Sustainability Appraisal and Strategic Environmental Assessment (January 2020)
Full Evidence Base
Representation ID: 20596
Respondent: Climate Friendly Policy and Planning (CFPP)
Issues with baseline carbon emissions, budgets and targets
8 Previous submissions by CEPP and NGP have made the case for baseline carbon
emissions, budgets and targets to be developed for the GNLP in a numerically
quantifiable, measurable and reportable form. The draft plan makes no progress
compared to the JCS on this, and also includes some confusing elements. These are:
(A) CONS bullet 84 introduces per capita CO2 footprints, whilst SA 2.11 (page 25)
introduced the population-wide footprint (from the DBEIS data for UK local
authority and regional carbon dioxide emissions national statistics). Whilst
both ways of looking at the data (per capita or population-wide) are valid, it
would be preferable to use just one. The population-wide footprint is the most
appropriate as that relates directly to the overall CO2 budget available (see
(B)No historic or future trend information is given. Any meaningful narrative
around carbon emissions must be focussed around trends, and national policy is
framed in targets (eg net-zero by 2050, or the Paris Agreement temperature
target of 1.5degrees). Targets imply a “journey” to reach a target, and
understanding trends, both real historic one and projected future ones, is
necessary to understand the journey.
(C) The methodology for assessing carbon emissions in the SA is given at SA, 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.”
It later becomes apparent in the SA (though it is not clear in the statement
above), that the percentage increase in carbon emissions for the above test is
calculated by simply calculating the increase in emissions based on new
population and the current levels of emissions. This method is naïve and
flawed for the following reasons.
It ignores the crucial fact that the underlying carbon emission footprint must
significantly decrease to meet national obligations. For example, using the
SCATTER budgeting (see below), emissions should be decreasing by over
13% per year. There is a real increase in emissions from population growth, but this is a second-order effect compared to the real reductions (a much larger
quantity) implied by meeting budgets – the first-order effect. Therefore, the
SA methodology is based on minor second-order effects rather than the
predominant first-order effect, and provides no reliable guidance on assessing
carbon emission reductions for the SA.
Further, it suggests that the only way the local plan can affect carbon emissions
is by population growth. And that all other effects of carbon emissions will
result from external effects (eg: national CC policy instruments).
However, the principle underlying Section 19(1A) of the Planning and
Compulsory Purchase Act 2004 is that local plans themselves must include
policies designed that “contribute to the mitigation of, and adaptation to,
climate change.” The SA provides no method to assess these policies, and it
should do to be consistent with the Act.
(D) The above SA test and SA methodology effectively set a default target for the
GNLP of maintaining carbon emissions as they are. This is clear that
development which did not increase the population would register a 0%
increase or decrease in emissions. The notion that underlying emissions stay
constant is not consistent with national policy.
(E) This approach appears to be reflected in the Monitoring Framework, and
objective GNLP16 which is:
“To minimise carbon dioxide equivalent emissions per capita to contribute to
meeting the national target to bring all greenhouse gas emissions to net zero
by 2050, taken from the Department for Business, Energy and Industrial
This appears to be the same monitoring as under the JCS where any reduction
in emissions (even a fractional percentage) is scored RAG “Green”.
“Minimise” means no increase. This is a wholly inadequate monitoring regime
in two respects:
i. in the climate emergency, significant year-on-year reductions are
ii. no quantification is given at all
The Sustainability Appraisal shows Climate Change objectives are not met
21 We have indicated above that the methodology for assessing carbon emissions in the SA
is not fit for purpose. However, despite this, the SA indicates in several respects that the
Climate Change objectives of the plan are not met, and emission reductions are not
(A) SA, page 72, Table 4.2 gives an impact matrix of all the policies assessed.
“Climate Change Mitigation and Adaptation” and “Natural Resources, Water and
Contaminated Land” each score the most negative scores as indicated by red
squares. “Air Quality and Noise” score the next worse. This impacts significant
environmental impacts of the plan objectives, especially for Climate Change. In
a Climate Emergency this is not a viable way forward.
(B) SA, page 53, Table 3.2 gives an impact matrix of all the sites assessed. Many
sites are scored red for Climate Change.
We note that the Director of Place, Norwich City Council, has commented that
the level of growth in rural areas “is very hard to reconcile with the climate
change agenda and the need to reduce carbon emissions” 4 which is reflected in
the SA assessment.
(C) SA, page 62 (part of Table 3.3) identifies adverse impacts. Under Climate
Change “Contribution to greenhouse gas emissions”, it states under 3 bullets:
i. That Policy 2 for low carbon energy generation and sustainable building
design is not expected to fully mitigate this impact. The statement is
meaningless as “this impact” is not defined properly, and what “fully
mitigate” would mean is also not defined. The statement lacks any
quantification; this is where proper budgeting, footprinting and targeting
could turn a meaningless statement into something which is measurable
ii. Policies 2, 3, 4 and 6 will provide a “multifunctional green infrastructure
network” that will provide “additional carbon storage” or carbon sinking.
This is again fine words, but totally unquantified. There is no clear
indication of what is intended to be achieved, and how much carbon will
be sunk, and how, and how much, it will contribute to keeping with a
Paris aligned carbon budget for the area.
The role of Green infrastructure as a carbon sink needs to be developed
with details of specific methods which will produce the best outcomes in
iii. Policy 4 aims to encourage sustainable transport and a reduction in traffic
related carbon emissions. They policy is not expected to meet a 30%
reduction in carbon emissions from road transport by 2032, an objective
under the 2018 DEFRA Clean Growth Strategy. This is of great concern
– we have shown above that transport emissions in the area are at 2005
levels and rising. We look at Transport in Policy 4 in more detail below.
We note that the Director of Place, Norwich City Council, has
commented that “the lack of ambition on transport issues and the focus on
significant development in rural villages is inconsistent with the
statements within the plan on addressing climate change” .
Please see attached
Please find my submission on the "Stage C Regulation 18 Draft Strategy and Site Allocations" consultation. This document comprise part of the Norwich Green Party submission, and submitted early as I am going away. I understand other sections of the Norwich Green Party submissions will follow later.
Full Evidence Base
Representation ID: 20697
Respondent: Norfolk Geodiversity Partnership
Box 2.3: SA Objective 3. Biodiversity, Geodiversity and Green Infrastructure
Geodiversity is mentioned in the title but is nowhere mentioned in the policy text. This means that the GNLP is unable to demonstrate that it is meeting sustainability measures for geological conservation, as per sections 109 and 1117 of the NPPF. This section needs rewriting to include County Geodiversity Sites and to explain how the GNLP can demonstrate that it can assess how it is meeting geoconservation objectives and what evidence base it will use.
Box 2.3: SA Objective 3. Biodiversity, Geodiversity and Green Infrastructure – Assessment Methodologies and Assumptions
* PAGE 27
Geodiversity is mentioned in the title but is nowhere mentioned in the policy text. This means that the GNLP is unable to demonstrate that it is meeting sustainability measures for geological conservation, as per sections 109 and 1117 of the NPPF. This section needs rewriting to explain how geoconservation objectives are to be assessed.
Mentions 'ecological receptors'. Are geodiversity assets considered to be one of these? If so that needs to be made explicit, and will need a lot of explanation !
List of Designated Sites
These include County Geodiversity Sites (CGS), which have equivalent Local Sites (non-statutory) status as County Wildlife Sites.
< Where a development proposal is coincident with, adjacent to or located in close proximity of an ecological receptor, it is assumed that negative effects associated with development will arise to some extent.>
How will negative effects of development proposals on geodiversity be assessed? What evidence base for sites will be used?
* PAGE 28
<Negative impacts would be expected where the following ecological designations may be harmed or lost as a result of proposals>
The list should include County Geodiversity Sites (CGS).
< It is anticipated that the GNDP will require detailed ecological surveys and assessments to accompany future planning applications >
Geodiversity needs to be scoped as well as biodiversity.
Full Evidence Base
Representation ID: 21839
Respondent: Natural England
Sustainability Appraisal and Strategic Environmental Assessment Report
Natural England welcomes the production of the latest iteration of the above document, dated January 2020, and prepared by Lepus Consulting, and in the following comments below it shall be referred to as the Sustainability Appraisal (SA).
We previously commented on the scoping of the SA in our response dated 12 August 2016 (our ref: 1887410) and on the interim SA in our response (dated 21 March 2018; our ref 235617) to the GNLP growth options and site proposals consultation. Whilst we recognise that some of our advice has been reflected in the latest version of the SA, we have the following comments to make:
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
We support Broadland District, Norwich City and South Norfolk Councils’ preparation of a joint Local Plan to ensure a consistent approach to planning across the Greater Norwich area, with policies aligned with the revised National Planning Policy Framework (NPPF).
We have made detailed comments in this letter in relation to the following Greater Norwich Local Plan (GNLP) consultation documents:
Draft Local Plan – Part 1 The Strategy
Draft Sites Document
Habitats Regulations Assessment of GNLP, December 2019
Sustainability Appraisal and Strategic Environmental Assessment, January 2020
Natural England acknowledges that the findings of supporting documents including the draft Greater Norwich Water Cycle Study (WCS) (AECOM 2019) and the emerging Green Infrastructure and Recreational Impact Avoidance and Mitigation Strategy (GIRAMS) will need to be incorporated in the policies of the Local Plan and supporting documents, once these are finalised.
To summarise our response briefly, we broadly welcome the progress and development of aspects of the Local Plan and supporting documents to date, though Natural England is not yet satisfied that the relevant Plan polices will provide sufficient mitigation to ensure that there will be no adverse impacts to designated sites alone, and in-combination, through changes in water quality and resources and in regard to recreational disturbance, and to demonstrate that policies are sustainable.
Full Evidence Base
Representation ID: 22239
n respect of transport emissions, the conclusion of the Interim Sustainability Appraisal (January 2020) on the location of sites suggests that dramatic changes are required to ensure that new development has sufficient access to sustainable transport and services:
“Almost all of the sites would be likely to situate site end users in locations with poor transportation links and access to surrounding areas, and approximately half of the sites have been assessed as having poor pedestrian accessibility in terms of access to surrounding pavements, footpaths and the PRoW network. The majority of the sites have good access to the surrounding road network, however, due to the rural nature of many of the sites, the proposed development would be unlikely to locate site end users within a sustainable distance to a railway station or a bus stop providing regular services.” (p. 72)
4. The approach to assessing the emissions impact of individual development sites in the Interim Sustainability Appraisal also fails to give any meaningful guidance on the suitability of different sites, including in terms of their associated transport emissions. As explained on page 25 of the Interim Sustainability Appraisal, the report appears simply to assess sites by the number of inhabitants applying constant per capita emissions and then categorises the sites as having a “major” or “minor” negative impact depending on whether any assessed increase in the area’s emissions falls above a 1% or 0.1% threshold respectively.
5. The approach to assessing the overall emissions impacts of plan policies in the Interim Sustainability Appraisal is also incomplete, without adequate justification or explanation, contrary to the Strategic Environmental Assessment (SEA) regulations. Nonetheless, it indicates that some of the plan policies will not contribute sufficient emissions reductions. For example, it is stated:
“Policy 2 aims to meet national carbon reduction targets by facilitating a reduction in carbon emissions through the promotion of low carbon energy generation and sustainable building design. However, these policies would not be expected to fully mitigate this impact … Policy 4 aims to encourage the integration of sustainable transport options in the design of new development and therefore contribute towards a reduction in traffic related carbon emissions. However, this policy would not be expected to fully mitigate this impact and is unlikely to facilitate significant reductions in carbon emissions, in line with objectives set under the 2018 DEFRA Clean Growth Strategy (30% reduction in carbon emissions from road transport by 2032).” (p. 62)
The Sustainability Appraisal also makes the following recommendation for plan policy:
“Policies should seek to prioritise renewable and low carbon energy sources, opportunities for development to draw its energy supply from decentralised, renewable or low carbon energy supply systems and for co-locating potential heat customers and suppliers.” (p. 62)
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%”.
Full Evidence Base
Representation ID: 23088
Respondent: Orbit Homes
Agent: David Lock Associates
We support the inclusion of GNLP2168 (Silfield Garden Village) as a ‘reasonable alternative’ withn the Sites Assessment and are of the view that if allocated could deliver sustainable growth and help to meet the objectives and ambitions of the GDNP.
We consider that SGV as a reasonable alternative site would be of great value to the GDNP in meeting the housing needs of the GNLP and this is covered in more detail in our representation on the Strategy Document.
However, we strongly object to the approach to the site assessment taken within the draft GNLP Sites document. Our comments below should be read in conjunction with the comments made on the approach to village clusters set out above which are interlinked to how the site assessment approach has been undertaken and preferred sites decided.
The decisions made within the draft GNLP Sites document are informed by the individual site assessment booklets which in turn have been informed by the various iterations of the HELAA.
It is noted that no site assessment booklets have been produced for the South Norfolk Village Clusters given the proposed approach to produce a separate document to allocate these sites (see comments on this approach in Section 2).
The individual site assessment booklets set out a 7-stage approach to the site assessment process. The process is outlined as follows:
THE SITE ASSESSMENT APPROACH
• Stage 1 – List of sites promoted in the settlement;
• Stage 2 – HELAA tables;
• Stage 3 - Summary of consultation comments;
• Stage 4 - Discussion of submitted sites;
• Stage 5 – Shortlist of reasonable alternative sites for further assessment;
• Stage 6 – Detailed site assessments of reasonable alternative sites; and
• Stage 7 – Settlement based appraisal of reasonable alternative sites and identification of preferred sites.
On this basis, it is not clear how the SA has featured in the site assessment process. We suggest that this is made more explicit for the next round of consultation, and would welcome any clarity on this point in the meantime.
In addition, some of the site assessment stages which have taken place are vague in detail and process. For example, the Stage 3 commentary recorded includes both attributed and non-attributed commentary (so it is unclear whether comments are from promoters, the Council, other stakeholders of objectors), and whilst it includes some stakeholder comments (eg. Wildife Trust) it does not include others.
Equally, Stage 4 (Discussion of Submitted Sites) does not include any written evidence (such as written minutes of discussions; a record of what criteria shaped these discussions; or a list of main outcomes), so it is not clear to a member of the public or a developer why a particular site has been excluded from the next stage of assessment.
We suggest that without further clarity on this matter, the assessment process is flawed. Again, this matter should be addressed as part of the next round of consultation.
Sustainability Appraisal comment in attachments.
For full representation, please refer to the attached documents.
Full Evidence Base
Representation ID: 23152
Respondent: Gladman Developments
3.2.1 In accordance with Section 19 of the 2004 Planning and Compulsory Purchase Act, policies that are
set out in local plans must be the subject of a Sustainability Appraisal (SA). Incorporating the
requirements of the Environmental Assessment of Plans and Programmes Regulations 2004, SA is a
systematic process that should be undertaken at each stage of the Plan’s preparation, assessing the
1 PPG Reference ID: 61-021-20180913
2 PPG Reference ID: 61-001-20180913
Greater Norwich Draft Local Plan Gladman Developments Limited
effects of the GNLP’s proposals on sustainable development when judged against all reasonable
3.2.2 The Council should ensure that the results of the SA process conducted through the Review clearly
justify any policy choices that are ultimately made, including the proposed site allocations (or any
decision not to allocate sites) when considered against ‘all reasonable alternatives’. In meeting the
development needs of the area, it should be clear from the results of the assessment why some
policy options have been progressed and others have been rejected. Undertaking a comparative
and equal assessment of each reasonable alternative, the Council’s decision making, and scoring
should be robust, justified and transparent.
3.2.3 The SA must demonstrate that a comprehensive testing of options has been undertaken and that
it provides evidence and reasoning as to why any reasonable alternatives identified have not been
pursued. A failure to adequately give reasons in the SA could lead to a challenge of the Council’s
position through the examination process. The SA should inform plan making. Whilst exercising
planning judgement on the results of the SA in the Local Plan is expected, the SA should still clearly
assess any reasonable alternatives and articulate the results of any such assessment.
Please find attached the headline representations of Gladman made in response to the Reg 18 version of the Greater Norwich Local Plan.
Full Evidence Base
Representation ID: 23183
Respondent: Barton Willmore
The full draft SA review can be found starting at p185 of the first attachment.
2.4 No areas of major deficiency were identified in the SA.
2.5 The following areas of the SA would potentially benefit from additional consideration:
• Existing environment (Habitats Regulations Assessment (HRA)) – A HRA has been
completed for the Regulation 18 Draft Plan and should be referenced in the Regulation 18 (C) SA Report. Briefly outlining the conclusions of the HRA would give more meaning to the assessment of ecological effects, particularly when assessing the sites and the decisions
made and would make the argument that the findings have been incorporated into the SA more robust. There is no evidence that cumulative effects have been assessed in relation to European sites, which would have been the case for in-combination effects in the HRA, for legal compliance. Given the need for assessments to be coordinat ed, it would be helpful to have more information within the Regulation 18 (C) SA Report on the HRA undertaken for the Local Plan to date.
• Relevant Policies, Plans and Programmes - The Regulation 18 (C) SA Report does not adequately reference the Cambridge Norwich Growth Corridor, SHMA Core Area or the NPA.
• Likely significant effects on the environment (cumulative effects) – A definition for short, medium and long-term effects, permanent and temporary effects, positive and
negative effects, and secondary, cumulative and synergistic effects is not provided and would be helpful for clarity. Cumulative effects are only mentioned in relation to major North East Wymondham Review of SA
21389/A5/SA March 2020 negative scores and there is no explanation of how these are considered within each topic. The approach to the assessment of cumulative effects is not well outlined and seems inconsistent between topics. SA Objectives 3 and 14 are the only Objectives that specifically mention cumulative effects in the assumptions and methodologies. In addition, there is no consideration of how each of the SA Objectives might interact with one another.
• Reasonable alternatives – Additional information on the site selection process would be helpful, for example more justification where sites have been excluded or options narrowed down. This should be reflected in the iterations of the SA and would make the process more robust and transparent.
• Reasonable alternatives – The assessment conclusions within Section 5 suggest that all sites/policies would have mixed effects with regards to sustainability and that it is not possible to identify a best performing option. The appraisal of the site in Bunwell against SA Objective 1 – Air Quality and Noise has been based on the number of new dwellings proposed (seven) and the site is awarded a negligible score. The sites within the Wymondham cluster have been awarded minor negative/major negative scores, even though some sites propose similar numbers of new dwellings (e.g. ten). It does not appear
to have been taken into account within the explanatory text that the sites in Wymondham are located within close proximity to local facilities, public transport, leisure and employment opportunities, which would help to reduce the need for travel by car, thereby reducing emissions and impacts on air quality. The site in Bunwell is located approximately 5.5km away from the nearest train station (Spooner Row, which does not have frequent
services compared to the larger stations in Wymondham) and approximately 7.8km away from the nearest town (Attleborough), and would therefore likely require all new residents to use cars to access these facilities, rather than more sustainable modes of transport, which would worsen impacts on air quality. Therefore, the objectivity and parity of the assessment when assigning scores could be questioned.
• Reasonable alternatives – The 2017 SA Scoping Report includes Appendix 2 ‘Demonstrating Compliance with SEA Directive’ – and states that this table will be completed and incorporated in subsequent SA reports to show how the SA has met legislative requirements. This table exercise has not been undertaken and included with the Regulation 18 (C) SA Report as set out in the Scoping Report. It would be helpful to set this out for
the next Consultation.
• Monitoring – The suggested monitoring targets are very vague and there are still some gaps to be identified. Additional information could be included by using local/national targets, and further details on how the effects will be monitored, over what period, frequency etc would increase robustness in the next Consultation.
• Non-Technical Summary – There is no Non-Technical Summary (NTS) within the supporting documents. Whilst the GNLP is at the Regulation 18 Consultation stage, it is
North East Wymondham Review of SA 21389/A5/SA March 2020 good practice to have an NTS for each revis ion of the SA, so that it is clear how the SA has evolved through the iterations. This should be rectified at the Regulation 19 Consultation.
2.6 Despite the improvements suggested above, the SA is not considered deficient and provides a comprehensive discussion around the likely effects of policy and site options as evidence supporting the GNLP as a reasonable strategy. Section 6 of the 2018 Interim SA Report and Section 2.7 of the Regulation 18 (C) SA Report sets out the uncertainties and difficulties of
predicting effects including assumptions made about secondary data, the accuracy of publicly available information and subjective judgement. Section 2.9 describes the assumptions made for the specific topics of the SA Objectives Assessments, which is helpful, for example where up to date ecological surveys and/or landscape and visual impact assessments have not been
available and have limited the assessment of sites.
2.7 Additional information to address the points summarised above at the Regulation 19 Consultation stage would increase further the robustness of the SA and assist in achieving the right outcome at Examination.
4.1 There are some areas of the SA which would potentially benefit from additional consideration at the Regulation 19 Consultation stage which would increase further the robustness of the SA and assist in achieving the right outcome at Examination.
4.2 The potential development site Land North East of Wymondham should be selected for inclusion within any proposed site allocations within the GNLP based on its location, opportunities and performance against the SA Objectives, to aid sustainable development in this urban extension area. The Regulation 18 (C) SA Report does not adequately reference the Cambridge Norwich Growth Corridor, SHMA Core Area or the NPA, when it is clear from this review that the GNLP should focus development here.
4.3 The twelve site assessments in the Wymondham cluster (Section B.51 within Appendix B of the
Regulation 18 (C) SA Report) show that Wymondham has been robustly and fairly assessed using appropriate methodology and justifiably represents a strategic location for growth. However, is clear that where some of the twelve Wymondham sites are awarded negative
scores in the SA, this is due to a lack of integrated mitigation, for example standard best practice mitigation usually implemented on such sites, a lack of s urvey information to properly assess potential impacts or a lack of knowledge of site design/masterplan commitments.
Therefore, it could be argued that these scores are not realistic. Including site assessments undertaken post mitigation would likely result in more positive sustainable scores than those awarded.
4.4 Wymondham represents a sustainable location for development in Greater Norwich and decision making and the GNLP should prioritise development along the Cambridge Norwich Growth Corridor, within the SHMA Core Area and the NPA.
Full representations (with appendices) submitted in response to the current Regulation 18 consultation of the Greater Norwich Local Plan on behalf of Landstock Estates Ltd and Landowners Group Ltd.