Back in October of 2021, we wrote about embodied and operational carbon in development, and how collaborative action was required across the industry to ensure real change. You can read it here.  At the time, COP26 was all over the media, and the topic was rightly getting a lot of airtime. It felt like a real moment for action on climate change.In this blogpost, Kiri Shuttleworth, Associate Director and Shaun Andrews, Executive Director at Nexus Planning, consider how things have changed in a post-COP27 world, and introduces a ‘London based Sustainability Policy Tracker’ prepared by researchers at Nexus Analytics & Research. Special thanks also go to Zena Foale-Banks for her contributions whilst at Nexus and before returning home to Australia. The research takes a look at planning policies in adopted and draft Local Plans across London and identifies the local authorities that are taking steps to introduce policies that will make a contribution to the decarbonisation agenda.

The bigger picture: the climate crisis globally

The Intergovernmental Panel on Climate Change (IPCC) 2022 report established that global warming is likely to reach above 1.5c within the next 20 years (with other reports indicating somewhere around 2035). According to the report, at present, extreme weather events caused by human action are surpassing the resilience of some ecological and human systems, sometimes with irreversible effects. Never has global warming been more relevant than during the summer in the UK, when temperatures reached above 40c for the first time.

The report also emphasizes the impact of climate change on health, stating that it would continue to deepen problems of inequality.

It is difficult to see how anyone can deny how important genuine action on climate change is at this stage, and local authorities and the development industry must play a vital role in that action.

UK wide view

In the UK, around 300 councils have declared a climate change emergency. This means that they have committed to taking action to reduce carbon emissions and tackle climate change within their local area. For many, it also means committing to being carbon-neutral by 2030.

But while this is all well and good on paper, analysis by the not-for-profit campaigning organisation Climate Emergency UK found that out of a total of 409 local authorities across the UK, 84 did not have climate action plans as of September 2021. And when scored against a range of criteria, many of the adopted action plans were found to be inadequate. This is of course against a backdrop of chronic under-funding.

The group assessed the action plans against 28 questions across nine topics, based on an expert-approved checklist. Each council was marked against these criteria and given a right to reply before the scores underwent a final audit. The average total score was just 50%.

Manchester City Council scored the highest with a total of 87%. Solihill Metropolitan Borough Council (85%), City of Edinburgh Council (82%) and Newcastle-upon-Tyne City Council (82%) also scored well.

In London

In London 29 out of 33 London boroughs have declared a climate emergency, and 24 out of those 29 have set targets to become carbon neutral earlier than the UK wide and London Plan target of 2050, many by 2030. However, according to the Climate Emergency UK audit, only four authorities in London (Hammersmith & Fulham, Southwark, Richmond and Lewisham) scored higher than 75% in total. The authorities that scored the highest had set measureable targets for getting to net zero carbon, including through setting actions relating to planning. For example, the Hammersmith & Fulham Climate and Ecology Action Plan includes an action to update the Planning Guidance SPD to ensure new development proposals comply with the higher building design standards specified in the London Plan.

As we discussed in detail in our November 2021 blogpost, the London Plan, which was adopted in 2021, introduced a range of policies that aimed to catalyse action to decarbonise the city. The London Plan introduced Whole Life-Cycle Carbon Assessments and Circular Economy Statements to the planning application repertoire, going beyond the more typical requirement to submit energy and sustainability statements with planning applications.

As a reminder, a Whole Life Carbon approach identifies the best opportunities for reducing the lifetime emissions of development across construction and operation, while a Circular Economy Statement demonstrates how a development will incorporate circular economy measures into all aspects of design, construction and operation (measures include, for example, recycling, re-use, repair, remanufacturing).  These documents are currently mandatory for schemes that are referable to the GLA.  However, the London Plan supports local authority development plans that apply a lower threshold for these documents. So is this the direction of travel?

The future of climate related planning policy

With the broader climate crisis in mind, our general expectation is that over the coming years, planning policy will evolve at the local level to require carbon reduction and circular economy requirements for more and more developments and that these will become increasingly stringent. If local authorities are to become carbon neutral by 2030 as so many of them plan to be, LPAs are likely to want to include planning policies in their new local plans and SPDs that match their climate emergency declarations.

Will we start to see local authorities requiring the submission of Whole Life-Cycle Carbon Assessments and Circular Economy Statements for most planning applications, as suggested by the London Plan?

Our research findings

Nexus Planning has conducted research that looks at adopted and emerging Local Plans across London. In particular, researchers looked at policy and validation requirements and have established where and at what thresholds LPAs require the submission of Energy Assessments, Sustainability Statements, Whole Life-Cycle Carbon Assessments and Circular Economy Statements as part of the suite supporting documents for planning applications.

The full resource can be viewed here.

While the submission of an Energy Assessment, Sustainability Statement or combination of the two is pretty standard across almost all 33 authorities, our research shows that references to Whole Life-Cycle Carbon Assessments and Circular Economy Statements are starting to become commonplace in Local Plans that are currently being drafted.

There is only one adopted Local Plan which currently requires a Whole Life-Cycle Carbon Assessment to be submitted – Westminster. Westminster’s City Plan 2019-2040 (adopted 2021) Policy 37 requires major applications that involve substantial demolition to submit a Whole Life-Cycle Carbon Assessment.

Early issues

The aforementioned Westminster policy has been the subject of very real and relevant public debate over many months, with M&S’s plans to demolish their Oxford Street store called in by the Secretary of State for Levelling Up, Housing and Communities and reviewed at Public Inquiry. Campaigners argued the project would release 40,000 tonnes of CO2 into the atmosphere, while M&S argued that the proposal would use 25% less energy than the existing site with a maximum carbon payback of 17 years and potentially less than 10.

The Inquiry closed on 4 November 2022 and it will be fascinating to see the outcome, and how this is dealt with by both the Inspector and the Secretary of State. It will be a landmark decision which sets the approach to how these issues are considered going forward.

More Policies Emerging

More broadly, nine other draft Local Plans include draft policies that require applications for major developments to be supported by either a Circular Economy Statement (City of London, Bexley, Enfield, Lewisham and Richmond) or a Whole Life-Cycle Carbon Assessment (Bexley, Enfield, Merton and Wandsworth).

Two local authorities that have consulted on draft Local Plans include draft policies that require applications for major developments to be supported by both (Bexley and Enfield). The Bexley Draft Local Plan underwent Examination in Public between May and October 2022, and they are currently consulting on the proposed main modifications to the Draft Local Plan, while the regulation 18 public consultation for the New Enfield Local Plan took place in September 2021 and an updated Local Development Scheme will be published in early 2023 providing updated timescales for the publication of the proposed submission plan (Regulation 19), and submission timetable.

More Local Authorities are likely to follow suit and we aim to update our tracker periodically.

A number of Local Authorities have also either adopted, or are in the process of producing, specific SPD’s relating to Climate Change. One advantage of using this route is that they can be produced and adopted more quickly than Local Plans, but that they become material considerations in decision making.  For example, we are already seeing the requirement for Water Neutrality Statements in some authorities in South East England.

Planning policy and action against climate change

The emergence of policies in draft Local Plans across London that require greater scrutiny of a development’s lifetime emissions and circular economy measures indicates that local authorities are beginning to develop and implement policies that seek to marry with their climate emergency declarations. This highlights the fact that they recognise the important role they have, and that the development industry must contribute to climate change action. However it will be important that policies are designed to allow for the nuanced arguments to be considered and that developments that are positive for the planet and the community can proceed.  There is likely to be much difficulty ahead as Local Authorities and the built environment sector at large grapple with this and the need to ensure that important developments are viable and can proceed. Planning policy therefore needs to be combined with other measures such as tax incentives for developers to decarbonise buildings (including VAT relief/tax credits) for major retrofits, or green mortgages with lower interest rates for more energy efficient properties. Such measures would represent an important shift in our battle against climate change.

As the IPCC continues to report, climate change is widespread, rapid and intensifying. However, strong and sustained reductions in CO2 and other greenhouse gas emissions could still limit climate change and its associated impacts. It is therefore immediately critical that the right steps are taken on climate change and Government working with the built environment sector will need to bring its A game.

Authored by

Kiri Shuttleworth, Associate Director

Authored by

Shaun Andrews, Executive Director