"A worrying vagueness"

Our concerns with Planning White Paper

19 October 2020

The Government's Planning White Paper is worryingly vague at best and catastrophic for the climate at worst, says Rachel Coxcoon, Programme Director at CSE. In addition to the blog below, we've published a response to the consultation which you can download here


Inherent in the Planning White Paper is a worrying vagueness about what planning’s contribution should be in delivering zero-carbon places. There are hints that planning should “play a strong part” and a promise (or is it a threat?) that the National Planning Policy Framework will be amended to “ensure that it targets those areas where a reformed planning system can most effectively play a role in mitigation and adapting to climate change”.

What will this role be? Will government encourage, dare we say expect, planning to help shape places with zero carbon emissions? Or will planning be limited to a walk-on part because of an over-reliance on building regulations licensing buildings to  be ‘zero-carbon ready’, poised to receive guilt-free zero-carbon heat and power from an energy system that will miraculously change around them?

It’s the work of only a few moments to review this assumption, and wonder what will shape a zero carbon grid that will work in real places and around real people, if not the planning system? How will new heat and power infrastructure be delivered? How will these new homes be arranged and oriented to best minimise their energy demand? How will new residents travel into, out of, and through them? Where will they go to work, shop and socialise?

The White Paper presents an alarmingly reductionist view of the role of the planning system, focusing mainly on the delivery and appearance of houses as individual units, and the appeal of an attractive street-scene, rather than holistically sustainable design and function of entire places. In a societal sense, this is worrying. How places function must be at the heart of planning, before any consideration of the aesthetics of individual buildings, or the system will simply deliver more of what we have seen from the most recent round of planning de-regulation, e.g. “Developments that lack basic amenities, and are poorly connected to jobs, schools and other facilities”1, not to mention, tiny living spaces prone to overheating, inefficient and expensive forms of energy delivery, along with baked-in car dependency and minimal provision of cycling and walking infrastructure2.

From a Climate Emergency point of view, this reductionist view is potentially catastrophic.

To align with our commitments under the Paris Accord, we must begin by reducing our current emissions by nearly half within the next nine years, achieving this at the same time as trying to deliver the nearly 3m additional homes that Government believes we need in that same period. Reducing emissions at this rate, even without accounting for any new development, requires a monumental shift in almost every aspect of our lives. For those emissions reductions to occur in the context of a supercharged housing delivery target requires a generational shift in the way all new communities are built and function. Not only must they be inherently zero-carbon from the outset, they must, wherever possible, make a meaningful contribution to reducing emissions from existing development around them.

There is little in the way of compelling evidence to suggest that volume housebuilders are best placed to lead this transformation; indeed, their very corporate structure requires them to answer first and foremost to shareholders. The chance of a voluntary shift in delivery that suddenly chooses to internalise environmental or social costs into this business model is vanishingly small.

Therefore, the planning system must be given the tools to demand this shift; the building blocks of our ‘net-zero future’ must pass through the planning system. At the planning stage, the largest number of homes is under the control of the smallest number of actors. Used imaginatively, planning can enable a holistic, place-based approach that is well informed from local circumstances and meets the needs of communities. Properly enabled, the planning system also has the regulatory power to prevent unsustainable development.

In his foreword to the Planning White Paper, the Secretary of State claims that “We will build environmentally friendly homes that will not need to be expensively retrofitted in the future”. A laudable aim, but one that the framework that follows it cannot hope to deliver. Zero-carbon development requires much, much more than thinking about the simple building blocks of each home and a (nonetheless welcome) commitment to ensuring every street has some trees.

Sensible change

Nobody disputes that the planning system could be improved. Under constant pressure over the last 10-12 years to morph plan making and development management from visionary set of genuine place-making tools to a mechanistic licensing regime for new housing, at the same time as seeing a hollowing out of staff capacity due to austerity, many local authority planners feel exhausted and demoralised. Sensible change is needed, which must include better funding for local authorities, and paying due regard to the findings of the comprehensive Raynsford Review of planning from 2018. The White Paper does neither.

The White Paper proposes change on a massive scale; a comprehensive overhaul of the planning system, moving away from plan-led, case-by-case decision-making to an approach that divides places into growth, renewal and protected areas, and then applies to them differing approaches to consenting new development. In two of the three zones, permission in principle would be granted and the only meaningful control that local authorities would have would be through the development and application of design codes and pattern books. It’s clear that these are principally intended to focus the mind of developers on building ‘beautiful’ homes, in an aesthetic sense, rather than places that perform beautifully, in terms of creating genuinely resilient and sustainable communities.

If, as the mood music suggests, Government is already determined on implementing the key central reform (a move to zoning), then the changes are so significant that almost all of the primary legislation underpinning the current planning system will need to be replaced. At this point, and faced with this legislative opportunity, at a time when the need for action on the climate emergency has never been more pressing, we urge government to ensure that there is no more ‘kicking the can down the road’.

With a proposed total reboot of the planning system on this scale, driven by a government with a substantial parliamentary majority, there is a once in a generation opportunity to bind together the Climate Change Act and the Planning Act and create a legal duty on carbon reduction through new development. Without such a commitment, this unique opportunity to avoid the planning system becoming an active enabler of the climate crisis, in and of itself, is lost.


We would encourage others to respond to the consulation before the deadline on 29 October. You can find out how here. And of course you can use any of the arguments that we put forward in our own response.


[1] Dr Andy Inch, Executive Summary, ‘The Wrong Answers to the Wrong Questions', TCPA, August 2020

[2] www.transportfornewhomes.org.uk/wp-content/uploads/2020/06/garden-village-visions.pdf

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