The TCPA has long been an advocate of the planning system’s central role in addressing the climate crisis. This is both because climate change demands the transformation of sectors for which the planning system performs an important regulatory function (including energy, transport, and buildings), and because so many of the actions necessary to address climate mitigation and adaptation are fundamentally spatial in nature.
The current planning system in England is not fit for purpose in addressing the scale and urgency of this crisis, and – with the notable exception of renewable energy, and a more progressive position on sustainable transport – the current NPPF proposals fall far short of enabling and accelerating action on climate change.
However, it is well within the power of this government to initiate a step change in the planning system’s capability to prioritise and accelerate climate action, and the TCPA’s consultation response highlights priority policy changes that could be implemented at speed, as well as recognising the need for a wholesale review of the NPPF to prioritise, reinforce and accelerate action on the wide range of policy issues that planning can influence.
A step change for renewables
It must be welcomed that the new government have reversed the ‘de facto ban’ on onshore wind. Given the clear need to decarbonise energy at pace, a more enabling policy framework for renewables is much needed. The government would be wise however to consider how the accelerated deployment of renewables can better embed community participation. Building consent by supporting communities to influence and benefit from renewable energy developments in their locality will be essential to the successful deployment of renewables at scale, and to reduce potential kickback in the long run.
It cannot be right that our system approves development schemes and spatial strategies with no understanding or consideration of their carbon impact.
Carbon accounting clearly adds up
One of the most powerful policy changes to the NPPF that could be made with relative speed would be to introduce a carbon accounting regime to inform local plans and decision making. It cannot be right that our system approves development schemes and spatial strategies with no understanding or consideration of their carbon impact. The fact that this is routine practice implies the legal basis of the Climate Change Act (2008) in planning law needs strengthening to ensure that planning is delivering against the national carbon budgets.
There are too many policy areas where national policy acts as a hinderance rather than an enabler to local ambition.
Enable local innovation
There are too many policy areas where national policy acts as a hinderance rather than an enabler to local ambition. None are starker or more pressing than the policy expressed through the 13 December 2023 Written Ministerial Statement which inhibits local authorities’ abilities to require net zero buildings through local planning policies. Policy on this issue needs an urgent rewrite to allow the acceleration of the delivery of net zero homes. This is true of other policy areas with climate implications ranging from embodied carbon, battery storage, overheating, drought and fossil fuel exploration.
Some of these issues can be addressed immediately (by revoking the aforementioned WMS, for example), and others through a comprehensive review of the NPPF to enable and accelerate climate action across the different policy levers of the planning system. This should also recognise the inter-relationships and multiple benefits that arise from addressing climate change, such as enhancing green infrastructure and addressing health inequalities.
The TCPA’s recent research into planning for coastal change and flood resilience has revealed significant systemic failings in the treatment of flood risk and coastal change through planning.
A rethink of risk and resilience
The TCPA’s recent research into planning for coastal change and flood resilience has revealed significant systemic failings in the treatment of flood risk and coastal change through planning. This demands a review of the framework applied to managing flood risk in England which needs to be less institutionally complex and secure a more precautionary approach to flood risk.
Likewise, the planning system must do more to address other climate risks including heatwaves, drought, resource efficiency and coastal change. Many resilience measures require us to look further ahead than typical local plan cycles, and this requires a fundamentally different approach to how we consider risk and resilience and accommodate long term changes through spatial planning.
Planning for climate action
Whilst our response highlights priority actions that could be taken forward in the short term through the current NPPF review, it is also clear that there are systemic issues that need to be addressed in order for planning to meaningfully rise to the climate challenge, particularly in regard to long term adaptation and resilience. The current proposals by no means take us to a system capable of facilitating the scale of changes that might be necessary in the face of a changing climate, this needs an urgent rethink, or we risk leaving ourselves critically unprepared for the future.
For those interested in this agenda, a draft of our longer response to the NPPF consultation questions on climate change is available here: The TCPA’s initial responses to the NPPF consultation questions on climate change (August 2024)
Our suggested changes to the NPPF that could take forward some of these issues in the short term is available here: The TCPA’s proposed NPPF changes on climate mitigation and adaptation (August 2024)
