Policy MW3: Climate change mitigation and adaption - STRATEGIC POLICY

Comment

Representation ID: 99122

Received: 11/11/2022

Respondent: Broads Authority

We have some queries and questions. These are not saying the Plan is unsound by asking these queries, but we would welcome thoughts on these and they may result in improvements to the Plan.
MW3 - Where a site will be in place for a number of years, would resilience to the effects of climate change be sensible to consider?

Comment

Representation ID: 99272

Received: 14/12/2022

Respondent: Anglian Water

We support the aims of the policy which aligns with our Strategic Direction Statement and strategic ambitions. Anglian Water recognises that climate change is one of the key challenges for us as a water company, and we have a clear ambition to become a net zero business by 2030 and reduce capital (embedded) carbon by 70% from a 2010 baseline. Our Net Zero Strategy to 2030 includes measures for decarbonising our electricity supply and vehicle fleet, as well as focusing on procuring green electricity. Currently we generate around 30% of our energy from renewable sources including bio-resources, wind, and solar power – our existing renewable energy installations not only contribute towards our renewable energy target, but also help to provide energy security for the operation of essential infrastructure such as our water supply and water recycling networks and assets. Our 2025 target is to increase our energy from renewables to 45% and 100% by 2030. Our strategy is based on decarbonisation principles and hierarchy that first reduces emissions, uses renewables and green energy, and then utilises carbon insets/offsets through natural sequestration measures.
We have also maximised opportunities to extract heat from final effluent discharged from Anglian Water water recycling centres which is then transferred to greenhouses in Norfolk (Whitlingham) and Suffolk. Closed-loop heat pumps are used to transfer waste heat from our water recycling centres to the greenhouses to accelerate the growth of the plants. The heat pumps are powered by a new CHP (Combined Heat and Power) plant, the carbon emissions of which are channelled back into the greenhouses to help the plants grow.
The policy accords with the paragraph 20 of the NPPF (National Planning Policy Framework), although it could set out clearer planning measures to address climate change mitigation and adaptation. A complete policy position would set out the current baseline of emissions from the mineral and waste sectors and show the pathway to reducing emissions by 78% by 2035 and to net zero by 2050, as set out in the Climate Change Act.
The recent announcement that the government has proposed changing national planning policy to relax restrictions on building new onshore wind farms in England by removing the rigid requirement for onshore wind sites to be designated in a local plan, is an opportunity to highlight that our operational sites such as WRCs could be potential locations for onshore wind, subject to other policy considerations.
In addition, we welcome the amendments to criterion d. following our representation to the Preferred Options consultation, regarding managing surface water flows through sustainable drainage systems, and connections to the public sewerage network.

Comment

Representation ID: 99293

Received: 14/12/2022

Respondent: Mineral Products Association

Due to the often-isolated nature of mineral workings public transport or cycling are not practical. Therefore, the additional wording is suggested to make the policy effective and preventing unnecessary work for the developer/applicant.

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.