In the year of COP26, we should be doing better than this ...

Responding to the National Planning Policy Framework Consultation

23 March 2021

What does CSE want to see from the latest round of changes to the National Planning Policy Framework? Dan Stone was one of the authors of our response to the government consultation ...


So here we are, responding to yet another government planning consultation, this time re-writes to the National Planning Policy Framework. You can read our submission here.

To tell the truth I’m feeling a shade disheartened, as these revisions only apply until the planning system is reformed all over again. It’s like trying to dress a toddler: you get them half dressed, then they wriggle away and take everything off again.

But the review certainly comes at a significant moment. It’s the first significant review of the NPPF since the 2018 IPCC report spelt out how much trouble we are in, and the first since the UK committed to achieving net zero emissions by 2050. And it comes just as the Committee on Climate Change has released the 6th Carbon Budget, setting out a detailed roadmap to net zero.

But the cherry on the top is that this year the UK is hosting the COP26 UN climate conference. So all in all you’d think this would be the perfect time for the NPPF to set out its stall and show exactly how the planning system will support the transition to a zero carbon economy.

Except it doesn’t. In actual fact, it’s mainly about making things pretty (sorry, beautiful) …

So what do we want to see? Well, first off, we – a coalition of comprising us, Town and Country Planning Association, Friends of the Earth, Green Alliance, UKGBC, Campaign for National Parks, Cycling UK, Rights: Community: Action, Wildlife and Countryside Link, CPRE, and the Ramblers – want the Government to explicitly tie the commitment to sustainable development to our binding legal commitments to achieving net zero emissions by 2050. Amazingly the paragraphs defining what sustainable development means (7-9) refer neither to climate change, nor to our commitment (as challenging as it is) to phase out carbon emissions in the next 29 years.

What we propose is the addition of this paragraph to apply to all planning policies and decisions:

9(a) Climate change is the greatest long-term challenge facing the world today. Addressing climate change is therefore the Government’s principal concern for sustainable development. For the avoidance of doubt, achieving sustainable development includes securing the mitigation of, and adaptation to, climate change. All planning strategies, and the decisions taken in support of them, must reflect the Government’s ambition to help business and communities build a zero carbon future and prepare for the impacts of climate change. Accordingly, planning policies and all planning decisions must be in line with the objectives and provisions of Climate Change Act 2008 including the 2050 net zero carbon target.

If you accept this, the implications flow thick and fast into nearly every aspect of planning. My take is that four things are needed if we’re to get to net zero emissions nationally:

Firstly, new buildings will need to be net zero, or ideally carbon negative. They really do. Decarbonising our existing, leaky old buildings is a massive enough challenge without new buildings adding to it.

Secondly, we'll need to drive much less, and walk and cycle more, and new development needs to be designed to facilitate this. No more car dependent housing estates on ring roads with no safe access on foot or by bike and no services. Everyone needs to be able to buy a loaf of bread, get their kid to primary school and get to work without using their car. Cycle infrastructure needs to be safe enough for your 75-year-old grandparent and your 7-year-old child to use, and comprehensive enough that your car starts growing moss.

Thankfully, the Department of Transport seems to agree. “Cycling and walking will be the natural first choice for many journeys with half of all journeys in towns and cities being cycled or walked by 2030” they wrote in 2020. "Routes must be designed for larger numbers of cyclists, for users of all ages and abilities.”

Great! But does the NPPF reflect spirit of the report? No - at least not to the extent or with the force needed (though the national design code does do a better job).

Thirdly, our energy system will need to be based on renewables, and local authorities must be pushed to have actual strategies to support renewable energy development - ideally to quadruple its deployment. Let’s have no more of the depressingly passive, negatively worded policies that are found in so many local plans.

As the current strategy is to cut emissions from buildings by 75% and electrify heating, you only get to net zero emissions if the electricity itself is renewable. The same is true of the electrification of transport. Decarbonising electricity is key to it all, and local authorities must not be allowed to opt out.

So does the revised NPPF stress the over-riding importance of rolling out renewables? Nope. Is there still a de facto ban on onshore wind, the cheapest form of electricity out there? Yes.

And finally, it’s not enough to do good stuff, we also need to stop doing bad stuff - I’m thinking of for high-carbon developments like airport expansions, gas power plants and coal-mines. When faced with planning applications for these, how should a planning authority go about actually assessing the carbon emissions? How should planners apply the national carbon reduction targets of the Climate Change Act and Paris Climate Accord to these projects?

I don’t know and it seems like local planning authorities don’t either. The NPPF is silent on the matter, with the relevant sections not even mentioning carbon emissions or climate change. And so applications are fought locally with unpredictable outcomes, like for example the Whitehaven mine in Cumbria and any number of airport expansion proposals. Why is the outcome of these proposals so uncertain and the approach to assessing climate impacts so unclear, given they lock us into high carbon emissions for decades? Making it up as we go along isn’t – or shouldn’t be – an option.

And this is unforgivable because we need a plan. For aviation, we may decide that being able to continue flying is important enough to pay the price in terms of sequestering carbon through some magical, yet to be fully defined (and suspiciously cheap) mechanism, but how much additional airport capacity can we stretch to? And how does all this square with our carbon budgets?

And as for fossil fuels, we really can’t afford to dig up and burn any more without blowing our carbon budget. So planning policy must have a presumption against all fossil fuel extraction, with assessment specifically linked to our national and international emission reduction commitments. Yet except for coal the NPPF is still largely supportive of fossil fuel proposals - and even there Planning Practice Guidance still requires local plans to define areas for further coal extraction, despite the fact that the use of this fuel for power generation is to be phased out by 2024.

The revisions to the NPPF fail to join the dots around the climate crisis; in the really high-carbon areas (fossil fuel development, aviation) it’s silent, while elsewhere (buildings, renewable energy, transport) it lacks urgency. As others have said before me, we need to treat the climate emergency as an emergency.

So if you can summon the strength, please respond to the consultation ahead of the deadline, 27 March 2021.


CSE response to the consultation into changes to government’s planning policy framework

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