Planning and climate change guidance: research report issue 3

Research comprising a desk-based study and stakeholder engagement with developers and decision-makers to develop understanding of the approaches currently being used to both assess and minimise lifecycle greenhouse gas emissions of development proposals. This research is to inform National Planning Framework 4.

7 Approaches Beyond Scotland

7.1 Background

7.1.1. To successfully achieve Scotland’s net zero targets, a consolidated effort is required across parties from the planning and design stages of a development proposal to the construction stage. Embedding climate considerations within decision making processes will be key to ensuring that carbon emissions are considered early and that all parties involved on a development scheme are aware of the requirements to be met.

7.1.2. Many regions and countries are considering how to best embed carbon and climate considerations within planning. The following section summarises examples of how other jurisdictions are seeking to embed carbon assessment and mitigation within the planning process by introducing policy and thresholds relevant to a wide range of projects and developments.

7.2 Sweden

7.2.1. Since the start of January 2022, the Swedish Act on Climate Declarations for New Buildings (2021:787)[42] requires developers to produce a ‘climate declaration’ for buildings. The declaration is essentially a carbon quantification exercise which sets out the carbon impact of the entire construction phase for life cycle stages A1-5 including raw material supply, transport, product manufacture and the actual construction work[43]. The climate declaration therefore ensures that developers are starting to report carbon emissions associated with their developments. However, there is also a need to actively reduce these carbon emissions to ensure compliance with net zero targets.

7.2.2. In May 2023, Boverket (the Swedish National Board of Housing, Building and Planning) published a paper entitled Limit Values for Climate Impact from Buildings and an Expanded Climate Declaration[44] as a proposal for amending this act. This paper set out the introduction of ‘limit values’ – or carbon targets – representing maximum levels for the climate impact of buildings and recommends the introduction to be as early as 2025. These encompass the life cycle stage A1-5 aligned with the act 2021:787. This proposal would mean that buildings would have to perform better than a carbon limit prescribed per building type (measured by amount of carbon dioxide equivalent per metre squared of the gross floor area (GFA)).

7.2.3. Boverket’s paper then suggests that with time, the scope of assessment is increased, and the carbon targets are made more ambitious. The paper suggests that from 2027, the scope should be expanded to cover the entire WLC of the building through construction, operation and use, and end of life (life cycle stages A1-5, B2, B4, B6, and C1-4 as within BS EN 15978). This is assumed to be in line with future regulations from the European Union from 2027. At the same time, limit values would be reduced and would continue to do so every five years. The first reduction would require a 25% carbon reduction by 2030 compared to the limits introduced in 2025.

7.2.4. It is worth noting that that is not the first case like this within Scandinavia. Denmark have introduced climate declarations and limit values in recent years aligned with their 2018 Building Regulations[45]. Whilst these introductions are specifically within their building regulations, these can be a means of harmonising the wider developmental approach to net zero by managing and reducing impacts such as carbon in alignment with national objectives and policy such as planning policy.

7.2.5. Denmark followed a similar pathway to Sweden, first introducing climate declarations and then – from the start of 2023 – introducing carbon limit values. Where Sweden’s approach looks at carbon emissions per square metre of GFA, Denmark’s thresholds are given per metre squared of GFA per year (kgCO2e/m2/yr) with an assumed building lifetime of 50-years. Finland is not currently as advanced but has been following a similar route with the introduction of climate declarations and limit values set to start in 2025.

7.2.6. As highlighted above, the positioning paper developed by Boverket is being written as a proposal for amending the Act on Climate Declaration for Buildings. Having liaised with stakeholders within Sweden on this amendment, it seems that at a national level the current appetite for this change is not there. However, greater ambition is being shown at a local and municipal level. For example, Stockholm have set targets to reduce emissions between 2020 and 2030 by 50% in relation to land allocation and housebuilding. Gothenburg are even more ambitious with a 50% reduction target in A1-5 emissions by 2025 and 90% reduction by 2030.

7.2.7. The difference in limit values, or reduction targets, at national and local levels could make it difficult for developers to fully understand what is required for their developments and, as such, ensuring alignment at a national level would better inform requirements. This was a point also made by a UK developer who stated that varying requirements by Local Authorities made it difficult for them to plan a consistent approach to developments across the UK.

7.3 Ireland

7.3.1. In 2021, Ireland amended the Climate Action and Low Carbon Development Act 2021[46], adding the requirement for Local Authorities to develop Climate Action Plans (CAP). Local Authority CAPs further enhance local authorities’ ability to lead, engage, coordinate, and become agents of change in response to the ongoing climate change crisis. They also represent a new opportunity to embed climate mitigation in local authority spatial planning.

7.3.2. Following this amendment, the Office of the Planning Register (OPR) published a case study paper entitled Climate Action and the Local Authority Development Plan[47]. The paper offers insight into the challenges that local authorities currently experience in terms of incorporating climate mitigation into development plans and highlights exemplary aspects of existing development plans that include climate mitigation measures.

7.3.3. To date, local authorities within Ireland have made considerable progress in accounting for their internal carbon footprint, in implementing energy efficiency improvements in public buildings, and in developing climate adaptation plans. However, they have made limited progress beyond their internal carbon footprint. The new statutory requirement in the 2021 Climate Action Act, allied to the pre-existing planning legislation climate provisions, presents an opportunity to strengthen local authority climate mitigation planning and development to improve coordination between local authorities ensuring emissions reduction targets are met.

7.3.4. Under Ireland’s 2021 Climate Action Act, the role of the local authority has been significantly expanded. Successful delivery of the role with require sufficient supports and resources to develop plans, engage with stakeholders and co-ordinate with adjoining local authorities. A framework has been created which is split into 3 key areas:

  • Direct Responsibility: For example, the Council’s own emissions.
  • Indirect Responsibility: For example, granting planning permission.
  • Championing: For example, leveraging influence through extended reach of authority and supporting implementation that falls outside of the planning system.

7.3.5. To support this, recommendations are given to how to align to climate mitigation to planning. These are as follows:

  • Show ambition;
  • Outline clear pathways and specific measures to achieve results;
  • Seek innovative ways to extend influence across different domains and sectors;
  • Monitor climate action measures; and
  • Integrate climate action throughout the development plan.

7.3.6. Key elements from these recommendations are the ability to measure and monitor actions taken against climate change. Within the paper, several examples are discussed where requirements are set for developments over a certain size, however, carbon reporting or the implementation of reduction targets is not explicitly described.

7.3.7. Another key action from the Climate Action and Low Carbon Development Act is the need to develop baseline emission inventories (BEIs) at a Local Authority level. However, the OPR’s paper highlights challenges with developing baselines at local levels given the baseline information at a national level is out of date and carbon modelling tools are onerous to replicate at a local level. There is also limited data sources to measure the impact of objectives within the CAPs. The paper highlights the need to bridge the gap between national and local objectives to reduce carbon emissions as currently the messaging is broad and offers insufficient direction. From engagement with stakeholders in Sweden and in the UK, it is clear that a more coherent message at both a national and local level is required.

7.3.8. To counter these challenges, OPR recommend that a broader evidence base is created to provide a baseline for how developments align to climate objectives and policies. Other recommendations described include the implementation of quantifiable carbon targets so that reductions from a baseline can be set and measured against.

7.4 New Zealand

7.4.1. In 2020, the New Zealand Government declared a climate change emergency and committed to a carbon-neutral government by 2025. The motion to declare such an emergency recognised the “alarming trend in species decline and global biodiversity”, including the indigenous biodiversity of Aotearoa (New Zealand).

7.4.2. New Zealand ratified the Paris Agreement in 2016 and committed Aotearoa to reducing greenhouse gas emissions by 30% by 2030 from a 2005 baseline via its Nationally Determined Contribution (NDC)[48]. The national government recognises its leadership role in conservations and has committed to influencing action on the NDC through leading by example.

7.4.3. New Zealand instilled its commitments into law through the introduction of the Zero Carbon Act 2019[49], which provides a framework by which Aotearoa can develop and implement clear and stable climate change policies. Four key things were introduced through this framework:

  • A new domestic greenhouse gas emissions reduction target for New Zealand.
  • The establishment of a new system of emissions budgets to act as stepping stones towards the long-term target.
  • The requirement for the Government to develop and implement policies for climate change adaptation and mitigation.
  • The establishment of a new, independent Climate Change Commission to provide expert advice and monitoring to help keep successive governments on track to meeting long-term goals.

7.4.4. As well as this, a requirement to conduct a Climate Implications of Policy Assessment (CIPA) was introduced in 2019. This CIPA requires central government agencies to undertake and report on the carbon emissions implications for all policy proposals that go to Cabinet and meet the following criteria:

  • An objective of the policy proposal is to decrease GHG emissions.
  • The impact on GHG emissions is likely to be equal or above 0.5 million tonnes carbon dioxide equivalent (CO2e) within the first ten years of the proposal period (representing an annual average of 50,000 tonnes)
  • For forestry-related proposals, the impact on GHG emissions is likely to be equal or above 3 million tonnes of CO2e within the first 30 years of the proposal period (representing an annual average of 100,000 tonnes).

7.4.5. The purpose of the requirement is to enable New Zealand to measure, monitor, and report on Cabinet decisions that will have an impact on Aotearoa’s carbon emissions. The mechanism covers a wide variety of development types and ensures that Ministers are aware of the implications a policy decision may have for New Zealand’s future carbon emissions. The process is set up to ensure early engagement with the Ministry for the Environment in the policy process and ultimately supports the transition to a net zero economy effectively through the form of a ‘Net Zero Test’ alike the CERG proposal.

7.5 Greater London Authority

7.5.1. One example of carbon being considered in UK developments can be seen from Greater London Authority’s (GLA) introduction of the Carbon Offset Fund[50] in 2018. Although not described as a tax, this could be seen as a form of carbon taxation and applies to new major developments through the planning process.

7.5.2. As part of the planning process, developers must provide:

  • A calculation of any carbon shortfall (the ‘residual emissions’ that will be produced by the development after carbon minimisation through design and construction has been applied); and
  • A commitment stating that any shortfall identified will be met off-site; and
  • Confirmation of the offsetting approach which will be taken, i.e. payment into a carbon offset fund, or an off-site project if this has been agreed with the local authority.

7.5.3. Therefore, developers must reduce the predicted operational carbon emissions from developments as far as possible, with remaining emissions taxed at £95 per tCO2e over a 30-year period, equating to a total contribution of £2,850/tCO2e. The revenue from this process, which has recently been extended to all major developments, is then used to fund carbon reduction projects across London.

7.5.4. The GLA’s offset fund carbon price was originally set at £60/tCO2e over a 30-year period, based on the “nationally recognised non-traded price of carbon…and the Zero Carbon Hub price[51]. However, this was raised to £95/tCO2e following a viability assessment, which allowed individual local authorities to set their own carbon offset prices through the same mechanism. For example, Lewisham Council adopted a price of £104/tCO2e after examining types of offsetting measures that could be funded and the expected shortfall of different development types against a range of policy scenarios.

7.5.5. This requirement forces the consistent assessment of carbon in proposed developments and incentivises lower carbon solutions by applying a price to carbon emissions arising as the result of new developments.



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