Clean Growth Strategy

Clean Growth Strategy (CGS): Published 12 October 2017

Comments to be sent to CleanGrowthStrategy@beis.gov.uk

All planners would know that the Foreword to the NPPF states that  ‘The purpose of planning is to help achieve sustainable development….Sustainable means ensuring that better lives for ourselves don’t mean worse lives for future generations’. Greg Clark who wrote that is now Business Secretary responsible for the Clean Growth Strategy.  Readers of this blog will also be familiar with  Planning to reduce carbon emissions 2 that suggests that planning  for the use of land and building could reduce emissions by 50%.  It is very disappointing that the CGS barely mentions land use planning.

By painting an overly positive picture (the successes amount to low hanging fruit - closing of coal burning power stations and exporting manufacturing emissions.), the CGS underestimates the scale of the challenges being faced, in particular the de-coupling of GDP and carbon emissions.

The  CGS is not pretending that emissions from aviation will reduce (ie no questioning of the building of more runways) but seeks to rely on ‘flexibilities’ which are actually carbon offsets which it  might be necessary to reserve for more essential services than aviation, which is largely a luxury.

Global temperatures are already 1degree above the agreed datum and the agreed target is now 1.5degree that is half the increase of 3 degrees which is predicted to result from the current budgets. Worse, the investments already made in energy infrastructure would use up the world carbon allowance by 2050. In order to meet the fourth and fifth carbon budgets (covering the periods 2023-2027 and  2028-2032) the CGS accepts that there will need to be a significant acceleration in the  pace of decarbonisation. The Committee on Climate Change gets a mention but the requirement for it to take cost effectiveness into account in making its recommendations is left out. This is a major constraint on its ‘objectivity’ and reliability in advising Government.

It can only be for ideological reasons that the CGS relies on market signals and subsidies (grants) as the main agents for change.  There are areas where regulations (eg  planning controls and lower speed limits) should be considered as more likely to trigger the systemic changes that are needed.

It is interesting to see agriculture (UNCTAD estimate responsibility for up to 50% of global emissions) occupying a prominent part in the CGS.  “To support greater productivity of agricultural land, …use precision farming technologies on smaller scale farms, … and investigate methods to improve soil health and carbon stocks...Emissions from land use and agriculture falling by 26 per cent on today’s levels. This could mean that woodland cover (over 11 million trees) increases by up to 16 per cent and the emissions intensity of agricultural outputs could improve by 27 per cent.” The Government should be looking to the land use planning system to deliver these reductions but in more holistic and socially beneficial ways; forest gardening would offer some of the answers.

For housing the proposals are very disappointing, relying on building regulations and not planning.  The report at http://www.rics.org/Global/Whole_life_carbon_assessment_for_the_BE_%20PG_guidance_2017.pdf deserves a blog to itself but shows how the RICS is ahead of the RTPI in addressing climate change in its area of influence.  The RICS is also doing further work on setting benchmarks for the carbon targets to be met by development through planning requirements.  BEIS may be regretting  the damage done by the last Government and the Housing Standards Review and might be working its (and DCLG’s ) way back into carbon saving mode.  This is where the RTPI and planning lobby (such that it is) should be helping.

Under-occupation is not recognized as a problem, ‘consequential improvements’ are specifically rejected and cusping has not appeared on the radar.   Reliance is being placed on innovative construction methods including factory production and off-site manufacturing. It is unclear whether the CGS is up to date on the promise of biogas and syngas  and replacing gas boilers would be unnecessary if only consuming ‘green gas’ (and not fracked and fossil gas).

On transport (seen to be responsible for 24% of emissions)  there is a wait for more efficient vehicles and driving behaviour without any recommendations as to the regulations that would help (ie lower national speed limits). As David MacKay said in ‘Sustainable energy without the hot air’, a reduced speed limit would reduce carbon emissions at the twiddle of a knob (ie it could be immediate, equitable,  and at no pubic expense).

These are just a of the few points that could picked up from the CGS by those interested in helping the Government  create a regulatory framework that would have a reasonable chance of reducing carbon emissions in line with domestic and internationally agreed targets.