Draft Greater Norwich Local Plan – Part 1 The Strategy
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Draft Greater Norwich Local Plan – Part 1 The Strategy
Question 12: Do you support, object, or have any comments relating to the Climate Change Statement?
Representation ID: 22241
Received: 16/03/2020
Respondent: ClientEarth
6. While we welcome many of the objectives set out in the “climate change statement”, including contributing to the delivery of national and local emissions targets, it is not clear why these have not been given the status of strategic policies, which would ensure that they are taken into account in the determination of planning applications.
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%”.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
3. Monitoring Framework
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%”.
