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Planning for Crisis: How the UK’s National Planning Policy needs to step up to the Climate Emergency

6 September 2024

Making the planning system more adaptive to the acute and chronic influences of climate change would underpin planning growth to net zero. A process that targets frequent updatable structured evidence building and adopts continual improvement in local plan making within the NPPF could make this happen. 

As the government’s National Planning Policy Framework (NPPF) undergoes consultation, there is a risk that without radical change, the UK’s planning system will continue to undermine efforts to reach net zero and protect communities from the growing threats of extreme weather.  It also risks negatively impacting other social and environmental priorities.

The NPPF, which sets out the government’s planning policies for England, is a culmination of over a decade of adjustments responding to the needs at that time.  The entire process has become an institutionalised way of planning for growth that hinders effective climate action.

From vague and abstract language (not speaking to the people) to a lack of integration across decision-making processes, these barriers are leaving local authorities ill-equipped to tackle the challenge of continued economic growth on a finite planet.

The outcomes of tinkering around the edges

Continued tinkering around the edges of the NPPF isn’t going to change the status quo.  We see continued issues with local planning policy and implementation stemming from the vagaries and a lack of firm policy in the NPPF.  These include:

1. Lack of Mandate: Local authorities are only suggested to ‘consider’ climate change, rather than being mandated to act.
2. Fear of challenge and failure: This and the lack of robust defence and/or ability for stakeholders to accept uncertainty combined with the need to ensure local plans are unchallenged creates watered down and weak climate change policies.
3. Siloed thinking: Evidence for local plans is often created in isolation from the climate emergency, ignoring systemic impacts.
4. Risk blindness: There’s a stark lack of criteria for climate risk tolerance in planning decisions.
5. Emissions oversight: The cumulative impact of local growth plans on national greenhouse gas budgets is not assessed from the bottom up.  We are collectively blind to the environmental impact of growth.

Much of this could be resolved within the NPPF by giving local authorities a clear mandate to generate evidence and show how their plans align with net-zero targets. Introducing a whole-system thinking into planning processes and establishing comprehensive emergency plans for managing climate risks would improve outcomes.

There is need to look at the system of planning for a changing world beyond just stronger mandates.

A call for a process of continual improvement in local plan making

The current process still looks to local authorities to fix growth and planning policies for 15 years with 5 yearly updates.

This is not adaptive, flexible or responsive enough for the pace of change needed to respond to climate change.

We are already witnessing the planning system’s failure to keep up with the current pace of change. The rise of energy-intensive ‘green’ technologies like battery storage, electric vehicles, and green hydrogen area already straining regional power capacity that would usually support traditional growth and existing economy net zero transitions.

It is clear the existing planning system cannot cope with the pace of change.

To be adaptive to these challenges the planning system will need a move away from the current rigid ‘fixed’ local plan.

The NPPF should look to allow local authorities to adopt a system of continual improvement that allows a local plan to evolve against a world that is changing weekly.

The approach of consistent improvement in policy making is not new.  It is baked into the Paris Agreement for example, allowing countries biannually to report on their progress to taking their economies to zero emissions and adjusting their national policies accordingly.  Continuous improvement, under Paris Agreement, is a term targeting transparency and data collection to inform decision making.

This approach could resolve the adaptive change needed in growth and at the same time provide the certainty for investors in growth to see the current position and future expected changes.  It would create more certainty for all stakeholders.

The clock is ticking, not just on the NPPF consultation, but on our ability to create a resilient, sustainable future for all.  Tinkering with the existing institutionalised failures does not respond to the climate emergency.

The NPPF revision could be used as a crucial turning point.

Author: Jonny Riggall. Contact: jonny.riggall@aether-uk.com

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