The Labour election manifesto and The King's Speech both promise substantive changes to the UK planning system. Some will be achieved through a new Planning and Infrastructure Bill, and some through changes to the National Planning Policy Framework (NPPF) which has just opened for consultation. Our first-glance analysis is that several of the proposed changes show good intentions to engender better strategic planning, to help deliver social housing and renewable energy, and a ‘vision-led’ approach to transport planning.
The changes are vaunted to unlock growth and accelerate housing delivery, but it’s worth remembering that these have also been the stated intentions of a slew of reforms over the past 12 or more years. Climate action did not fare well in these changes: zero-carbon housing requirements were dropped, barriers to onshore wind energy were imposed and, most recently, Local Plans were instructed not to go beyond national standards for energy performance than.
There is plenty of evidence as to what an effective, climate responsive planning system should look like. As the TCPA’s Hugh Ellis puts it, “the main questions which surround planning reform have all been asked and answered in the various reviews of the system over the last decade. The Raynsford Review provided the foundations for an effective and legitimate system, Oliver Letwin dealt with strategic delivery issues, the RTPI with the funding crisis, and the Committee on Climate Change has repeatedly set out the preconditions for an effective planned response to the climate crisis.” Here we look at three key aspects of the proposed reforms and how they relate to addressing the climate and nature challenges we face.
Housing supply and the need to build better
The government’s headline ambition for 1.5 million new homes is the same 300,000 homes per year target that has been a longstanding government policy. The planning system was last substantially overhauled in 2011 in a deregulatory push intended to accelerate housebuilding. Yet housing completions have struggled to pass 200,000, leading to an accumulating shortfall against the target. It’s reasonable to conclude that deregulating the market hasn’t worked: it hasn’t delivered the numbers, and it certainly hasn’t made housing affordable or climate-ready. To meet society’s needs, around half all new homes need to be available at a lower cost than the market is provides (i.e. affordable housing) compared to the rate of 10-20% typically achieved.
Meanwhile, 100% of those new homes should be climate-ready, compared to almost none at present, according to the Local Government Association. Eighty per cent of the homes that will exist in 2050 are already built, so building the remainder to the highest possible standard is crucial to avoid further costly adaptations being needed. Many local authorities want to be more ambitious than the national standards on carbon and energy performance set down in the Building Regulations, and there is no good reason to stop them.
Key standards that could be adopted include Energy Use Efficiency Targets, which would help target the benefits towards lower-income groups; and Whole Life Carbon Assessments, which encompass both the embodied carbon within buildings and their construction, and the operational emissions they produce while in use. Neither of these appear to be embedded in the proposed reforms.
In recent years there has been a lack of strategic planning that has limited the ability of planning to deliver its intended outcomes. Opportunities for local authorities to work together across their boundaries to make higher standards more viable and deliverable would be widely welcomed, and this could be done through new Joint Strategic Plans if the government were to enable it.
Combined authorities already have significant ambitions to support sustainable and affordable housing and, if given greater powers to be pro-active in development, including through additional compulsory purchase powers for land assembly, they may have an opportunity to overcome viability obstacles and ensure that new homes and neighbourhoods are built to higher standards.
The ‘Grey Belt’: setting high expectations?
Some land currently protected by Green Belt policy to prevent suburban sprawl is of a low environmental value, including previously-developed land. Labour have called this the Grey Belt, and consider it could be better used for development. But just because it’s ‘grey’ doesn’t necessarily mean building on it would be a sustainable outcome.
A good solution could be to make the release of Green Belt sites for development contingent on exceptional standards of sustainability. For example, a development that simultaneously supports a tram service, a district heat network, small business premises and a wildlife corridor would be a good example of a situation where the Grey Belt could be genuinely beneficial. The policies covering the release of such sites need to be precise and pro-active. The NPPF consultation appears to go part way towards this with new ‘golden rules’ for Green Belt land release, but higher sustainability ambitions are needed.
It's also striking that, at least in Yorkshire and Humber, much recent nature recovery has happened in former industrial sites, quarries and open cast mines, so the current environmental quality of a site is not a reliable indicator of its future potential. Nature and development should be delivered together, if places are to become more liveable and responsive to the climate and nature challenges we face.
Onshore wind: harnessing support
In 2015 a new footnote to national policy set a much higher threshold for community acceptability for onshore wind proposals than for any other form of development. Insidiously, this embedded the idea that planning system can enable or constrain different forms of development by varying the threshold for opposition. But the planning system provides almost no mechanism for gathering and measuring community support for development and, in the case of wind energy, there is good evidence that it is widely supported.
For smaller and community-based schemes, tools like Neighbourhood Development Orders could be harnessed to bring proposals forward. Meanwhile the government’s review of National Policy Statements (NPSs) will undoubtedly bring onshore wind energy within the scope of Nationally Significant Infrastructure Projects (NSIPs), meaning that large-scale schemes could be determined nationally rather than by local authorities. This could help wind power to take a bigger share of future energy needs and potentially accelerate the phasing out of fossil fuels from the electricity sector, in support of the government’s green energy ambitions. Care is needed, though, to avoid a political backlash if communities feel their concerns are being bypassed.
What’s missing?
Planning needs to take a much stronger role in reshaping existing places and making them fit for the future. In particular, the UK’s existing housing stock is the least energy efficient in Europe, and for many families this means homes that are too expensive to heat or cool, and contribute to poor health. YHCC’s new evidence Our Carbon Story shows that a focus on upgrading pre-1919 terraced housing and pre-1930 semi-detached housing would have the most impact on reducing the carbon emissions from the housing sector, with associated benefits in tackling health and fuel poverty. It’s important to emphasise here that whilst some experts consider these ‘deep’ retrofit approaches – mainly insulating walls, underfloors and inhabited attics - as too slow and costly a decarbonisation route compared to heat pumps, solar photovoltaics and battery storage; only deep retrofit can really tackle the fuel poverty and associated health and comfort challenges.
Planning currently has very limited powers within existing neighbourhoods, and in our own regional policy principles we suggested innovations in how this could be tackled. For instance, Conservation Area policies can protect the visual and functional character of neighbourhoods. This approach has been used very creatively in some places, for example in the Kelham Island and Neepsend area of Sheffield, which is a perfect example of how higher development expectations and a creative relationship between local authority and developer have transformed the area into one of Sheffield and the region’s greatest regeneration successes.
Another possible innovation would be an amendment to the General Permitted Development Order (GPDO) so that conversion, change of use and refurbishment works to your home or commercial premises are only exempted from needing planning permission if they achieve key upgrades in energy and water efficiency. You would still have the option of not upgrading, but you would have to apply for permission.
Labour’s election manifesto singled out the planning system as a major brake on economic growth. But there is good evidence that the solution is not to remove planning from the equation but to make it more strategic and proactive – giving it more powers to secure truly sustainable development. Giving local and combined authorities more powers to acquire and bring forward land in the right places to deliver development where it’s needed and especially where the market is weak. The logical solution is to provide more financial powers, not fewer planning ones.
Andrew Wood, Senior Engagement and Impact Officer, Yorkshire & Humber Climate Commission
Photo: Wikimedia Commons
