase the Plan area’s carbon emissions
by 0.1% or more in comparison to the 2017 estimate would be expected to
have a minor negative impact for this objective.”

Both the above scenarios will still result in an increase in carbon emissions whereas the imperative is to dramatically reduce emissions. The underlying carbon emission footprint must significantly decrease to meet national obligations.

In 2019, carbon budgets were produced for every UK local authority area with the support of the Tyndall Centre at UEA, known as SCATTER models, based on a UK budget calculated using climate equity principles from the Paris Agreement. A summary of the aggregated SCATTER budget for the Greater Norwich local authorities is given below:

[See table in attached document]

A significant step-change in the reduction of emissions is required if we are to reach the stated targets locally, nationally and to meet the Paris obligations. The following graph indicates the magnitude of the task.

[See graph in attached document]

In summary, to meet the UK’s Paris Agreement obligations carbon emissions in the GNDP area need to reduce by an average of 13.4% per year. Continuing at the current rate of emissions will mean using up our remaining carbon budget by 2026/27. These figures are best estimates and are supported by the UEA Tyndall Centre.

The draft GNLP is aspirational with fine sounding statements about combatting climate change but much more is needed than is currently in the draft plan. These are suggestions for serious consideration:

• Zero carbon development through building design to deliver the highest viable energy efficiency. Passivhaus standards, etc.
• Re-use of buildings and recycling of building materials.
• Minimising waste produced.
• Energy recovery.
• Promotion of decentralised energy through encouraging community-led initiatives such as the promotion of decentralised renewable energy.
• Reduce the need to travel, particularly by private car; and secure the highest possible share of trips made by sustainable travel.
• Encouraging development that utilises and promotes the use of sustainable transport.
• Developing a more integrated transport system using new technologies and the promotion of active travel and smarter choices.
• Securing land for local food sourcing and the promotion of allotments.

As stated in Rising to the Climate Crisis: “Action on climate change should be an integral part of the culture of plan-making and should be embedded and integrated into policy preparation. Only by treating climate issues as central to policy formulation will a local authority have effectively discharged its duty under the 2004 Planning and Compulsory Purchase Act. ”

Such policies also support other health and social objectives. Safe active travel, such as cycling, and local food sourcing, supports healthier lifestyles and social interaction at the same time as reducing carbon emissions.

Behaviour Change

There is no clear strategy for the required behaviour change to turn awareness into action. The 2008 Climate Change report for Norfolk recommended:
“Our behaviour change strategy should be unified under a strong, single sustainability brand for Norfolk that is readily recognised and promotes a clear message. We will need to include clear steps for engaging proactively with the wider local community to incentivise and reward behaviour change, working with community groups, schools, businesses and local partners.” (page 38).

“Norfolk is particularly vulnerable to the impacts of climate change, and has a higher carbon footprint per person than the UK average. We need to take action both to reduce our contribution to the problem and minimise our exposure to future risks.” (page 39).

We therefore recommend implementing the “Next steps” as stated in the 2008 report:
• Establish a wider Climate Change Partnership for Norfolk, with Sector Groups to address our strategic priorities, with clear governance and performance management arrangements to ensure we deliver.
• Develop a Behaviour Change Strategy, including detailed plans for community engagement.