Revisions to NPPF to address climate change

The NPPF was revised in July 2021. Upon publication, it was immediately pointed out that the new version did not mention net zero and that although it referred to the 17 Global Goals for Sustainable Development, it did little to demonstrate how these would be met. 

The Government immediately responded in saying that it is, ‘committed to meeting its climate change objectives and recognises the concerns expressed across groups that this chapter should explicitly reference the Net Zero emissions target’. Specifically, it stated, ‘It is our intention to do a fuller review of the Framework to ensure it contributes to climate change mitigation/adaptation as fully as possible.’

Likely changes 
The 2021 NPPF’s focus on sustainability was widely seen as little more than window dressing, and too often overshadowed by, or confused with, design.  

Furthermore, the NPPF’s references to climate change largely concerned climate change adaptations rather than proactively preventing (or at least reducing) climate change.  

Following COP26 there is little doubt as to the extent of public concern over climate change. The Government has a policy for reaching net zero, but has not yet clarified what role the development industry can play in that. So what might a 2022 revision include?

Brownfield development
Government policy is clearly focussed on brownfield development as an early panacea, but brownfield sites do not have sufficient capacity to deliver the necessary 300,000 homes per annum. 

Furthermore, redeveloping brownfield land is far from carbon neutral, clearance and remediation often proving very energy inefficient.  

Planning must move on from saying ‘no’ to greenfield development and instead give greater thought to how it can say ‘yes’. It is not possible both to pull up the drawbridge and to meet housing targets.

There’s also a continued question about existing stock. Solutions have included the possibility of leveraging S106 funding to ensure that existing homes and conversions also address the problem. This may be as simple as retrofitting insulation and new heating systems, or as complex as replacing entire 1960s and 1970s housing estates. 

Local Plans

Impact on the planning and development sector 

Whether a revised NPPF will have a significant impact is a moot point. Most local authorities have already declared a climate emergency. Most developers have made a commitment to net zero and have evaluated their carbon footprint. We are in a not uncommon situation whereby the policy writers could learn much from the industry.  
While we welcome the prospect of a revised NPPF, our working practices are unlikely to change significantly as a result.

CONCLUSION
Although social distancing restrictions may impact the market during the first part of 2022, the big story of the year is likely to be inflation. Annual CPI has risen dramatically, from just 0.3% a year ago to 4.2% in October and 5.1% in November 2021, well above most expectations. Rising costs, and the shortages of labour and materials that are its underlying cause, are now top amongst the concerns of businesses. Existing upward inflationary pressures could be further exacerbated if Omicron creates more supply chains disruptions, and CPI could peak above 6% in the first half of 2022. 

Revisions to the NPPF are much needed but will not address the development sector’s ability to meet net zero. 
Local Plans must become more sophisticated, moving on from climate change mitigation to climate change prevention. More specific recommendations, such as the uses of certain technologies, could form part of a national design guide. Importantly, the industry desperately needs the removal of the current uncertainty that plagues it, in the form of the long-awaited Planning Bill.