How and why we created this section 

Planning is one of the most fascinating and headache inducing sectors within the Council Climate Actions Scorecards. It is the area where local authorities legally have the most power to set higher building standards, and direct all development in the local authorities area. Also, the reduction of emissions has been moved to a more prominent position with the National Planning Policy Framework – an indication to local authorities that the role to reduce emissions should be taken more seriously in Planning.

But is it all a facade? Local authorities have very little budget for inspections, so are unsure if buildings are built to the regulations they require; planning teams have been cut to the bone and; developer viability (minimum 15% profitability of any development) means developers have a get out of jail card to ‘plead poverty’ if standards are deemed ‘too stringent’. On top of this there are major differences of standards in building regulations between the UK nations. And crucially, the actions to reduce emissions in planning are new and evolving, which means many local authorities are unsure how far they can go with their Local Plans and what they can require developers to do. 

We should also remember that Planning only deals with buildings yet to be built. While thousands of homes are built every year, it pales in comparison to the circa 27 million homes and the multitude of commercial properties already built, many of which need to be retrofitted. But at least a strong planning system can (sort of) stop the problem getting worse.

Why were these questions chosen? 

We have 14 questions in our Planning section, although this number varies between English District and County Councils. This blog covers a selection of  questions rather than discussing all of them. 

Building regulations: Local authorities still have the power to require higher building regulations than national standards, or in Scotland to enforce the stricter ‘Gold’ standard building regulations. Legally, there is no upper ceiling to a local authorities ambition to require higher building standards but they have to make a sound case for any higher standards. As the TCPA explains, the Planning and Energy Act of 2008 allows local authorities to set higher standards in on-site renewable energy generation and energy efficiency standards but they must be consistent with national policies and of course pass the viability test.

There are a number of draft local plans (5 plans covering 7 local authorities), which are currently trying to set a requirement that homes are built to a net-zero standard. Therefore we have matched this ambition by including a question on it (Question 3c). However, the Planning Inspectorate could be a major barrier – they have removed stricter standards before and is threatening to do so again. If this is the case, and it is clear that local authorities cannot set this standard then we will have to remove Question 3c as it will not be possible.

Continuing with Question 3c we now move onto the difficulties of how to define a net-zero home. A net-zero home does not mean an energy efficient one and, most of the time, any regulations do not include embodied emissions. The current industry standard and local authorities powers extend to operational regulated energy – the energy associated with heating, hot water and fixed electrics, which is assumed not to change depending on the occupant. The actual energy usage, which could include occupants installing a hot tab or power shower is not deemed under the developers control and therefore left out of the remit of any net-zero standards. Furthermore, embodied emissions are not even counted for local authorities, outside of London’s policy for Whole-life cycle assessment, and a few other instances.

Therefore we are left with local authorities powers already curtailed. Any net-zero homes standards refers to the operational regulated emissions. Therefore you could build a new home, install a heat pump or solar panels and deem it net-zero. But local authorities have one more tool in their Planning toolkit to strengthen the net-zero homes regulations. They can require stronger fabric (or space energy efficiency) standards. This means new homes would be more energy efficient than the UK government’s current fabric standards. More efficient homes equals less energy usage, which drives down emissions and protects users from steep bill increases. This is why we have included Question 3b – which specifically refers to the fabric first approach to complement Questions 3a and 3c.

Local authorities can also require new council homes to be built to whatever standard they desire, as Swansea and Norwich have led on. This can also act as a skills enabler projects, helping develop the local industries capability to build energy efficient, renewable homes. This is the reason for including Question 2

In terms of embodied emissions (that we ask about in Question 4), local authorities have the power to require developers to at least document them. Currently, this can only be found in London and in Central Lincolnshire’s draft local plan – read more here. By documenting them developers are forced to consider them and even reduce them because of reporting requirements. 

The next question to cover is the local authorities power to map areas suitable for renewable energy systems, which is often underutilised but incredibly important. This map demonstrates to energy companies, landowners and community groups the areas that are suitable for renewable energy systems to be built. This saves time and demonstrates that the local area will be more likely to support renewable energy systems in these areas. With the lifting of the blocks on onshore wind this is a crucial tool that local authorities can wield to support the growth of onshore wind and other renewable energy systems. 

What didn’t we include? 

We didn’t include two major questions in the Planning section due to their perceived lack of impact and difference in impact between different types of authorities.

We didn’t include a question on mandating Electrical Vehicle (EV) chargers in new developments, as this is already required. While local authorities could require higher standards of EV charging we did not think this was as important as the planning policy to build walkable communities that would reduce the  use of cars overall for new developments.

Retrofitting heritage buildings can be a huge block to reducing emissions but something we decided not to ask a question on because this is mainly a problem to local authorities with a significant proportion of heritage buildings. Local authorities that do want to take action in this area should follow Kensington & Chelsea’s lead. They introduced a new planning order which gives consent for solar panels to be added to most Grade II or III listed buildings without the need for individual planning consent. 

Freedom Of Information (FOI) Requests

You can see from the trial FOI requests that we are asking one question via a FOI request n in the Planning section. This deals with the fact that councils are still approving new coal mines or other carbon intensive energy systems that will increase emissions, harm local air quality and negatively impact biodiversity. We have defined a carbon intensive energy system as coal mines, fracking/shale gas/gas drilling, oil drilling, and other unabated fossil fuel generation. Take the Cumbrian coal mine – the UK government would have had a far more difficult time in approving the new mine if the local authority had rejected the mine’s application in the first place. This is a negatively scored question, a council will lose points if they have approved a carbon intensive industry planning application. We believe it is important to hold councils to account on these negative actions, as well as celebrate the positive ones they have taken to reduce emissions in planning, which is all other questions in the section.

National Data

We are using one national data source in the planning section. This is the Department of BEIS database on renewable energy applications, which details what renewable energy systems local authorities have approved and when. It is a really incredible data source and we will be awarding points based on the number of renewable energy applications local authorities have approved with a limit of 5 points awarded.


As with all of our sections, we have tried to keep the questions focussed on the most impactful and measurable actions of councils for planning. A special thank you to those we consulted with as part of this section. We’re looking forward to marking councils on this section to find out in full detail what councils are doing to reduce greenhouse gas emissions from planning in their area.