In August 2020, the government released a new White Paper which proposed significant changes to the planning system in England. Taken as a whole, Planning for the Future represents the biggest set of reforms to the rules governing land use since the 1948 Town and Country Planning Act. However, as notable as the proposals themselves are, one of the most significant features of the White Paper is the lack of detail about how the government intends to deliver an urgent step change in sustainability that fundamentally addresses climate change.
Perhaps the most glaring omission is the failure to address – or even mention – the declaration of a climate and biodiversity emergency by the government in 2019. The headline target of a 75% reduction in carbon emissions for new homes by 2025 is welcome – however, when it comes to the bigger picture, as it stands we are highly concerned that the White Paper lacks the urgency required in an emergency. The White Paper focuses on new homes, but we will not meet our carbon reduction target by building new homes, and therefore the policy should extend to include a National Retrofit Strategy to sustainability retrofit our existing housing stock.
The Royal Institute of British Architects (RIBA) believes that the government must address this omission and embed sustainability within the planning system.
1. Use the national sustainable development code to rethink how we think of sustainability in the built environment
The creation of a national sustainable development code is a once in a generation opportunity to reset our planning system to fully align with net zero carbon, biodiversity, and sustainable best practice guidance. To be truly transformational, the White Paper should focus on the interrelatedness of sustainability and its mutual restorative benefits. It is vital that the government consults with sustainability expert groups across the construction industry in the development of this code – something which was notably absent in the development of the White Paper.
What needs to happen?
- Government must urgently address the lack of any substantive detail in the White Paper on the new ‘sustainable development code’ before drafting legislation
- Government should consult with key sustainability organisations to provide the correct level of detail and priority to align with the climate and biodiversity emergency
- The planning system must stop pitting the environment against other aspects of development. Instead of requiring local plans to “strike the right balance between environment, social and economic objectives” (page 28), local plans should focus on how sustainability can deliver social and economic objectives
2. Use the planning system to drive a new approach to how and where we live
Even the most sustainable new homes can be hugely damaging to the environment if they are built in the wrong places. Too many new developments in England lack an alternative to car usage – this must change. As land which had previously been used for industrial and commercial development comes forward, it is essential that the opportunity is seized to promote sustainable behaviour as well as development.
What needs to happen
- To avoid perpetuating low density zoned suburbia, sustainable development should be mixed use at a density close to existing public transport to support local amenities and walkable to avoid the continued reliance of personal car use (this includes electric vehicles)
- New developments should embed resilience to climate change impacts such as flooding and overheating
- New developments should be prioritised on existing developed land in urban areas and ensure that all developments significantly enhance local biodiversity
3. Make sure we are protecting the right things
The White Paper emphasises ‘enforcement and sanction’ powers without describing in detail what it seeks to ‘protect’. Without clearer objectives, the new planning system could inadvertently act as a barrier to sustainability and social goals.
What needs to happen?
- Greater clarity on the sustainable outcomes of the White Paper is urgently required to allow for an assessment of the appropriateness of the proposals on zoning land
- Any planning reform must sit alongside major reforms to land ownership, land and asset taxation, local authority funding, public procurement and land disposal and building regulations
- The planning system should allow for the phased completion of deep energy retrofit works where a 'whole building retrofit plan' is in place, and support reasonable visual changes where these support robust retrofit (e.g. removing chimney stacks, or adjusting window frames)
4. Ensure that the national ‘sustainable development test’ drives innovation rather than reinforcing the status quo
Getting the ‘sustainable development test’ right is one of the most important tasks the government faces. The wrong decisions at this stage would be catastrophic. We are concerned that the merging of Environmental Impact Assessments with Sustainability Appraisal will oversimplify what is a complex interrelationship of issues, and will not, as hoped, drive up local environmental and ecological standards.
What needs to happen?
We believe that a set of key principles should inform the government’s thinking. The test should be:
- Holistic and based on the UN Sustainable Development Goals that relate to the built environment, including but not limited to: affordable clean energy, sustainable cities and communities, responsible consumption and production, and climate action
- Ambitious and flexible. It should also allow exemplar local councils to go further and faster
5. Focus local engagement on the wider built environment – not just new buildings
Local plans and design codes should have face to face local community engagement at their heart and avoid over reliance on remote engagement technologies. The focus on digitisation and technology is welcome: however, it needs to be done in a way which recognises concerns about the potential for misuse.
What needs to happen?
- Sustainability, social value, and occupant health and wellbeing should be driving the government's open data work
- The proceeds of development levies need to be used more strategically. This is to avoid the highly likely situation where the vast majority of funds are being invested in affordable housing, rather than also investing in green infrastructure which is of vital importance
6. Broaden how we assess the environmental performance of new buildings
The RIBA welcomes a 75% reduction in emissions for housing by 2025, but quite simply this will not be enough to avert the climate emergency. We need to go further.
What needs to happen?
- Government’s response to the White Paper and Future Homes Standard should provide a clear road map of intention linked to building regulations and the UK carbon budgets
- Operational energy should be the key metric for measuring energy efficiency and should be calculated before carbon conversion and offsetting
- New regulation should include a commitment to use a revised design for performance energy model to replace the Standard Assessment Procedure (SAP)
- Ensure new homes meet embodied carbon, water, health metrics and biodiversity standards set out in the RIBA 2030 Climate Challenge
- Government should specify strict back-stop u-values, thermal bridging, airtightness, and shading for new homes
7. Address the lack of resources in local planning systems
One of the biggest challenges faced by the current planning system is the lack of resources. While efficiency savings and new ways of working may free up some resource, it is imperative that the government recognise the damage that cuts to funding have caused. Without skilled personnel, the ambitious agenda of the White Paper will not be deliverable.
What needs to happen?
- The chair of the local design panel must have balanced design agenda with sustainability at its core
- The design panel should include an industry recognised sustainability expert representative
You can help shape the RIBA response to the White Paper by submitting your thoughts.
