08 Sep 2022
How is Action 16 tackling the climate crisis?
Around 20% of the UK’s carbon emissions come from residential gas and electricity use according to the Climate Change Committee 5th Carbon Budget. It makes no sense to build homes now that will need retrofitting in the future, but national building regulations do not currently require new homes to be zero carbon. However, councils can set their own local planning requirements that do demand this standard - although very few have done so.
Reading Borough Council is one council that has. The council’s 2019 Local Plan requires that all new residential developments of ten or more homes are built to zero carbon standards if possible. Zero carbon is an achievable standard that, until recently, was intended to be a national requirement in UK building regulations. A zero-carbon home is one that creates no new carbon emissions once built, by minimising energy use and using renewable energy supplies.
The council’s Local Plan states that if reaching the zero-carbon standard is not possible (as determined by the developer), the development must deliver a 35% or greater reduction in carbon emissions compared to minimum UK standards. The developer must pay £1,800 per tonne of carbon emissions to offsetting in Reading - with offsetting relating directly to energy efficiency or renewable energy contributions in the local area. The council is in the process of developing guidance on how the offset contributions will be spent. (Developments complying with this policy are only just starting to be built and contributions will only be paid just after occupation).
Other residential developments in Reading involving nine or fewer homes are required to deliver a 19% carbon reduction over national minimum standards. As defined in the Local Plan, offsets may be possible through planning contributions ring-fenced for carbon savings elsewhere, if this standard cannot be reached.
What impact has the project had?
The majority of new homes granted planning permission have met the criteria to apply the zero carbon policy, with a minority of small developments and changes of use that do not require the application of the policy. Between April 2020 and March 2021, a relatively low number of 165 homes (in five developments) were granted planning permission, all of which will conform to the zero-carbon standards as defined in the policy, with an additional 1150 by November 2021. As of November 2021, none of these developments had yet been completed. However, Reading’s local plan sets out a target to build almost 16,000 homes between 2020 and 2036, so the impact of the policy will increase over time.
As well as requiring zero carbon homes, the Local Plan also requires new-build housing to be accessible and adaptable to future changing needs (as specified in the Building Regulations), with 5% of new housing on sites of 20+ homes to be wheelchair accessible and with high levels of water efficiency. There are also requirements for all new houses with dedicated off-street parking to include electric vehicle charging points and developments with communal car parks to include a charging point in 10% of spaces.
What made this work?
Reading’s local plan was created following the council’s declaration of a climate emergency in 2019 so the council was able to incorporate its ambitions to cut carbon emissions.
Two factors were critical to enabling this policy:
- Political buy-in: before the council declared a climate emergency, key lead members suggested they wanted to hit the highest sustainability standards from the outset and at least match the carbon targets set out in the London Plan.
- Viability assessment of the local plan: the council’s viability consultant attended the council’s local plan examination and contributed to the discussion on zero carbon standards, preparing an additional note for the Inspector on how the assessment took zero carbon into account.
The consultant assumed a 1% increase in build costs created by the new standards. The proposals only received a handful of objections from developers. Given that homes with high standards of energy efficiency can command a higher price, a small increase in build cost should not be a barrier to developers. And as the council points out in its Supplementary Planning Document: “In many cases, whole-life considerations may justify capital costs at the time of construction. For example, installation of energy-efficient technologies will likely decrease the electricity and gas costs for users over the lifetime of the development.”.
What resources were needed?
The policy creates extra work that the council doesn't have the resources to complete. Reading’s only in-house expertise on SAP assessments (which are used to assess home energy efficiency) is in its building control department, but this has no capacity to assist the work of the planning department.
The council has a small in-house sustainability team, but this has little capacity to give regular advice to the planning department, and in any case, the team are not experts in assessing SAP information.
The council therefore uses consultants (Element Energy) to review the submitted information for major schemes. The cost of this is charged to the developer. The council is currently considering how it can expand its in-house expertise and whether this can be funded by developers.
Lessons from Reading
Dealing with opposition from developers
Resistance from developers may be less than councils anticipate. Reading had a handful of objections to the Local Plan policy, mainly driven by developers either:
- stating that they considered the viability information to be insufficient
- claiming that the policy was not necessary as it was covered by national building regulations
- claiming that national policy states that such standards should not be put in place
These were discussed during the local plan examination when the Inspector was persuaded by the council’s case, demonstrating that councils can overcome developers’ concerns about viability.
The council has had very little resistance from developers since the policy was adopted. The council adopted a Sustainable Design and Construction Supplementary Planning Document shortly afterwards, and this gave some advice that may have been helpful to developers in demonstrating how the standards could be met, for example, they should use the SAP12 methodology with SAP10 carbon factors (details are provided in the Reading Borough Council document).
National policy (set out in the National Planning Policy Framework) specifically allows councils to set higher than national standards, confirming that “local authorities are not restricted in their ability to require energy efficiency standards above Building Regulations”. But not many do partly because the government has not yet set out clear guidance on this, and because the government’s decision to allow higher standards came after many councils had started preparing or reviewing their Local Plans.
The Future Homes Standard will be updated to ensure new homes built from 2022 produce 31% less carbon emissions compared to current standards – so still below the Reading requirement – and there’s already a delay to previous targets since the Code for Sustainable Homes sought zero carbon homes from 2016.
In the absence of clear guidance from government, it is important that local authorities share good practice in setting higher standards while waiting for national standards to catch up.
Emissions from materials and construction are not currently included in national building regulations – but should be in the future to ensure a lifecycle approach. Some councils are starting to address this too.
We've found some examples of other council activity on this topic.
- Cornwall and Lancaster City councils are carrying out climate emergency reviews of their planning policies, including new policies for zero carbon housing.
- Manchester City Council is considering an ambitious net zero policy for new buildings, including reducing embodied carbon.
Friends of the Earth view
Reading is one of several councils going above national standards to require zero carbon new homes. Importantly Reading has succeeded in getting its policy - which goes beyond even the latest update to the UK government’s Future Homes Standard - approved by the Planning Inspector and accepted by developers. This should encourage more councils to develop bolder policies.
But for genuinely zero carbon homes to become the norm even higher national and local standards of energy efficiency are needed, embedded carbon must be included, and the supply of local renewable energy increased to meet the needs of new developments. Offsetting should not be a substitute for cutting emissions.
Councils should also be ensuring that new developments are accessible by public transport, walking and cycling as car-dependent developments will increase carbon emissions (Action 28 of the Climate Action Plan).
Friends of the Earth is showcasing specific examples of good practice in tackling climate change, but that doesn’t mean we endorse everything that a council is doing.
This case study was produced by Ashden and Friends of the Earth.