Planning and climate change guidance: research report issue 3

5 Existing Standards and Regulations

5.1 Background

5.1.1. There are a number of standards and regulatory requirements for assessing carbon emissions, which may be relevant to different development types in Scotland. Whilst some of these requirements focus on operational carbon, NPF4 Policy 2a) requires consideration of whole life carbon and evidence of minimisation of these emissions. This section summarises current regulatory and planning mechanisms that reference carbon mitigation and highlights any associated benefits and constraints.

5.2 Environmental Impact Assessment

5.2.1. Certain development proposals require an EIA to ensure that potentially significant environmental effects are appropriately understood and opportunities to mitigate adverse effects identified. The assessment of the project’s likely significant impacts on climate is a requirement of the EIA process, however determining the significance through this mechanism can be subjective and is increasingly being challenged.

5.2.2. For example, in 2020, the Climate X Change published a review of carbon in the EIA process^[24] which highlights limitations with the varying methodologies and level of detail included in relation to assessing whole life carbon and carbon significance of a development. The review found inconsistencies in the approach to quantitative carbon assessments at this early stage of the project, with some based on very high-level data and others more granular data, and found that whole life carbon was often not fully assessed with end-of-life being not as well documented. However, the report recognises that there is opportunity to incorporate these elements into the EIA process especially given the increase in maturity and data availability and policy movements will ensure a focus on whole life carbon within the EIA process.

5.2.3. Recently published guidance on the assessment of the significance of carbon emissions through the EIA process from the Institution of Environmental Management and Assessment^[25] provides further clarity for addressing carbon assessment, mitigation and reporting in both statutory and non-statutory EIAs. The guidance is valuable in assessing potential alignment between the estimated emissions from proposed developments and national carbon objectives, hence its inclusion in this report.

5.2.4. Not all development projects are however required to submit an EIA, with required development types typically being large-scale projects only^[26]. Therefore, there are many development types that do not have to undergo an EIA and will currently not have an assessment undertaken to identify whether delivery of the project aligns to Scotland’s net zero targets. Additionally, EIA may not always be undertaken at the early design stages of a proposal, and so the critical consideration of carbon at the beginning stages of project development may have been missed. This restriction can be addressed through a wider approach to whole life carbon management, notably through PAS 2080, in which consideration of whole life carbon emissions is embedded into the earliest stages of the development process.

5.2.5. Strategic Environmental Assessments^[27] are conducted at the development plan or strategy stage during which time important decisions relating to the environment are often made. At this time, however, the climate assessment can be broad and would often be a qualitative assessment highlighting potential risks and opportunities. The requirement for a quantitative and/or qualitative whole life carbon assessment to be developed early, where appropriate and meaningful to do, so is crucial to ensure carbon mitigation opportunities are considered from the outset.

5.3 Net Zero Public Sector Building Standard

5.3.1. The Net Zero Public Sector Buildings Standard^[28] is a voluntary standard, developed by the Scottish Government and Scottish Futures Trust (SFT), applicable across all new or major refurbishment construction projects. Adopted in 2020, it aims to credibly align project objectives with current and forthcoming net zero policies, promoting exemplary energy and environmental practices within public sector buildings in Scotland in order to achieve net zero by 2045.

5.3.2. Public bodies adopting the Standard aim to enhance local communities, reduce carbon emissions and energy costs, and create healthier indoor and outdoor environments. The framework supports compliance with Scottish Government policies, providing a step-by-step approach, integrating with existing sustainability standards, and emphasising quality in design and construction. Collaboration across the public sector in Scotland is a crucial aspect of the Standard.

5.3.3. The Standard recognises that WLC assessments are likely to play a significant role in delivering decarbonisation across the public sector as they provide visibility to the carbon cost of design choices, enable low-carbon decisions, and assist with the management of carbon budgets. The Standard also acknowledges that a significant proportion of a building’s WLC can be attributed to embodied carbon of its construction, maintenance, and end-of-life treatment, and thus the Standard calls for the assessment and reduction of these emissions.

5.3.4. The Standard serves as a framework for public bodies, facilitating the definition of net zero outcomes, transparent performance reporting, and the declaration of compliance at key stages in a building's life cycle.

5.3.5. Supported by a comprehensive document suite, the Standard provides guidance, requirements, sector-specific guides, tools, templates, case studies, and training resources. While not a replacement for independent advice, it serves as a valuable tool for public bodies, promoting sustainability, environmental health, and net zero objectives in construction projects with the goal of delivering a net zero public sector building estate by 2045.

5.4 Scottish City Region and Growth Deals

5.4.1. The Scottish City Region & Growth Deals ‘Carbon Management Guidance for Projects and Programmes’^[29] aims to provide guidance for how to manage carbon emissions associated with Scottish City Region and Growth Deal projects. The Guidance states that it “may be considered to be an emerging form of ‘Net Zero Test’ whereby the effect of a project, policy or programme on climate change mitigation can be assessed using a proportionate, consistent and tiered approach.”.

5.4.2. The Guidance aims to achieve effective carbon management across the Deals programme by ensuring that carbon is considered at the earliest stage of project development. It aligns with HM Treasury Green Book requirements and supports the achievement of the following key goals for all projects under the Deals:

• Quantification of whole life carbon using appropriate and authoritative sources;
• Minimisation of whole life carbon using relevant best practice methodologies; and,
• Identification of potential barriers to achieving net zero, e.g. skills, materials, technology.

5.4.3. A key element of this Guidance, and best practice carbon management as set out in PAS 2080, is that it is always possible to quantify whole life carbon for developments. There is a strong correlation between carbon and cost in buildings and infrastructure, therefore wherever it is possible to estimate cost, it is possible to estimate carbon, to the same degree of accuracy.

5.4.4. The Guidance was developed to be applicable for all types of development under the City Region and Growth Deal programme, from transportation infrastructure projects to net zero research facilities. Importantly, there are no development types to which the Guidance could not be applied.

5.4.5. The Guidance provides examples of hypothetical projects and their associated carbon emissions impact across varying project types from transport infrastructure to investment programmes. In the appendices, the Guidance includes a ‘carbon checklist’ for project owners and business cases reviewers to ensure the relationship between the project and a just transition to net zero in accordance with Scotland’s Climate Change Plan is clearly conveyed and covers what items for inclusion in business cases including quantifiable carbon and cost assessments and the intended methodology for carbon management.

5.4.6. To allow an inclusive, proportionate approach to categorisation and decision making, the Guidance utilises a categorisation system that requires consideration of both the controllable carbon emissions impact of a project and the influence a project will have on emissions beyond its control boundary. This is referred to as control and influence respectively.

5.4.7. The approach is qualitative and includes five categories of carbon control and three categories of carbon influence:

Control:

• Category 1: Whole life carbon negative - the project directly results in less atmospheric carbon.
• Category 2: Whole life carbon net zero - the project has no measurable effect on atmospheric carbon.
• Category 3: Capital carbon increase then operationally net zero - the project will release carbon at the construction stage but will then stop emitting carbon in accordance with relevant net zero targets.
• Category 4: Capital and operational carbon increase - the project will release carbon at the construction stage then continue to emit carbon, e.g. by burning fossil fuels for heating.
• Category 5: Operational carbon increase - no construction is planned but the project will result in an increase in operational carbon emissions.

Influence:

• Category A: Carbon emissions reduction - the project leads to wider carbon savings through reduced use of fossil fuels.
• Category B: Negligible effect on wider carbon emissions - the project has no measurable effect on wider carbon emissions.
• Category C: Carbon emissions increase - the project leads to a wider carbon increase through increased use of fossil fuels.

5.4.8. An assessment of opportunities to improve the categorisation and align with Scotland’s Climate Change Plan is required for those projects that fall in any of control category 4, control category 5 or influence category C. Therefore, the Guidance provides the necessary oversight and consideration of a project’s carbon impact and provides advice on appropriate governance steps to take once this has been established. This ensures that there is effective carbon management across the Deals programme in line with the nation’s net zero commitments.

5.5 Scottish Infrastructure Investment Plan

5.5.1. Scotland’s Infrastructure Investment Plan 2021-2025^[30] focuses on three core strategic themes for guiding investment decisions in Scotland:

• Enabling the transition to net zero emissions and environmental sustainability;
• Driving inclusive economic growth; and
• Building resilient and sustainable places.

5.5.2. The plan recognises the role that infrastructure investment will have in the transition to a net zero economy and in working to end Scotland’s contribution to climate change. The delivery of the plan is also supported by NPF4 as it shapes the geographic distribution of development and infrastructure.

5.5.3. The plan introduces a new investment hierarchy framework to aid planning and decision making, Figure 1 below, which prioritises enhancing and maintaining Scotland’s assets over building new to reduce environmental impact and ensure value for money.

5.5.4. Aligning to the hierarchy requires that each step would need to be considered sequentially before deciding on the approach for a development. Figure 1 includes the hierarchy with the steps followed including first Determining Future Need (Determine future need Consider appropriate infrastructure needs and demand in light of net zero carbon and inclusive growth priorities, changes in service design, availability of digital platforms and technological innovation, and resilience in light of population and climate change forecasts), then Maximising the useful life of existing assets (maximise adaptation, repair and maintenance of existing assets), then Repurposing and Co-Locating (reconfiguring or repurposing existing assets, giving preference to co-location or shared facilities) and finally Replacing, Creating or Building New Assets (consider suitability and sustainability of new assets). For example, a new development may only be built if there is a defined need, and an existing asset could not be repurposed or co-located.

5.5.5. This investment hierarchy aligns with the ‘Carbon Reduction Hierarchy’ within PAS 2080:2023: Avoid, Switch, Improve (Figure 2, below). This hierarchy ensures alignment to a net zero transition by assessing the need, deploying low-carbon solutions, and applying circular economy and nature-based solutions principles to reduce overall impact:

• Avoid: align the outcomes of the programme of work with the net zero transition at the system level and evaluate the basic need of the development by exploring alternative means for satisfying the need without a new construction or through reusing and repurposing existing assets.
• Switch: assess alternative solutions that would reduce whole life carbon emissions through initiatives such as alternative scope and design, alternative materials and technologies.
• Improve: identify and adopt solutions and techniques that improve the use of resources and design life of a development, including applying circular economy principles and nature-based solutions.

5.5.6. NPF4 Policy 2a) requires appropriate siting of developments to minimise WLC emissions. Siting particularly influences transportation emissions which need to be considered when locating a project. The hierarchies within the Scottish Infrastructure Investment Plan and PAS 2080:2023 address the siting of a project or development to minimise WLC emissions by challenging the need for new infrastructure and considering 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 of by utilising alternative solutions across the development’s life cycle.