The C word: Did no-one tell Labour that a “radical plan” to build loads of new homes is bad for the climate?

Labour’s eagerness to tackle the housing crisis was evident within days of the party taking power. Less than a week after Rachel Reeves was handed the keys to 11 Downing Street she committed to consulting on changes to planning law, one of the sector’s long-running bugbears.  “Nowhere is decisive reform needed more urgently than in the case of our planning system,” she said. 

 

Housing secretary Angela Rayner picked up the baton, launching a consultation on the National Planning Policy Framework (NPPF) in late July. The headline-grabbing announcement was a plan to reinstate mandatory housing target for local councils. It will lead to a new overall national target of 370,000 homes a year - greater than the previously stated 1.5 million new homes over the course of the parliamentary term.

 

A head-spinning number of initiatives including broadening the definition of brownfield land, defining the grey belt and building New Towns were also announced as part of the wider mix.  

 

 

Rayner branded it a “radical plan”. She said it would “not only get the homes we desperately need, but to also drive the growth, create jobs and breathe life back into our towns and cities”.

 

It shows Labour is not afraid to take on the thorny issue of planning despite a succession of Conservative administrations failing in their attempts. 

 

But there are rumblings of concern. With the government’s primary focus on “growth” some fear not enough attention will be paid to creating healthy places. Others are worried the government has not properly considered the environmental impact from building thousands of new homes. And the consultation process itself has left some perplexed. 

 

Julia Thrift, director of healthier place making at the Town and Country Planning Association (TCPA), says there is a “lot of moving parts” around the consultation on the NPPF, which closed on 24 September. “It’s a slightly odd consultation, because there are very minor potential changes and there’s quite big strategic changes,” she says. 

 

Thrift says: “At the moment, I think it’s very unclear what the government’s going to do. There’s also the impact of the Levelling Up and Regeneration Act, which will introduce national development management policies. But we’re also expecting the Planning and Infrastructure Bill (announced in the King’s Speech) to be published before the end of the year.”

 

 

The new 84-page NPPF contains tracked changes from the previous government’s version, notably with all references to “beauty” dropped. 

 

Overall though, Thrift is concerned that tweaks to the NPPF do not go far enough. “The proposals to change the NPPF are not really radical enough,” she says. Chapter eight is entitled ‘Promoting healthy and safe communities’, while the following chapter is called ‘Promoting sustainable transport’. But Thrift is worried these priorities will get lost.  

 

“There needs to be a really strong focus right at the beginning that says the purpose of planning is to create places where people can easily live healthy lives,” she says. “When these things are that far down the agenda, they’re not a priority, they are a nice to have.

 

“It’s hard work to make a case for implementing policies that really support good health. Why are we planning places that will make people sick?” 

 

The Local Government Association, which represents councils in England and Wales, has also raised concerns. “The NPPF must be stronger on promoting sustainable and resilient place-making,” the body said in its response.

 

 

“Within a clear set of expectations set by a national framework, local planning authorities are best placed to make decisions about ways in which to address climate change mitigation and adaptation in their local areas, and therefore the NPPF should be suitably flexible to accommodate this.” 

 

The LGA also says the new Future Homes Standard and Buildings Standard should be “more ambitious” introduced “as soon as is practically possible”. This will “reduce the future costs and disruption of building homes today that we know are not ready for tomorrow”, the LGA says. 

 

Chris Brown, managing director of Climatise, is also concerned about the government’s housebuilding ambitions in light of net zero. “No one seems to have told the government that building loads of new homes is bad for the climate,” he says.  

 

“The issue is the materials: concrete, bricks, steel, glass. And that’s the bit that the government doesn’t seem to grasp.”

 

A study in 2022 found that England would use up its entire carbon budget solely on housing alone if the 300,000 homes a year target was met. As an alternative Smith points to Scotland, where a high proportion of new build homes are timber frame, compared to a relatively small proportion in England. 

 

“Timber frame is fundamentally the cheapest and most efficient way, economically, as well as from a carbon point of view, to build homes,” says Brown. Major PLCs are turning to timber more, building timber-frame homes, which allow them to tick the modern methods of construction (MMC) box.

 

 

Insulation is often seen as a key way to make homes more energy efficient. But this is also a concern. “Using fossil-fuel based insulation is hugely damaging,” says Brown. “We can use plant based insulation - straw, hemp, cellulose. These are all standard insulation products that just need incentivising.” 

 

He’s encouraged that the government is looking to change the building regulations to mean new homes are electrified, while the grid is being decarbonised. “Those things are great but they’ve forgotten the other bit [on materials].”

 

But why have they forgotten this bit? Echoing the title of Al Gore’s 2006 documentary, Brown suggests it is “inconvenient” for the government. “It’s inconvenient because they want to build 1.5 million new homes, which is a ridiculous target. I can guarantee you it will not be achieved. But it’s clearly very inconvenient for them to be told the materials involved in doing that are extremely damaging to some of the other legal obligations that they have as a government.” 

 

“Depending whose numbers you believe a house is somewhere between 50 and 200 tons of carbon. So if you multiply that by one and a half million, you get to a very large number.”

 

He adds: “At a strategic level they are putting growth as their primary mission and I think they are reflecting that in what they’re doing with the NPPF.” 

 

Brown says there should also be better use of the existing housing stock. “We’ve all been living, on average, in larger and larger floor spaces for years now... There’s a lack of incentive for people to downsize when they’re living in much bigger housing than they need.”

 

 

A government source told The Developer: “Sustainable development is the bedrock of the NPPF. The purpose of the planning system is to contribute to the achievement of sustainable development, including the provision of homes, commercial development, and supporting infrastructure in a sustainable manner.” 

 

But some want the government to go further on its ambitions for new homes. In its submission to the NPPF consultation, the Home Builders Federation (HBF) describes the 1.5m new homes target as “hugely ambitious” but then goes to say “arguably the requirement could be higher”. However on the consultation’s question of how planning policy could better support local authorities in promoting healthy communities and tackling childhood obesity, the HBF offered no comment. 

 

Olaide Oboh, managing director at place management firm Populate, urges the government to “make it really clear” how it would make developers tackle those issues. “If I’m honest, 85% of developers would think ‘what role do I have in tackling childhood obesity’? 

 

“The government needs to impose some of this stuff on developers. While I’m not a fan of big government, sometimes it has to step in on health inequalities.”

 

She is also wary of the obsession with the number of homes built. “When we focus on numbers, the focus is not on quality, not on diversity of housing.” 

 

Elizabeth Rapoport, a director at consultant Polygon Place Strategy, suggests the NPPF should allow councils leeway on housing delivery targets. “It’s about having some high-level principles, and then if you properly resource local authorities, they can set out what the right thing is for their area.”

 

Not all the responses have been negative however. The RTPI says it would “strongly support” ideas in the NPPF on supporting green energy. These include large onshore wind projects being brought back into the NSIP regime, and “more weight being given to the benefits of renewable energy for net zero.” 

 

 

But on a more general point, the group adds: “The RTPI is clear that national policy must be more ambitious in addressing climate change through the setting of appropriate mandatory targets. The need to consider resilience is ever-more important as we plan for the future.”  

 

Lichfield’s, the planning consultancy, has also pointed out some positives around renewable energy and low carbon developments. Planning support for renewable energy and low carbon energy sources and associated infrastructure is to be “beefed up”. Local Planning Authorities will be “required” to identify suitable areas for development, rather than just “consider” identifying such areas. But it added: "It will be interesting to see how constrained urban LPAs seek to meet this requirement without a greater reliance on cross-boundary working.” 

 

Elsewhere, the NPPF consultation says the government is committed to “promoting active travel and tacking childhood obesity”. The document talks about a “vision-led” approach to transport planning. 

 

The current document says that “opportunities to promote walking, cycling and public transport” should be considered in the early stages of planning a scheme. But Thrift believes the government still has a job on its hands in this area. “Helping people to walk and get them out of their cars would be hugely beneficial to their health and reduce cost for the NHS.” 

 

But she says there’s a “very strong car lobby in many parts of the country for very good reasons.” She adds: “People just cannot see how they can live their ordinary lives if they don’t have a car. There are parts of the country where there is no public transport and you can’t live your life like that.

 

“It needs political leadership. It has be about making it more pleasant to walk and cycle, and a little more difficult to jump in the car.” A government source said: “While local planning authorities are already able to develop policies to support strategies at the local level which seek to improve health and wellbeing, we are ensuring that the NPPF is clear on how healthy communities can be supported.”

 

 

But for these plans to work many believe that more planning resource is required. It’s an area the government is addressing with plans to recruit an extra 300 planning officers. However Rapoport thinks that “needs to be many more”.  

 

And it is not just from within the industry that is banging the drum for more consideration to be given to health and environmental concerns. Professor Chris Whitty, England’s chief medical officer, is an advocate for healthy homes and neighbourhoods. Whitty reportedly told the Healthy City Design conference in Liverpool last month: “Historically, in public health, some of the earliest and biggest impacts in improving mortality and long-term illness have come from the built environment. 

 

“Everyone knows – improvements in water and sanitation, and better housing, better transport – all of these have contributed enormously to health,” Whitty said. 

 

As the sector waits for the government’s response to the NPPF consultation, they may take solace from the fact this administration appears unafraid to make decisive interventions. The decision to close down the Office for Place is evidence of this. Explaining the move, housing minister Mathew Pennycook said improving the quality and design of new homes and places could be “more efficiently and effectively delivered” in-house by the Ministry of Housing, Communities and Local Government, rather than by an arms-length body. 

 

However Pennycook insisted that the government is “not downgrading the importance of good design and placemaking”. 

 

Nevertheless, other manoeuvres in Parliament could yet cause a headache for ministers. The Environmental Audit Committee (EAC) - a cross-party group of MPs - has launched an inquiry on the environmental impact of the government’s housebuilding plans.

 

Toby Perkins, the EAC’s chair, says: “We will be examining whether environmental protections are being sufficiently considered in the reforms, and if not, what the committee can recommend to government to ensure that they are.”