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Let’s not make the floor the ceiling! The draft NPPF consultation (National Planning Policy Framework) proposes changes that would rewind progress, stifle innovation, and reduce our ability to meet national carbon targets.

The consultation closes on 10th March. We urge AD signatories in England to respond and make clear that national policy must enable and not restrict climate leadership, innovation, and the ability of local authorities to go further where viable.

While there are aspects of these broad-ranging changes that are positive, we want to draw your urgent attention to section PM13 'Setting Standards'.* If adopted this would prevent England's local authorities from setting higher standards (EUI, renewable energy, and related measures). A reliance on Building Regulations, the ‘floor’, is simply the wrong mechanism to use.

Across the UK, local authorities have led the way in raising standards - driving down operational carbon, accelerating industry capability, supporting biodiversity, and providing the market the certainty needed to innovate. This progress has not happened by accident; it has been enabled by local leadership. Countless authorities have been raising the bar and, in doing so, galvanising our industry while reducing carbon and enhancing biodiversity.

At a time when the UK’s net-zero economy is growing three times faster than the overall economy, this is not the moment to retreat. It is not the moment to constrain ambition. And it is certainly not the moment to lock in mediocrity. Why put on the brakes?

* See page 24 of the document, and question 18 in the consultation.

Please get involved!

We support our friends at LETI who are rising to the challenge and ensuring we can respond to this consultation with ease. They have also organised a 45-minut webinar: 'Join LETI’s Call to Action on the NPPF Consultation' on Wednesday 25th February at 1pm. You can register here.

They have also created a template to help us respond to the consultation concentrating on PM13: Consultations | LETI

Do contact us if you would like more information or indeed would like to discuss any of this further.

Last month, UK Architects Declare responded to the Scottish Government's consultation: Building Regulations: Determining the principles for a Scottish equivalent to the Passivhaus standard: Stage 1 consultation.

Whilst we are encouraged to see ambitious new legislation being put forward, our response supports the Passivhaus Trust's position that following the Passivhaus methodology offers a documented approach that is effective at reducing the performance gap between performance in design and operation, and we would be disappointed to see this approach watered down at such a critical time in history when rapid emissions reduction is essential.

We encourage the Scottish Government to set a heating demand limit. This legislation has the opportunity to tackle environmental issues at the same time as addressing pressing socio-economic issues such as fuel poverty. We would also welcome standards that consider both regulated and unregulated energy to ensure the full scope of energy use is being considered and are aligned with the objectives of the UK Net Zero Carbon Building Standard, the pilot version of which was released in September.

Whilst this new legislation is a step in the right direction, Architects Declare would also encourage the Scottish Government to look beyond operational energy, and consider adopting embodied carbon legislation as soon as possible, similar to the "Part Z" proposal (an amendment to The Building Regulations 2010) being advocated for by the construction industry in England and Wales.

UK Architects Declare has joined with other environmental and built environment organisations in responding to the Government's recent consultation on the National Planning Policy Framework for England (NPPF). 

The joint statement - from Alliance for Sustainable Building Products, Bioregional, Centre for Sustainable Energy, ClimateEmergency UK, Friends of the Earth, Good Homes Alliance, PassivHaus Trust, Rights Community Action, The Good Law Project, Town and Country Planning Association, UK100, UK Green Building Council and others - suggests three priorities as part of the government’s planning reform agenda:

1. The planning system must prioritise action on climate, and this should be articulated through a definition of the purpose of planning in the NPPF that reflects the crucial role of planning in securing our future in a changing climate;
2. The carbon impact of planning proposals must be accounted and inform planning decisions and plan making; and
3. The NPPF must be reviewed to give increased direction and urgency to the opportunities for planning and development to support resilience and adaptation.

It goes on to say that detailed changes are required to make the NPPF fit for purpose in responding to the climate crisis. As a minimum starting point, it calls for the insertion of the following text into the NPPF, to clarify the relationship between planning decisions and the Government’s statutory carbon budgets and to make clear the overall priority to be given to climate change in the planning system:

"Climate change is the greatest long-term challenge facing the world today. Addressing climate change is therefore the principal concern for sustainable development. For the avoidance of doubt, achieving sustainable development includes securing the mitigation of, and adaptation to, climate change. All planning strategies, and the decisions taken in support of them, must reflect the ambition to help business and communities build a zero carbon future and prepare for the impacts of climate change. Accordingly, planning policies and all planning decisions must be in line with the objectives and provisions of Climate Change Act 2008 including the 2050 net zero carbon target."

Architects Declare submitted written evidence to the House of Commons Environmental Audit Committee, and this has now been published on the Committee's website. The inquiry was established to "examine the sustainability of the built environment. It will look at the best routes to net zero for our future building needs from low carbon materials through to policies to minimise the whole life carbon impact of new buildings."

Architects Declare have responded to the Planning for the Future Consultation.

View our response here

Construction Declares has partnered with the Architects Climate Action Network in a response to DEFRA's England Tree Strategy. We see this as a chance to influence this strategy for the next 30 years, and help the government to maximise benefits of tree planting. To support this, and for more information about why this consultation is so important for architects to respond to, please click here . You have until 11 September.

As the first year anniversary of Architects Declare approaches, we are conducting a survey of all our signatories, asking how practices have responded to the climate emergency. We would also like to know what practices have planned for the future, and what they expect from Architects Declare. To take part in this survey, please click here.