Question 12: Do you support, object, or have any comments relating to the Climate Change Statement?

The transport strategy seems insufficiently ambitious. Rather than just promoting active travel and public transport, there needs to be a strategy to actively discourage car use, including building developments that do not include storage for vehicles other than bikes and car club vehicles.

It would also mean that any development includes filtered streets, so that cars can only drive in and out but not through.

All new properties must have space to store a bicycle, and identify how to access a cycle route, in a similar manner to the Oxford Local Plan.

Support, but must be delivered and even expanded upon.

I support any effort to reduce emissions but you don’t achieve this my increasing traffic!

This is not ambitious enough. We need radical change. Solar PV should not be free standing it should be on every roof that is appropriate for this. You need to have stronger more rapidly instigated building regs on sustainable development all building should be built to Passivhaus standards. Traffic free routes everywhere so that all children can bike and walk to school safely. Incentives to give up your car. Radically improved electric public transport. Good broad band connections everywhere so that people can work locally and do meetings by skype reducing the need for travel.

Aspirations but ineffective follow on. Policies should lead on how they will address climate change. Village Cluster policy is an example of opportunity lost: no criteria on location of housing and how countering climate change is to be helped. Design of development means little when SNDC acknowledge that Building Regulations can only be changed to the extent that builders will cooperate.

It is my view that in order to have credibility the GNLP team need to calculate the environmental cost of the entire GNLP process and publish the outcome of that investigation / research. This will help in understanding what the environmental impact of building the additional homes identified by the GNLP and the supporting infrastructure across the city and districts will be.
I think local authorities, parish councils and residents need to know from the GNLP a best estimate of the carbon cost of building 1 home.
The GNLP team should identify what requirements are being made of developers to mitigate against environmental impact and carbon emissions through the build process.
I believe there should be a carbon neutral attitude to the development of new homes this would enable The authorities in GNLP to lead the way. It would add credibility to the whole project and divert criticism.

Strategies to deliver a healthier environment
1 Offsetting at the point of build. All new building projects will be expected to have undergone a carbon assessment (tCo2e) and to publish the result at the time the application is made (prior to any decision by the planning authorities).
All new builds should clearly identify the carbon-offset strategy they intend to utilise to meet the carbon offset requirements prior to consent being given.
2 Strategic Offsetting. The GNLP should make the assessment (tCo2e) of the cost of implementing the GNLP in full. The GNLP should then mitigate the cost by creating a South Norfolk GNLP woodland. This could be a series of smaller woodlands linked that run across the South of the county across a large number of parishes.
3 Strategic Offsetting. The GNLP should make the assessment (tCo2e) of the cost of implementing the GNLP in full. The GNLP should then mitigate the cost by creating a South Norfolk GNLP woodland. This could be located as a single large public woodland handed over to and managed by an organisation such as the Woodland Trust
4 Strategic Offsetting. The GNLP should make the assessment (tCo2e) of the cost of implementing the GNLP in full. The GNLP should then mitigate the cost by creating a South Norfolk GNLP woodland. This could be woodlands planted in all the parishes that have housing through the GNLP process. These public woodlands would be managed by the Parish councils.

The commentary in the Climate Change Statement seems to be a complete fantasy. Many of the things relating to living near services is not happening now either because the service do not exist, have been eliminated by austerity or development being allowed indiscriminately. No mention of nature from the small to the large. No mention of green lungs or recreational areas or water usage. No necessary wildness. In fact the opposite is occurring with the cutting down of trees for road or housing development. No recognition that there is a climate emergency.

General Objections

The GNLP is deeply flawed. It appears to pursue a political agenda rather than duly considering sensible and pragmatic issues and flouts national policy on climate change mitigation.

The recent Court of Appeal decision to rule the expansion of Heathrow unlawful because it didn’t take climate change commitments into account puts the proposed GNLP in a dubious position, given that its proposed higher levels of rural development would lead to increases in carbon emissions, which contravenes national planning policy to facilitate their reduction. This would inevitably lead to it being challenged on that basis. It could even be that a legal challenge would be upheld and the policy deemed unlawful.

I’d argue that the GNLP is a redundant document, given that the current Joint Core Strategy has only been in effect since 2014 and covers the period up to 2026. Certainly, the unexplained change in policy in the GNLP concerning rural development is startling and inappropriate.

One of the core strategies in the JCS was to locate housing and other growth primarily in and close to Norwich, with minimal new development to be permitted in rural areas. One of the stated reasons for the development of the NDR, at great public expense, was to help the distribution of traffic to and from new housing built inside its length and in the northeast growth triangle (as that is what the JCS pointed to). The GNLP consultation document abandons that policy and sacrifices the important protection the JCS gave rural communities against inappropriate development. The main justification for this appears to be the availability of primary school places in the “village clusters”. The issue of climate change is a much more important factor and appears to have been completely ignored despite the introduction stating that ‘the GNLP must also assist the move to a post-carbon economy and protect and enhance our many environmental assets.’. This goal is completely undermined by the proposed policy.

The GNLP calculates housing needs based on the 2014 National Household Projection. It should use the 2016 National Household Projections and there is no acceptable excuse for not doing so.
Objections Specific to Reedham
Paragraph 120 of the GNLP stresses the need for good access to services and facilities, but the decision to allocate up to 60 new houses to the village appears to be based almost entirely on the fact that the primary school has a number of vacancies. This is poor decision-making,.
The recent development of 24 houses in Barn Owl Close in Reedham has resulted in one person of school age moving into the village. Clearly, the provision of additional housing does not automatically guarantee increased take-up of school places.
Other services in the village are extremely limited. There is a doctors’ surgery; it is only open four half-days per week. There is a post office; it is only open three half-days per week. There is no free cash point. There is a village store; most people use it for odds and ends and do most of their shopping at supermarkets in Acle (six miles each way), Yarmouth (10 miles each way) or Norwich (16 miles each way), to which they drive or from which they have their groceries delivered.
There are no significant employment opportunities in Reedham. The current businesses are generally fully staffed and do not have plans for expansion and it is not a village that will ever attract new business because of its location and lack of access to good roads.

Given the lack of employment opportunities within the village, there will be a massive increase of journeys from and to work for many of those living in any such new housing, as well as additional journeys by delivery vehicles.

Paragraph 125 states the need for ‘a radical shift away from the use of the private car, with many people walking, cycling or using clean public transport.’ That is not feasible for people who live in Reedham, where 96% of journeys are made by private car due to the infrequency or unreliability of public transport. This may not be an issue if we ever reach a point where electric-powered cars predominate, but it’s a huge gamble to base policy on that happening within the lifetime of the GNLP.

Another significant issue with the increased road traffic the proposed additional development would cause is that the road infrastructure in and around Reedham is poor and would not support the increased demand. The required road width for any road servicing 50 or more dwellings is 5.5 metres.
Most of the roads within Reedham do not comply with this requirement. Mill Rd is 3.8 metres wide, narrowing to 3.2 - 3.3 metres in places. Church Road is 3.7 metres at its narrowest point, and only 4.4 metres at its intersection with Freethorpe Rd. Station Road beyond Barn Owl Close is 4.2 metres wide. The Hills is 4.2 metres wide.
Site Specific Objections
GNLP1001
I object to GNLP1001:-
• Outside the development boundary for the village.
• Contrary to GNLP Policy 2 issue 1 as the site cannot provide “safe, convenient and sustainable access to on-site and local services and facilities including schools, healthcare, shops, leisure/community/faith facilities and libraries” without the use of a car.
• Contrary to GNLP Policy 7.4 347 as there is no safe walking route to school. As per the Discussion of Submitted Sites “Sites which do not have a safe walking route to school, or where one cannot be created, will not be considered suitable for allocation”. Highways have confirmed it is not feasible to provide an off-carriageway pedestrian facility to enable safe journeys to school.

GNLP3003
I object to GNLP3003:-
• Outside the development boundary for the village.
• Contrary to GNLP Policy 7.4 347 as there is no safe walking route to school. The Discussion of Submitted Sites states “Sites which do not have a safe walking route to school, or where one cannot be created, will not be considered suitable for allocation”. Highways have confirmed it is not feasible to provide a footway to enable safe journeys to school as there is no scope for improvements within the highway.
• The single entrance access is too narrow with no scope to widen. Highways confirm it is not feasible to provide a safe access as the carriageway is narrower than required for 2-way traffic and there is limited site frontage to the highway.
• The HELAA Conclusion states that Mill Road is “relatively lightly trafficked”. However, there is no evidence to support this statement.

I make no apology for echoing other residents concerns as detailed below.

General objections:
The GNLP is deeply flawed. It appears to pursue a political agenda rather than duly considering sensible and pragmatic issues and flouts national policy on climate change mitigation.
The recent Court of Appeal decision to rule the expansion of Heathrow unlawful because it didn’t take climate change commitments into account puts the proposed GNLP in a dubious position, given that its proposed higher levels of rural development would lead to increases in carbon emissions, which contravenes national planning policy to facilitate their reduction. This would inevitably lead to it being challenged on that basis. It could even be that a legal challenge would be upheld and the policy deemed unlawful.
I’d argue that the GNLP is a redundant document, given that the current Joint Core Strategy has only been in effect since 2014 and covers the period up to 2026. Certainly, the unexplained change in policy in the GNLP concerning rural development is startling and inappropriate.
One of the core strategies in the JCS was to locate housing and other growth primarily in and close to Norwich, with minimal new development to be permitted in rural areas. One of the stated reasons for the development of the NDR, at great public expense, was to help the distribution of traffic to and from new housing built inside its length and in the northeast growth triangle (as that is what the JCS pointed to). The GNLP consultation document abandons that policy and sacrifices the important protection the JCS gave rural communities against inappropriate development. The main justification for this appears to be the availability of primary school places in the “village clusters”. The issue of climate change is a much more important factor and appears to have been completely ignored despite the introduction stating that ‘the GNLP must also assist the move to a post-carbon economy and protect and enhance our many environmental assets.’. This goal is completely undermined by the proposed policy.
The GNLP calculates housing needs based on the 2014 National Household Projection. It should use the 2016 National Household Projections and there is no acceptable excuse for not doing so.
Objections Specific to Reedham
Paragraph 120 of the GNLP stresses the need for good access to services and facilities, but the decision to allocate up to 60 new houses to the village appears to be based almost entirely on the fact that the primary school has a number of vacancies. This is poor decision-making,.
The recent development of 24 houses in Barn Owl Close in Reedham has resulted in one person of school age moving into the village. Clearly, the provision of additional housing does not automatically guarantee increased take-up of school places.
Other services in the village are extremely limited. There is a doctors’ surgery; it is only open four half-days per week. There is a post office; it is only open three half-days per week. There is no free cash point. There is a village store; most people use it for odds and ends and do most of their shopping at supermarkets in Acle (six miles each way), Yarmouth (10 miles each way) or Norwich (16 miles each way), to which they drive or from which they have their groceries delivered.
There are no significant employment opportunities in Reedham. The current businesses are generally fully staffed and do not have plans for expansion and it is not a village that will ever attract new business because of its location and lack of access to good roads.
Given the lack of employment opportunities within the village, there will be a massive increase of journeys from and to work for many of those living in any such new housing, as well as additional journeys by delivery vehicles.
Paragraph 125 states the need for ‘a radical shift away from the use of the private car, with many people walking, cycling or using clean public transport.’ That is not feasible for people who live in Reedham, where 96% of journeys are made by private car due to the infrequency or unreliability of public transport. This may not be an issue if we ever reach a point where electric-powered cars predominate, but it’s a huge gamble to base policy on that happening within the lifetime of the GNLP.
Another significant issue with the increased road traffic the proposed additional development would cause is that the road infrastructure in and around Reedham is poor and would not support the increased demand. The required road width for any road servicing 50 or more dwellings is 5.5 metres.
Most of the roads within Reedham do not comply with this requirement. Mill Rd is 3.8 metres wide, narrowing to 3.2 - 3.3 metres in places. Church Road is 3.7 metres at its narrowest point, and only 4.4 metres at its intersection with Freethorpe Rd. Station Road beyond Barn Owl Close is 4.2 metres wide. The Hills is 4.2 metres wide.
Site Specific Objections
GNLP1001
I object to GNLP1001:-
Outside the development boundary for the village.
Contrary to GNLP Policy 2 issue 1 as the site cannot provide “safe, convenient and sustainable access to on-site and local services and facilities including schools, healthcare, shops, leisure/community/faith facilities and libraries” without the use of a car.
Contrary to GNLP Policy 7.4 347 as there is no safe walking route to school. As per the Discussion of Submitted Sites “Sites which do not have a safe walking route to school, or where one cannot be created, will not be considered suitable for allocation”. Highways have confirmed it is not feasible to provide an off-carriageway pedestrian facility to enable safe journeys to school.
GNLP3003
I object to GNLP3003:-
Outside the development boundary for the village.
Contrary to GNLP Policy 7.4 347 as there is no safe walking route to school. The Discussion of Submitted Sites states “Sites which do not have a safe walking route to school, or where one cannot be created, will not be considered suitable for allocation”. Highways have confirmed it is not feasible to provide a footway to enable safe journeys to school as there is no scope for improvements within the highway.
The single entrance access is too narrow with no scope to widen. Highways confirm it is not feasible to provide a safe access as the carriageway is narrower than required for 2-way traffic and there is limited site frontage to the highway.
The HELAA Conclusion states that Mill Road is “relatively lightly trafficked”. However, there is no evidence to support this statement.

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.

The positive objectives set out in the climate change statement will be undermined if no provision is made to reduce/stop polluting activities as well as promoting low-carbon ones. It is therefore crucial that as well as monitoring emissions, the Greater Norwich authorities base decisions on carbon impact, carrying out carbon footprinting of proposed development and infrastructure options and rejecting proposals which are not compatible with the UK's zero carbon target and climate budgets. Many of the aims stated are positive, but they are too vague - we need measurable targets in order to assess progress.

Para 84 cites projected temperature increases and changes in precipitation patterns for the East of England by 2040. However, nothing is done with these figures. It would be useful for the preparation of the plan to include details of the potential effects of these changes, and for them to be factored in to relevant policies on water management, buildings etc.
The TCPA’s document Planning for Climate Change states that “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.” It is not clear that climate is really being treated as central in the draft plan – it is still seen as one policy issue among many, and does not really feature in the sections on the different settlements and on the economy. If the Greater Norwich councils are serious about addressing the climate crisis, all development and infrastructure decisions should be based on the project’s contribution to and compatibility with a rapid transition to zero carbon.

Given the stated measures in the Climate Change Statement, it is impossible to see how the proposed additional allocation of sites for housing in “village clusters” can be justified. Furthermore, it is stated that ‘growth in villages is located where there is good access to services to support their retention’, when this is rarely the case beyond providing a primary school with sufficient places or room for expansion. Many services are simply not located within the “village clusters” with many additional vehicle journeys being an inevitable consequence of such housing allocations. Therefore, these would be contrary to measures 2 and 3 of the Climate Change Statement.

By locating additional housing in “village clusters” there would be an increased need to travel, particularly by private car, due to the lack of viable and clean public transport. If Climate Change is seriously going to be addressed then it is unacceptable to allocate additional sites for housing in rural areas which are not at all, or poorly served by public transport. New housing must be located where jobs and a wide range of services are or can be provided.

In addition CPRE Norfolk is concerned by the lack of any 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 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.

Given the stated measures in the Climate Change Statement, it is impossible to see how the proposed additional allocation of sites for housing in “village clusters” can be justified. Furthermore, it is stated that ‘growth in villages is located where there is good access to services to support their retention’, when this is rarely the case beyond providing a primary school with sufficient places or room for expansion. Many services are simply not located within the “village clusters” with many additional vehicle journeys being an inevitable consequence of such housing allocations. Therefore, these would be contrary to measures 2 and 3 of the Climate Change Statement.

By locating additional housing in “village clusters” there would be an increased need to travel, particularly by private car, due to the lack of viable and clean public transport. If Climate Change is seriously going to be addressed then it is unacceptable to allocate additional sites for housing in rural areas which are not at all, or poorly served by public transport. New housing must be located where jobs and a wide range of services are or can be provided.

Hempnall Parish Council has serious concerns about the lack of any 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 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. All new housing should have solar panels, be insulated to the highest standard and include features such as grey water capture.

GENERAL OBJECTIONS

The GNLP is deeply flawed. It appears to pursue a political agenda rather than duly considering sensible and pragmatic issues and flouts national policy on climate change mitigation.

The recent Court of Appeal decision to rule the expansion of Heathrow unlawful because it didn’t take climate change commitments into account puts the proposed GNLP in a dubious position, given that its proposed higher levels of rural development would lead to increases in carbon emissions, which contravenes national planning policy to facilitate their reduction. This would inevitably lead to it being challenged on that basis. It could even be that a legal challenge would be upheld and the policy deemed unlawful.

I’d argue that the GNLP is a redundant document, given that the current Joint Core Strategy has only been in effect since 2014 and covers the period up to 2026. Certainly, the unexplained change in policy in the GNLP concerning rural development is startling and inappropriate.

One of the core strategies in the JCS was to locate housing and other growth primarily in and close to Norwich, with minimal new development to be permitted in rural areas. One of the stated reasons for the development of the NDR, at great public expense, was to help the distribution of traffic to and from new housing built inside its length and in the northeast growth triangle (as that is what the JCS pointed to). The GNLP consultation document abandons that policy and sacrifices the important protection the JCS gave rural communities against inappropriate development. The main justification for this appears to be the availability of primary school places in the “village clusters”. The issue of climate change is a much more important factor and appears to have been completely ignored despite the introduction stating that ‘the GNLP must also assist the move to a post-carbon economy and protect and enhance our many environmental assets.’. This goal is completely undermined by the proposed policy.

The GNLP calculates housing needs based on the 2014 National Household Projection. It should use the 2016 National Household Projections and there is no acceptable excuse for not doing so.

OBJECTIONS SPECIFIC TO REEDHAM

Paragraph 120 of the GNLP stresses the need for good access to services and facilities, but the decision to allocate up to 60 new houses to the village appears to be based almost entirely on the fact that the primary school has a number of vacancies. This is poor decision-making,.

The recent development of 24 houses in Barn Owl Close in Reedham has resulted in one person of school age moving into the village. Clearly, the provision of additional housing does not automatically guarantee increased take-up of school places.

Other services in the village are extremely limited. There is a doctors’ surgery; it is only open four half-days per week. There is a post office; it is only open three half-days per week. There is no free cash point. There is a village store; most people use it for odds and ends and do most of their shopping at supermarkets in Acle (six miles each way), Yarmouth (10 miles each way) or Norwich (16 miles each way), to which they drive or from which they have their groceries delivered.

There are no significant employment opportunities in Reedham. The current businesses are generally fully staffed and do not have plans for expansion and it is not a village that will ever attract new business because of its location and lack of access to good roads.

Given the lack of employment opportunities within the village, there will be a massive increase of journeys from and to work for many of those living in any such new housing, as well as additional journeys by delivery vehicles.

Paragraph 125 states the need for ‘a radical shift away from the use of the private car, with many people walking, cycling or using clean public transport.’ That is not feasible for people who live in Reedham, where 96% of journeys are made by private car due to the infrequency or unreliability of public transport. This may not be an issue if we ever reach a point where electric-powered cars predominate, but it’s a huge gamble to base policy on that happening within the lifetime of the GNLP.

Another significant issue with the increased road traffic the proposed additional development would cause is that the road infrastructure in and around Reedham is poor and would not support the increased demand. The required road width for any road servicing 50 or more dwellings is 5.5 metres.

Most of the roads within Reedham do not comply with this requirement. Mill Rd is 3.8 metres wide, narrowing to 3.2 - 3.3 metres in places. Church Road is 3.7 metres at its narrowest point, and only 4.4 metres at its intersection with Freethorpe Rd. Station Road beyond Barn Owl Close is 4.2 metres wide. The Hills is 4.2 metres wide.

SITE SPECIFIC OBJECTIONS

GNLP1001

I object to GNLP1001:-

•Outside the development boundary for the village.

•Contrary to GNLP Policy 2 issue 1 as the site cannot provide “safe, convenient and sustainable access to on-site and local services and facilities including schools, healthcare, shops, leisure/community/faith facilities and libraries” without the use of a car.

•Contrary to GNLP Policy 7.4 347 as there is no safe walking route to school. As per the Discussion of Submitted Sites “Sites which do not have a safe walking route to school, or where one cannot be created, will not be considered suitable for allocation”. Highways have confirmed it is not feasible to provide an off-carriageway pedestrian facility to enable safe journeys to school.

GNLP3003

I object to GNLP3003:-

•Outside the development boundary for the village.

•Contrary to GNLP Policy 7.4 347 as there is no safe walking route to school. The Discussion of Submitted Sites states “Sites which do not have a safe walking route to school, or where one cannot be created, will not be considered suitable for allocation”. Highways have confirmed it is not feasible to provide a footway to enable safe journeys to school as there is no scope for improvements within the highway.

•The single entrance access is too narrow with no scope to widen. Highways confirm it is not feasible to provide a safe access as the carriageway is narrower than required for 2-way traffic and there is limited site frontage to the highway.

•The HELAA Conclusion states that Mill Road is “relatively lightly trafficked”. However, there is no evidence to support this statement.

The strategic policy is considered to provide a framework to ensure communities developed and infrastructure delivered under the plan will be resilient to the impacts of climate change.
The principles of the policy are, where relevant, all capable of being delivered / supported by the proposed development.

For Para 136 the wording should be changed. Not "which will both help decarbonise and assist" . Omit the words "help" and "assist" and change to a Policy Framework using the words "will decarbonise and address climate change". Para 141. As a continuum and looking to the future the need for perpetual growth must be challenged and changed. After 2038 do we do this all again with more land and resources grab ?

As indicated in our earlier representations, the proposals relating to climate change are partial and lack any serious attempt to drive change on environmental issues. Many of the statements and proposed actions within the wider plan are contradictory.

The climate change statement is supported. However, Lanpro consider that if the Growth Strategy includes 9% dispersal to small village clusters which could potentially be in the rural parts of South Norfolk and some within the rural parts of Broadland (outside of the old NPA) this is incompatible with the specified climate change ambitions, particularly insofar as they relate to reducing car and other journeys.

Although the majority of growth allocated in the plan may well be located to help reduce the need to travel by locating it in accessible larger settlements with good employment opportunities within them, or well connected by public transport, locating significant housing growth in small rural cluster villages may not support the specified Climate Change Measure to reduce the need to travel, particularly by the private car. We would, therefore, question whether the plan is doing enough to meet this important climate change objective and suggest that it could do more by amending its overall approach to the location of development and reducing the amount of dispersal to small rural villages (outside the old NPA). See our response to question 13 for further information on this.

If you are 100% fine with human caused mass extinction (85% of species die out including humans) please continue with fluffy words and policies that allow business as usual as much as possible while doing the minimum to 'promote' sustainable behaviours. If you are even 1% edgy about tipping us into mass extinction then prioritise and follow the IPCC warnings - we have 10 years to allow future generations a chance to have their own choices. All policies should stop climate change emissions and provide for greener living above economic or any other considerations - these are luxuries.

The proposal to allocate sites in "Village Clusters" runs contrary to the Climate Change Statement. Allocating sites in rural areas with little or no access to public transport will increase travel by car and delivery vehicles for those needing to access facilities, jobs and shops.
Why is there no policy on the design of new housing and the insistence on the highest possible environmental standards?

The climate change statement is supported. However, Glavenhill Ltd consider that if the Growth Strategy includes 9% dispersal to small village clusters which could potentially be in the rural parts of South Norfolk and some within the rural parts of Broadland (outside of the old NPA) this is incompatible with the specified climate change ambitions, particularly insofar as they relate to reducing car and other journeys.

Although the majority of growth allocated in the plan may well be located to help reduce the need to travel by locating it in accessible larger settlements with good employment opportunities within them, or well connected by public transport, locating significant housing growth in small rural cluster villages may not support the specified Climate Change Measure to reduce the need to travel, particularly by the private car. We would, therefore, question whether the plan is doing enough to meet this important climate change objective and suggest that it could do more by amending its overall approach to the location of development and reducing the amount of dispersal to small rural villages (outside the old NPA). See our response to question 13 for further information on this.

More reassurance is required that there is an awareness of all the greenhouse gases we need to control notably anaesthetic gases are serious greenhouse pollutants and in rising older populations this may require careful management

In our opinion, the building of 1200 (minimum!) new houses plus 400 windfall dwellings in South Norfolk is excessive because it means that the GNLP Climate Change Statement cannot be met. Because rural South Norfolk is so widespread, private transport is necessary and it is not environmentally friendly. Already roads such as the A146 and A140 are very busy.
Also, as the plan projects forward to 2038, it is likely that climate change will be having a greater effect by then and we should be:
‘encouraging sustainable travel on all new developments within the county’ Norfolk County Council Environmental Policy

Please see attached for consultation response from Hempnall Parish Council.

Please see also the Hempnall Parish Council Position Statement on sites in Hempnall proposed by landowners for inclusion in the GNLP - included with this submission. This Position Statement, which deals directly with the detail of what Hempnall Parish Council wants for Hempnall, should be considered alongside our consultation response which makes a number of more general comments about the Draft GNLP.

We do not feel that the wording of this policy is strong enough in the light of the ongoing climate emergency. This comment is true of a number of aspects of the climate change policy including references to promotion of sustainable transport and to encouraging renewable energy but I would like to specifically focus on the role of green infrastructure and in particular of trees and woods.

It is stated that development must include green infrastructure but there is no mention of the specific ability that trees and woods have to sequester carbon from the atmosphere, which is much greater thatn, for example, areas of intensively mown grass. There is a further advantage that woods can be considerably cheaper to manage than intensively mown grass, as evidenced by research which is outlined in the Woodland Trust's Trees or Turf report, which is available from the publications section of our website.

Trees can also help in adaptation to the impact of climate change, for example by significantly reducing midsummer temperatures in urban areas. This could be referred to in the policy.

There is a reference to the need to reduce surface water flooding but again no reference to the specific role that trees can play in this, particularly in urban areas. Research by the University of Manchester has shown that run off of water into drainage systems can be reduced by up to 60% by presence of trees: trees achieve this through their foliage reducing the rate at which rainwater reaches the ground.

I support the number of projects to enhance the issues of climate change including the planting of new trees.
However, I feel that there is much to be done in the area of air pollution from both commercial and domestic origin which needs to be addressed.
I would like to see a total ban on bonfires on building sites and in gardens, as well as a ban on burning non-smokeless fuel from chimneys. I believe that this is crucial in order to provide a smokeless, clean atmosphere to improve health and reduce lung disease within the community.

We support the Climate Change Statement.

Location of development:
Honingham Thorpe is well located to the strategic road network, and the proposed improvements to the A47. Additionally, the site is well located to Easton, and the proposed Bus Rapid Transit route promoted as part of the Transforming Cities bid, and to Longwater Retail Park. These factors, and the location in close proximity to Norwich City Centre would reduce the need to travel long distances to access significant retail and leisure opportunities, and would allow for the promotion of sustainable transport measures as the primary method of accessing these.

The site is well related to the Food Enterprise Park, Easton College and Norwich Research Park and would support the evolution of a clean growth agri-tech corridor.

Design of development:
The proposed settlement would seek to be carbon-neutral. It would predicated on The Garden City Principles and provide truly walkable neighbourhoods with integral multi-functional green infrastructure and ‘room to breathe’.

All essential services and facilities would be provided within the village centre so as to reduce the need to travel. This would include medical facilities, all-through school, flexible working spaces and a range of community facilities.

The village would be designed to take advantage of passive solar gain, and with climate resilience embedded in the fabric of homes and the community.

Support delivery of decentralised, renewable and low-carbon energy generation and grid infrastructure:
Honingham Thorpe would examine the opportunities to provide decentralised, renewable energy generation.

Clarion have delivered such infrastructure elsewhere, most notably at Graylingwell Park which has won multiple awards including Best Low or Carbon Zero Initiative at The Housebuilder Awards 2010.

Shape places and secure new development to minimise vulnerability and provide resilience to impacts from climate change:
The proposed settlement is not located in an area at risk of flooding, development would incorporate sustainable drainage methods as part of the multi-functional green infrastructure network.

Climate resilience would be embedded within the settlement through design, layout and suitable technologies.

Encourage community-led initiatives such as the promotion of decentralised, renewable and low carbon energy use or securing land for local food sourcing:
Land would be provided throughout the settlement for food production. Whilst the creation of a Community Trust and Residents Association would provide opportunities for community ownership and involvement in development from the time of first occupation.

Increase sustainable transport use and local transport solutions:
The provision of essential services and facilities within the village centre, together with flexible employment space and the nearby Food Enterprise Park would reduce the need to travel. Whilst a comprehensive green infrastructure network and human-scale spaces would increase the attractiveness of walking and enhance connectivity.

The development would provide enhanced public service provision so as to facilitate suitable sustainable transport into the city centre.

Have 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:
Clarion would retain long-term stewardship and monitoring of Honingham Thorpe.

The focus of the Climate Change statement is mostly on carbon impacts resulting from climate change. There is no mention of how increased water demands combined with drier, hotter summers will lead to reduced flows in rivers and the potential impact on both the water resource (in terms of quantity and quality), and protected habitats

Has thought been given to construction of a large storage reservoir as a water supply with multiple use benefits e.g. recreation and biodiversity buffer, potential source for irrigation of arable crops? Greater aspiration will be required if climate targets are to be realised.

Please see attached
1 There appears to be no strategy put forward by the GNLP to identify the carbon footprint of these activities.
2 There appears to be no strategy to ensure that once built the houses and infrastructure will have a reduced impact upon the environment and mitigate against carbon release or environmental outcomes such as flooding.
We would like answers to the following questions:
1 What will be the environmental impact of building the additional homes identified by the GNLP and the supporting infrastructure across the city and districts?
2 What is the calculated cost of CO2 emissions and environmental impact of the whole GNLP process?
3 What requirement is being made of land owners and developers to mitigate against the environmental impact of their specific development?
4 It has been suggested that CIL monies can be used to offset the environmental impact of a development. The CIL monies are principally used to provide infrastructure needed within the community to facilitate the additional homes and families. What new monies are going to be provided specifically to accommodate the environmental impact of the development?

Dickleburgh and Rushall Parish Council Proposals:
1 Offsetting at the point of build. All new building projects will be expected to have undergone a carbon assessment (tCo2e) and to publish the result at the time the application is made (prior to any decision by the planning authorities). This should be shared with the local community and additional requirements made upon the developer to mitigate against environmental damage. This could include: providing additional funding for the purchase of carbon offset capabilities, or providing additional habitats and environs for species, or providing offset land within the community for carbon capture.
All new builds should clearly identify the carbon-offset strategy they intend to utilize to meet the carbon offset requirements prior to consent being given.
2 Strategic Offsetting A. The GNLP should make the assessment (tCo2e) of the cost of implementing the GNLP in full. The GNLP should then mitigate the cost by creating a South Norfolk GNLP woodland. This could be a series of smaller woodlands linked that run across the South of the county across a large number of parishes.
3 Strategic Offsetting B. The GNLP should make the assessment (tCo2e) of the cost of implementing the GNLP in full. The GNLP should then mitigate the cost by creating a South Norfolk GNLP woodland. This could be located as a single large public woodland handed over to and managed by an organisation such as the Woodland Trust
4 Strategic Offsetting C. The GNLP should make the assessment (tCo2e) of the cost of implementing the GNLP in full. The GNLP should then mitigate the cost by creating a South Norfolk GNLP woodland. This could be woodlands planted in all the parishes that have housing through the GNLP process. These public woodlands would be managed by the Parish Councils.