Please find the full response on Climate Change, Energy and Air Quality from Climate Friendly Policy and Planning (CFPP), Dr Andrew Boswell attached here CFPP-BOSWELL_GRF_CLIMATE_CHANGE_FINAL (please go past the first three pages to get to the real document).
The current climate change policy (at Regulation 18 or CC1R18) is to continue as before with the Joint Core Strategy (JCS) “policy”, but that has locked in over 6% carbon emission increases over the Norfolk transport sector to 2032 on the Councils own data, and has failed to deliver on sustainable transport infrastructure long promised. The transport carbon footprint in Norfolk, as derived directly from the Norfolk County Council traffic model, is currently around 1.1million tonnes of CO2 a year. This is the equivalent of burning c.400,000 tonnes of coal into the Norfolk atmosphere each year. Halving this by 2030 which is approximately what national policy requires – national policy is moving towards 44%emissions reduction in transport by 2030 but Norfolk is currently set to increase by 6% – would be a great achievement and one Norfolk, and the Greater Norwich councils could take great pride in.
So, something different is needed urgently. Here are my suggested requirements for a CC1R19 , the climate change policy to be developed for the regulation 19 consultation in about a year’s time. Read all the background and technical detail at CFPP-BOSWELL_GRF_CLIMATE_CHANGE_FINAL.
CC1R19, must be a “we’re taking climate change seriously” policy. To be so, it should be developed as follows:
- Bring forward the NATS review and NATSIP consultations. As at the NDR EiP, NATS was a set of around £140m of sustainable transport interventions.
The upcoming review should be based on reprioritising these projects. As the initial delivery dates have been completely missed, the emphasis now should be on reprogramming the delivery so that those which reduce carbon emissions and air pollution quickest are delivered first. This will require a detailed evidence base based on the Norfolk Transport Model and carbon projections – I also develop a requirements specification for carbon footprinting which would also enable this to be done in my document.
Whilst reprogramming, or basically redoing the delivery programme for NATS, is essential, a requirement should be that the BRT on all routes to Phase 3 level should be achieved by 2026 as originally intended in the JCS. In other words, there needs to be creative “catch up” built into the plan.
The new implementation schedule should also be designed to make sure that it aligns with the phasing of projected build-out of housing too. Proposals made below for a modelling requirements specification provide a way to do this. It is vital that sustainable transport infrastructure come on-line at the same time as new residents moving in. If good public transport services are readily available, it can help prevent lock-in to private car use for commuting.
- Freeze all new road building projects. These should be removed from the GNLP where they are implicitly implied, such as the Norwich Western Link and the Long Stratton by-pass. The freeze should cover both construction spend, and on-going planning and design costs as these divert vital resources.
The councils have a decision on whether to invest properly in NATS, and NATSIP, and deliver a sustainable transport system that, if implemented by 2026 as original planned, would be able to make a serious impact on carbon emissions within a decade. Irrespective on environmental issues, there is not enough funding for both NATS sustainable transport and road building. For the first time in many decades, sustainable transport should be prioritised over road building in Norfolk.
- Produce traffic models of each of the GNLP spatial options that go forward to Regulation 19 consultation and generate their carbon footprints compared to the base carbon footprint. Only the lowest carbon footprint options should go forward. If options 4, 5 and 6 are still in the pot at Regulation 19, they would most likely be eliminated on this evidence-based approach, although CFPP think they may be eliminated before that anyway on other grounds.
It is most likely that Option 1 of Urban Concentration close to Norwich would have the smallest transport footprint. However, I don’t think that the choice should be made on the handwaving statements (ie unevidenced) as at the top of page 35 in the Growth Options document. The choice should be made for the option that is modelled to produce greatest carbon emissions savings, in conjunction of delivery of a serious sustainable transport system alongside it. That choice can only be made, in an evidence-based way, when the carbon footprint exercise has been carried out. This evidence is a necessary requirement to be able design final options for the Regulation 19 consultation.
CC1R19 – an evidence-based approach using carbon footprinting
- Since before the JCS, CFPP have called for carbon footprint to be properly carried out and to underwrite evidence-based plan policy on climate change.
- In my response, I propose that carbon footprinting is pursued for the GNLP on a sectorial basis. The reason for this is that a well-developed transport model already exists which can provide the data for transport sector. It is also the transport sector where most can be done to reduce emissions in absolute quantities. Modelling the effects of housing distribution can largely be achieved by using the transport model too (the modelling of each options as discussed above).
- Therefore, CFPP propose that the focus of carbon footprinting is initially based on the transport sector as a function of the housing distributions and transport intervention delivery.
I provide a detailed requirements specification of how such carbon footprinting should be implemented building on the existing Norfolk Transport models which are well developed by Norfolk County Council, see CFPP-BOSWELL_GRF_CLIMATE_CHANGE_FINAL
Climate Friendly Policy and Planning (CFPP) is a one-person, Norwich based independent environmental consultancy. In response to the global climate crisis, CFPP have the mission to lobby for the development of climate friendly policy at all levels of governance and jurisdiction – local, national and international. I particularly specialise in advocating an integrated, systems approach that takes the best science, law, technology in developing policy to tackle social and environmental issues, particularly climate change, energy, air quality and housing.