Summary of issue
The Committee on Climate Change has highlighted that, in order for the UK to achieve its net zero carbon target by 2050, step changes are needed to decarbonise the building and transport sectors. The planning framework is central to this. It is a fundamental lever to deliver carbon mitigation and adaptation strategies from the building to the city level, as well as numerous other environmental, health and wellbeing benefits.
CIBSE’s recommendations for the planning framework (focusing on England and Wales) include new measures, and ending policies which are currently inconsistent with the UK’s climate change objectives.
1. Environmental, health and wellbeing benefits
Low-carbon buildings and cities can deliver numerous benefits in addition to carbon emissions reduction. These include low energy bills, high levels of safety and comfort, active lifestyles, and the multiple benefits of green infrastructure including biodiversity, improved air quality, lower run-off, and reduced urban heat island effects. This needs to be reflected in the public narrative and taken into account through a consistent system of planning requirements and incentives that truly encourage and reward the schemes which offer long-term benefits.
2. Climate leadership from local authorities and applicants
Government should allow and encourage local authorities and applicants who can and wish to adopt exemplar carbon standards on their developments, just as it is proposed to allow local choices around the appearance of developments. In addition to achieving carbon savings early, this will support the whole industry by developing skills, expertise and cost efficiencies. Measures government should take include:
2.1. Confirming that local authorities are allowed to set carbon performance standards beyond national standards, where viable. CIBSE does not support the proposals to restrict this contained in the 2019 Part L & Future Homes Standard consultation.
2.2. Providing a common framework to minimise uncertainty and costs for applicants: government should as soon as possible announce the steps to net zero carbon operational buildings, including new and existing buildings. Local authorities should be allowed to set standards on that trajectory and should be encouraged to require evidence of operational performance, rather than relying on as-built standards only.
2.3. Considering the creation of incentives for applicants to adopt net zero carbon standards e.g. reduced taxes, fast tracking of certain procedures.
2.4. Considering the creation of incentives for local authorities to require better-than-minimum standards, for example allowing them to retain a higher proportion of the proceeds from development (rather than them being collected at the national level).
3. Local authority resources (staff, training, guidance)
In addition to much better implementation of building regulations and planning policies, adequate resourcing could help make better use of a number of existing policies and tools which are currently under-used, to deliver improved environmental, safety, health and wellbeing outcomes e.g. the Social Value Act, policies to reduce construction waste, health impact assessments etc.
4. Adaptation to climate change
We must avoid creating a legacy of buildings which will need retrofitting or create risks to the safety, health and comfort of occupants. Local authorities should be required to address adaptation needs, including overheating risk, in their policies. Government should develop planning practice guidance accordingly.
5. Retrofit of heritage buildings and conservation areas
Government should develop planning guidelines on energy efficient, low-carbon and climate-adapted retrofit, in collaboration with heritage bodies, the IHBC, CIBSE and other professional institutions. It is crucial that this be thought through in order to maintain the quality and integrity of our built heritage, while allowing the transition to a zero-carbon built environment. This will require investment in resources and expertise, including conservation officers and energy / sustainability officers.
6. Permitted development rights (PDRs)
CIBSE support the adaptation and conversion of buildings as this can help minimise expenditure of embodied carbon and other resources. However, this must be given proper consideration, as with any design and construction project. While having a place for minor interventions, PDRs now apply to substantial developments, including housing. There are serious concerns about the safety, health and wellbeing consequences of this, and these developments are also missed opportunity for local authorities to:
- apply higher standards than the minimum regulatory requirements, in particular on carbon reduction and adaptation measures;
- ensure that new development takes account of public transport and local amenities, to reduce reliance on private vehicles;
- receive contributions towards the local community, which could go towards carbon reduction and climate adaptation measures.
In addition, recent announcements (March 2020) that PDRs will be extended to allow demolition of empty buildings for replacement by new housing are concerning: adapting and retrofitting existing buildings should be a priority; demolition should be minimised, and only happen with careful consideration and scrutiny where there is no viable alternative.
Overall, PDRs risk the creation of a subset of buildings that will require further and potentially expensive adaptation to meet net zero standards. If these buildings are leasehold properties, this also creates the risk of significant and unexpected costs for residents who buy leases in these buildings. Government must review the approach to PDRs.
7. Transition to an increasingly all-electric buildings and transport system
Government should develop requirements and guidance for local authorities to support the transition towards electric vehicles and increasingly all-electric buildings: this transition needs consideration of local infrastructure (capacity and needs) and of the interaction between buildings, generation and distribution infrastructure and the transport system (e.g. charging points, large-scale storage). Local and regional authorities are well placed to coordinate and plan for this. Furthermore, plans for vehicle electrification should be set within a wider transport and land use framework that delivers a significant shift towards public and active modes of transport.
8. Energy infrastructure
Government should review its approach to energy infrastructure: it is not consistent with the UK’s net zero carbon target to allow fracking and new coal mining, and therefore encourage a continued investment in fossil fuels. The planning system should encourage renewable energy schemes and other low-carbon energy infrastructure projects based on genuine community engagement, including community energy schemes, which facilitate acceptance and share benefits among local populations.
We strongly recommend the above changes to ensure the planning framework is consistent with and helps deliver the UK’s net zero target. This must be accompanied by better local authority resources to ensure the proper implementation of policy and the monitoring of outcomes.
- CIBSE briefing notes on Building Regulations Part L – Steps to net zero, 2019
- CIBSE response to consultation on the National Planning Policy Framework, 2018
- CIBSE Journal, The fallacy of Permitted Development Rights, October 2019
- CIBSE response to Environmental Audit Committee inquiry on Heatwaves, 2018
- CIBSE response to consultation on Part L 2019 and the Future Homes Standard
Julie Godefroy, Technical Manager
Date approved by Technology Committee: March 2020