3. Monitoring Framework
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22069
Received: 16/03/2020
Respondent: Norfolk Wildlife Trust
Appendix 3 Monitoring
The monitoring framework is intended to identify how well the local plan is implemented, but we believe that the indicators chosen for the natural environment need to be changed, as those currently selected do not relate to the planning system.
Indicator GNLP18 measures the percentage of SSSIs in favourable condition, whilst indicator GNLP19 measures the percentage of County Wildlife Sites in positive conservation management. However, these variables are unrelated to the local plan and planning permissions and we recommend they are reviewed. We support the inclusion of GNLP20 which gives an indication of the proportion of cases approved against formal advice. However, given that NWT are not able to comment on all cases where there are biodiversity impacts, whilst this indicator could act as an index of development pressures on wildlife sites, it is incomplete. We recommend the addition of an additional target which records the areas of nature conservation sites (as listed in Table 4 of the plan) and non-designated Priority Habitats including ancient woodland (as defined by the NERC Act 2016) lost to development. As one of the plan objectives is to protect and enhance the natural environment, we recommend the target is set at zero loss.
In addition, in anticipation of the mandatory biodiversity net gain requirement included in the current Environment Bill, we recommend that an additional target is added to measure the amount of net gain delivered, as per the DEFRA Biodiversity Metric. The related aspiration in the Environment Bill to create a Nature Recovery Network also has clear overlaps with the requirement for development to provide biodiversity net gain.
Thank you for consulting Norfolk Wildlife Trust on the draft Greater Norwich Local Plan. We have attempted to comment wherever possible in response to the questions set out in the consultation, but have a number of comments which cover multiple policies or supporting documents and so have compiled our comments in this letter.
See attached for full submission
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 23126
Received: 16/03/2020
Respondent: ClientEarth
7. Finally, having an effective monitoring framework is also a key part of ensuring that plan policies are achieving their intended impact. Clearly, to be effective, monitoring indicators need to do more than aim for a simple increase or reduction. They need to specify yearly targets that have been assessed in the policy development process as representing sufficient progress in contributing to the relevant emissions reduction target. Currently, on a number of themes, such as climate change, sustainable transport, renewable energy capacity and green infrastructure, the proposed indicators in the draft strategy do not achieve this
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%”.