Planning and climate change guidance: research report issue 3

10 Findings

10.1 Introduction

10.1.1. WSP was commissioned to identify relevant information sources, tools, methods, and approaches that could be used to successfully support the delivery of NPF4 Policy 2a in the planning process. Through this research, best practice methodologies and approaches to whole life carbon assessments of developments in the UK were identified as well as appropriate tools to undertake this analysis, and approaches taken from other jurisdictions in Europe and further afield. Additionally, current relevant standards and regulations were identified, and insights into relevant regulatory proposals were also gathered. This section summarises the key findings of this research.

10.2 Information Sources, Tools, Methods & Approaches

10.2.1. From WSP’s desk-based research, stakeholder engagement, and WSP’s experience conducting whole life carbon assessments in various sectors in the built environment, it is clear that appropriate information sources, tools and methodologies for assessing whole life carbon already exist and are being used by industry.

10.2.2. Best practice methodologies, outlined in Section 4, such as PAS 2080:2023 and the RICS WLCA are being used frequently in the built environment to approach the assessment of whole life carbon in various development types. Strong signalling from the industry itself and from government agencies to adhere to a common best practice approach has become more apparent in recent years. For example, National Highways, a major UK infrastructure public body, has become accredited to the standard and Ofgem has required transmission and distribution network operators to align to PAS 2080 and provide annual reports on the whole life carbon emissions of their developments to the regulator.

10.2.3. As outlined in Section 4 and Section 8, there are several tools available to conduct whole life carbon assessments and several which are currently being utilised by the industry and professional organisations, such as OneClick Planetary which is free to use and is accessible on a global scale. There are also emerging asset libraries, such as the BECD and ICE databases, which are freely accessible and inform the associated WLC emissions for a whole host of product and entity-level assets. These enable accessible and best practice whole life carbon assessments by providing the necessary building blocks to ensure carbon is considered at the very earliest stages of project development.

10.3 Relevant and Emerging Regulations and Policy

10.3.1. NPF4 Policy 2a) requires appropriate siting of developments to minimise WLC emissions. Existing standards such as the Scottish Infrastructure Investment Plan and PAS 2080:2023 include hierarchies which address the siting of a project or development to minimise WLC emissions by challenging the need and considering the design at the very earliest stages of the project life cycle, as well as encouraging appropriate siting through considering co-location and repurposing in the first instance. If followed, both hierarchies reduce overall impact including whole life carbon and other environmental impacts by repurposing in the first instance by utilising alternative solutions across the development’s life cycle.

10.3.2. As well as NPF4, there are other relevant regulatory and policy requirements that seek to consider carbon in the development process, e.g. EIAs and the Scottish City & Regional Growth Deals guidance. There is opportunity to ensure consistency and encourage a focus on whole life carbon management given the increase in maturity across the development sector and the planning process and the increase in data availability.

10.3.3. Whilst recognising that planning encompasses a wide range of industries and sectors, some members of the development industry are acting to pave the way for a more consistent approach to assessing whole life carbon and considering carbon mitigation early in the project life cycle. This can be seen from the industry led proposals outlined in Section 6, such as proposed Part Z to the Building Regulations and the CERG Briefing Paper, which aim to provide a cohesive methodology and appropriate standards to inform WLC assessment and carbon mitigation in the built environment across various development types.

10.3.4. The CERG Briefing Paper, calling for a ‘net zero test’, sets out an assessment of significance during early stage business case development to inform decisions ahead of the procurement stage. This is essentially an assessment mechanism to ensure a project’s alignment to net zero, which could be in the form of a whole life carbon assessment directly aligned with NPF4 Policy 2a).

10.4 Lessons from International Approaches

10.4.1. The case studies in Section 7 of this report show the positive steps that are being introduced to ensure that carbon and climate considerations are made during the planning stage of developments. There are some key considerations that come out of these which could be adopted and taken forward in Scotland.

10.4.2. Ensuring that carbon is measured and quantified on relevant development projects, such as the climate declarations required within Sweden’s planning process, is a crucial first step. Before consideration can be given to reducing emissions it is key that there is a consistent approach to measuring emissions and setting carbon baselines. Following this, measures can be taken to set carbon targets or budgets, and from there plans can be made to set reduction targets. Taking each opportunity at a time enables developers to understand the requirements and make plans for how to cost effectively ensure that developments algin to national and local net zero targets.

10.4.3. The paper by Boverket raises issues that need to be considered and addressed around cost, skills, and data. Firstly, there is a recognition that there will be a cost associated with this as developers will need to collect and collate information on their schemes, and Boverket who will need to employ people who can check and verify the results. The cost of low-carbon materials to meet carbon targets could also potentially increase costs. They estimate that the costs of development could increase by 1-5% as a result. Secondly, the paper points out the need to upskill people to be able to conduct carbon assessments and knowledgably embed low-carbon opportunities within developments. Finally, there is a need to ensure consistency between projects and developments to enable projects to be assessed on a like-for-like basis. To do this, Boverket recognise that digitalisation is needed to make things as simple as possible and have been developing a tool and database for developers to use to ensure this consistent approach.

10.4.4. For building developments within the UK there are already guidelines on carbon baselines and future targets for buildings given in kgCO₂e/m²). LETI^[65] and RIBA^[66] have set benchmarks for different building types and projected what good and exemplary practice would be in the future. Although these are not legally binding it provides a good starting point on where the industry sees the direction of travel. Standardised tools are also being developed, for example the Future Homes Hub^[67] are currently developing a tool which could be used to ensure a consistent approach to quantification and measurement going forward.

10.4.5. A key point to raise from the Scandinavian examples discussed in Section 7 is that they are only relevant for building developments. To ensure that all development proposals that fall under NPF4 are considering ways to minimise carbon emissions, providing appropriate guidance to infrastructure projects should be considered. Whilst there is a straightforward metric for buildings, for example kilograms of carbon dioxide equivalent per metre squared, this is not the case when looking at infrastructure projects as they differ so greatly. Metrics that could be used could be total emissions per spend, however, cost volatility could lead to large differences year-on-year. Linear infrastructure projects could use a metric of carbon emissions per linear metre, but other infrastructure projects and development types may not be able to use the same approach.

10.4.6. Additionally, within Ireland, many case study examples related to buildings and modal shifts between vehicle choices, specifically energy performance during operation and the use of renewables and electric vehicles. There is a need to ensure that whole life carbon, including life cycle stages A1-5, is considered through planning to ensure that the impacts of land use, materials, and construction all form part of the decision-making process.

10.4.7. Greater London Authority’s approach to enforce the reduction of the operational carbon emissions from developments could be an effective way to ensure major developments are aligned with net zero by prescribing a cost to any unaddressed carbon. Finally, New Zealand’s approach to ensure that the carbon impact of policy decisions is included in the appraisal process is a great step to ensure that the true implications of policy decision making are considered at an early stage in the process to ensure alignment with their net zero ambitions.

10.5 Stakeholder Engagement

10.5.1. WSP engaged with key stakeholders from all sides of the planning process through targeted engagement and more wide reaching engagement through a survey to ensure a range of stakeholder feedback was gained. Stakeholders included developers, Local Authorities and planning officers, and relevant agencies.

10.5.2. After analysing feedback received, some pertinent and common themes can be recognised:

1. There is a lack of resourcing and capability within the current landscape across Local Authorities and planning officials. Therefore, to build internal capability and ensure that there is good understanding, there is a need to consider the specific skills, capacity, and understanding across the planning system. This would ensure consistency in the planning process across various development types.

2. There is a varying degree of maturity across both sides of the planning process in terms of the approach to managing and minimising whole life carbon. However, best practice approaches such as PAS 2080:2023 are being used successfully.

3. There is overwhelming support for a simple and easy-to-use guidance document such as the proposed NPF4: Planning and Climate Change Guidance. The request to ensure guidance is proportionate and accessible can be met by SG.

10.6 Assessment and Quantification Thresholds

10.6.1. Whilst it is possible to quantify the carbon likely to result from any kind of development (as the Scottish City & Regional Growth Deal Guidance points out: “whenever cost can be estimated, so can carbon to a similar degree of accuracy”) it is also reasonable to recognise there should be a threshold below which WLC emissions may not require to be quantified and reported through the planning process.

10.6.2. The January 2024 Policy Position Paper signed by several industry bodies (including the UK Green Building Council, the Institution of Structural Engineers, RICs and the Institute of Civil Engineers, amongst others) included a proposed threshold for developments of a “gross internal area of more than 1000m2 or that create more than 10 dwellings” at which mandatory quantitative whole life carbon assessments would need to be conducted.

10.6.3. The Moray Council Guidance also includes the same thresholds for developments and stipulates a third threshold for energy generation projects of 5MW or more. Developments over these thresholds must conduct a quantitative whole life carbon assessment and evidence a carbon management and reporting plan, as well as including a carbon sequestration statement, a renewable energy and heat decarbonisation statement, and ‘barriers to net zero’ statement.

10.6.4. From the thresholds outlined in the positioning paper and the Moray Council Guidance, and the LETI Climate Emergency Design Guide, it is possible to interpolate a broad threshold value as an indicator of a scale of carbon emissions below which quantification may not be proportionate. From these, it could be inferred that the threshold of 1000m² relates to an embodied carbon value of around 800 to 1000 tonnes of carbon dioxide equivalent. This is a logical starting point for the development of a threshold above which formal whole life carbon assessment and management could be required to satisfy NPF4’s climate change mitigation requirements.

10.6.5. The Institute of Environmental Management and Assessment (IEMA) guidance, explored in Section 4 and 9 of this report, emphasise the significance of all carbon emissions and encourages contextualisation of a project’s carbon impact against pre-determined carbon budgets. It also includes guidance for exclusion thresholds; where a proportion of lifecycle emissions is less than 1% of the total carbon emissions impact of a project then the proportion could be scoped out of a quantitative assessment. However, this exclusion threshold is purposefully low to ensure significant emissions are included in any assessments.

10.6.6. The positioning paper, the Moray Council Guidance, and the IEMA guidance align with both the CERG proposal for a ‘Net Zero Test’ and the Proposed Document Z as a proposed amendment to the Building Regulations, both of which are described in detail in Section 6 of this report.

10.7 Key Findings Summary

Three summary key findings in relation to assessing and minimising WLC emissions in the planning process have been determined through this research and stakeholder engagement. Consideration to each of these would further ensure that whole life carbon is considered and addressed early in the planning process thus informing decision making and ensuring that development proposals align with NPF4 Policy 2a).

1. Appropriate and best practice tools and methodologies for assessing WLC already exist and are already being used:

a. Despite there being an evolving landscape in terms of assessing WLC emissions (e.g. the increasing provision of Environmental Product Declarations), and varying degrees of maturity in terms of the approach to assessing whole life carbon in the built environment, appropriate and best practice tools for measuring whole life carbon emissions already exist and are already being used in the development sector. Best practice methodologies are also already being used (e.g. PAS 2080 is widely used and is already a requirement for some infrastructure companies by their government regulators).

2. Stakeholders on both sides of the planning process want clear guidance and a consistent approach:

a. It is clear from the stakeholder feedback that simple, accessible and consistent guidance is required to ensure best practice standards are upheld across the planning process. It is also clear from industry led proposals such as Part Z, the CERG Briefing Papers, that the key stakeholders in the built environment itself want WLC to be addressed.

3. The Scottish Government can level the playing field:

a. There are several best practice and appropriate standards and methodologies that exist and are already being utilised. The SG is well placed to level the playing field in the planning process by providing clear guidance and signalling which accounting methodologies and approaches are considered best practice.

b. Lessons learnt from international case studies show that providing appropriate guidance ensures consistency and is a key first step to the sector driving down emissions in line with Scotland’s net zero goals.