The significance of upfront carbon

I have just emerged from a public inquiry that is the result of the Secretary of State recovering the decision to be made on whether a road should be built across south Oxfordshire to serve seeveral thousand new houses planned for the area. The claim being made in support of the road is that it would result in a reduction of carbon emissions. The expert evidence that includes an environmental statement suggested that the very substantial carbon embodied in the building of the road would soon be compensated for through avoiding the gridlock that would occur without the new road. This claim was supported by the chartered civil engineer who specialises in this susbject, the three planning officers representing the county and district councils and the planning consultant ("our practice is always supporting sustainable development") paid by the county to support the application/appeal. The second schoolchild error made by these highly qualified experts was to claim that the carbon emissions involved were "insignificant". I suggetsed that what might appear to insignificant to an emgineer in Didcot might not look the same to a farmer in Bangladesh or a fisherman on a Pacific Island. And what might be insignificant when a mile from a cliff edge was highly significant if we had reached a cliff edge or tipping point. There would not be much good in avoiding carbon emissions one we had fallen over the edge. And then there was me. A chunk of my evidence was taken from the code of p[ractice that applies tp all chartered planners; members of the Royal Town Planning Institute,that points out the paramount importance of reducing carbon emissions. Nobody referred to the expection that climate change should be determinative of the decision. This was aimed primarily at the inspector who was MRTPI. The resto of the proof of evidence explained that upfront carbon emissions were certain and damaging and the carbon avoided from a more efficient transport system was speculative and not necessarility dependent on a new road. Twelve different measures were identified that could have reduced carbon emissions without the road; road user charging, APPGI/ICE report, road user charging, workplace parking levy, lower speed limits, electrification, car sharing, automation, public transport, active travel including E-bikes, and working from home, and/or the Government’s Transport Decarbonisation Plan? The claim by the county that all these possibilities had been in the transport modelwas never discussed but obviously the model which "predicted" an 80% modal shift for all traffic if the road was built could have been adjusted to find a combination of these measures that would shift say 50% of traffic from private car without the road. The point of a model is to investigate "decide or vision and provide". As a mere interested party it was made difficult to be involved in the inquiry. However, my final contributiton was to encourage the inspector to write a report that would recommend the rejection of the road on grounds of the significant level of upfront carbon emissions in a way that would survive legal challenge, unlike the refusal of the replacement of the M&S Oxford Street store where the Secretary of State had seen the upfront emissions being unacceptable despite of promises of a more efficient replacement building. Framing of the decision would be critical and I had given uncotested evidence to make that possible.

Upfront carbon

In refusing permission for the redevelopment of the M&S Oxford Street store against the recommendation of his inspector,Michael Gove the Secretary of State for DLUHC relied on the unacceptable level of upfront carbon emissions. This is the sensible term applied to embodied emissions that occur in the short term before the relatively low emissions from and energy efficient replacement building kick in. I particularly like the evidence given by Susan Barfield who "... highlighted that the IPCC told us in 2018 that we have 12 years to avoid a catastrophe, and we see growing evidence all around the world that it is happening – with floods, droughts, fires and melting ice caps. Instead of acting as if there is an emergency, by proposing to throw a huge carbon bomb unnecessarily into the atmosphere, the scheme misunderstands the urgency of our situation. What the science tells us is that what we do in the next 8 years is critical. The brief here was clearly to maximise the site’s potential and the architects have fulfilled their brief well – creating a building minimising operational carbon that 5-8 years ago would have been considered fine. However, now that we understand the upfront impact of embodied carbon it really isn’t. Particularly building two extra basements! They are the worst in terms of embodied carbon.” This decision should make it hard to justify building 300,000 houses every year instead of devising ways to use the under-used space in the existing housing stock. The use of unwanted retail space in town centres as being proposed by the PM would be a step in the right direction but is very unlikely to be sufficient. Sub-dividing some of just a small proportion of the 28m existing dwellings would meet genuine housing needs, including an element of custom-splitting (see numerous previous blog posts).

Too little too late or climate tittle tattle

The planning and development industry is becoming increasingly frustrated with the Government's attitude and approach to both mitigating climate chnage and nature recovery. A letter has been sent coordinated by the UK Green Building Council (UKGBC) and sent to Prime Minister Rishi Sunak, levelling up secretary Michael Gove, environment secretary Thérèse Coffey, and energy secretary Grant Shapps. It claims that the planning system is not providing a consistent approach to handling climate change and environmental considerations resulting in delays, costs, and legal challenges. The 100 businesses that have signed the letter are calling on the government to strengthen the current planning bill by including “a new, clear legal duty for planning decisions and plan-making to explicitly align with the UK’s carbon budgets and adaptation goals under the Climate Change Act 2008, and nature restoration targets under the Environment Act 2021”. The letter is on the UKGBC web site.All these businesses should be taking posve action while they wait for a response. Unfortunately the Government is preoccupied by fighting off legal challenges to its dangerously ill informed approach to climate change; the Saltcross Garden Village, coal mining, airport expansions and north sea oil licensing. Instead of steering the UK onto a path consistent with the carbon budgets set by the Climate Change Committee it continues to make unwarranted claims about world leadership and claims that Lord Callanan at Beis is still, after 5 years of trying, up to the job of insulating over 20m sub-standard dwellings to address both fuel poverty and carbon emissions. Having it explained that deploying carbon negative technologies to remove carbon from the atmosphere could trigger rebound effect as carbon will re-emerge from the oceans Beis have confirmed that this effect is not taken into account in the Energy Bill as the focus should be on reducing emissions in the first place. And the Climate Change Committee are issuing its progress report on 28 June 2023 which should analyses the impact of building large numbers of houses with high levels of embodied carbon. Suggestions are welcomed for a collective noun for well meaning but useless individuals and organisations that are failing to deal effectively with carbon emissions that build the Keeling Curve showing concentrations at 424ppm

Builders not blockers but carbon blind

It is not everyday that the Guardian publishes my letter. This is the theme of a Blog sent to rd Brick, rejected on Any Answers but accepted by the paper on second asking subject to a little editing. "Promising to be the "builders not the blockers" might be good electioneering but suggests that Labour is attempting to sidestep carbon budgets when making its policies (Labour plan to free up land to tackle housing crisis 30 May). If new housing is to be added to the existing surplus (currently about one million more dwellings than households) it must be right to focus on registered providers building houses on cheaper land, preferably at social rent. But the proposed 300,000 new dwellings a year would result in carbon emissions embodied in the houses and associated services equivalent to 113% of the carbon budget for the whole of the economy. The crisis is caused by the grossly unfair distribution of housing and, in particular, under-occupation is at unsustainable levels. About 50% of the space and fabric required to be insulated and heated is not meeting housing needs. As under-occupation is also a main cause in the closing of local schools (Primary schools in cities at risk as families move to cheaper areas 30 May) this is where Labour should be focusing its attention." It's nice to have an audience but Labour will take no notice.

New build and bust

Pressure is building for a change to the planning regulations to enable the Government to claim that it is helping young people onto the housing ladder. And any such claim will immediately be exceeded by Labour. The volume of this debate will increase as a general election approaches. Despite there only being a tenuous link between the plight of the thousands of households in need of a decent home and the building of new estates by the volume builders, there is fresh talk of renewing the recently expired Help to Buy scheme that makes it easier to raise deposits on new homes. The explanation that the scheme has increased to price of houses for those both on and those off the scheme is falling on deaf ears. There is a growth in those claiming that even 300,000 new homes a year would not be enough to meet the need without a mention that the embodied carbon would exceed the budget for the whole economy, the 1million empty homes (there are about 28m houses and 27m households) and the 50% of space in existing houses that is not meeting housing needs (but the space and fabric needs insulation and heating). Another current debate is about the meaning of 15min neighbourhoods and how these can be achieved. I have not heard mention of the impact that under-occupancy has on the viability of services in these areas that could be significantly increased if the existing houses were subdivided, enabling downsizing in place and new households creating a home. Meanwhile the statutory self build registers started in 2016 are fading into the distance. For those who spotted the story about the former RAF Upper Heyford in a previous blog, on 9 September 2022 Cherwell District Council approved the 2018 application for a masterplan but did not inform me until 19 December. It has taken 5 months to provide an explanation for a delay that extended beyond the statutory 6 weeks in which to challenge a decision in the courts. An officer who had emailed after 9 September implying that the decision had not been made claimed that there was no delay because the public could and should be tracking applications online. The notification was in response to emails enquiring about progress, but not such an enquiry made within the 6 week period. This will now be a footnote in the book about Upper Heyford and Cold War memory to lower expectations about the delivery of the planning service, describing the lack of remedies for mistakes including the closing of ranks as officers cover for the failings of each other.

The Oxford Real Farming Conference and time for planners to promote agroecology

As is my wont I attend and then produce a blog about the Oxford Real Farming Conference.  This year the conference grew to over 4000 delegates with 1300 in Oxford and the remainder joining online from around the world.  My purpose is gauge where real farming is heading and whether the planning system could help. Nothing I heard dented my conviction that the potential of the planning system continues to be ignored.  The failure of the agroecology movement to engage with the planning system handicaps its growth and  prevents those operating the system from learning whet agroecology has to offer and how it could be supported and encouraged - a true double whammy. When one of the few (I think that there was one other) chartered planners could not even name the Minister for Planning (Lucy Frazer?) it is clear that some steeled status is needed before normal people can be expected to spend time on plan-making or decision-taking. It is almost impossible to understand the impact of existing plans and policies before trying to keep up with proposed changes.  The latest consultation to the National Planning Policy Framework actually signposts further changes scheduled for next year, and then wonders why people find better things to do.

Unfortunately when discussing what the land use planning system could do I also need to recommend changes to the system as well as challenging officers, councillors and inspectors to do what is already possible with existing controls to privilege applications that advance the cause of agroecology.  This includes the allocation of land for smallholding around settlements where there would be a presumption in favour of approving agricultural workers dwellings.  This would complement a practice of requiring all development proposals on the edge of settlements to place land for smallholding purposes into a local community land trust (through the use of s106 undertakings). One or more of the houses being proposed would be transferred to a housing association as part of the social housing quota but with the occupation limited to somebody working all or some of the smallholding land being secured.

It has become increasingly clear that agroecology has a materially different impact on land and soils that industrial farming in ways that can be measured; nutrient density of crops, soil depth and fertility, biodiversity etc.  In these circumstances there are grounds for changing the planning legislation to require permission to be sought than granted for material change of use.  It would be permitted development for farming practices to improve soil depth and fertility but planning permission would be needed for any operations that would harm soils; deep cultivations; applications of artificial fertilisers, pesticides and herbicides.  Industrial farmers would not approve but that is the point.  The expertise in planning offices would have to grow but the distinctions being drawn would be no more detailed than in the change of use of buildings that can be extremely tricky to investigate, measure and enforce. 

This change would excite those who are doing their own thing and to form a critical mass of 'real farmers'.

How can LNRSs benefit from the LURB?

One of the reasons why normal people develop a deep distrust for the planning system must be down the difficulty experienced in trying to understand and track proposals to address its failings and propose improvements. Every new Government seems to see it as a duty to introduce fundamental changes through manifesto pledges, white papers, green papers, and ministerial statements in the press and in Hansard.   During years of grandstanding there will be expressions of public opinion through opinion polls and by-election results, and the publication of reports by NGOs and think tanks.  Eventually a Parliamentary bill will emerge that seeks to meet the test of fundamental change but actually amounts to more than tinkering around the fringe.

 

Welcome to the Levelling up and Regeneration Bill.  Fortunately this bears little if any resemblance to the Future of Planning White Paper drafted by Policy Exchange.  But neither does it meet any of the criteria associated with the levelling up of a divided country.  The unintended consequence is to alienate all those who would like to engage with the planning system to explore the potential to tackle the closely joined crises afflicting the climate and nature.

Borne out of this frustration is another report and Making the Most Out of England’s Land can be found on the UK Parliament website (pdf). Lord Cameron of Dillington, chair of the Land Use in England Committee said,  "Land use in England is facing a growing number of conflicting pressures and demands including for food, nature, biodiversity, net zero targets, housing, energy and wellbeing.  The government cannot afford to deprioritise this issue.”

The proposed  Land Use Commission would be responsible for creating a land use framework which will help identify and address current and emerging challenges and opportunities for land use in England.  The framework should, "replace the current siloed approach to land use policy with a deliberative and cooperative technique in order to make use of the opportunities and synergies that provides".

The provision, access to and maintenance of green space would be a priority in the framework.  Lord Dillington added that, in addition to a land use framework, regional priorities should be encouraged through the proposed Local Nature Recovery Strategies (LNRSs).  "The government must ensure LNRSs are given appropriate funding and prominence in the planning system to enable them to operate successfully and gain traction amongst farmers and other land managers.”

While it is preferable for the LNRSs to be embedded in the planning system that emerges from its brush with the LURB, the progress of the latter bill through Parliament is so fraught with political infighting that Lord Dillington and his colleagues might be well advised to look elsewhere and promote LNRSs for their own sake and on their own terms.  That is a very unfortunate conclusion to arrive at as the losers will be all those who have been waiting for the planning system to deliver on the regeneration of the environment.  The environment itself will be poorer from these political games as it is treated as something separate from rather than intrinsic to our daily lives.