17 Jan 2025

CIH response to the Environmental Audit Committee inquiry into environmental sustainability and housing growth

We welcome the opportunity to respond to the Environmental Audit Committee’s (EAC) important inquiry on environmental sustainability and housing growth.

CIH responded in detail to the government’s consultation on proposed reforms to the National Planning Policy Framework (NPPF). To inform our response to that consultation, we undertook extensive engagement with our membership, and with partner organisations working in the housing, planning, and built environment sectors.

In what follows, we draw on the evidence collected as part of this engagement to respond to the inquiry questions. We have answered only those questions where we can provide an informed and evidence-based response, and would welcome the opportunity to provide further evidence to the committee on these matters.

Read the full response
What policy levers does the government plan to use to ensure that local authorities deliver the development which the revised NPPF ‘standard method’ requires?

While we are fully supportive of the government’s ambition to build 1.5 million new homes this parliament, outlined in the NPPF reforms, we know this will be difficult to accomplish without significant capital spending. This is especially true for affordable homes, including homes for social rent. Consequently, while the reforms to the planning system are vital, CIH feels a wider range of policy levers must be utilised to ensure local authorities can deliver their targets. We explained these levers in detail in our submission to the 2024 Autumn Budget and Spending Review, but briefly, they are:

  • Immediately increasing investment by redirecting subsidies. Of some £6-8 billion invested annually by the government in housing, about half is spent on support for the private market. A major shift of subsidy from private market support would enable funding to be directed where it would meet the greatest housing need, and could enable Homes England and the GLA to support more affordable housing projects within the current Affordable Homes Programme (AHP).
  • Develop a long-term housing investment programme, which should take the form of a more ambitious, ten-year AHP, beginning in April 2026. Alongside a long-term rent settlement, recently consulted on by the government, and funding for social landlords to invest in required improvements to their existing stock, this would enable housing associations, local authorities, and the private market to develop more affordable housing, including homes for social rent.
  • Generally, prioritise investment in social rented homes, to meet local needs, as noted above. These homes are far less viable without government grant contributions but are central to tackling the housing crisis.
To what extent is the current planning presumption in favour of sustainable development compatible with the environmental objective of the planning system? To what extent will the proposed ‘streamlining’ of the sustainable development presumption work to deliver developments which will meet this objective and be compatible with the government’s environmental targets and obligations?

The government’s focus on sustainable development in the updated NPPF is welcome. However, we believe that additional detail is necessary to strengthen the presumption to deliver the right homes and protect communities where there is not a local plan in place, whilst accelerating housing delivery.

Specifically, we have a concern that the presumption in its current form can be a pathway for the development of low-quality, unsustainable homes, which further undermines trust in local authorities to deliver necessary homes in line with the legitimate concerns of local communities. Additionally, homes should be built to the highest standards of energy efficiency and support quality placemaking by making it explicit that homes on these sites should have access to local facilities, green spaces and transport links. 

We are also unclear whether urban understandings of density and sustainable development overlook much needed increases in density for small, rural settlements of 3,000 people or fewer. The provision of new homes in rural areas is a persistent challenge, with a chronic under-delivery of affordable homes contributing to a marked rise in rural homelessness in the last five years. We provided more detail on the policy levers and reforms that are necessary to tackle this in our response to the NPPF consultation.

Lastly, we would like to draw the Committee’s attention to the continuing use of permitted development rights (PDR), and how the conversion of non-domestic premises (e.g. office blocks) to housing through PDR is creating unsustainable, poor-quality homes that harm the environment as well as their occupants. Relevant building regulations to do not fully apply to these homes (e.g. Part O), and their quality is often poor, especially in terms of ventilation, energy efficiency, excess cold and excess heat, damp and mould, and space standards. However, the revised NPPF makes no provision for tightening regulations for PDR homes. We would therefore like to see the previous government’s changes to PDR formally reviewed with the government’s environmental obligations in mind.

What contribution can the NPPF make to meeting government targets for the reduction of greenhouse gas emissions?

The revised NPPF has some welcome changes to facilitate this. In particular, the addition of Paragraph 163, stipulating that the need to mitigate and adapt to climate change should be considered in preparing and assessing planning applications, is a noteworthy addition. The inclusion of a wider range of climate impacts, such as drought, in the revised NPPF are also appropriate, and will help to ensure that extreme weather events are more holistically considered as part of plan making.

However, this is a step removed from explicitly referencing the UK’s legally binding net zero targets or carbon budgets, which are not necessarily the same as climate mitigation and adaptation. Previous research by the Royal Town Planning Institute (RTPI) has shown that all planning policy and relevant decision-making should be aligned with the Climate Change Act 2008 to ensure that all new developments are consistent with our climate obligations. The addition of Paragraph 163 is a step in that direction, but could have gone further to make explicit reference to the Climate Change Act 2008, or our carbon budgets.

The revised NPPF could also have been strengthened to support housing associations to improve the energy efficiency of their homes. In 2022, domestic heating was responsible for 20 per cent of carbon emissions in the UK, and most housing associations have a target to improve the energy efficiency of their homes to EPC Band C by 2030.

Paragraph 167 of the revised NPPF states that local planning authorities (LPAs) should give significant weight to the need to support energy efficiency improvements in existing buildings. This is unchanged from the previous NPPF. While we support the principle of this paragraph, CIH members working in housing associations have told us that it is interpreted inconsistently by LPAs.

Specifically, we are aware of one example where, at a preliminary inquiry stage, one LPA asked a housing association to submit individual applications for every home in a retrofit programme. This was not only financially unviable for the housing association, but impossible for them to undertake, because it would have involved the preparation of thousands of individual applications. However, the same housing association received a presumption of approval following the submission of outline information from an adjacent LPA, which enabled them to quickly move forward with energy efficiency works.

The planning system should make it as simple as possible to undertake urgent energy efficiency and low-carbon heating upgrades to existing homes. We would therefore have liked to see Paragraph 167 of the revised NPPF strengthened, perhaps through the addition of a statement of presumption in favour where adequate outline information has been provided.

While we welcome overall the revised NPPF, it must be accompanied by the rapid conclusion of government’s work on broader policy levers to reduce greenhouse gas emissions, especially the finalisation of the Future Homes Standard and related updates to Building Regulations. CIH supports the introduction of Option 1 from the previous government’s technical consultation on the Future Homes Standard, which would see all new homes built with low-carbon heating and solar PV as standard.

Lastly, the government’s response to the NPPF consultation also states it will keep building regulations under review to ensure new buildings are built to mitigate the risk of climate change. We particularly welcome the possibility of a thorough review of Part O. In its technical consultation on the Future Homes Standard, the previous government proposed some updates to Part O, but in our response we noted that these questions were potentially premature, given that homes built with Part O are only beginning to be occupied, and there is therefore a lack of robust evidence on how it is working. A review undertaken in 2025 would have more evidence available to it, and would therefore be appropriate.

What account does the NPPF take of advice from the Climate Change Committee on reducing the use of embodied carbon as well as operational carbon in the built environment?

The revised NPPF does not consider the reduction of embodied carbon from the built environment. Although the government’s response to the NPPF consultation noted that many respondents referenced the need to reduce embodied carbon emissions, no amendments were made to the revised NPPF to do this.

We agree with others that the omission of embodied carbon from the government planning policy and building regulations is concerning. The Chartered Institute of Building Services Engineers (CIBSE) has noted that around one in ten tonnes of the UK’s total greenhouse gas emissions are from embodied carbon. Importantly, academic evidence suggests that without action on reducing embodied carbon, meeting the government’s targets could use the remaining 2050 carbon budget apportioned to housebuilding by 2036. Other researchers have claimed that in its current form, “meeting the national housing targets through new construction is fundamentally incompatible with the UK’s legally binding carbon reduction targets.”

This means there is clearly a need for policy that reduces embodied carbon. In its technical consultation on the Future Homes Standard, the previous government noted that it would seek views on measuring and reducing embodied carbon in new buildings in due course. The new government should honour this commitment and develop appropriate policies for reducing embodied carbon. This could be achieved through incentivising the use of sustainably sourced timber in housebuilding, and/or through the adoption of a new Building Regulation, the so-called Approved Document Z, which is widely supported.

However, we would note that CIH members we consulted with to inform our response to the NPPF consultation emphasised that LPAs would require significant support to understand and put into practice any policy on embodied carbon. As noted later in 7.1, LPAs are experiencing considerable resource, staffing, and cost pressures, and the adoption of Approved Document Z or similar policies would need to be accompanied by a package of support to enable LPAs to implement the policy.

What provisions will the National Policy Planning Framework, as revised under the government’s proposals, make for protection and enhancement of the environment? Are these provisions likely to be adequate?

As noted above, while we welcome the addition of Paragraph 163, the most significant challenge is that the planning system is not sufficiently aligned with our carbon budgets and emissions reduction targets.

Aligning the planning system with net zero must also be one part of a wider set of policy initiatives to meet our carbon budgets. The Committee on Climate Change’s recommendations in their 2024 report to parliament are a necessary starting point for achieving this.

Will the government's proposals affect the ability of local authorities to implement policies designed to protect the natural environment in their areas?

As highlighted in work by CIH, many local authorities are currently struggling with reduced capacity, resources, and financial stability. These broader financial pressures mean that, to some degree, all of the proposed changes in the NPPF will be challenging for local authorities, as they all require familiarisation costs and time, as well as potential increases in housing development targets.

For these reasons, we welcome the announcement that councils will receive an additional £100 million next year to hire more staff and consultants, as well as more resources to carry out technical studies and site assessments. Combined with the boost for local authority funding at the 2024 Autumn Budget, this will go some way to supporting LPAs to fulfil the requirements of the revised NPPF. However, we would note that these changes are unlikely to significantly improve local authority finances in the medium- and long-term. We hope that the Housing, Communities and Local Government Committee’s recently announced inquiry into the funding and sustainability of local government finance will reflect these challenges.

In relation to the environment, we have more specific concerns about resource issues in ecological expertise that were not addressed in the government’s response to the NPPF consultation. Government figures show that in 2022/23, Natural England received 17,761 planning application consultations, and missed its statutory or otherwise agreed deadlines in around 13 per cent of cases. Workload and resourcing issues, especially higher than normal levels of staff turnover and the need to upskill new staff, were identified as the main driver of missed deadlines. Simultaneously, Natural England has indicated an intention to focus its advice provision on high-risk and high opportunity casework, noting that decision makers should expect more standardised approaches for lower risk cases. In response to changes, LPAs are supposed to take on the responsibility to apply those standardised guidance in the event of lower risk cases. This is a concern when just over a quarter (26 per cent) of LPAs do not have access to ecological expertise.

As such, we are concerned that without adequate resourcing of local authorities, including ecological experts in planning departments, the proposals set out by the government will not be as achievable or effective as they need to be. It may also mean that less time and attention can be paid to the environmental impact of planning applications, and thus limit local authorities’ ability to protect the natural environment in their areas. At the time of writing, it is not clear to us whether the additional £100 million noted in 7.2. will be able to be used for ecological expertise, and clarity on this would be a welcome outcome of the Committee’s work.

Lastly, we are pleased to note the government has provided a new definition of grey belt as part of its response to the NPPF consultation. Along with many others, we raised concerns in our response to the  consultation that a lack of clarity in the proposed definition could lead to inconsistency in decision-making by LPAs, and ultimately impact on the purposes of the green belt. The government’s new definition, which aims to clarify the relationship between previously developed land and other grey belt land to ensure that both routes to development provide clear and separate tests, is therefore welcome. We wait to see how the definition will be operationalised as the revised NPPF comes into force.

How will the revised NPPF operate to promote the Nature Recovery Network and the implementation of local nature recovery strategies by responsible authorities?

In our response to the NPPF consultation, we explained that we would welcome more clarity on the relationship between Local Nature Recovery Strategies (LNRSs) and the guidance for identifying land which makes a limited contribution to green belt purposes.

To an extent, the government has taken action to do this in its own response to the NPPF consultation. It has stated that, in due course, it will produce new guidance and updates to the existing planning practice guidance to clarify the role of Local Nature Recovery Strategies in enhancing the green belt. The government has also added a specific reference to LNRSs in Paragraph 159 of the updated NPPF, which states that where land has been identified on sites included within LNRSs, proposals should contribute to habitat creation and/or nature recovery. These are welcome changes and commitments that CIH supports.

Find out more about the inquiry

Visit parliament's website for more information on the inquiry.

Contact

For more information on our response please contact Matthew Scott, senior policy officer, matthew.scott@cih.org.