This section compares the NPPF draft with the PPS1 supplement – Planning and Climate Change
Much of the supplement is in the form of good practice rather than national policy, so it is inevitable only the key points that are at issue. It is these points that ill concentrate on.
One change sine the supplement is the introduction of national annual binding targets on greenhouse gas emissions/carbon budgets, as introduced in the 2008 Climate Change Reduction Act and now being introduced by the current government. This should be referred to in the draft, otherwise phrases such as ‘limit’ and reduce’ become meaningless.
The draft says:
plan for new development in locations and ways which reduce greenhouse gas emissions;
What is the subject of this sentence. Clumsy English it should say
Plans and decisions should ensure the location, distribution and design of new development reduce greenhouse gas emissions in order to meet the national carbon budget.
Though far shorter than the supplement this general statement, in whatever form, captures the essence of the policy.
What has changed is the specific manner in which this is implemented.
The practitioners draft states:
use the Government’s published carbon buildings policies when applying any requirements for a building’s sustainability. Local planning authorities should not develop alternative or additional standards but should adopt national standards and building regulations.
Now one of the problems is the government has not published these national standards. It originally wanted entirely local standards. The industry didn’t like this, it would rule out modular construction and economies of scale for example, so now we have the Harman group, which wont report until early 2012. This leaves local planning authorities and all stakeholders in something of a quandary of what to do in the interim.
The draft would rule out all local enhancements to standards. This would be contrary to the Planning and Energy Act 2008, and would appear to be contrary to the direct will of parliament. We could therefore expect a legal challenge to the NPPF if it came forward in its current form.
The act states in clause 1:
A local planning authority in England may in their development plan documents, and a local planning authority in Wales may in their local development plan, include policies imposing reasonable requirements for—
(a)a proportion of energy used in development in their area to be energy from renewable sources in the locality of the development;
(b)a proportion of energy used in development in their area to be low carbon energy from sources in the locality of the development;
(c)development in their area to comply with energy efficiency standards that exceed the energy requirements of building regulations.
The NPPF would appear to be contrary to clause 1(c). The current supplement states:
There will be situations where it could be appropriate for planning authorities to anticipate levels of building sustainability in advance of those set out nationally. When proposing any local requirements for sustainable buildings planning authorities must be able to demonstrate clearly the local circumstances that warrant and allow this. These could include, for example, where:
– there are clear opportunities for significant use of decentralised and renewable or lowcarbon energy; or
– without the requirement, for example on water efficiency, the envisaged development would be unacceptable for its proposed location.
What has happened to the water efficiency target for example? In some areas such as East Anglia unless stricter standards than national standards are applied it wont be possible to meet housebuildings requirements at all.
As the 2016 target dates becomes ever closer local standards on energy have become less common. There will be locations though where it is much easier to build high density developments which are low carbon. Such as areas where CHP/District heating is possible, which is the simplest way of reducing carbon emissions, but is extremely difficult for this to be zero carbon until we have developed a renewable hydrogen or methane source to power the boilers which is some years away. It is possible to use biofuel as a source but this is expensive and only possible in some areas. The perverse impact then of current national policy is to discourage low carbon high density policy in favour of low density zero carbon development. But zero carbon is a misnomer here because of the misleading way it is measured. Without being able to use CHP from 2016 renewable sources are required. If on site this limits density as these technologies are not feasible at higher densities, also many forms of on-site non utility scale renewable’s use up far more energy in their manufacture than they will ever generate. This is particularly the case with small scale wind generators which in terms of there energy rate of return are as sensible, as one noted renewables expert put it, as putting an electric lawnmower on your roof. True zero-carbon requires energy costs of different densities (transport) and manufacturing of materials and energy sources to be taken into account. Failure to consider these means current policy and faux ‘zero carbon’ developments are actually taking us backwards in carbon terms.
The other problem with the UK policy is that it doesn’t scale and is expensive, only a handful of zero-carbon units have been built. Whilst in Germany the low cost and pragmatic ‘passiv-haus’ standards sees thousands of units built each year. This doesn’t require complex computer modelling room by room (like the UK building regs) just a simple spreadsheet.
Lets hope the Harman group sets a rational standard in this field. I think many experts in this field would recommend something along the following lines.
- Set a very low energy consumption standard for dwellings, which would require consultation such as the passivhaus standard.
- Generate the residual energy from a combination of renewable s and CHP/district heating depending on the location and density of the site
- Bring in zero carbon (measured in terms of energy rate of return- including manufacturing costs over lifeime) for all energy generated for new developments
- All CIL contributions where there a shortfall from off site sources to pay for the development of new off-site zero carbon sources
- Encourage negative carbon developments. These are developments that consume carbon through using food wastes as a fuel and fertiliser for agriculture in a closed cycle which traps atmospheric carbon in the soil and plants. With enough of such developments we can reverse global warming. This uses technologies such as sewerage based energy generation, pyrolysis and biochar. (I hope to do a series on this shortly and suggest the design of some demonstration projects.
Contrast what both documents say about design.
Planning policies should support innovation and investment in sustainable buildings and should not, unless there are exceptional reasons, deter novel or cutting-edge developments (PPS1 Supplement)
Local planning authorities should not refuse planning permission for well-designed buildings which promote exceptional levels of sustainability because of concerns about incompatibility with an existing townscape unless the concern relates to a heritage asset protected by a national designation and the impact would cause material harm to the asset or its setting, and this harm is not outweighed by the proposal’s wider social, economic and environmental benefits. (NPPF)
The NPPF seems rather negative. A clever designer will often utilise low energy local materials in their design.
I deal with renewable and low carbon energy generation in the next section.