Planning and climate change guidance: research report issue 3

8 Feedback from Key Stakeholders

8.1 Introduction

8.1.1. WSP have 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 broad range of stakeholder feedback was gained. Stakeholders included developers, Local Authorities and planning officers, and relevant Government bodies. This section explores some pertinent feedback gained through this engagement, highlighting some common approaches used as well as any challenges experienced in relation to assessing whole life carbon in the planning process.

Survey Methodology

8.1.2. In March 2024, WSP issued surveys to a range of relevant stakeholders from both sides of the planning process including developers and decision makers such as planning officials and Local Authority officers (outlined in section 3.2.4.). The survey was designed to understand common approaches to both evidencing minimisation of WLC emissions of developments as well as to assessing planning applications in line with NPF4 Policy 2a), including what information sources, tools and methods or approaches were being deployed.

8.1.3. The survey was issued via MS Forms and compiled a series of 14 questions considering the types of developments the respondents were involved in, their experience of conducting or assessing WLC assessments, and which information sources, tools and models, or methods and approaches they used to do so. The survey also invited respondents to rank these in terms of their usefulness and relative ease of use and indicate what was best practice in the industry. There was also a question specifically related to what should be included in any guidance document for satisfying NPF4 Policy 2a). A total of 21 responses were received from a range of stakeholders such as Local Authorities, central Government and/or Agencies, and housing developers, with around 85% of respondents being ‘decision makers’ and around 15% being developers.

8.1.4. Pertinent feedback from the survey responses is explored below.

8.2 Survey Responses

Survey Responses

8.2.1. The majority of respondents with a role in decision making were from a Planning Authority with roles across Development Planning, Development Management, consultees to the planning process, as well as and other roles such as ‘influencing policy’. Some decision makers also responded from central government and / or agencies. The respondents were involved in developments across the designated categories with around 72% involved in Local and Major Developments, in Major Developments, and around 56% involved in National Developments in some capacity. Respondents indicated their involvement in a variety of types of developments such as housing, electricity generation, transport and infrastructure, and minerals.

8.2.2. Once the types of roles and types of developments covered by the respondents was identified, questions focused on whole life carbon assessments and evidencing WLC emissions minimisation in planning applications. Only 50% of decision maker respondents had themselves reviewed evidence of WLC emissions minimisation in planning applications with only 6% stating they regularly review these as part of the application process, though this may be reflective of the range of differing roles represented amongst respondents.

8.2.3. Few respondents had direct experience of using information sources specifically designed to provide guidance to decision makers: 59% had never used guidance such as the Town and Country Planning Association’s ‘The Climate Crisis: A Guide for Local Authorities on Planning for Climate Change’^[52] or the UK Green Building Council’s ‘Net Zero Whole Life Carbon Roadmap’^[53] (these are explored further in Section 4 of this report for reference).

8.2.4. However, respondents did reference other useful guidance documents such as the Scottish Government Growth Deal Carbon Guidance (see further details in Section 5 of this report). The Moray Council ‘Carbon Guidance for Planning Applications and S36 and S37 Consents’^[54] was also referenced as being particularly useful given it was created and adopted specifically to support the development management process in line with NPF4 Policy 2. Other information sources or guidance documents also referenced by respondents include the RICS ‘Whole Life Carbon Assessment for the Built Environment’^[55], the ICE Database^[56], and the LETI guidance^[57], all of which are explored in Section 4 of this report.

8.2.5. One decision maker recognised their lack of resourcing which proved challenging in assessing evidence of WLC emissions minimisation. The respondent described the need for a “clear nationally required methodology” which did not differ from local authority guidance to ensure a consistent approach and to reduce fatigue on planning officials.

8.2.6. Subsequent questions explored the decision maker’s experience of various tools and methods or approaches used by developers to evidence minimisation of WLC emissions in planning applications. 80% of respondents had not seen any of the suggested tools (such as OneClick LCA and OpenLCA) and models being used by developers. However, respondents suggested that other tools may be utilised such as manual calculations in MS Excel using the DESNZ or ICE emissions factors, explored in Section 4 of this report, and the Scottish Government’s Carbon Calculator^[58] for wind farms. Limitations with this calculator were recognised by a respondent in that it “does not account for all stages of the development” so cannot be representative of WLC emissions. Another respondent suggested that they recommend tools that follow BS EN 15978:2011 standard^[59] such as OneClick LCA, eTool and CarboniCa.

8.2.7. The majority of decision maker respondents (62.5%) had also not reviewed applications that had referenced the utilisation of best practice methodology/approaches such as PAS 2080:2023 or the RICS guidance as explored in Section 4 of this report. Many respondents indicated that they had little experience of best practice approaches to evidencing a minimisation of WLC emissions due to their own lack of training and resources, with one stating “we are making a best stab at what we think is appropriate”. However, some respondents indicated best practice examples include those following the Scottish City Region & Growth Deals and the Moray Council Carbon Guidance (see further details in Section 5 and Section 9 of this report) and those using detailed site specific assessments and those with complete data sets to ensure comprehensive assessment and reporting.

8.2.8. Survey respondents from the development sector included those with an involvement in Local, Major, and National Developments and in sectors such as housing, electricity generation, transport and infrastructure and other development types. Respondents provided information on their approach to conducting whole life carbon assessments, suggesting that calculations could be done without a tool and instead using MS Excel in combination with best practice methodologies and standards to inform their approach such as PAS 2080:2023, the IEMA guidance, the RICS guidance, and the Net Zero Public Sector Buildings Standard (further explored in Section 4 of this report).

8.2.9. Respondents from the development sector also rated the Built Environment Carbon Database and the ICE Database as useful information sources/toolkits to conduct WLC assessments given these are best practice emissions source databases (as further explored in Section 4 of this report).

8.2.10. Constructive feedback was received from both the ‘decision maker’ and developer respondents relating to the proposed NPF4: Planning and Climate Change Guidance. Several responses indicating any guidance should be “simple”, “straightforward” and “consistent” to enable consistency in approach and reduce fatigue for those on either side of the planning process. Suggestions included guidance containing a checklist that both decision makers and developers can use to easily highlight areas of compliance in order to reduce complexity, and the inclusion of guidance for each stage of the project WLC for the development in terms of what should be considered to minimise whole life carbon in line with NPF4 Policy 2a).

8.2.11. Additional feedback was received around ensuring proportionality and providing guidance around both assessing planning applications in terms of the weighting attributed to Policy 2a) compared to other policies in NPF4, and in terms of balancing other development considerations such as safety, cost, and the supply chain. Respondents also referenced the need to define the wording in NPF4 Policy 2a) specifically related to what satisfies minimising WLC emissions “as far as possible” for varying development types within any guidance.

8.2.12. Finally, feedback was received questioning how the planning system interacts with the building regulations in terms of the approach to managing carbon. For example, it has been questioned whether whole life carbon quantification and assessment should sit solely within the planning system and whether in some cases it should also be considered within the building regulations given the technical nature of carbon quantification, as operational carbon is currently considered. Whether the use of mechanisms such as planning conditions would ensure best practice whole life carbon management and considering how this would overlap with the building regulations was also raised.

Conclusion

8.2.13. The survey issued invited views on a range of best practice information sources, tools, and methodologies and their relative usefulness in conducting or assessing WLC assessments for developments in Scotland. It gained insight into which information sources, tools, and methods have been used by those involved in either side of the planning process, as well as providing insight into the needs of decision makers to inform preparation of the NPF4: Planning and Climate Change Guidance.

8.2.14. From the respondents with a ‘decision making’ role, only 50% had reviewed a WLC assessment or evidence of WLC emissions minimisation in the planning process, although this could be representative of the particular roles of the respondents and the type of application they are involved in. Several respondents highlighted a lack of training and resourcing to enable them to effectively assess evidence of lifecycle emissions minimisation in planning applicants.

8.2.15. Decision makers suggested that the Scottish Government Growth Deal Carbon Guidance and The Moray Council ‘Carbon Guidance for Planning Applications and S36 and S37 Consents’ (see further details in Section 5 and 9 of this report respectively) are particularly useful resources supporting the development management process in alignment with Scotland’s net zero ambitions. Developers suggested that PAS 2080:2023 was a particularly useful guidance document in the process of carbon management and the Built Environment Carbon Database and the ICE Database were useful toolkits in conducting WLC assessments.

8.2.16. Decision makers invited any guidance document for NPF4 Policy 2a) to be accessible and simple. Suggestions included guidance containing a checklist that both decision makers and developers can use to easily highlight areas of compliance or non-compliance, and the inclusion of guidance for each stage of the project WLC.

Developers also recognised that clear and straightforward guidance for satisfying NPF4 Policy 2a) would be essential to ensure a consistent approach. Additional feedback was received around ensuring proportionality and providing guidance around both assessing planning applications in terms of the weighting attributed to Policy 2a) compared to other policies in NPF4, and in terms of balancing other development considerations such as safety, cost, and the supply chain.