Draft Greater Norwich Local Plan – Part 1 The Strategy

Object

Representation ID: 20592

Received: 10/03/2020

Respondent: Climate Friendly Policy and Planning (CFPP)

Please see attached for full representation

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.

Need for baseline carbon emissions, budgets and targets
17 The draft plan contains quite a few statements on Climate Change that sound promising
(for example, bullet CONS 82 “Mitigating the effects of climate change within the
Greater Norwich area is a cornerstone of the GNLP”) but which lack substance and any
clear demonstration of a route to their deliverability.
18 We have made the case, many times previously (please refer back to previous
consultations responses from NGP, CEPP and Dr Andrew Boswell) that the gap between
warm words and deliverability can only be achieved by fully understanding baseline
carbon emissions, setting a GNLP carbon budget that is aligned to national and
international obligations, and with measurable targets for achieving it. None of this
exists in the draft plan.
19 Again, we refer to the Stroud Draft plan as an example of good practice. Here the
Council declared a target to become carbon neutral by 2030, ahead of the current
Government target. This target has been brought into the local plan, joining up political
will with strategic planning3.
20 The situation in Greater Norwich is less clear politically with the County Council stating
in its Environmental Policy that it will work towards carbon neutrality by 2030, the City
Council having a 2050 target. And Broadland and South Norfolk apparently working
towards positions. There is a clear need for a unified target across the area, and for it
then to be embedded into the GNLP with the necessary policies to help deliver it through
the strategic planning system. No work appears to have been done on this, although the
time before the Regulation 19 consultation and subsequent process, gives space for
related political decisions to be progressed.

Object

Representation ID: 20593

Received: 10/03/2020

Respondent: Climate Friendly Policy and Planning (CFPP)

Climate Change Statement
3 We welcome the Climate Change Statement at CONS page 38 as, for the first time in the
GNLP process, issues relating to Climate Change have been brought together in one
place. This is helpful.
4 However, the statement serves only as a set of pointers into other policies. It does not
provide a Climate Change (CC) policy. As such, it is not effective in providing an
overarching policy on CC that can have effective weight at later planning application
stages which is required by the legislation.
5 Despite, bullet CONS 140 immediately above the statement stating how the NPPF
requires local plans to set strategic policies which address CC mitigation and adaptation,
the statement does not fulfil this requirement.
6 However, the statement, with its different limbs, forms that basis of material that could
be converted into the skeleton of an overarching GNLP Climate Change policy. Such a
policy would be a very positive step for GNDP to take considering the Climate
emergency. However, we emphasise the word skeletal, as there would be additional
work to take the skeletal structure provided by the statement and turn it into a robust
policy, as we outline below. We posit strongly that this is done for the next draft of the
plan.
We note that the Director of Place, Norwich City Council, has commented that there is a
disconnect between the Climate Change statement and the policy substance needed for
the plan to “contribute significantly to delivery of a low carbon future”.
Overall, we submit that a dedicated CC policy is required. As a recent example of good
practice in please see Stroud District Local Plan Review, Draft Plan, in which a new
Core Policy on Climate Change mitigation has been included.

Trend based baseline carbon emissions, budgets and targets
Overall there has been a 28% reduction in emissions over this period. The figure above
shows that in Greater Norwich area, Industry and Domestic emissions have reduced
whilst Transport emissions are rising and are at the same levels as in 2005. In general,
national trends in the decarbonisation of electricity has enabled significant reductions for
industrial and domestic carbon footprints. A robust climate change policy in the GNLP
could have further significant impact locally on bringing down Industry and Domestic
emissions.
12 Road transport emissions have made no significant reductions in over 14 years,
indicating a major policy failure, both nationally and locally. This may only be
remedied by a very tough set of policy interventions in transport for modal shift away
from private car use; electric vehicles may only play a small part in decarbonising
transport for reasons we give elsewhere. The GNLP Climate Change and Transport
policies should have reducing transport emissions as their number one objective.

Policy 4: Transport
22 Policies 2 and 4 are mentioned at CONS, page 39 (the Climate Change Statement table).
The DEFRA Clean Growth Strategy objective to meet a 30% reduction in carbon
emissions from road transport by 2032 should be included here as a footnote (before
footnote 49). As above, the SA states that this objective will not be met by the plan.

More detailed comments on Egnida EIS document
Throw away comments in the CONS document eg: CONS, page 39 (Climate Change
statement) “Encourage community-led initiatives such as the promotion of decentralised,
renewable and low carbon energy use or securing land for local food sourcing”, and
CONS, page 101, Policy 7.1 “providing for sustainable energy generation, including a
local energy network serving the area as a whole” need much more development within
the plan.

Object

Representation ID: 20594

Received: 10/03/2020

Respondent: Climate Friendly Policy and Planning (CFPP)

Policy 4: Transport
CONS, page 61, Policy 2, bullet 6. This is a very weak, bland statement and contains no
reference to modal shift and targets for modal shift.
We note that the Director of Place, Norwich City Council, has commented that Policy 4
is “insufficiently ambitious in supporting the transition to a low carbon future by
achieving significant modal shift” 6.
We would agree and suggest a modal shift hierarchy needs to be developed and made
central to Policy 4, Transport section. Road building, known to increase traffic, lock-in
car dependence, congestion and carbon emissions, should be the option of last resort.
Currently Policy 4 places various road building projects as options of high priority; these should be removed as below.

Policy 2: Energy section
26 EIS, Table 1, page 5. This essentially showed the lights going to go off in most of
Norwich with the planned developments and without any intervention. This risk to the
existing network is an argument for a much more creative, visionary approach to energy
which would facilitate significant carbon reduction too. The GNDP councils should be
thinking of smart grids, much greater efficiency in housing (including retrofit insulation
programs), greater on-site renewables and energy balancing and storage. The Egnida
EIS document does make some good suggestions toward this (see more detailed critique
below), for example “semi-islanded development” in chapter 5.
27 However, CONS, Page 61, Policy 2, bullet 10 (Energy policy) does not pick up on this
and embed it into policy. The statement needs to be much more pro-active. It also
needs to be factored through into the site appraisals which does not appear to have be
done.
28 Further on CONS, Page 61, Policy 2, bullet 10 – “All new development will provide a
20% reduction against Part L of the 2013 Building Regulations (amended 2016)”. This
is a weak target with other areas doing better. For example, Bristol and London (GLA) have 35% beyond Building Regulations, and Reading “All housing developments over
10 dwellings / 1000m2 to be designed to achieve zero carbon (subject to viability)”. The
financial arguments against more than 20% at the top of CONS, page 63, need to be
revisited.

Object

Representation ID: 20595

Received: 10/03/2020

Respondent: Climate Friendly Policy and Planning (CFPP)

Policy 4: Transport
23 CONS, page 61, Policy 2, bullet 6. This is a very weak, bland statement and contains no
reference to modal shift and targets for modal shift.
We note that the Director of Place, Norwich City Council, has commented that Policy 4
is “insufficiently ambitious in supporting the transition to a low carbon future by
achieving significant modal shift” 6.
We would agree and suggest a modal shift hierarchy needs to be developed and made
central to Policy 4, Transport section. Road building, known to increase traffic, lock-in
car dependence, congestion and carbon emissions, should be the option of last resort.
Currently Policy 4 places various road building projects as options of high priority; these
should be removed as below.
24 CONS, page 76, Policy 4, bullet on A47 dualling, and other, projects being promoted by
Highways England. Following the February 27th 2020 judgement in the appeal court7,
the Airports National Policy Statement (ANPS) has been prevented from having any
legal effect "unless and until the Secretary of State has undertaken a review of it in
accordance with the relevant statutory provisions". This is because the Secretary of
State failed to consider the Paris Agreement (signed 22 April 2016) in the ANPS. This
is a landmark judgement that will have repercussions for any infrastructure projects that
increases emissions going forward in the Climate emergency.
We submit that the A47 dualling projects, on Highway's England own analysis increases
carbon emissions in construction and use. Highways England has also failed to consider
the Paris Agreement as the Paris Agreement is not mentioned in any of the scheme documents. We expect to see a legal challenge is being mounted against the National
Network National Policy Statement (NN NPS) which would cover proposals for
developments such as the A47 under the NSIP regime. We await the outcome of legal
challenges to the National Network NPS that will provide further clarity on this issue. In
the meantime, we do not believe that the plan can rely on including the A47 proposals
under “strategic infrastructure”, and the A47 proposals should be removed.
25 CONS, page 76, Policy 4, bullet on “delivery of the Norwich Western Link road”.
(A) The NWL on Norfolk County Council’s own analysis increases carbon emissions
in construction and use. The issue above (for A47) applies here too. The Paris
Agreement has not been considered in the NWL business case. Given the legal
uncertainty, we do not believe that the plan can rely on including the NWL
proposal under “strategic infrastructure”, and it should be removed.
(B)We also note that the HRA assessment of Policy 4 at HRA 8.2.2 considers the
impact of the NWL on the River Wensum SAC and recommends the additional
text underlined ‘Delivery of the Norwich Western Link Road provided that it can
be achieved without causing an adverse affect on the integrity of the River
Wensum SAC.’ The wording of Policy 4 does not include this recommendation
from the HRA.
(C) Given the recent, and emerging scientific evidence for impacts to the Weston
super-colony of rare and protected species of barbastelle bats, we recommend
that if the NWL remains in the plan (at (A) above we give reason for its complete
removal), then the additional text should be “…provided that it can be achieved
without causing an adverse affect on the integrity of the River Wensum SAC,
and to the Weston super-colony of rare and protected species of barbastelle bats.”