Comment

Representation ID: 99339

Received: 18/12/2022

Respondent: Norfolk Wildlife Trust

We support the policy requirement for proposals to take a proactive approach to mitigating and adapting to climate change. However, the wording of section f appears unclear and open to interpretation. We recommend the policy wording better reflects the important role protecting all Priority Habitats, not just woodland, has in mitigating climate change and contributing to climate adaptation. We also recommend the inclusion of specific targets in order to ensure the policy is effective and delivers guaranteed benefits.

Full text: We support the policy requirement for proposals to take a proactive approach to mitigating and adapting to climate change. However, the wording of section f appears unclear and open to interpretation. In mitigating climate change and helping wildlife adapt to the changing climate, the retention of existing habitats is far preferable to their loss and replacement. Their value comes in part from their ability to sequester carbon but also from the carbon then stored in the soils, plus their ability to contribute to adaptation through allowing native species to move in response to climate change, helping secure the ongoing contribution of the natural environment to climate mitigation in the future. We therefore recommend the wording is modified to ensure that retention of not only trees but all Priority Habitats, are retained as the preferred option with the other options only where on site retention is not possible. We also query why the policy does not include any specific targets, instead using language such as ‘minimise greenhouse gas emissions’ and ‘help reduce carbon emissions’. Noting the legal targets for net zero by 2050, despite the best intentions of this policy it is unclear how it will actually secure the plan’s contribution to national climate change targets, or measure that delivery to demonstrate its effectiveness.