Observations and comments
Carbon footprint
The GNLP Reg 19 draft plan is neither sound nor legally compliant. It provides no effective modelling of baseline carbon emissions for the plan area and how to reduce them by 2038. What, for example, is the proposed house building carbon footprint between 2018 and 2038? There is no measure or target for this key parameter so how will you monitor?
The Plan needs to address how carbon emissions are to be reduced. It does not effectively do this.
A clear process needs to be included on how to assess and monitor carbon emissions so that progress, or lack of progress, can be monitored and publicised so that effective mitigation actions can be taken.
Planning and Compulsory Purchase Act 2004 requires, by law, robust climate change policies in local plans. Such climate change policies should be consistent with national policy. NPPF 149 states:
“Plans should take a proactive approach to mitigating and adapting to climate change, taking into account the long-term implications for flood risk, coastal change, water supply, biodiversity and landscapes, and the risk of overheating from rising temperatures”.
Local Plans must also be in line with the objectives and provisions of the Climate Change Act 2008. The “Climate Change Statement” at Reg 19, 157, does not constitute a holistic strategic policy on climate change and the reduction of carbon emissions.
Hence, without an overriding strategic policy on how climate change will be addressed within the GNLP the plan is neither effective nor sound.

Norwich Western Link (NWL) Road
NWL is assumed as infrastructure that will be delivered under Policy 4. However, such a major piece of infrastructure needs to be tested for compliance with climate change policies and carbon footprint.
The NWL must be tested for soundness on several issues:
• Compliance with national policy on climate change and international obligations under the Paris Agreement under strategic Policy 4, and plan “ambitions” to reduce carbon emissions.
• Any adverse effect on the integrity of sites protected under the Habitats Regulations Directive, especially under strategic Policy 4.
• Land allocation for the construction of the NWL.
The GNLP is not sound on any of these counts. Therefore, the inclusion of the NWL in the GNLP is unsound and not consistent with national policy to reduce transport emissions by 70% by 2035.

The claim in Reg19, 83 claims “mitigating the effects of climate change within the Greater Norwich area is a cornerstone of the GNLP”.
This statement is clearly not true. The Plan needs revision.