Consultation Alert: Future Homes Standard

All those concerned about the contribution that the built environment makes to GHG emissions and the need to get to net zero by about 2030 and carbon negative soon thereafter should read the consultation at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/835536/Future_Homes_Standard_Consultation_Oct_2019.pdf and respond by 10 January 2020.
When doing so it would seem to be important to bear in mind that most of the housing stock (ie about 27million dwellings) will still be being occupied over the next ten years and beyond and that all will need a substantial energy upgrade.  To add any substandard (ie not zero net carbon in construction and operation) dwellings to this liability would seem to be a recipe for failure.
Note that the Future Homes Standard is intended to remove the current ability for local councils to impose higher (eg net zero carbon standards) and for the Government to insist on anything less should be resisted, while a leveling up should be strongly argued for and supported.
The problem of carbon emissions arising from the construction of new dwellings (ie about half of lifetime emissions but all occurring in the short term when reductions are most important) does not feature in this consultation as it is not yet seen as a matter for the Building Regulations. However, if the Government is serious about reducing emissions it should be referred to the UK Green Building Council Framework 2019 that sets out the correct way to calculate carbon emissions.
It might also be helpful to remind HMG and Mr Jenrick that housing is one of the few sectors that has the potential to become carbon negative as transport, agriculture, manufacture (and imported emissions), the military and power generations will struggle and look for offsetting. And offsetting will be needed to remove emissions to get from 408ppm to 300ppm in the next ten years and not to mitigate for continuing emitters (see British Airways or Heathrow plotting a route to zero carbon) enabling business/pollution as usual.

Family declaration of climate and ecological emergency

Family Emergency Declaration

Okay, this might not look strictly like a land use planning issue but families making this declaration will not be able to get their emissions down and biodiversity up without the assistance of land use planners and the 'system'. 

The first draft looks like this:

We, the xxxxs, xxxxs, xxxxxs and xxxxxs – and any others who want to join in, pledge individually and collectively to become informed about the climate and ecological crises and to act accordingly.  This is most likely to mean reducing our individual and collective carbon footprints in a way that transparently and honestly follows a trajectory consistent with reaching net zero carbon by 2030, incorporating the most substantial reduction by 2025.  We also commit to increasing biodiversity by our actions as consumers and as householders and local activists. We are acutely aware that, while we undertake to do everything in our power to reduce our emissions and protect and increase biodiversity, there are significant factors outside our control. This declaration extends to lobbying and/or rebelling to effect the necessary systemic change.

If you like the idea then edit to suit and pass on to family members in this country  and across the world

Planning, equality and health

On 22 July the Department of Health and Social Care published and ‘open consultation (Green Paper) Advancing our health: prevention in the 2020s https://www.gov.uk/government/consultations/advancing-our-health-prevention-in-the-2020s/advancing-our-health-prevention-in-the-2020s-consultation-document

There is no closing date for responses to the consultation for which an online questionnaire is provided, although a word document could be sent to the social care Minister Caroline Dinenage MP  msc@dhsc.gov.uk 

There are about 15 specific questions relating matters affecting our health and wellbeing.   Most of these questions have been around for a long time and there is good reason to suppose that they will be dragging society down for many more unless and until a more fundamental approach is taken by our central Government.  For the purpose of this blog it is important to note that ‘living conditions’ are identified as an underlying cause of illness, stress and premature death.  So those with concern for housing and green (and blue) infrastructure have the opportunity to suggest to  the Minister that the discovery that trees can contribute to a healthier environment could justify the adoption of  the principles and methodologies being advocated by the National Forest Garden Scheme and to support the movement to promote bioregions as the guiding principle for land use planning.  The Government should be made aware that the housing model being promoted by developers, Homes England, Growth Boards and Local Planning Authorities has produced swathes of anti-social housing.  By pandering to privacy we are the loneliest people in Europe and new models of community-led housing should become the norm.

Another point that could be made is the identification of stress and anxiety being caused by growing awareness of the effects of climate change. This will impact on sleep deprivation (one of the specific questions) and levels of mental health.  In this respect carbon reduction targets are a matter for the Department.

But the main problem is that this and previous Governments will not see these issues as being symptomatic of the levels of inequality that make the UK world leading in this respect.  For example, the percentage of people in prison in a country is directly correlated to levels of inequality and this leads to proposals to build more prisons.  Until we become more equal (even if this coincides with use becoming poorer – see The Spirit Level 2009 by Wilkinson and Pickett) these issues will remain intractable.

A final thought about inequality.  The comparison made in The Spirit Level to show that more economically equal countries have fewer social problems cannot be made between this world and any other.  It is unlikely that any earlier period would reveal a more equal world for such comparative study to be carried out.  However, on an absolute basis, Government should be made aware that inequality has a divisive and corroding effect and fighting against inequalities across the world is likely to have a beneficial effect on its own population.

DfT offsetting consultation

The DfT have launched a consultation ‘Carbon offsetting in transport: a call for evidence closing on 26 September 2019.https://www.gov.uk/government/consultations/carbon-offsetting-in-transport-a-call-for-evidence

There are a number of points that seem to be particularly relevant starting with the need for travel to be carbon negative long before 2050.  Net zero carbon will only stop the carbon in the atmosphere from going up (plateauing at between 450 and 500ppm), when it actually has to come down to 300ppm. Travel is rarely a basic need like housing, sustenance (food and water) and heating so should experience the most severe cuts in emissions.  The military will continue to be carbon intensive unless wars turn cyber.  The next point is how much easier it would be to regulate the operators of aircraft, ships, trains and coaches than the consumer/traveller.  In either case all business travel should be carbon negative.  Offsetting should only be a short term expedient until carbon negative travel becomes commonplace and must cover the carbon embedded in the related infrastructure; runways, railways, ports and roads.  The DfT is looking for evidence of behaviour changes and it is likely that a combination of price signals and sticks will be needed.  The price signal will be the cost of a ticket increased by the cost to the operators of making the mode carbon negative. The stigma could be a colour of a ticket and/or baggage label (red for excess of the zero carbon target, amber in excess of the 300ppm target and green for on target). The DfT is interested in conveying information to the consumer/traveller and this should be in simple terms, like having carbon counters (412ppm set above 300ppm) in airports, sea ports, railways and variable message signalling on M ways.  The parts of carbon per million will soon be a well known metric as will the alarming gap between imminent catastrophe and safety. 

A green light for self and custom builders

To my knowledge  the appeal decision letter at
https://www.theplanner.co.uk/decision/appeal-inspector-sets-precedent-on-councils%E2%80%99-self-build-provision?utm_source=Adestra&utm_medium=email&utm_term=
is the first to grapple with the challenge posed by the  Housing and Planning Act 2015 as amended.
This is very important and could have been predicted when the legislation was passed.
However, when the Government appreciates the consequences it might either seek
to repeal the act or possibly/preferably 'go with the flow' and celebrate the DIY approach to
meeting the pent up demand.

The Government are keen to see the level of self and custom building
to grow from a measly 8% per annum to something that compares with
examples in other countries (eg <50% in Austria).  It is also aware
that the current housebuilding industry does not have the capacity to
build the 300,000 dwellings deemed necessary (the evidence of need is actually
contestable, and new building at that scale cannot be achieved within
carbon budgets without a sea-change in building techniques/materials).
So, to incentivise self/custom building, there is legislation in place
(the Housing and Planning Act 2015 as amended) that requires planning
authorities to maintain a register of those who would like to build in
the area, and to provide sufficient service plots to reflect the level
of demand on the register. The law also requires the supply of plots to be
permitted at a rate such that  those on the register should not have to wait
more than three years for an opportunity to arise. As the first tranche of
self/custom builders joined the register in October 2016  the first
tests of whether planning authorities have fulfilled their duty will
now emerge.

This appeal decision shows that planning authorities cannot rely on any permission
that is not specifically limited by condition or obligation to
self/custom builders. Landscape considerations are taken into account
but the decision shows that the lack of serviced plots to meet the
registered demand can be a material consideration to override the
local plan policies. I would expect planning authorities to respond to
this decision by reserving significant areas of the larger sites being
allocated and permitted for self/custom building or even allocating
sites specifically for this purpose.  Meanwhile, the absence of an
adequate supply is an invitation for self/custom builders (especially
those already on the registers) to find suitable sites and make
applications based on the fact that the planning authority is failing
in its duty.  This decision might also encourage more people to
register as the prospects of finding  serviced plots will increase
through both the more proactive approach taken by councils and other successful
applications and appeals.

There is also the interesting view taken on viability, indicating that in the area in question, self-building does not create sufficient surplus value to pay for affordable housing.  Given that this should have been deducted from the land value, it might be better to argue that self/custom building is a form of affordable housing (as a fact or material consideration, even if not accepted by the NPPF).

Land use planning and nutrition

One of my ‘hobbies’ is to attend lectures and seminars arranged by various institutes within Oxford University. The standard format is for a world expert to introduce and issue or problem and suggest ‘solutions’ to an audience of academics, postgraduate students and smattering of the public.  Last week I was at a session on food and nutrition where the problem was graphically described by the data showing that a worrying majority of the UK population is buying too much of the wrong kind of foods, and consuming them in the wrong kinds of ways, causing harm to personal and societal health and wellbeing. 

This is in the context where, in theory, the right kinds of food is already available and could be prepared and consumed in the right quantities and in the right way. These practices would not only relieve the NHS from some of its greatest burdens (eg dealing with diabetes) but could also have positive impacts on agriculture/horticulture and the environment.

What made the discussion so interesting, if not unique, was the near complete absence of any agreement on the ‘answers’ to take forward into public policy.

In the desperate search for answers the contribution being made by the planning system is to limit (ie refuse) permission for new fast food shops within 400m from the gates of schools on the theory that this would limit the opportunity for school children to snack on burgers or fried chicken.  Research has shown that this measure is ineffective and should no longer be regarded as a ‘solution’.  There seems to be evidence that a ‘sugar tax’ might have some effect in reducing consumption and/or the quantity of sugar in food products but is unlikely to get where we need to in terms of dietary change.

As usual the only way to have any real and lasting effect is to take a systems approach and analyse the food system from ‘plough to plate’, taking into account that this might conclude that most if not all ploughing is unnecessary.  Taking this holistic view would show that land use planning could play a more effective role than in limiting the change of use of high street premises.  Some of these ‘answers’ appear in earlier blogs (eg January 2016

http://dantheplan.blogspot.com/2016/01/if-agro-ecology-is-different-how-can.html)   that relate to how land use planning could assist in a move away from industrial scale agriculture based on minimising human labour by substituting high and unsustainable levels of fossil fuel inputs, and enable food production under agroecological and agroforestry principles.  Food and nutrition are so important that a case could be made to actually increase the legal scope of the planning system.

Are you happy with offsetting emissions?

The Committee on Climate Change (the CCC) has recommended that the UK emissions be reduced to zero https://www.theccc.org.uk/publication/net-zero-the-uks-contribution-to-stopping-global-warming/ by 2050. The strategy/recommendations rely very significantly (ie about 50%) on 'offsetting' the emissions that will continue at 2050.  This would be done through burning biomass (timber and grasses) and capturing and burying the carbon dioxide separated from the exhaust and, in a separate category, the removal of carbon from the air by mechanical systems and tree planting and soils.  Mechanical separating and burial (carbon capture and storage or CCS) has been tried on a relatively small scale but has not even been piloted in the UK.  These processes also required energy as does the mechanical extraction of carbon from air.  Tree planting is a very good thing (carbon sequestration could be seen as a a 'co-benefit' (see  http://www.wwwnationalforestgardening.org/ to enhance the benefits) but there are uncertainties about how effective trees would be in the short term when emissions are still at their maximum and most dangerous (ie not being avoided during the decade which matters most).  There are also questions about how the carbon is kept in the timber and forestry products. These reservations need to be very closely analysed and the CCC challenged to back up its recommendations with research and monitoring. In fact the UK Green Building Council also seems to have accepted that carbon offsetting could enable the building of new housing to continue at scale to minimise the impact of  embodied carbon.
The expression "offsetting is an excuse for business as usual" has started to appear in carbon conversations.   For the last twenty years we have been able to pay (eg Climate Care) a premium on air tickets to enable trees to be planted or low energy light bulbs to be fitted.  The idea of relying of offsetting to enable the building millions of houses during a period (ie 12 years) when net emissions should be moving close to zero requires a huge leap of faith.  Whether or not it is a legal requirement, the CCC takes into account the financial consequences of its recommendations and is unlikely to support or promote measures which significantly disturb or disrupt the status quo.  It may be that a genuinely net zero carbon economy will have to be very different in many important respects and the transition should include and element of 'planning'. By reducing the reliance on offsetting (which should not mean any reduction in tree planting) there would be a greater incentive for 'businesses to become unusual'  and promote and adapt to the new low carbon conditions.