Planning sticking points

More environmental rigour is needed to support the government’s rhetoric on deregulating planning while ensuring standards, says Julie Godefroy

Government wants to make the biggest changes to the English planning system since 1947. The aim is clear: ‘tear it down and start again’. The emphasis in the white paper Planning for the future is on building new homes. Land will be placed into one of three zones: growth, renewal or protected. For substantial developments in growth zones, there will be streamlined approval, subject to local design codes framed by policies contained in the National Design Guide, Manual for Streets and the National Model Design Code. Developments in renewal zones will be subject to limited checks, while development in protected zones – such as the Green Belt – will be subject to more stringent controls.

The white paper states that ‘we are cutting red tape but not standards’ to ‘improve outcomes on design and sustainability’. Beyond the rhetoric, how could the proposals make planning work better for climate change and sustainability?

In April 2020, CIBSE set out eight priority recommendations on planning.1

1. Encourage and reward schemes that offer environmental and health benefits

  • The white paper includes a headline-grabbing ‘all new streets to be tree-lined’ and a requirement for biodiversity net gain in the upcoming Environment Bill. Local plans would be subject to a ‘sustainable development test’. Beyond that, more detail is needed on climate change and sustainability requirements.     
  • It wants to make environmental impact assessments less time-consuming and process-driven, and more meaningful – this is welcome. It is, however, unclear how this will happen.

2. Encourage climate leadership

  • Government previously proposed stopping local authorities from setting carbon-performance requirements beyond national standards. CIBSE disagrees: local leadership can cut carbon earlier and ease the transition to net zero. The paper is tantalising, but ambiguous: government will ‘review the roadmap to the Future Homes Standard to ensure… the shortest possible timeline’ and ‘clarify the role [local authorities] can play in setting energy-efficiency standards’.
  • The paper proposes a ‘fast-track for beauty’. CIBSE believes incentives should, instead, reward exemplar sustainability schemes to reflect their reduced long-term burden on carbon emissions, healthcare and transport.

3. Local authority resources

The white paper announces ‘a comprehensive resources and skills strategy’ and a strengthening of planning enforcement. New resources must cover climate mitigation and adaptation, including retrofit and heritage conservation. Outcomes should be evaluated to feed back into policies.

4. Adaptation to climate change

The paper indicates that high flood-risk areas should not be designated for growth – but building on a low-risk area could increase risk elsewhere. To be effective, zoning and blue-green infrastructure must be planned at a wider scale.

5. Retrofit of heritage buildings

The paper says many buildings will need to be adapted ‘to respond to new challenges, such as mitigating and adapting to climate change’, including ‘more historical buildings (to) have the right energy efficiency measures to support our zero carbon objectives’. This is encouraging. A low carbon retrofit and regeneration strategy could use opportunities from the shift to home working to create jobs across the country and relieve housing pressure in the South East.

6. Permitted development rights (PDRs)

PDRs are known to lead to the creation of homes of poor standards. This must be addressed beyond the new regulation for ‘adequate daylight provision’.

7. Transition to electric

Features such as charging points could be addressed through design codes. However, the real opportunities are through location and mix of uses that reduce the need for transport. It is unclear how this will be taken into account.

8. Energy infrastructure

It is not clear how sites will be allocated for low carbon energy infrastructure, such as renewable energy schemes.

Much will depend on the detail, ‘to be consulted on this autumn’. Key areas include how the new system will address planning for blue-green and low carbon infrastructure, and how carbon and sustainability objectives are embedded in policies and design codes. Policies should encourage and reward climate leadership and low carbon retrofit and regeneration strategies.


1 CIBSE position statement on planning and climate change, March 2020: