Publication

The economy objective should be more explicit about the objective carbon emission reductions which are required by national legislation.

We recommend that your objective in relation to infrastructure provision is strengthened to reflect the scale of infrastructure provision required to deliver a zero carbon future, and the scale of the transport modal shift required for a net zero future, reflected in the governments decarbonising transport strategy9 and the Prime Minister’s 10 point plan for a green industrial revolution10:

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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.

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.

Whilst paragraph 10 of policy 2 above is a good start, it could go much further to reduce carbon emissions from new development. We acknowledge that the planning White Paper proposes and Future Homes Standard proposes interim standards to be introduced in 2020 and stronger regulations which would come into force in 2025, requiring an 80% improvement over building regulations. We’re concerned that these proposed regulations will be weaker than policies already in place in some local authorities, would permit development to be built with lower fabric standards than the existing 2013 building regulations. Additionally the 2025 standards will not result in new development being fully de-carbonised, assuming instead that the remaining carbon emission reduction will be delivered by the de-carbonisation of grid electricity. There is no guarantee that electricity from the national grid will be fully decarbonised, or the period over which this will happen.

We would also point out that the future Homes Consultation11 proposes requiring interim carbon emission reductions of 31% beyond existing building regulations from 2020. This should be the baseline for policy formation.

We would encourage you to go further therefore and toughen your policy stance to require new development to be net zero carbon. The most ambitious and all-encompassing zero carbon policy of which we are aware is that from the draft London Plan, which has now gone through examination without major amendments.

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We strongly welcome the reference to maximising the use of “local energy networks and battery storage” however the policy is not clear how this statement relates to new developments, other than standalone projects. The wording should be clarified to be clearer whether and how new developments (for example significant housing developments) are expected to incorporate these technologies. The inclusion of battery storage within significant new housing and mixed use developments would be very helpful in alleviating constraints in the electricity distribution grid and enabling greater utilisation of renewably generated electricity.

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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.

The text and policy aspirations could go much further, encouraged by a number of excellent policy publications from central government this year which should be referenced in the supporting text. In particular, it could be explicit on the scale of modal shift needed and reduction in car miles needed to get to net zero emissions.

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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.

We suggest below revised wording which would align the first part of policy 4 closer to these government policy documents. Policy 2 should also be aligned with these policy documents.

Policy 4 – Strategic Infrastructure Transport

Transport

Transport improvements will support and embrace new technologies and develop the role of Norwich as the regional capital, support strategic growth in the Cambridge Norwich Tech Corridor, improve access to market towns and rural areas and promote sustainable and active transport.

Transport infrastructure will be brought forward to support the development aims of this plan. A considerable shift towards non-car modes will be promoted in the Norwich urban area over the plan period with half of all journeys in towns and cities being cycled or walked by 2036.

To achieve this major development shall incorporate or fund the provision of high quality segregated cycle routes and direct and safe pedestrian infrastructure commensurate with the scale of development and trip generation and designed in accordance with Local Transport Note 1 / 20 - Cycle Infrastructure Design. Cycling is or will become mass transit and must be treated as such. High density growth will be focussed in locations with good access to improved sustainable transport networks and interchanges in Norwich, creating a virtuous cycle where clean transport is prioritised, less use is made of cars and space is used more efficiently and attractively. Development is to be designed around the principle of presumed access on foot, by bike and by public transport..

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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.

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.

The evidence base should provide an overall carbon budget for the district to 2050, consistent with the updated Climate Change Act. It should show baseline emissions and the impact of development and mitigating policies on this emission curve. The policies should
aim to secure radical carbon reductions in line with a trajectory for the authority area that is consistent with the UK achieving full carbon neutrality by 2050, and in the short term should test the policy options available to achieve the highest level of ambition possible to meet
this goal. To the extent possible, all new development should be zero carbon given that the country’s net zero target must be met in the next 30 years.

Where local authorities have followed the process of carbon auditing their plans set out in the NPPF and Planning Practice Guidance, the conclusions are often that it would be very difficult to achieve the required carbon reduction trajectory without new development
being developed to a zero-carbon standard, due to the additional emissions growth inherent in new development commitments. Thus, following the process set out in legislation, planning policy and guidance to the letter will support the need for very ambitious planning policies around building performance. Such an approach also provides evidence to support proactive and supportive renewable energy policies as essential.

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.

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.