Object
Publication
Representation ID: 23939
Received: 17/03/2021
Respondent: Centre for Sustainable Energy
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
We are concerned about the scale of development proposed for village clusters and the additional 5000 homes, on top of existing commitments.
Paragraph 384 on village cluster sites states that “the village clusters cover the remaining areas of Broadland outside the Norwich fringe, main towns and key service centres”, implying that the village clusters are not well serviced by shops, services and public transport, raising concerns that these housing developments will be highly car dependent. This aspect of the policy doesn’t seem to be compatible with your objectives to significantly reduce carbon emissions and give communities good access to jobs, services and facilities.
The plan does not provide any specific measures to prevent these housing developments from being car dependent in use.
See attachment for full representation
Summary of issues and commentary
The plan is not carbon audited. It is not in line with the Climate Change Act (2008) as required by national policy and guidance, and is unsound in relation to the duties around the mitigation of climate change, descending from the Climate Change Act and the Planning Acts.
The plan does not contain adequately detailed climate adaptation policies and its mitigation policies could go much further to reduce emissions from buildings. The GNDP councils are significantly behind many leading authorities who have developed binding policies requiring new development to be net zero carbon.
Much of the housing stock is historic, with relatively low levels of energy efficiency. Planning policies should be incorporated to support the appropriate retrofitting of this housing stock whilst minimising harm to historic fabric and significance.
Renewable energy policies are reactive and passive and there is no evidence of a proactive strategy to maximise renewable energy as required in national policy. The approach to onshore wind, to leave the identification of suitable areas to neighbourhood plans, is unlikely to boost the pipeline of projects coming forward, unless communities are given proactive support to identify such areas, and there is no evidence of such support being given.
Transport policies should be more robust in requiring new development to incorporate sustainable transport infrastructure.
Overall, the approach throughout the plan appears to be largely to leave carbon emission reductions to central government. Whilst central government is doing much to reduce carbon emission reductions, the UK is not on track to achieve an 80% reduction in carbon emissions by 2050, still less the new commitment to bring emissions down by 68% by 2030, and down to net zero by 2050. Local authorities have a vital role to play in adding to what central government is doing.
The IPPC report on global warming of 1.5°C, the Climate Change Act and the legal duties on local planning authorities around climate change mitigation and adaptation mean that climate change needs to take a more central role within Local Plans. Local Plans need to take a more rigorous approach to bringing forward development which is consistent with and moves very quickly towards a zero carbon world, with radical changes set in motion well within the lifetime of your plan. The gradualist approach set out in the plan is not equal to the scale and rate of change required.