Whilst paragraph 10 of policy 2 above is a good start, it could go much further to reduce carbon emissions from new development. We acknowledge that the planning White Paper proposes and Future Homes Standard proposes interim standards to be introduced in 2020 and stronger regulations which would come into force in 2025, requiring an 80% improvement over building regulations. We’re concerned that these proposed regulations will be weaker than policies already in place in some local authorities, would permit development to be built with lower fabric standards than the existing 2013 building regulations. Additionally the 2025 standards will not result in new development being fully de-carbonised, assuming instead that the remaining carbon emission reduction will be delivered by the de-carbonisation of grid electricity. There is no guarantee that electricity from the national grid will be fully decarbonised, or the period over which this will happen.

We would also point out that the future Homes Consultation11 proposes requiring interim carbon emission reductions of 31% beyond existing building regulations from 2020. This should be the baseline for policy formation.

We would encourage you to go further therefore and toughen your policy stance to require new development to be net zero carbon. The most ambitious and all-encompassing zero carbon policy of which we are aware is that from the draft London Plan, which has now gone through examination without major amendments.

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We strongly welcome the reference to maximising the use of “local energy networks and battery storage” however the policy is not clear how this statement relates to new developments, other than standalone projects. The wording should be clarified to be clearer whether and how new developments (for example significant housing developments) are expected to incorporate these technologies. The inclusion of battery storage within significant new housing and mixed use developments would be very helpful in alleviating constraints in the electricity distribution grid and enabling greater utilisation of renewably generated electricity.

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Summary of issues and commentary

The plan is not carbon audited. It is not in line with the Climate Change Act (2008) as required by national policy and guidance, and is unsound in relation to the duties around the mitigation of climate change, descending from the Climate Change Act and the Planning Acts.

The plan does not contain adequately detailed climate adaptation policies and its mitigation policies could go much further to reduce emissions from buildings. The GNDP councils are significantly behind many leading authorities who have developed binding policies requiring new development to be net zero carbon.

Much of the housing stock is historic, with relatively low levels of energy efficiency. Planning policies should be incorporated to support the appropriate retrofitting of this housing stock whilst minimising harm to historic fabric and significance.

Renewable energy policies are reactive and passive and there is no evidence of a proactive strategy to maximise renewable energy as required in national policy. The approach to onshore wind, to leave the identification of suitable areas to neighbourhood plans, is unlikely to boost the pipeline of projects coming forward, unless communities are given proactive support to identify such areas, and there is no evidence of such support being given.

Transport policies should be more robust in requiring new development to incorporate sustainable transport infrastructure.

Overall, the approach throughout the plan appears to be largely to leave carbon emission reductions to central government. Whilst central government is doing much to reduce carbon emission reductions, the UK is not on track to achieve an 80% reduction in carbon emissions by 2050, still less the new commitment to bring emissions down by 68% by 2030, and down to net zero by 2050. Local authorities have a vital role to play in adding to what central government is doing.

The IPPC report on global warming of 1.5°C, the Climate Change Act and the legal duties on local planning authorities around climate change mitigation and adaptation mean that climate change needs to take a more central role within Local Plans. Local Plans need to take a more rigorous approach to bringing forward development which is consistent with and moves very quickly towards a zero carbon world, with radical changes set in motion well within the lifetime of your plan. The gradualist approach set out in the plan is not equal to the scale and rate of change required.