Planning for climate power

23 March 2021

It is estimated that more than 1400 municipal bodies, spanning no fewer than 28 countries, have now declared some form of climate and ecological emergency – with more than 300 in the UK alone. Declarations of this nature at a more local level are fundamental, signalling that action on climate change is not the preserve of national governments. The promotion and management of reducing carbon at a local level is critical in joining up the climate change dots; without local action there is little upon which we can build the cumulative impact that we need globally to avert climate disaster.

We know that within the UK the built environment contributes to around 40% of our carbon footprint, with half of that from the energy used within buildings. So, unlocking the potential for renewable energy in buildings and homes has to be at the centre of local action. However, that is easier said than done. With most housing and other assets sitting with private developers, and a complex planning framework, the UK still sees far too many developments that fail to meet the environmental standards that would help reduce rather than exacerbate carbon levels. And this is where planning comes in. While we recognise the pressures on planning, with many councils facing specific challenges both in resource terms, and the legislative frameworks in which they must operate, planning is nonetheless vital.


Harnessing the power of local plans

Local plans, in particular, have a lifespan that allow for the development of energy projects over the long term, but the sooner these come to fruition the greater the carbon reduction in the longer term. Some are already leading the way. The Greater Manchester Combined Authority was an early starter with their Energy Spatial Plan gathering data as far back as 2016, demonstrating that the lead time to adoption can be lengthy. While local planning authorities have faced some confusion – such as in 2015 when then minister Eric Pickles sought to alter the ability of local planning authorities to stipulate the energy performance of residential buildings – we argue that the 2008 Planning Act still remains in place. This requires local plans, taken as a whole, to contribute to climate change adaptation and mitigation, including the baseline monitoring of carbon emissions on an annual basis. What is more, the ability of local authorities to set higher standards of energy efficiency in new buildings, and require the generation of renewable energy onsite, was never taken away through legislation, although many have chosen not to include this in local plans.

While we recognise that energy projects will require significant investment, and some long-term thinking, local plans are an ideal way to secure a strategic and managed approach. This provides much needed certainty for developers and of course for communities. Coupled with a rigorous process and tested in terms of viability, local plans can provide the mechanism to ensure that developers improve standards, connect to key infrastructure such as heat networks, and where this is not possible, make financial contributions to energy projects within the local area.

While all local planning authorities must prepare a local plan, the extent of ambitions for environmental objectives to be enshrined within them is varied, and arguably some timidity remains in just how far planning can be used to gain traction on carbon reduction. That is why APSE Energy, with specialist planning associate Tim Crawshaw, set about researching the practical ways in which the power of planning can be harnessed to embed climate change ambitions, looking at councils who have successfully removed blockages within the planning framework, to generate meaningful reductions in greenhouse gas emissions in new developments and embedding renewable energy strategies into planning.

Arguably the development of the ‘Merton Rule’ has provided a solid legacy for local plans to set targets for renewable energy in new buildings. Initially adopted as part of the Unitary Development Plan of Merton LBC in 2003, this was the first planning policy to mandate the use of micro-renewable energy associated with new buildings.

Stipulating that all major new housing and commercial developments must have provision to generate at least 10% of their projected CO² emissions from onsite renewable sources, this policy was replicated by many local authorities, some increasing this to 20%.

While some probably unfair criticism of the Merton Rule focused on the lack of provision for enhanced energy efficiency measures, and the perceived ‘bolt-on’ nature of the policy, it is now common for local plans to have a similar policy to the Merton Rule, also including higher standards for Dwelling Emission Rate (DER) over and above the Building Regulations.

The Merton Rule and Stockton-on-Tees: A solid legacy for renewable energy

A recent example of the successful inclusion of ambitious ‘Merton Rule’ type policies is the Stockton-on-Tees Local Plan (2019). The council’s experiences will undoubtedly be informative to others having faced opposition from developers and a still often confusing legislative context. The ‘Examination in Public’ took place in 2018 and a series of questions were raised by the inspector, following representations made regarding consistency with the National Planning Policy Framework, the ministerial statements on technical housing standards in 2015, and the financial viability of increasing energy efficiency standards in new build schemes. However, Stockton-on-Tees made a case for the retention of Policy ENV 1 citing the 2008 Planning and Energy Act (2008) and correctly stating that the Deregulation Act was not under a Commencement Order. As such, the powers of local planning authorities to require improved energy efficiency standards remains in place.

Like many others facing similar challenges, the council successfully cited the Infrastructure Act (2015) and referenced the energy performance standards of the Code for Sustainable Homes Level 4. This enabled them to argue that a 19% improvement over and above Building Regulations was appropriate. Their policy was also consistent with the Clean Growth Strategy and the Tees Valley Strategic Economic Plan, alongside the council’s stated commitments to reducing fuel poverty within their area.

What the Stockton-on-Tees case study demonstrates is that it is possible to improve environmental outcomes but this must be robustly evidenced. Moreover, newer policy developments such as the Clean Growth Strategy (2017) and the Industrial Strategy (2017) can support the setting of higher environmental standards. What is more, such small cost uplifts of higher environmental standards should be viewed in the context of the overall life cycle value that sustainable development delivers, for a multitude of stakeholders. This includes significantly lower operational costs of the development, reduction in energy consumption and emissions, much improved resource use, and significantly improved competitiveness. In other words, not shying away from improved environmental standards will deliver long-term cost benefits and energy savings.

Other examples of carbon reduction through local planning

Stockton-on-Tees is one of many innovative authorities maximising carbon reduction through its planning approach. In Gateshead the District Energy Scheme currently serves a number of heat and power customers including the Baltic Centre for Contemporary Art and Gateshead College. The location places the District Energy Scheme ideally to serve the ‘Exemplar Neighbourhood’, with plans for around 1,000 homes. Taking in previously developed land in a sustainable location, and supported by supplementary planning documents since 2013 the Exemplar Neighbourhood is an allocation in the local plan. The supplementary planning documents, adopted in advance of the District Energy Scheme, makes reference to the emerging heat network. This integrated approach has resulted in the first applications for 300 homes alongside heat network investment project funding to extend the network to serve the new development. In addition to the current energy centre, heat from redundant mine workings is also being extracted and distributed.

In Birmingham the successful implementation of the District Energy Scheme is being further supported by the Development Plan (2017). Their specific policy (TP4) requires smaller new developments to connect to the District Heating Scheme while larger schemes must give first consideration to combined heat and power, potentially extending the network. And in Bristol the city council, through Energy Service Bristol, is an example of mature implementation backed up by the local plan. Underpinned by ‘heat priority areas’, the Bristol Development Framework Core Strategy has specific policies requiring support for and connections to the district heating network. These policies have provided the certainty required for the expansion of the network. The current review retains policies to require connection to district heating and cooling, alongside setting high standards for design and construction of new buildings.

Planning for our future

So to harness planning as a power tool in the fight for a cleaner and greener environment, we need to ensure that in a plan-led system all local planning authorities have an up to date plan. Indeed Planning for the Future (from the Ministry of Housing, Communities and Local Government – 2020) requires this to be the case by December 2023 or face direct intervention from Government. Yet it is estimated that around half of local authorities do not have an up to date local plan – while this situation continues, greener planning will fall behind. We are supporting calls made by the Royal Town Planning Institute and the Town and Country Planning Association in planning for climate change, that local planning associations should attach great weight to climate change adaptation and mitigation.

Our changing climate is a repercussion of actions taken in the past while the agenda is focused entirely on the future. In the same vein, the local plan with sustainability embedded within it, can influence the future we are building for generations to come.

Paul O’Brien is chief executive of the Association for Public Service Excellence (APSE) and Phil Brennan is head of APSE Energy


The report Planning for our Future: Embedding energy and climate change into local plan policies is available to view at

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