Stage C Evidence Base

Object

Representation ID: 20596

Received: 10/03/2020

Respondent: Climate Friendly Policy and Planning (CFPP)

Issues with baseline carbon emissions, budgets and targets
8 Previous submissions by CEPP and NGP have made the case for baseline carbon
emissions, budgets and targets to be developed for the GNLP in a numerically
quantifiable, measurable and reportable form. The draft plan makes no progress
compared to the JCS on this, and also includes some confusing elements. These are:
(A) 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 (see
below).
(B)No historic or future trend information is given. Any meaningful narrative
around carbon emissions must be focussed around trends, and national policy is
framed in targets (eg net-zero by 2050, or the Paris Agreement temperature
target of 1.5degrees). Targets imply a “journey” to reach a target, and
understanding trends, both real historic one and projected future ones, is
necessary to understand the journey.
(C) The methodology for assessing carbon emissions in the SA is given at SA, Box
2.2 (page 25):
“Development proposals which could potentially increase the Plan area’s
carbon emissions by 1% or more in comparison to the 2017 estimate would
be expected to have a major negative impact for this objective. Development
proposals which may be likely to increase the Plan area’s carbon emissions
by 0.1% or more in comparison to the 2017 estimate would be expected to
have a minor negative impact for this objective.”
It later becomes apparent in the SA (though it is not clear in the statement
above), that the percentage increase in carbon emissions for the above test is
calculated by simply calculating the increase in emissions based on new
population and the current levels of emissions. This method is naïve and
flawed for the following reasons.
It ignores the crucial fact that the underlying carbon emission footprint must
significantly decrease to meet national obligations. For example, using the
SCATTER budgeting (see below), emissions should be decreasing by over
13% per year. There is a real increase in emissions from population growth, but this is a second-order effect compared to the real reductions (a much larger
quantity) implied by meeting budgets – the first-order effect. Therefore, the
SA methodology is based on minor second-order effects rather than the
predominant first-order effect, and provides no reliable guidance on assessing
carbon emission reductions for the SA.
Further, it suggests that the only way the local plan can affect carbon emissions
is by population growth. And that all other effects of carbon emissions will
result from external effects (eg: national CC policy instruments).
However, the principle underlying Section 19(1A) of the Planning and
Compulsory Purchase Act 2004 is that local plans themselves must include
policies designed that “contribute to the mitigation of, and adaptation to,
climate change.” The SA provides no method to assess these policies, and it
should do to be consistent with the Act.
(D) The above SA test and SA methodology effectively set a default target for the
GNLP of maintaining carbon emissions as they are. This is clear that
development which did not increase the population would register a 0%
increase or decrease in emissions. The notion that underlying emissions stay
constant is not consistent with national policy.
(E) This approach appears to be reflected in the Monitoring Framework, and
objective GNLP16 which is:
“To minimise carbon dioxide equivalent emissions per capita to contribute to
meeting the national target to bring all greenhouse gas emissions to net zero
by 2050, taken from the Department for Business, Energy and Industrial
Strategy data.”
This appears to be the same monitoring as under the JCS where any reduction
in emissions (even a fractional percentage) is scored RAG “Green”.
“Minimise” means no increase. This is a wholly inadequate monitoring regime
in two respects:
i. in the climate emergency, significant year-on-year reductions are
required
ii. no quantification is given at all

The Sustainability Appraisal shows Climate Change objectives are not met
21 We have indicated above that the methodology for assessing carbon emissions in the SA
is not fit for purpose. However, despite this, the SA indicates in several respects that the
Climate Change objectives of the plan are not met, and emission reductions are not
being facilitated.
(A) SA, page 72, Table 4.2 gives an impact matrix of all the policies assessed.
“Climate Change Mitigation and Adaptation” and “Natural Resources, Water and
Contaminated Land” each score the most negative scores as indicated by red
squares. “Air Quality and Noise” score the next worse. This impacts significant
environmental impacts of the plan objectives, especially for Climate Change. In
a Climate Emergency this is not a viable way forward.
(B) SA, page 53, Table 3.2 gives an impact matrix of all the sites assessed. Many
sites are scored red for Climate Change.
We note that the Director of Place, Norwich City Council, has commented that
the level of growth in rural areas “is very hard to reconcile with the climate
change agenda and the need to reduce carbon emissions” 4 which is reflected in
the SA assessment.
(C) SA, page 62 (part of Table 3.3) identifies adverse impacts. Under Climate
Change “Contribution to greenhouse gas emissions”, it states under 3 bullets:
i. That Policy 2 for low carbon energy generation and sustainable building
design is not expected to fully mitigate this impact. The statement is
meaningless as “this impact” is not defined properly, and what “fully
mitigate” would mean is also not defined. The statement lacks any
quantification; this is where proper budgeting, footprinting and targeting
could turn a meaningless statement into something which is measurable
and monitorable.
ii. Policies 2, 3, 4 and 6 will provide a “multifunctional green infrastructure
network” that will provide “additional carbon storage” or carbon sinking.
This is again fine words, but totally unquantified. There is no clear
indication of what is intended to be achieved, and how much carbon will
be sunk, and how, and how much, it will contribute to keeping with a
Paris aligned carbon budget for the area.
The role of Green infrastructure as a carbon sink needs to be developed
with details of specific methods which will produce the best outcomes in
emissions reductions.
iii. Policy 4 aims to encourage sustainable transport and a reduction in traffic
related carbon emissions. They policy is not expected to meet a 30%
reduction in carbon emissions from road transport by 2032, an objective
under the 2018 DEFRA Clean Growth Strategy. This is of great concern
– we have shown above that transport emissions in the area are at 2005
levels and rising. We look at Transport in Policy 4 in more detail below.
We note that the Director of Place, Norwich City Council, has
commented that “the lack of ambition on transport issues and the focus on
significant development in rural villages is inconsistent with the
statements within the plan on addressing climate change” .

Object

Representation ID: 20597

Received: 10/03/2020

Respondent: Climate Friendly Policy and Planning (CFPP)

More detailed comments on Egnida EIS document
29 The comments in this section have been kindly provided by Dr Nigel Hargreaves of
the Norfolk Community Solar, and are reproduced with his permission.
30 The EIS is promising, but we highlight concern to the frequent references to CHP (if
biomass or fossil gas fired), gas boilers and diesel generators. No fossil fuel or burning
technology should be encouraged in the plan in the Climate Emergency and for Air
Quality reasons.
31 The report is “light” on some specifics:
i. Inclusion of energy storage as part of the flexibility solution
ii. No mention of community energy, although despite promoting ESCos. The plan
could significantly support community energy schemes via ESCos, as per EIS
page 47 "The potential for local authorities to be involved within this type of
approach [ESCo] is being explored further in an additional study investigating
appetite for local investment and suitability of public, private or hybrid
investment model approaches.”
iii. No mention of microgrids, although “semi-islanded” developments are
mentioned. The plan could provide pro-active policy support to promote
development of these.
iv. There could have been more specific recommendations such as solar car ports
v. Grid connection ‘capacity bagging’ ahead of building should not be tolerated
beyond a limited period.
vi. The Electricity tariff of 11p/kWh set in the case study (EIS, page 40) is far too
low - making the business case for the proposed scheme appear less viable,
despite a healthy looking 8.3% IRR.
vii. The exclusion of community energy shares, or any non-developer commercial
interests, in any of the discussion, which could substantially change the costs and
look of projects, is a big omission. Denmark, Sweden, Germany and even
Scotland are much more switched on to this – why not Greater Norwich?
32 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.