How much is too much? Planning’s role in reducing carbon emissions

The planning system needs to adapt and change to show that the UK is serious about reaching its net zero carbon target, says Freya Crunden from Atkins.

The infrastructure sector is a major contributor to the UK’s carbon emissions. So, if we’re to reach the government’s net zero carbon target by 2050, the sector will also need to play a leading role in emissions reduction. But without a clear mechanism in the planning system to ensure that future developments are low-carbon, it’s hard to see how this necessary paradigm shift will happen.

How do we change this? In 2017, amendments to the Environmental Impact Assessment (EIA) Regulations introduced the requirement for developments to quantify their carbon emissions. This is a positive step. By driving developers to understand and mitigate their impacts on the environment, the process can lead to better projects, and some projects not happening at all.

But we’re yet to see carbon assessments for EIA really impacting project design or planning decisions. The reason may well be the lack of real assessment criteria - what is a ‘significant effect’ when it comes to carbon? For many environmental specialisms, there are thresholds for a development’s impact.

No such criteria exist for carbon emissions. It’s left to the judgment of a developer’s consultant to determine at what point the effect on climate becomes ‘significant’. But what reason would a developer have to say that their project emits too much carbon? What is ‘too much carbon’, anyway, and who should get to decide? 

Under the current system, it’s all too easy to claim a project won’t have a significant effect on climate change, and there are no firm policy grounds to argue against that stance. And if an effect is not categorised as ‘significant’, there’s no mandate within the planning system to mitigate it. Finding your carbon emissions to be insignificant essentially means you don’t have to do anything to reduce them. This places the potential for reducing emissions entirely on the good will of the developer.

Perhaps there’s a reason it’s so hard to set a threshold for ‘too much’ carbon, and we’re just not bold enough to say it: maybe no carbon emissions are okay. Maybe, the real threshold is zero. To address the climate emergency before it’s too late, we need to stop emitting greenhouse gases altogether. It’s the reason we need radical targets that we don’t yet know how to meet, like a net zero carbon nation within a generation. One thing is for sure: we are not going to achieve this until we dramatically rethink the way we design, deliver and manage our built assets.

We’ve got our radical targets. So, where are the radical controls within the planning system? The government is consulting on making biodiversity net gain mandatory for receiving planning permission. Will a net zero carbon requirement follow, where carbon-emitting developments are refused permission? It might seem infeasible, but we need a requirement for developers to do more than add up their carbon emissions and then write them off as insignificant. The stakes are too high.

Of course, there are projects where this is happening anyway, where responsible developers have taken it upon themselves to really grapple with the net zero challenge. The new campus at the University of Leeds is a great example. But we need our planning system to encourage more decisions like this, because not everyone will do it on their own.

Some may read this and think: isn’t our planning system cumbersome enough? Do we really need to add extra hoops to jump through? I’d answer that with another question: are we serious about tackling climate change? If we are, I don’t think we’ve got a choice. As we design our built environment, we’re creating the framework of the future we’re all going to live in. If we want that future to be zero carbon, we need to force ourselves to think creatively and apply the ingenuity of a whole sector to come up with new solutions. 

And the first step has to be saying: “this development will have a significant effect on climate. Now, what can I do about it?”

Freya Crunden is an environmental consultant at Atkins.