Planning matters blog | Lichfields

Planning matters

Our award winning blog gives a fresh perspective on the latest trends in planning and development.

Planning for climate change: Is London STILL leading the way?
Last year Lichfields published a series of blogs examining various climate change issues. The first in this series explored London’s response to date on the climate change crisis and reviewed the recent findings of the CCC’s 2020 report to parliament. Almost one year on, climate change continues to be at the forefront of both public and government consciousness. This blog provides an update on London’s progress in achieving its Net Zero Target, in the context of a newly adopted London Plan and recovery from the Covid-19 pandemic. Before the pandemic, the need to tackle the climate crisis was a policy priority both in London and across the UK[1]. However, the economic and social context for climate action has changed in importance in the past year and it is recognised that pursuit of low-carbon can support economic recovery. From this, policy proposals and funding packages are now being framed as a means to create jobs, promote a “green recovery” from Covid-19 and help the UK meet its revised 5-yearly carbon budgets and achieve its net-zero emissions target. Over the past few months a number of key events have taken place including the Leaders Summit on Climate (22nd and 23rd April) and the 2021 G7 Summit (11th – 13th June) paving the way for vital UN climate talks at the COP26 summit, hosted by the UK in November 2021. Hosting these talks is a major responsibility and gives the UK more influence on the climate commitments of other countries. The power of our example is crucial and the Prime Minister has announced radical new climate change commitments that will set the UK on course to cut carbon emissions by 78% by 2035 and will require more electric cars, low-carbon heating and renewable electricity. The need to make progress was given emphasis by the recent publication of the IPCC Report[2]. The government is under pressure to back up this ambitious new target with investment and robust policies and to put the foundations in place for reaching Net Zero. It is doing so in the face of some domestic political challenge over the costs this might incur on poorer households and for managing public spending[3], and criticisms over the geo-political management of the issue in the run up to COP26[4]. Latest policy response In the last year, several key policy documents have emerged at the National level, including the Planning for the Future White Paper (August 2020) and the Ten Point Plan for a Green Industrial Revolution (November 2020). The latter sets out the Prime Minister’s ambitious plan for a ‘green industrial revolution’ and covers clean energy, transport, nature and innovative technologies, with the headline-grabbing announcement of a ban on new petrol and diesel cars from 2030. Whilst many welcomed the plan’s ambition and the Government’s recognition that tangible action is required to meet society’s Net Zero aspirations, the RTPI stressed that “only by investing in local authority planning teams would a localised framework be established to ensure investment is properly integrated into the built and natural environment”. This was recognised to some extent in the White Paper, which cited planning as having a central role in addressing climate change. However, its proposals did not require local plans to pursue carbon emission reductions in line with the Net Zero target under the Climate Change Act, nor did it address how national and local climate targets will inform the new local plans and planning decisions under the new system. In an effort to attempt to strengthen climate change considerations in local plans, the revised NPPF (2021) includes a change to the wording of the “presumption in favour of sustainable development” for plan making, and now requires plans to “mitigate climate change and adapt to its effects” (para. 11a). Whilst this might beef up the NPPF’s climate change policies, key conclusions from our previous blog were that the Net Zero Target is only achievable if it is embedded and integrated across all levels of policy and investment. There is still some way to go in ensuring that national policy is supporting and enabling local authorities to align their local development plans with national objectives. Recent policy proposals have demonstrated a centralisation of planning policy consideration on topics that affect the climate, which disempowers the ability to consider those issues at the local level. What’s going on in London? The pandemic has impacted London significantly, with the widespread (if temporary) emptying of offices prompting new commuting behaviours and changes to lifestyle. Headlines last year showed a dramatic fall in carbon emissions during lockdown – demonstrating that it is possible to reduce emissions in a short period of time. However, these reductions are largely linked with the slowing of the economy. In response to the pandemic, The GLA has produced a London Recovery Programme[5] which intends to ‘tackle the climate and ecological emergencies and improve air quality by doubling the size of London’s green economy by 2030 - accelerating job creation for all.’ Sadiq Khan has also spoken about the possibility of a Green New Deal for the city that will ‘increase access to green spaces, support active travel and zero emission fleets to eradicate air pollution, help adapt to climate change and deliver better health.’ These strategies are supported by the London Plan which was published on 2 March 2021.[6] Key headlines from the plan, relating to climate change, include the redefinition of zero carbon, requiring new buildings to meet at least 35% reduction of carbon on site with at least 10% (housing) and 15% (non-housing) from energy efficiency (paras. 9.2.5-9.2.7). This demonstrates how reducing energy requirements could be achieved through good design. The plan also introduces the regulation of embodied carbon levels in proposed buildings, requiring all major developments to be Net Zero Carbon by 2030. Its welcome policies mean all new developments must “calculate whole lifecycle carbon emissions through a nationally recognised assessment and demonstrate actions taken to reduce them” (Policy SI 2, Part F). In the context of the now adopted London Plan, the response of Boroughs (in terms of climate emergency declarations and the target dates for reaching net zero emissions) has varied (as shown below). London headline figures 29/33 (88%) London Boroughs have declared a climate emergency. 24/29 (82% of those that have declared) have set targets to become carbon neutral earlier than the UK/London Plan target. Only 2 boroughs have allowed themselves until 2050 to reach carbon neutral. The boroughs that haven’t declared a climate emergency are all outer London boroughs. Whilst most London Boroughs have now made significant commitments to net-zero carbon, it is not yet clear how the reduction targets are to be implemented. We are beginning to see London Boroughs advancing beyond these first steps of recognising the climate crisis by developing strategies to reduce emissions and create on the ground change. LB Greenwich has consulted on its Greenwich Carbon Neutral Plan (2020) which includes the principle of reducing emissions from new buildings, by committing to “strengthen the Local Plan by 2021 to deliver zero carbon development – through adopting a tiered carbon off-set price via SPD; increasing planning officer capacity to negotiate higher sustainable standards in new development; and evaluating options for a Local Plan review”. Similarly, LB Merton’s Climate Strategy and Action Plan (2020) links to the existing Strategic Objectives and Core Strategy planning policies of the Local Plan which features climate and carbon policy requirements, but also identifies the need to draft Local Plan policies in line with the London Plan: including net-zero carbon development for new buildings and reducing embodied carbon. Whilst London Boroughs do appear to be progressing their Climate Strategies/policies, there is still a long way to go and it will need a continuing commitment and development of expertise at city and borough level. The presence of the Mayor of London as a regional planning authority as part of a compact-city approach to strategic planning means that London, unlike anywhere else in the UK, has its own regional plan and the opportunity to develop robust planning policies, setting strong standards to inform and guide the policy approaches of the 33 London Boroughs. But is it the case that London is leading the way, or are local authorities elsewhere in the UK making significant progress without the backing of an additional tier of governance? Our forthcoming research on the UK-wide response of local authorities to climate change will explore place-based responses to the Climate Emergency across the UK. [1] As evidenced by the introduction of the Committee on Climate Change (‘CCC’) (2008), the UK’s commitment to the UN Paris Agreement and the legislation of a Net Zero emissions target of 2050[2] The report and its background appendices is available here:[3] The Office for Budget Responsibility estimated the total cost to the UK of reaching net zero by 2050 could reach £1.4trillion. The National Infrastructure Commission says the poorest tenth of households will pay an extra £80 a year in bills by 2050, the richest tenth an extra £400. HM Treasury is reviewing the costs of the overall programme.[4][5][6] credit: @Aquobex via Twitter  


Planning for climate change: Is London leading the way?
Last week was London Climate Action Week 2020, where world-leading experts and policy makers have come together to deliver a series of webinars to drive the national and international climate policy response, prioritising green recovery and focusing on solutions for adaptation and resistance. To coincide with this, Lichfields is publishing a series of blogs that examine various climate change issues.  This first blog looks at how London has responded to the climate change crisis thus far. Last month, the Committee on Climate Change (‘CCC’) published its 2020 report to Parliament assessing progress in reducing UK emissions over the past year, following its commitment in June 2019 to achieving Net Zero emissions by 2050. The report highlights the importance of securing a green and resilient recovery following the COVID-19 pandemic – seizing the opportunity to turn the current health crisis into a fight against the already accelerating climate change crisis. The committee reported that a limited number of steps have been taken in the last year, particularly in terms of policy progress, despite growing levels of public concern and activism around this issue by groups such as Extinction Rebellion. Five clear investment priorities are outlined by the CCC, including retrofitting buildings and constructing new housing to the highest efficiency standards; land use measures such as tree planting and building low-carbon infrastructure such as bike lanes. What is clear is that the Net Zero Target for 2050 is only achievable if it is embedded and integrated across all departments and at all levels of Government. The CCC recommended that all policy and infrastructure decisions will need to be checked against their consistency with the UK’s Net Zero target and as such, national planning documents e.g. the NPPF should be reviewed to ensure consistency against this objective. Thus, a change in national policy approach is the key to ensuring local development plans align with the national consensus. A Carbon-Neutral London? In London, the impacts of climate change are exacerbated by its dense population and its vulnerability to flooding, overheating and drought conditions. While the City has so far been protected from its worst impacts, much of London’s ageing and energy inefficient housing stock is not prepared for temperatures recorded in the UK in recent years and our infrastructure and communities are already suffering. The Mayor has set London some of the most ambitious plans to tackle climate change in the world. His recent mayoral campaign pledge centred around delivering a £50m Green New Deal for London, with a target to be carbon-neutral by 2030 – bringing the deadline forward from the legal commitment from the government of reaching the Net Zero Target by 2050. The New London Plan intends to support the Mayor’s strategies for tackling climate change, particularly relating to the built environment. The plan focuses on building homes to the highest possible standards through a variety of programmes and policies, including: Higher energy efficiency standards - extending the ‘zero carbon’ standards, (in force for residential development since 2016) to non-residential development and new energy efficiency standards, requiring a 10% CO2 reduction through efficiency measures for dwellings and a 15% CO2 reduction for non-residential development, contributing towards the minimum 35% on-site CO2 saving. Introducing more local decentralised energy sources – to achieve air quality neutral, developments are expected to low or zero-emission heating and power sources. By 2030 the Mayor is aiming for the city wide deployment of low carbon heating systems such as air source heat pumps. Kick-starting ‘whole-house’ retrofit projects across the capital – through the Retrofit Accelerator (launched in February 2020) which advises London Boroughs and housing associations on retrofitting buildings to reduce their carbon footprint and increase efficiency. The Plan predominately places the onus on London Boroughs to develop more detailed policies in line with the principles underlying sustainable design and construction, as well as increasing the requirements on developers of new schemes which can be secured at the planning stage. However, the Mayor has made it clear – particularly within his 2018 London Environment Strategy and in recent comments regarding the Government’s Future Homes Standard Consultation – that without the devolution of more powers from Central Government, London Boroughs will be held back on implementing policies which set higher energy efficiency standards for new homes and as such, the capital will not meet its net zero target. What are the London Boroughs doing? Since the Mayor’s December 2018 declaration of a climate change emergency, 29 of the 33 London Boroughs have followed suit and passed their own ‘climate emergency declarations’. A variety of targets in respect of reducing council-generated emissions have been adopted and while the majority have set a target of net zero emissions by 2030 – two decades ahead of the national government goal, some such as Tower Hamlets have set ambitious targets of becoming a carbon neutral Council as early as 2025. So what are London Boroughs doing so far? Islington Council, in partnership with TfL and engineering firm Ramboll, have developed ‘The Bunhill 2’ Energy Centre which extracts hot air from the Northern Line’s tube tunnels and provides heating and hot water for hundreds of homes and several public buildings in the borough. This ‘first of its kind’ system reduces carbon emissions and air pollution as well as lowering heating bills. Earlier this year, Tower Hamlets Council became the first London borough to rubber stamp a road made partly from old recycled tyres that would once have been destined for a landfill site. Other boroughs have focused on the aspirations and recommendations of their residents on how to tackle the crisis. Last year, Camden Council hosted the UK’s first Citizens Assembly on the climate crisis, allowing residents to consider evidence and develop proposals for practical action including making all new buildings zero carbon and installing solar panels on as many homes as possible. Camden introduced their ‘Solar Together’ group-buying scheme which enables Londoners to install solar panels on their homes at an affordable price – supported by the Camden Climate Fund. Although these examples demonstrate proactive steps taken by some London Boroughs, the majority are still only in the early stages of developing climate action plans and establishing their way forward. Recognising the severity of the climate crisis and committing themselves to reducing the causes is the first step, but it is important that these aspirations, whilst timely and valiant, are translated into effective policy and on the ground change. Whilst the London Plan sets out net-zero carbon home standards and how, through planning control, LPAs can potentially require developers to demonstrate how their proposals reflect carbon neutral objectives, few LPAs can show that their planning policies are designed to secure their area’s contribution to the full decarbonisation of the UK. This can lead to a situation where officers have no clear guidance as to whether proposals are consistent with the borough’s net-zero carbon plans and this can leave a substantial gap between planned policies set out at national or regional level and action at the local level. Climate change mitigation is therefore a vital component of wider planning and infrastructure policy that should not hinder the delivery of climate objectives at the local level. The CCC recommends that the Government should incentivise, support and enable local authorities to deliver emissions reductions and climate adaptation measures at a local level as ultimately, without adequate local planning systems and policies, it will be more difficult to progress zero carbon in practice.