I am conscious I haven’t posted a blog for some time. In part I blame the ever increasing amounts of time I’ve had to put into navigating our so-called simpler and faster planning system… (And we’re now allowed to leave our houses again so there are a few other things to do too).
Whilst the planning system as a whole seems ever-more sclerotic, government rhetoric notwithstanding (and if you haven’t read some of the accounts from the public sector on the 50 Shades of Planning blog stop reading this and go and do so first…) one area that has moved uncharacteristically quickly has been the treatment of carbon within the planning system (or at least in the little patch of it where I spend my time). Especially around carbon costs associated with knocking existing buildings down and spending lots more carbon building new ones, as well as the carbon that buildings emit during their life cycle.
We saw this start to feature as one of the reasons for rejecting the Tulip viewing platform in the City of London. Essentially, it was suggested that building something that was fundamentally unproductive was not a good use of carbon.
More recently, the Mayor has published the final version of his Whole Life Carbon guidance, alongside related Circular Economy guidance. Westminster City Council (a significant proportion of my work is in Westminster – I know I need to get out more) also made some substantial changes to the final version of its Environmental SPD including a beefed-up section on embodied carbon.
(Actually, beefed-up is perhaps a poorly chosen expression, beef being so carbon intensive, but soya’d-up doesn’t quite sound right. Thank you Vacherin catering for patiently explaining this to me when I asked why we had to have chicken rather than beef in the lasagna in the office canteen. As a newly-minted Italian citizen as of September last year I considered crying cultural appropriation, but I feared this could be unconvincing. Not least as I have no idea how to say ‘cultural appropriation’ in Italian.)
The issue has received considerably prominence in the recent shenanigans regarding Marks and Spencers on Oxford Street, where the Secretary of State has issued a holding direction whilst he considers a call-in, following a relatively unusual update to the Mayor’s Stage II report on the scheme. I try to avoid commenting on specific schemes in Westminster because it is quite close to home, but Simon Ricketts has done a very thorough explanation on his blog which is well worth a read. There is one point on which I’m going to (very tentatively) disagree with him, though. More of that in a moment.
Having been dealing with a rapidly growing list of connected issues, I’ve had a few thoughts.
1: Carbon Offsetting
First – carbon offsetting. At present, in London at least, development is supposed to be carbon net zero, in respect of regulated operational emissions (here’s looking at you LP Policy SI2), with at least 35% of the reductions on-site and the remainder achieved by offsets, if on-site reductions are impractical. Usually this means that an element of carbon offsetting is required, as buildings generally still need some energy.
That’s normally achieved by popping a set figure in £££s, based on £/t of CO2 emitted, into the s106 and then paying up at the appropriate time. The thing is, though (and I do wish this would be more widely recognised and understood by those drafting planning policy) designing buildings is really expensive. This means you generally don’t do it until after planning is granted (or at least once you’ve submitted your application, read the tea leaves* and concluded there’s a reasonable chance of it being OK). And when that detailed design starts, there will probably be further opportunities to reduce carbon emissions through detailed material procurement, tweaks to M&E design, improvements to the facade, etc.
But if that carbon offset figure is set in stone in the s106, going back to try to reduce it to reflect the updated carbon performance of the RIBA Stage 3 / Stage 4 design is quite unattractive. Not least because, even with a willing LPA, a deed of variation is needed to make that change, with all the associated delays. So maybe those improvements to the design are included anyway (and given corporate ESG mandates and the market expectations for commercial developments at least, they probably will be) but the planning system is not encouraging this, with it being easier to pay the offset contribution. Given that it is far better to prevent the carbon emissions in the first place, rather than offsetting them, this is counterintuitive.
It should be absolutely standard that the carbon offset in s106 agreements can be easily reviewed up to occupation of the development without needing to renegotiate s106 agreements. This would mean that there are clear incentives within the planning system for developers to realise improvements in detailed design. This would tally neatly with the new additional rung on the Mayor’s energy hierarchy – “Be Seen” – which requires greater transparency, reporting and data collection in any case.
At the same time, we should get to grips with allowing developers to secure their own offsets. I know that offsets, certainly nationally or internationally, can be a little murky (and I’m a bit suspicious of those little tick boxes on airlines’ websites that say I can easily assuage my environmental guilt for my flight by paying an additional 83p) but conceptually it seems appropriate that the burden of actually delivering carbon offsets does not fall entirely on the public sector / LPAs. Developers should be enabled to contribute, perhaps on a local level, including by delivering verifiable and auditable carbon improvements to other buildings, to start to create real economies of scale.
My suspicion is that this is going to become really pressing, really quickly. The cost of carbon offsets is likely to trend up, especially if they become more based upon local costs (central London build costs being what they are) and as the the easier-to-do projects get snaffled up. Westminster’s SPD already proposes a carbon price of £300/t (and this was reduced from £1,500/t in an earlier version of the underlying evidence).
Moreover, remember that at the moment only regulated, operational emissions are offset. It seems quite plausible that there will be a move to whole-life offsets (so including unregulated emissions and the embodied emissions associated with construction, see below) which, when combined with a dearer carbon price, could lead to offset costs increasing by six times or so.
Structuring s106 agreements so that they incentivise carbon efficiency to be driven all the way through design and construction seems an essential response to this.
Second – culture. As a bit of a cynic I’m realistic about suggesting that the world / planning would be so much better if we all sat down around the camp-fire together to sing kumbaya. But nevertheless I do think that, in trying to realise the shared goal of reducing carbon emissions, the antagonistic assumption that that each side in the planning system is trying to get one over on the other is supremely unhelpful.
In carbon terms, what I fear this often means is that one is tempted only to put forward through planning the minimum improvements one thinks will be necessary to achieve planning, but no more. Why? For fear that, if one suggested one might, possibly, just may be able to go further, that will immediately be latched onto by the LPA and written into the permission/s106 in blood – a sacred commitment that must be delivered come hell / high water / whatever other apocalyptic metaphor floats (or indeed sinks) your boat. And then, if those further improvements can’t be delivered in full, it is the fear of a long-drawn out discussion and amendment to the permission to revise those requirements, where you have to explain and justify and try to remind the LPA that when you said you “might” be able to make those improvements, you genuinely meant that it was possible, but not certain.
I am sure there is some game theory or similar that can be applied to this, but in common sense terms it is understandable why this scenario is unattractive.
Conversely, if discussions could be held in a more collaborative manner, where there was a degree of mutual trust that potential opportunities for further carbon improvement could be tabled and discussed without necessarily being seized upon and made obligatory, with permissions and s106s then structured in a way that secured a baseline of performance and that not only allowed for, but encouraged, further improvements to be delivered this could support better, lower carbon buildings not only being built but being seen to be built. Which is the collective, shared objective.
3: Embodied Carbon
Third – embodied carbon. This increasingly feels like the next frontier in this discussion. I said earlier I disagreed with Simon Ricketts on one point. Actually that was an exaggeration for rhetorical purposes (I wouldn’t dare). Simon laments the lack of guidance on this issue that has led to the M&S situation and the fact that this potentially may be resolved only through a call-in inquiry, rather than in a clear statement of national policy. That is of course right – and highly regrettable.
I would, however, suggest that the public policy position is not only clear but the only policy appropriate in the circumstances.
The Mayor’s Stage II addendum report sets this out succinctly.
GLA officers accept that the retrofit and reuse of buildings can play an important role in meeting national and London Plan carbon reduction targets; however, neither Policy S12 nor Policy SI7 of the London Plan prohibits demolition, with the WLC Assessments LPG and Circular Economy LPG requiring priority consideration to be given to the retrofitting of buildings.GLA Stage 2 Addendum Report, M&S Marble Arch
The re-use of existing buildings should be considered, as part of a circular economy approach. Where demolition and redevelopment is proposed, every effort should be made to reduce the embodied carbon implications of doing so, as well applying circular economy principles such as reusing or recycling materials. But, as the Mayor says, policy “neither Policy S12 nor Policy SI7 of the London Plan prohibits demolition.” Try to retrofit and refit buildings. If you can’t reuse them, reuse part, or their materials. And in the new building, make sure it is built as carbon efficiently as possible. The aspirational targets for embodied carbon in Appendix 2 to the Whole Life Carbon guidance, and the LETI standards, are presumably helpful in setting meaningful, quantifiable targets for this.
And conceptually, this has to be right. Because this policy sits in the context of a London Plan, an NPPF, and local plans that, essentially, plan for growth. Indeed, the first two words of the London Plan are “Good growth…”. The NPPF is predicated on “sustainable development” which it defines as “meeting the needs of the present” without compromising the ability of future generations to meet their own needs. The London Plan calls for new housing for people to live in, places to accommodate new jobs, for attractive town and city centres that provide attractive services, including functions in the Central Activities Zone that support and sustain London as a World City, as well as infrastructure to connect them all up.
Realising this involves physical change to the built environment. It means that buildings will be replaced with larger and newer buildings, and places that aren’t currently all that developed will become more so. Heaven knows that in practice working out which building, where, gets bigger and by how much is difficult. But the strategy at least is clear. Change, renewal and growth in the built environment is at the heart of the plan for London and England. That naturally has implications for the associated carbon expenditure – to pretend otherwise would be intellectually dishonest.
In other words – to continue with the food theme – there is tacit acceptance of carbon expenditure that has been “baked in” to the decisions that have been made in national and regional plans. The fact that the carbon issue was perhaps not looked at as closely as it may be in subsequent plans does not undermine the fact that the decision has been taken. The cake has come out of the oven; we cannot now try to remove ingredients from it.
It could be a possible public policy decision to conclude that the challenge of climate change is so severe, so immediate and so pressing that carbon should no longer be spent upon construction, or certain classes of construction. That the next planning policy cake should be made with substantially less carbon.
In fact, the Tulip decision hints at what this could look like – a viewing platform is essentially not worth that level of carbon expenditure.
In making such a choice, policy makers would have to accept that they were, potentially, surrendering on the housing crisis and condemning huge numbers of people to living in overcrowded, overpriced accommodation indefinitely, allowing for the deterioration of our town and city centres, and permitting the decline of London in particular as a world-leading office location, as a public policy choice. That would be a legitimate choice (although not one I would favour) – but it is not the choice that has been made and expressed in national and regional policy. It should only be selected as a result of a national debate and certainly not emerge in an adhoc manner as a result of a call-in, where in reality the carbon argument has elided with affection from some conservationists for the appearance of the existing M&S building.
I do worry that the increasingly Manichean debate on embodied carbon cannot be properly addressed unless contextualised alongside the other objectives of planning and public policy. At the end of the day, we need space of the right type and form for our economy to function and in which our people can live. Building that space needs carbon, at least for now. We can – should – must – minimise the amount of carbon we use, but we’re going to need to carry on using some.
Final thought – and actually going back to all the resourcing issues on the 50 Shades of Planning blog.
There is a real challenge here for the planning, environmental and development industries to find the skills, resources and words to both assess and communicate these challenges effectively.
For planners in the public sector this is a new area of potentially huge complexity to grasp when resourcing is already very tight.
For the development industry, allied professions in structural, environmental and mechanical/electrical engineering have suddenly been thrust, willingly or not, to the centre of the planning stage. Having the technical skills and analysis and the ability to read the audience and communicate hugely complex concepts succinctly has suddenly become vital.
Chicken lasagna and cake, anyone?
* Other forward-looking predictive methodologies are available.