The challenges to making zero carbon a reality in new housing developments
December 04, 2020
December 04, 2020
How can developers and local authorities in the UK collectively deliver clean growth through flexible policy making?
The Government’s 10-point plan released last week was welcome news to actions that will take the UK close to the 2050 net zero commitment. Ultimately actions rather than targets will move us forward.
In this article, Jonny Riggall explores the difference between just setting targets against the need for action, the disconnect between the two and how developers and local authorities need to collectively deliver clean growth through flexible policy making.
In 2019, the UK Government passed a law for the UK to achieve net zero emissions of greenhouse gases (“net zero carbon”) by 2050, as recommended by the Committee on Climate Change. The UK is the first major economy to do so.
Government have reiterated their strategy for delivering an approach to net zero carbon for new housing development in the Planning White Paper Planning for the Future, through the Future Homes Standards. Through this consultation Government are also looking for views on the role of local authorities in supporting this ambition.
Running parallel to this, following a wave of Local Authority Climate Emergency declarations in 2019-2020 , there has been a rush to establish and deliver action on climate change through the local plan making process, preceding Government definition.
We are already seeing this aspiration translated into wide ranging local planning policies striving to deliver zero carbon development. Whilst commendable this rush to take action is arguably creating confusion and ambiguity around expectations and requirements.
We have previously seen requirements from authorities asking for Zero Carbon Homes, Net Zero Carbon Buildings, Net Zero Carbon Development, and Carbon Neutrality. These terms all have very different meanings, have different implications for different developments, and, crucially, result in different outcomes.
We’ve been here before. Back in 2006, Government set a path to zero carbon which was scrapped seven years later. This era of zero carbon homes, and Code for Sustainable Homes (Levels 5 and 6), showed a diminishing carbon return on investment into energy efficiency. The additional costs of more insulation, high quality ventilation systems, alternative heat technologies, and longer more complex construction processes affect development viability.
Whilst zero carbon homes are technically possible, the issue is that the traditional development stack across the majority of the UK cannot afford it. This has not changed.
The Government defined the economic trilemma of cost, decarbonisation and energy security as the Clean Growth Grand Challenge within the UK Industrial Strategy. It is a Grand Challenge for a very good reason. There is no silver bullet that delivers zero carbon growth, without significant short-term cost.
Not tackling the trilemma in policy making has the potential to take us all back to the ‘Cutting the Red Tape’ era which will not result in good outcomes for the planet.
But who should be paying for our collective obligations to the climate emergency? It is right that Local Authorities should be placing this cost and additional onus on developers beyond the National framework in addition to asking them to find the silver bullet? Are Authorities in the best position to marry the complexities of Town and Country Planning, the Electricity Act, Climate Change Act and Building Regulations?
First of all, it is important to understand what is being asked for in the decarbonisation in new development.
Traditionally the term zero carbon in the housing sector only focused on energy usage. The evolution of this concept has seen independent organisations such as the Green Building Council look to create further parameters for zero carbon to include carbon emissions associated with construction, operation and embodied within materials.
Holistically, true net zero carbon requires consideration of a greater range of parameters, arguably more important than just energy use alone. Net zero carbon is where the balance of greenhouse gas emissions within project, asset or system is equal to those captured or displaced.
We are seeing local planning evidence bases being created that refer to independent standards such as the Green Building Council as being ‘industry recognised’ and therefore justified.
Applying such standards within the Town and Country Planning process present a range of issues.
What is the legal basis for regulating emissions outside of the existing National Allocation and Implementation Plans? Who pays to meet such standards: the land owner, developers’ margins or out the Section 106 pot? Who is responsible for compliance monitoring if standards are managed by independent third parties and out the hand of the local planning authority?
Independent standards have not gone through regulatory testing against such issues and are therefore open to challenge if used in local policy. It doesn’t mean they don’t have value but can they be used for planning policy?
Where will planning inspectors draw the line? A limited evidence base and the potential to make new development unaffordable may not pass sustainability tests.
This could well end up stymieing the UK’s housing sector from achieving net zero carbon, which is ultimately what we are striving for.
Has nothing been learnt from the last 15 years of failed zero carbon homes policy?
Local Plan making needs to allow flexibility for development to achieve the required outcomes. This needs a holistic understanding of the issues.
For example, UK transport emissions have seen no meaningful decrease in 30 years. Yet energy emissions by 2030 will be near 80% lower than 1990. This is an important consideration, especially in light of the legal challenges to Road Investment Strategy 2 on the basis of alleged failure to address CO2 reduction and the lack of a realistic roadmap to transport zero carbon. If a land development scheme requires significant road improvements to enable growth could it face similar legal issues?
Only time will tell but it is not unreasonable to suggest that climate emergency policy that deals only with energy demand (Zero Carbon Homes or Net Zero Carbon Buildings) is discounting the largest direct emitter of carbon from new development, transport.
We believe encouraging investment into decarbonisation needs patience and pragmatism. It needs to be considered in parallel to all Local Authority needs including social housing, road investment (ironically), and social infrastructure (schools, nature etc).
It requires National Government and Local Authorities to work together on the agenda to create a consistent message and definition to the zero carbon outcomes being sought.
That does not mean watering down the definition, it instead requires whole system thinking.
At a National level, investment is needed to enable supply chains to rise to the challenges. For example, a Green New Homes Bonus could be offered to stimulate action on raising construction standards.
Local Authorities need to act as a catalyst to make the change happen. Mandating targets through the Town and Country Planning Act has previously proven complex. Perhaps now is the time for local authorities to consider alternative approaches to enable change rather than through local plan making policies?
For example, local plan making could be used for spatially planning Nature Based Solutions to carbon removal. Ultimately such approaches to carbon removal are based on land use change and should be planned for accordingly. Perhaps, a better use of the planning instruments to create value?
If a pragmatic approach is taken, then Net Zero Carbon Development or Carbon Neutrality are far more likely to be achieved outside the Town and Country Planning Act than within it. A sensible net zero approach perhaps?