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Planning policy requirements for climate change

by Mel Starrs on March 25, 2010

in Planning

CLG have just issued research (by Arup): …to examine the implementation of the Planning Policy Statement (PPS) on Climate Change, particularly through the take up of its policies in regional spatial strategies and local development plan documents, and their application through development control. It also identifies any barriers to effective implementation of the policies in the PPS on Climate Change.

I haven’t seen much fanfare in the press about this, so a quick summary blog post is in order. The findings should be of interest to anyone who writes sustainability or energy statements for planning (such as myself). Those who do will be painfully aware of the variances between authorities. This report supports that experience and suggests reasons why this is the case.

I’ve cheated and only read the conclusions and dipped back into the body of the report when I’ve found something of interest (it’s a 196 page pdf!). The highlights are below:

  • The two principal aims of this study were to examine the implementation of climate change PPS policies through take up of its policies in regional spatial strategies and local development documents and their application through development control; and also to identify any barriers to effective implementation of the policies of the climate change PPS.
  • The existence of SPD policy reduces (on occasion) a local authority’s priority to address the same issue (such as renewable energy) in detail in their core strategy; and this can create risk and confusion for developers.
  • Just under half the respondent authorities have such energy assessments in place but others are about to commission them. Together this represents 62 per cent of respondent authorities.
  • Key barrier to prioritising, carrying out and using feasibility assessments – Lack of any standardised methodology or clear advice in relation to the preparation of such assessments and debate regarding the importance of (and how to) consider financial viability.
  • Limited reference in RSS and core strategy visions to: achieving zero carbon in all new development; creating an attractive environment for innovation and investment in climate change technologies; and capturing local enthusiasm.
  • Perception that national zero carbon target is over ambitious particularly in heavily built up areas.
  • For some authorities a lack of understanding regarding the basics of climate change terminology, e.g. the difference between zero carbon and carbon neutral.
  • Least frequent consideration is given to the potential feasibility of decentralised and renewable or low carbon energy, and the ability to build and sustain socially cohesive communities.
  • Lack of clarity about the concept of building and sustaining socially cohesive communities might influence the land selection process.
  • Availability of low carbon and renewable energy resources were rarely used as criteria when selecting areas for development.
  • Perception of most regional authorities that identification of opportunities for decentralised renewable and low carbon energy could not easily be done at the regional scale.
  • While some authorities have identified specific areas of land as suitable for renewable or low carbon energy sources, this practice is not yet widespread.
  • A significant proportion of local authorities claim to have policies promoting renewable and low carbon energy generation and supporting infrastructure, but many relate solely to targets for supply to new development.
  • Sustainable buildings policy is less evident, with some local authorities suggesting that there is little to add to regional policies.
  • A lack of clarity regarding the policy requirement to promote decentralised, renewable and low carbon energy generation and the appropriate means to do this.
  • Targets relating to the supply of energy to new developments are being set in just over half emerging core strategies. Differentiated targets are less common, even in authorities where feasibility assessments have been undertaken.
  • There are inconsistent approaches to the scope and phrasing of energy supply targets (and also in relation to calculations regarding anticipated energy use).
  • Grouping of decentralised, renewable and low carbon energy together considered to be unhelpful due to their differing costs.
  • The need for a clearer inter-relationship between planning and building regulations, with a more strategic approach to land use planning.
  • Belief amongst some councils that viability testing of an energy supply target of 10 per cent is unnecessary because the use of such a target is widespread.
  • Nearly two thirds of authorities require information relating to climate change and sustainability through design and access statements or other sustainability assessments. Some request renewable energy statements.
  • Level of training and awareness amongst local authority planners and councillors in relation to climate change issues is proving to be a significant barrier. This includes a widespread lack of access to technical expertise.
  • Perceived conflicts with PPS22 and PPS3.

There are many, many more barriers and findings in the main report. Suffice to say, the conclusions are that the waters are generally very muddy. It’s good to see evidence that vindicates my personal experience between planners – now we just need to work out how to get ourselves out of this pickle! Some of the recommendations Arup suggest are:

Carbon reduction target instead of energy supply target. Consideration could be given to providing a greater linkage between planning policy and the national climate change agenda by replacing the PPS requirement for DPDs to set energy supply targets, with a requirement for the setting of carbon emissions reduction targets for new development. At regional level, the carbon reduction target could be apportioned sub-regionally, in the context of opportunities and scale of development in different districts. Local ‘carbon reduction target’ policy would require the reduction of emissions of the planned development from nationally agreed levels normally associated with a building/development of its type. This would provide a clearer relationship between the LDF and local authority performance targets and from these to regional targets and ultimately to national targets. It also provides greater simplicity for local authorities who already measure carbon emissions.

Consistency in target wording and calculations. Consideration could be given to an appropriate means of achieving consistency across the country in relation to the wording of targets (and the calculations associated with them), in order to ease the process of implementation by developers.

Scope of feasibility assessments. The PPS could clarify the range of uses for which feasibility assessments are required, including the process of land selection at both:

• the strategic (core strategy) level, in relation to, for instance, identifying areas for sustainable urban extensions and also

• a finer grain level in land allocations DPDs.

It could also include greater clarity on the intended scope of the assessments i.e. to include consideration of financial viability and to clarify the role that heat mapping can play. Reference should also be included to a standard methodology in Practice Guidance, a proposal widely supported by developers and consultants in preference to a series of separate good practice examples.

Training in energy planning. There are likely to be advantages in:

• Training for plan makers, in order for authorities to recognise the limitations of their knowledge and experience and enable them to seek appropriate advice regarding feasibility assessments. This should include clarification of climate change terminology.

• Training for development managers in order that they can understand and interrogate technical information appropriately.

• Training for council members in the field of strategic energy planning and its potential advantages for local authorities in order to increase political awareness.

• Extending training for enforcement officers to include issues related to climate change

• Further training for Inspectors to help ensure greater consistency and confidence in dealing with climate change issues in applications.

Any further thoughts on how we clarify this issue?