Lowering the speed limit is only a matter of time

I have just received a reply from the Department of Transport to my FOI request about the work that is being done on the impact of the national speed limits and possible changes there to. By coincidence, the Guardian also today published my letter on smart motorways and speed limits.

 

It is true that most if not all the necessary research has been carried out to show that a 50 or 60mph limit would substantially reduce carbon emissions from road transport (currently  dominated by ICEs) as well as trigger a modal shift to bus/train and now, crucially, to EVs. One piece of research that might be useful is how a 50mph limit could allow the narrowing of M-way lanes to allow the hard shoulder to be retained, and change the nature of smart motorways.

 

The DfT point to pilots where the speed limit has been reduced to 60mph to reduce NOX.  In fact Highways England has sent me research to show that NOX increases at lower speeds!? The DfT also refers to the suggestion, now dropped,  that the limit should be increased to 80mph.

 

The encouragement to be gained from this DfT ‘blind spot’ is that this is not a case where the ministry has been looking at the role of speed and has decided to carry on with the 70mph (unenforced) limit.  This is a case where the need to reduce the speed limit will become overwhelming as a means of managing the distribution and use of renewable (ie low carbon) electricity.  It seems unlikely that Government will prioritise personal transport over the heating of homes with heat pumps and the manufacturing of heat pumps, EVs/batteries and houses through Modern Methods of Construction. 

 

Making a virtue out of the necessary lowering of the speed limit the Government could take credit for reducing  the burden on the NHS as accidents become fewer and less severe, families suffer less trauma, public transport becomes relatively more attractive (coaches could safely continue at 60mph plus), lessening the  noise from engines and tyres, showing that no new road space would be needed as congestion would be reduced, and commuting journeys would be shortened to match the perceived increase in drive time (ie the constant time budget).

Mr Jenrick and the Queen's Speech

The Planning Bill that has been mentioned in the Queen’s Speech is programmed for the autumn and was debated by over 50 MPs last week https://www.theyworkforyou.com/debates/?id=2021-05-18a.566.3#g647.0

 

The only contribution that matters is that from the Secretary of State from which I have extracted, “The other thing that the Bill will do is empower local people to set standards for beauty and design in their area through design codes that developers will have to abide by, putting beauty at the heart of our planning system for the first time, and embedding the work of the late Sir Roger Scruton and everyone who was involved in the Building Better, Building Beautiful Commission in the planning system as a matter of law. There will also be a greater emphasis on better outcomes, rather than simply on process, to protect and enhance the environment. We will ensure that biodiversity net gain is met, we will ensure that all streets are lined with trees, and we will deliver on net zero homes as a matter of national priority.”

 

Were that to be the case, the Bill will have to deviate from the White Paper ‘Planning for the Future’ that proposed carbon zero ready housing (ie not requiring major refitting to reach zero carbon), and absolutely nothing on construction carbon that is about half the lifetime carbon attributable to a new dwelling before the servicing and infrastructure is taken into account.  The Sec of State need to speak to his officers responsible for the Future Buildings Standard that kicks construction carbon down the road ‘for the longer term’ and not to be dealt with as a ‘national priority’.

 

This comments will appear in Hansard and Mr Jenrick will expect to be held to this commitment (as an expert in dissembling). Readers could cut and paste this into an email to their MPs who can try to keep him ‘honest’ (but see what Stephen Reed MP had to say about  the Westferry scandal).

Under-occupation and 15min neighbourhoods

 

It is worth repeating many of the issues that arise out of the scale of under-occupation of the existing housing stock.  Figures vary and are debatable, but there seems to be about 28m dwellings and 27m households.  There was a decrease in household size impacted by the increase in housing costs leading to a suppression of new household creation. While grown-up children living at home can be bad, there can be some advantages in growing ‘multi-generational households’. About half of existing residential space and fabric is not meeting genuine housing needs (ie bedrooms being used for storage or working from home – that could and perhaps should be accommodated in neighbourhood workspaces – another blog post needed).

 

The heating and insulation of un-occupied  or under-occupied space and fabric is and will continue to be unsustainable while accompanied by new building and the carbon emitted in the construction of buildings, services and infrastructure.  The real zero carbon electricity will need to be fairly apportioned between heating, transport and manufacturing (as well as NHS, service/creative industries, security forces etc). Demand from the building sector must be reduced as the scope for building the generators of real zero carbon electricity within carbon budgets is limited.

2.     Active travel and 15min neighbourhoods depends on the density of resident populations and are both impacted by under-occupation.  At current levels of under-occupation (often by the elderly and less mobile) will mean that a 15min ‘locality’ will have fewer and less thriving facilities and services.  This will have the result (as now) that the more mobile will use motorized transport to extend their orbit, and be generally less dependent on both active travel and the local facilities.

3.     The serious inequality in Britain (see The Spirit Level and/or The Inner Level by Wilkinson, R and Pickett, K) is reflected in housing occupation and availability. If some people occupy more space than they need then it is likely if not inevitable that others will not have enough.   Given the adequacy of overall supply, in bald terms (ie ignoring factors such as geography), a relatively small reduction in under-occupation could all but eliminate overcrowding.

4.     The only way to increase supply of  ‘new’ housing in areas of the country where new building is severely restricted (ie Green Belts, AONBs, flood plains) is to sub-divide existing stock.

 

None of these issues are non-trivial but do not appear to be receiving any serious attention by professional bodies or policy makers.(see earlier DanthePlan posts on custom-splitting for one  possible response)

Is the proposed The National Planning Policy Framework fit for purpose?

There is an important consultation from MHCLG that requires the attention of all those concerned about how the National Policy Planning Framework(s) has failed to control the carbon emissions from the building and operation of new housing over the last 8 years and have ideas as to what amendments might do the job. Google NPPF or use https://www.gov.uk/government/consultations/national-planning-policy-framework-and-national-model-design-code-consultation-proposals Respond by 27 March and copy your MP.

My response urged the Government to insert reference to the Climate Change Act 2008 as amended and change ‘low carbon’ reference to ‘net zero carbon’.  I think that it is most important to revise the definition of climate change mitigation to link it specifically to the zero carbon target but also the statutory carbon budgets that cover the necessary rate of emission reductions.

This consultation has been triggered by the conceit that ‘beautiful’ buildings will be more popular and attract pubic support for the 300,000 houses a year that has been ingrained as the scale of housing need.  Without saying that beauty is being used as a dangerous diversion from the need to require all new building to be net zero carbon (in construction and operation), respondents could suggest that good design, if not beauty, is where form follows function.  So instead of the current fascination with brick and tile, beautiful buildings are those where the carbon saving features are most evident.

The issue of housing numbers should also start with good evidence of the levels of overcrowding and under-occupation (as well as the fact that there are 27m households and 28million dwellings.  Growth of 'working from home' should not mean more privately owned/occupied space, but finding sites and buildings for serviced neighbourhood offices/workshops. 

The issues of housing older people and meeting the demand for self/custom building need to be addressed (and not passed over in one short paragraph.  It may be that these housing needs and demands could best be met within carbon budgets through incentivising (including supportive planning policies) residential sub-divisions (including custom-splitting or cusping).

Strong suburbs; from redevelopment or sub-divisions?

Policy Exchange do not invite comments on their publications. The think tank just assumes that most if not all its recommendations will be picked up by a Conservative Government.  Their housing and planning researcher is installed in No10 and this latest report is endorsed by Mr Jenrick the Sec of State if only as 'continuing a conversation'.   It would be wrong to attempt a summary of the 75 report that can be found at 2021https://policyexchange.org.uk/wp-content/uploads/Strong-Suburbs.pdf .  One criticism is that it goes into too much detail, but this might be because it is so close to a Government  that likes the phrase if not the reality (see Brexit and social care) of 'oven ready'.  It is also based on so many assumptions that the detail covers the bases and amounts to an 'all or nothing' proposal.

Briefly, the idea is to meet housing needs through gentle intensification of suburban post 1918 housing, based on 'street votes' where a majority of residents (owners and renters) support the idea of redevelopment at much high densities.  The claim is that new floorspace the  equivalent of 40m new dwellings could be built  and, "... the average participating homeowner would make £900,000, while the local authority would get an average of £79,000 for every new property delivered". The authors include net zero requirements for the new housing, suggest car clubs to meet the increased demand with no increase in parking, net biodiversity gain, custom -building and support for SMEs, and the use of Modern Methods of Construction -What's not to like!? Whilst the proposals might fit within the 'Renewal Areas' proposed in the Planning for the Future White Paper, the authors explain that new legislation is not required (Local or Neighbourhood Development Orders might suffice).

Tenants would be given a generous pay-off, but it was unclear whether there would be any rental properties at social rents being provided.  The steep decline in home ownership was a justification for the proposal so maybe not?  Given the timing of the publication, it was surprising not to find how Working from Home was to be worked in (eg offices and workshops woven into the schemes). The garden areas would be protected and overshadowing strictly controlled but there would be many fewer household having access to a garden (there could be roof gardens on some mansion blocks).

The main issue relates to the construction carbon. Reference to the UK Green Buildings Council framework and acknowledgement that construction carbon can be half the lifetime emissions (but occurring in the critical short term) does not mean that the scale of rebuilding being proposed could meet housing needs within carbon budgets.  Recycling materials and offsetting is unlikely to be good enough. The report refers to more ambitious 'housing need targets' without understanding that 'need' is a measure and not a target. There are currently about 1m more dwellings (28m) than households (27m) and about half the existing residential space is not meeting genuine housing needs.  This is a platform from which to build a programme of green sub-divisions and not for large scale rebuilding. The need is for a fairer distribution of the housing fabric and space and for this to be affordable (including fuel/running costs). 

The 'street vote' gentle densification scheme could be worth a try and, importantly, is an example of a proposal as radical as relying on residential sub-divisions and comes from a very influential think tank. When, as it must be, priority is given to carbon budgets (without relying on offsets), sub-divisions (including custom-splitting) would seem to be preferable.  Could Policy Exchange explore how this could become part of the conversation with the Sec of State?

Future Buildings Standard by 2025 or zero carbon now?

The Government claims that agreeing the proposals in the Future Buildings Standard (for England only) consultation  (ending 13 April 2021) would provide a pathway to highly efficient non-domestic buildings which are zero carbon ready, better for the environment and fit for the future. At https://www.gov.uk/government/consultations/the-future-buildings-standard and responding online at

  https://www.smartsurvey.co.uk/s/FutureBuildingsStandard/

The Government’s preferred option is to increase the standards in Part L of the Building Regulations in readiness for the proposed introduction of the Future Buildings Standard from 2025.   Given that the building sector is not having to wait for any technological innovations to achieve net zero or negative carbon there is no excuse and no evidence id provided to delay the raising of standards in 2021 or 2020 at the latest.  A systems analysis indicates that the demand for electricity in transport and manufacturing requires the demand from the buildings sector to be minimised as soon as is possible.

It  is difficult to know what to make of the statement, "We are committed to moving at pace and will implement higher energy efficiency standards to the fastest achievable timeline, Our ambition is for the Future Buildings Standard to be implemented in 2025."? The consultation invites the response that this would be too late, adding to the legacy of buildings needing upgrading.  

The consultation says that many responses to the Future Homes Standard "...raised issues and concerns regarding the energy efficiency of buildings which went beyond the scope of our consultation proposals and the existing Building Regulations. These topics included: embodied carbon; Modern Methods of Construction; suggestions for how we can further address the performance gap of new buildings." Impatience is wearing thin waiting for the Government to address some of the broader and more fundamental questions around how all new buildings are designed and constructed to be fit for a zero carbon future. With a prompt from the Climate Change Committee there is a hint that using more timber in construction will sort the problem of construction carbon, avoiding the issue of sustainable sources, the substantial scale of carbon emitted in constructing services and infrastructure, and the 'building beautiful' agenda where there will be votes in bricks and mortar.

The consultation asks for views on alternatives, Option 1 aimed at a 22%improvement based on services and Option2 (27%) based on fabric. The only assumption to be made on why these are not combined into an improvement equivalent to net zero or negative carbon is the cost. To economise on the energy efficiency of buildings in a climate emergency is the epitome of a 'false economy'. The claim that the proposal is the highest standard for each element which is still cost-effective using a simple measure of payback for investment over the life of the product or work (ie 7 years) is applying a measure that ignores the infinite costs of climate collapse.

The references to 'world leading' are meaningless unless the Carbon Budgets set by the CC are being met. And even then, carbon neutrality by 2050 probably means 3degrees of warming without negative carbon technologies setting course from over 450 parts of carbon per million back to 300ppm.

Saying that improving the energy efficiency of the existing housing stock will be the subject of other government consultations draws attention to the latest 'green deal' already showing signs of failure and scratching the surface of the 25m plus dwellings needing deep energy refitting.

 A specific example of misdirection is 6.6.7 saying that, "Although Option 1 would support a smooth transition to the Future Homes Standard by increasing the skills of people building fabric elements of homes, it may also make it less appealing for some developers to install heat pumps under Part L 2021. This is because the difference between the costs of installing heat pumps and the notional building specification, which has a gas boiler and solar panels, will be reduced. However, a home built under this specification with a heat pump will still have a lower capital cost than one built with a gas boiler and solar panels, at £3134 and £4847 respectively." The Future Buildings Standard, representing a significant level of interference and regulation is evidence that the Government understands that carbon reductions from buildings will not be delivered by the private development industry by applying current measures of profitability.  In these circumstances the Government should be persuaded to take the logical step of ensuring that these regulations are consistent with net zero or negative emissions. 

You could read all 183 pages and comment on the U value of roof lights measured horizontally or at an angle, or take the opportunity to remind the Government that there is an emergency now not in 2025 and that early carbon emission reductions matter most.  Given that the building sector is the easiest to de-carbonise with no technological innovations necessary, all new buildings should be carbon negative in construction (eg timber and lime) and solar positive in operation (ie thermal and PV panels). It is also important to pressure you local council to take these more effective measures.

Community Infrastructure Levy (CIL)

 Despite the 2020 Planning White Paper: Planning for the Future telling its very sceptical and expert readership that infrastructure (and affordable housing) needs reform, this is going to take some time as it works through 44,000 responses. Although few are likely to be favourable there will be pulling in different directions that will allow the Secretary of State to plough on.

Meanwhile councils are getting round to revising the schedules for collecting Community Infrastructure Levy and should be carrying out consultations.  There is a real danger that the 2021 CIL schedules will seal our fate by making small changes to present infrastructure 'demands'  and depriving innovative projects. The following was sent to one council clearly expecting something less radical.  

These documents seem to have been prepared before the Council's declaration of a climate and ecological emergency and the commitment to reduce carbon emissions to net zero by 2030? There would also seem to be an absence of evidence relating to the likely or possible changes to the use of land and buildings arising from the current pandemic.

A new paper is needed that explores the infrastructure needs of a net zero or negative carbon economy and one that fits with likely post-covid behaviours. The failure to have this as part of the evidence base will result in an SPD that would be funding and lock-in lifestyles that represent the 'old normal', and which is likely to frustrate and not assist the transition to a new net zero and biodiverse environment - a double whammy.

Without pre-judging such research, it is likely to show the emerging importance of local food systems (inc regenerative agriculture and awareness of protecting soils and water), local energy/heat distribution systems, more local working, more active travel, a huge shift from new building to retrofitting (to minimise embodied/construction carbon).

 And this makes the mistake of not underling the need to plan comprehensively for the electrification of road transport (ie publicly accessible charge points associated with desirable parking places) and anticipating more elements of automation and Mobility as a Service.

The point about embodied carbon could be reinforced with problems of resources (eg lithium and cobalt) and the real problem of construction carbon being emitted in the short term with the benefits of electrified vehicles being felt in the medium and longer term while the 'early' carbon is still doing its damage.