Are local plans planning for the zero-carbon future we need?

7 July 2020

Dan Stone, Project Manager at CSE, reports on what he's learnt from reviewing the climate content of a dozen Local Plans ...

Nearly 70 % of local councils have now declared a climate emergency, and many have set 2030 as a date for going zero-carbon, 20 years ahead of central government’s 2050 target.

The planning system has crucial role to play in delivering effective action on climate change: it is the gatekeeper that allows renewable energy projects to go ahead and regulates how our built environment is constructed. It is also the only mechanism through which the spatial aspects of decarbonisation and climate adaptation can be addressed. So while the Climate Change Act legally commits us to net zero emissions by 2050, this will be achieved only if we plan for it; hence the question: are Local Plans actually planning for the zero-carbon future we need?

Since autumn 2019, the Centre for Sustainable Energy has been reviewing and commenting on Local Plans produced by various local authorities (both rural and urban), looking at their climate policy content and collecting good practice. This work is funded by BEIS, and will feature in a future joint publication with the TCPA. By June 2020, we had reviewed and commented on plans from a dozen local authorities around the country, nine of which have made climate emergency declarations. So this has provided a glimpse of what is going on out there, and we can make some tentative inferences.

The first thing to note is that – confirming research carried out in 2016 by the TCPA – most of the Local Plans we reviewed needed significant changes in order to address the climate crisis adequately. Most Local Plans do not acknowledge quite how radical and challenging the 2050 zero-carbon commitment is for planning and place-making. Indeed, the implications for planning beyond binding zero-carbon standards for new builds are dramatic enough to warrant listing here, and include:

  • A significant modal shift (and reallocation of road space) to cycling, walking and public transport, and a significant overall reduction in vehicle miles – this will require a wholescale re-imagining of development patterns and layouts based on presumed access on foot, by bike and by public transport, rather than by car. (See, for example, the research CSE undertook for Bristol City Council.)
  • Widespread electric vehicle charging networks, to allow petrol or diesel vehicles to be phased out.
  • A quadrupling of renewable energy capacity.
  • Energy efficiency upgrades to nearly all our building stock, including listed and historic buildings, public and private.
  • The removal of gas boilers, to be replaced with district heating network connections and heat pumps.

Climate change declarations targeting net zero emissions by 2030 necessitate doing all this in the next ten years.

Carbon auditing

Only two plans that we saw were carbon audited and set out carbon budgets. Fewer than half of the others mentioned carbon emissions at all. Where they did so, it was in general rather than specific terms, and the councils involved did not set out a carbon budget for their district, or quantify the impact of their policies on their emissions. This is important because you can only know your progress in reducing emissions if you are measuring them in the first place.

Plans that are not carbon audited to achieve radical carbon emission reductions ‘in line with’ the Climate Change Act, are unlawful. The 2019 briefing paper by Client Earth, the RTPI and the TCPA sets out further detail.

Climate mitigation policies for new development

Only a third of the Local Plans reviewed (all from ‘core cities’) had binding zero-carbon policies or objective standards for energy efficiency or carbon dioxide emissions. The remainder either had no policies at all for reducing emissions from buildings, or merely supportive policies, encouraging ‘high levels of energy efficiency’.

It certainly appears that urban unitary authorities are doing better: while most of the core cities with big planning teams and in house expertise in energy or carbon are pushing ahead with ambitious and binding zero-carbon policies, many rural authorities just don’t have these resources and are struggling to keep up.

Interesting in this context is the Future Homes Standard, which threatens to remove the discretion of local authorities to go beyond building regulations and impose zero-carbon policies – as many core cities have. National regulation is clearly the way to go, but only if it is strong enough and actually requires new development to be net zero-carbon. The Future Homes Standard should be a floor for those authorities struggling to keep up, rather than a ceiling constraining what the most ambitious authorities are doing to reduce carbon dioxide emissions from new development.

District heating

Only half the Local Plans reviewed included policies requiring the incorporation of district heating infrastructure into new developments. Among those that did not, some included supportive policies encouraging developments to be planned so as to allow it to be added at a later date; but this approach will require buildings to be retrofitted to decarbonise their heating systems soon after their construction, at significant public cost.

Even in authorities with district heating policies, few plans carried these requirements through into their site allocation policies – a missed opportunity, since significant housing or mixed-use developments are often tailor-made for district heating.

The best plans we have found require evidence that masterplanning and energy planning have happened concurrently and that district heating is a design parameter from as early as the masterplanning stage for any new development. It is no surprise that district heating is not found to be feasible in many large developments if it is introduced only as an afterthought.

Historic buildings

Given its age, condition and extent, de-carbonising our existing housing stock is a massive challenge – more difficult in fact than removing emissions from new development. It is therefore disappointing that only three of the Local Plans had policies encouraging energy-efficient retrofitting of historic and listed buildings, and only one had gone beyond this to set out locally relevant guidance for householders.

In many councils, conservation expertise has been pared back to a basic reactive service, with no scope for proactive advice to householders. The lack of supportive policies and practical guidance joining up conservation and climate issues is a significant concern; in many places, our planning and conservation systems are little more than barriers to the task of retrofitting our historic housing stock.

Climate adaptation

In the majority of Local Plans, climate adaptation related predominantly, or even solely, to flooding. Only half contained an overheating policy, and not all of these set out criteria and a specific methodology against which overheating was to be assessed. Only half of the Local Plans made the link between flooding or overheating and the provision of green infrastructure, and only a couple committed to increasing tree cover.

Renewable energy

Only a minority of the Local Plans had what we would describe as proactive and positive renewable energy policies which genuinely seek to maximise generation.

Two councils – both urban – had no stand-alone renewable energy policy at all, and, while stand-alone renewable energy projects are more difficult to deliver in urban contexts, they are possible, and opportunities should be explored and encouraged. Of the rural councils, some had policies which sounded entirely negative in tone (for example listing only negative impacts to be considered) or limited the scale of renewable energy schemes without apparent reason. Three plans gave support without listing the type of schemes that might be acceptable; only four gave in-principle support and defined suitable areas for different types of renewable energy.

This is not good enough. Renewable electricity is key to the UK’s entire decarbonisation strategy: decarbonising our buildings relies on the full decarbonisation of grid electricity; and decarbonising our transport system relies on the role-out of electric vehicles, powered by renewable energy. The Committee on Climate Change estimates that renewable electricity generation needs to quadruple to meet these demands.


Carbon dioxide emissions from transport have remained essentially static for decades. National planning policy, Local Plans and promotional materials for new developments are full of talk about prioritising sustainable and active travel over cars.

As explored in the (fairly devastating) transport for new homes report and illustrated in the brilliant and well-informed (though sweary) twitter account @planningshit, what actually gets built tells a different story: development located, designed and built for cars (often hung off a new link road, bypass or motorway junction), with token nods to cycling and walking infrastructure. All too often, the end result is fractured and unsafe cycling routes, unpleasant and inconvenient conditions for pedestrians, and car-oriented space-hungry layouts with dead frontages rather than active human streets incorporating green space.

Two thirds of the plans we assessed adopted a business-as-usual approach to transport issues, which will not deliver the step-change in travel needed to meet our carbon dioxide reduction commitments. Again, this isn’t enough. We cannot reach zero-carbon simply by swapping our petrol and diesel cars for electric. As illustrated in our work for Bristol City Council4, we need to reduce vehicle-miles and move to a modal split more like that in Amsterdam, as well as phasing out petrol and diesel cars.

The Covid-19 lockdown gave us a glimpse into what a sustainable transport system could offer: clean air and skies, quiet safe streets for kids to cycle and play in, more wildlife, and an insight into how malleable people’s transport behaviours might be given the right conditions and good infrastructure. During the lockdown when the streets were safe and pleasant for cycling and walking, families and new cyclists took to the streets in their thousands and bike shops reported bumper sales. The response from some councils has also been encouraging, with several decades’ worth of cycle infrastructure being provided or planned in a few weeks. Guidance from the Department for Transport has been clear: ‘The government ... expects local authorities to make significant changes to their road layouts to give more space to cyclists and pedestrians. Such changes will help embed altered behaviours and demonstrate the positive effects of active travel.’ [Emphasis added]

The government publication Decarbonising Transport includes similarly positive messages.

Yet even here, the money being put up is a fraction of what’s needed and a fraction of ongoing road investment, and the Department for Transport have not provided sufficient backup for making temporary schemes permanent. Some county councils are resisting efforts that will remove any parking and we’ve seen some cycle and pedestrian space allocations being quickly reversed at the first sign of resistance.

What we have seen is a convergence of an event (the pandemic), shifting public attitudes and government policies that begin to change transport expectations and behaviours. The public response and the lesson for planners and government is clear: when people feel safe to cycle and walk and have good infrastructure, they cycle and walk, and when they don’t, they won’t.

As a result, our approach to sustainable transport in the face of both Covid 19 and the climate emergency needs to be “build it, and they will come”. Capturing some of the best practice we’ve seen, the following changes are needed in Local Plans:

  • Safe and high-quality walking and cycling networks within all significant new development proposals linking to the wider network – for example segregated cycle lanes, more space for pedestrians. 
  • Going beyond the provision of transport infrastructure to talk about shaping places and streets for pedestrians and cyclists, with child friendly low speed layouts incorporating green space.
  • A more planned, comprehensive approach to cycle infrastructure provision at an authority-wide scale, as opposed to the poor, piecemeal improvements that we currently see.
  • Active planning out of cars from urban centres, reclaiming road space and implementing changes to create low-traffic neighbourhoods.
  • Re-developing over-engineered junctions, roads and roundabouts which deter cycling and walking, releasing former highways land for re-development, turning urban roads and roundabouts into more human streets, and further encouraging modal shift.
  • When planning for the contraction of retail floorspace, looking first at the re-development and densification of big-box retail areas and out-of-centre shopping areas before contracting traditional town centres. 

Many of these things are already being done by UK councils – but we need to go much further, much faster.

Beefing up Local Plans

In summary, most of the Local Plans we have reviewed are not planning for the zero-carbon future we need, or are not doing so with sufficient gusto. There are examples of great work, but there is just not enough of it, and the majority of local planning authorities appear to lack the necessary knowledge or experience. Many councils who have made climate emergency declarations need to beef up their Local Plans if they are not to fall short in their climate resolutions.
Our perception is that broadly there are three types of authority:

  1. The willing and able: These councils are busily creating robust policies fit for a zero-carbon, climate-adapted future. Typically better resourced city and unitary authorities, they are often well ahead of central government thinking and in light of the proposed Future Homes Standard, are achieving good things in spite of, rather than with the support of, central government. Central government can help this group best by providing surety on the direction of high-level policy, removing the shackles on policy innovation – on the condition that housing delivery is maintained and development remains economically viable.
  2. The willing but under-resourced: These authorities – often rural – face funding constraints that mean they are struggling just do the day-job. They need to be properly resourced and need access to tested policy approaches to cut and paste into their plans and pre-packaged support.
  3. The unwilling, uninformed or pre-occupied: Encouraged by the government prioritisation of housing provision over everything else, these authorities continue to plan as though the climate crisis is not happening and will not affect their residents. Central government can help by fully enforcing councils’ existing legal duties on climate mitigation and adaptation through Local Plan examinations, reinforced by messaging from the Ministry of Housing, Communities and Local Government.

If Local Plans are to genuinely contribute to the zero-carbon transition, and not frustrate it, the local authority plan-making function must be better resourced. Councils and the planning profession generally need much greater assistance on what a zero-carbon plan actually involves, and we need better collation and dissemination of the good practice already out there.

An officer from Wirral Council (whose emerging plan we reviewed) said: "The rapid shift in our understanding about the climate crisis can be difficult to square with the planning process. Wirral Council’s emerging Local Plan is seeking to address carbon reduction, leading us to ask what do carbon budgets look like at a local level, and how can we assess the carbon impact of different development options? Planning has traditionally been about balancing competing interests, but a huge challenge now is to rebalance the system, having overstepped environmental limits."

The promised release of revised Planning Practice Guidance on climate change may help answer these questions. And the forthcoming Planning White Paper offers a great opportunity to stress the centrality of planning to achieve a zero-carbon, climate-adapted future.

At the Centre for Sustainable Energy we have funding to offer three local authorities in the North of England a free, confidential ‘critical friend’ review of the climate policy content of their Local Plan, and beyond this, we can offer reviews of Local Plans for £1,800 plus VAT. To discuss this further, contact Dan at More widely, we are thinking hard about what a zero-carbon climate adapted plan looks like.

The issues raised by climate adaptation will be explored in a forthcoming article by Hugh Ellis in the ‘Time and Tide’ column in Town & Country Planning.

Stay up to date with our work - sign up for our fortnightly newsletter