Central government should reform the local planning system and the National Planning Policy Framework (NPFF) now. The reformed system should have a clearer vision on net zero with the intention to introduce a net zero test, give clarity on when local areas can exceed national standards, give guidance on LAEP, encourage greater use of spatial planning and the creation of 'Net Zero Neighbourhood' plans, and set out a framework for community benefits. Government should undertake a rapid review of the bottlenecks for net zero and energy efficiency projects in the planning system and ensure that local planning authorities are properly resourced to deliver faster turnaround times. |
815. Pillar 2 highlighted the need for government to work with local authorities, devolved administrations and relevant stakeholders to streamline planning processes to ensure the transition to net zero at pace. There are a number of other reforms that should be taken at a more local level to ensure that the planning system properly facilitates net zero.
816. The Town and Country Planning Association told the Review that "changes are essential for the planning system to facilitate progress towards net zero", and that "further legislative change is needed to enable planning to play the critical role necessary to achieve net zero targets."565 They also told the Review that stronger national direction and clarity on net zero in the planning system would "give confidence and the clarity needed to encourage growth in the green building sector, bring forward investment and support the development of skills."566
817. While the National Planning Policy Framework (NPPF) references climate change, it does not reference net zero specifically and the Review heard that the vision of the planning system on net zero is not clear. Too often there are conflicting or unclear messages, with important points relegated to footnotes.
818. The planning system should be an essential tool in delivering the changes needed for net zero. A system that appears ambivalent to net zero will not be capable of delivering the scale of change required.
819. The planning system should move towards implementing a test for all developments to be net zero compliant, ensuring enough lead-in time to prevent adverse economic consequences or stalling of current development plans. Across the economy the cost of building to net zero standards and using net zero technologies is coming down. Providing clarity and certainty on net zero requirements in the planning system could help drive further action and build supply chains, making net zero development the norm.
"Planning can be a driving force for not only net zero but for growth as well, helping to unlock opportunities across the country [...] The reputation of planning in the UK would only be furthered if it were given the ability and position to be a key driving force for net zero. Our own research suggests that planning brings in millions to the UK and has the potential to have a much larger impact if the passion and expertise of our consultancies both large and small were showcased as one of our key exports" - the Royal Town Planning Institute.567
820. There is also confusion over whether, where and how local authorities can exceed national standards on planning. The litigious nature of the planning system means local authorities are often unwilling to take risks, and so the system effectively puts a ceiling on local ambition.
821. For example, the Review heard from several stakeholders about the difficulty faced by West Oxfordshire District Council in their plans for the Salt Cross Garden Village.568 The Council had proposed that development at Salt Cross would be required to demonstrate net zero carbon, with submission of a validated and monitored energy strategy. However, in May 2022 the Planning Inspectorate provisionally found that such a policy was not 'consistent with national policy or justified' and the plan was modified as a result. This is a clear example of the planning system being unclear in its support for net zero.
"Local authorities are wary of the threat of legal challenge, this means to make confident use of their powers, they have to undertake rigorous legal checks, which slows delivery, adds expense and makes some of them risk averse'' - Climate Change Committee (CCC).569
822. Similarly, some local authorities felt that planning requirements on viability presented a hindrance to net zero development. These local authorities felt that some developers use viability requirements to reject proposed net zero improvements. These local authorities suggested that such viability considerations should be reformed or scrapped, and that net zero should be a fundamental consideration when determining the viability of a project. Current guidance states that viability assessments "should not compromise sustainable development."570 This language should be strengthened to ensure that viability assessments actively encourage sustainable and net zero developments, and that assessments take a longer-term approach to determining what is viable.
823. Reforms to the planning system should therefore make it clear when local authorities can exceed standards and provide guidance on how local areas could go further should they wish to.
824. The reforms outlined above should also encourage taking a system-wide approach to planning that is joined up across neighbourhood and community planning, as well as at the spatial level. The Intergovernmental Panel on Climate Change's (IPCC) sixth assessment report finds with very high confidence that cities that use spatial planning to become more compact and resource-efficient could reduce greenhouse gas emissions by between 23-26% by 2050.571
825. Approaches such as '20-minute neighbourhoods' aim to design places in such a way that residents can access all of their daily needs through just a short walk or cycle. There are advantages to taking a systems-level approach in this context - for example, considering public transport options or electric charging capacity when planning new housing developments.
826. This Pillar has already outlined some of the benefits of Local Area Energy Planning (LAEP). Plans of this nature could provide the basis from which energy projects could be efficiently delivered, with more targeted consenting and planning - for example, York and North Yorkshire told the Review that in their area, they have estimated that LAEP "will deliver £280 million in cost savings resulting from planned energy infrastructure investment over unplanned and piecemeal delivery."572,573 LAEP could also provide the data to help underpin a net zero test in the planning system as described above, and provide a basis from which better spatial planning could be undertaken.
827. Along with the requisite powers, Government should provide clear guidance on how areas can undertake LAEP, including with regards to their governance and implementation. This guidance should require close community engagement to encourage community support and increase understanding of local energy and net zero plans.
828. Once areas have undertaken LAEP to identify future energy needs and projects, Government should encourage and support them to create their own 'Net Zero Neighbourhood' plans. Areas should engage closely with local communities when making these plans, which could also combine current plans for water, habitats and nature, farming support, air quality and coastal management where relevant.
829. The complexity of the system also makes it difficult for individuals and amateurs to navigate, and the system often moves slowly. Government should undertake a rapid review to identify the bottlenecks in the planning system for local energy efficiency and renewable energy projects. This should include looking at pre-application stages. Lessons should be learned from Project Speed and the review of Nationally Significant Infrastructure Projects (NSIP) planning processes and applied to smaller scale renewable energy and retrofit projects.
830. In addition, it is clear that if we are to reach our net zero goals, we will need a greater level of applications for renewable and energy efficiency projects in the coming years (see also Pillar 2). Additional support should therefore be provided to Local Planning Authorities and other system actors as needed so that they can reduce the average turnaround time of small- and community-scale energy projects, with target timelines put in place. There should be consistent reporting and monitoring of timelines across the country, as well as public data publishing, to identify areas where timelines are longest.
831. The Review also heard that local consent for net zero projects can be an issue. There is a balance to be struck between national need and local impact; at a national level, Government will need to take a more strategic approach to future energy infrastructure placement, and at a local level there must be improved efforts to involve communities and show the benefits of net zero action.
832. One way of doing this is through direct community benefit. The Review heard of many local energy projects which are delivering community benefits, from grants to install energy efficiency upgrades in community buildings to creating a cooperative community cycle club. The Scottish Government has published a set of good practice principles for community benefits from onshore renewable energy developments.574
833. UK Government should give practical guidance and establish a framework on future community benefit with a clear plan for how this can be implemented within the planning system (see also Pillar 2). Local communities should be directly involved in determining how this benefit is realised, but the starting point should be other net zero or climate positive actions such as retrofit or development of local green space. There should also be an effort to empower and upskill communities to better understand and engage with planning processes so that projects and benefits reflect true local feeling and consent.
834. On energy efficiency, the British Energy Security Strategy committed to reviewing the practical planning barriers that households face when installing energy efficiency measures, including in conservation areas and listed buildings. There are now around 10,000 conservation areas in England, covering an area the size of Luxembourg.575 This represents a huge potential source of energy production through solar and demand reduction through energy efficiency measures. Government should publish the findings of this review as soon as possible, and should eliminate relevant planning barriers for energy efficiency measures.
835. Central government should reform the local planning system and the National Planning Policy Framework as soon as possible. The reformed system should have a clear net zero vision with the intention to introduce a net zero test, give clarity on when local areas can exceed national standards, give guidance on LAEP, encourage greater use of spatial planning and the creation of Net Zero Neighbourhood plans, and mandate community benefits from energy projects.
836. Government should undertake a rapid review of the bottlenecks for net zero and energy efficiency projects in the planning system, and ensure that Local Planning Authorities and other system actors are properly resourced to deliver faster turnaround times.