Do Not “Build, Build, Build”!
Architects Climate Action Network (ACAN) protests the new laws on Permitted Development Rights (PDR) as being detrimental to meeting underlying climate targets.
1. Summary of the major changes in PDR:
From September 2020 new PDR laws will mean planning applications will not be required in many instances where full approval currently regulates quality. Amongst the changes, the extended rights will allow the demolition of existing buildings for new homes that will not have to meet the (already low) expectations of Local Planning Authorities.
Owners of residential blocks and homes built between 1948 and 2018, will also be able to add up to 2 storeys to create new homes or additional space through a fast track approval process. This new power comes only with a requirement to ‘carefully consider’ the impact on neighbours and the appearance of the extension.
2. ACAN Comments:
The construction industry currently is responsible for more than 40% of carbon emissions. The speed and nature with which the industry was constructing under the current Building Regulations prior to COVID-19 would not have allowed adhering to the UK 2050 targets to bring all greenhouse gas emissions to net zero. While the Building Regulations continue to be reviewed, the new laws would further sacrifice the environment in the mistaken notion of aiding the economy. It is negligent and short-sighted of this government to take such reckless action that will only serve to expedite catastrophic climate change to the detriment of the citizens of this country.
PDR have been extensively critiqued by researchers, organisations and campaigns such as UCL academics(1), TCPA(2), LGA(3), RIBA(4) amongst the many others. These well-addressed criticisms mainly challenge the design, democratic and equitability, economic, social and well-being aspects of the PDR and its new changes.
ACAN fully acknowledges and supports these organisations’ calls to review and revoke PDR, and would like to emphasise that there has not been enough scrutiny on the environmental and climate change aspects of the proposed changes;
New laws on demolition and rebuild are not aligned with the Circular Strategy Approach, cited in the ‘Design for Circular Economy Primer’(5)
Demolition of structures and buildings that are adaptable, and the knock-on effect from transport and building materials and the associated increase of unregulated energy consumption, will lead to a considerable increase of both embodied and operational carbon emissions and is considered incompatible with the UK’s 2050 net zero greenhouse gas emission commitment and the recommended mid-term targets
The new laws do not address the inadequacies of Building Regulations in relation to the climate emergency which has been highlighted in ACAN’s previous and ongoing campaigns(6)
New laws are not clear that the VAT relief for new build projects under PDR will discourage retrofitting
3. ACAN Demands:
We are calling on the Government to:
Not expand the Permitted Development Rights as proposed
Conduct Public Consultation on the new changes to PDR before they are adopted in September
Vastly restrict PDR to only include near zero* carbon or better retrofitting projects and to exempt demolition and new build
Update the ‘Environment Act 1995’ to align to achieving net zero carbon by 2050 before the enforcement of any new laws
Introduce climate change mitigation and adaptation strategies* into the new laws combined with new Building Regulations (i.e. Introduction of Embodied Carbon limits into legislation)
To allow for demolition only if enough scrutiny has been conducted that retrofitting is not viable by including a Whole Life Cycle Analysis and incorporating the principles of Circular Economy*
Allow VAT relief only on retrofit projects under the PDR
* Provide all stakeholders with retrofitting design guidance and toolkits. This should be applied for via the Prior Approval Notice process and would adhere to the climate change commitments
Since the introduction of the new major changes to PDR on 21 July 2020, there has been an introduction of a new ‘Use Class Order’ and proposed extension of the ‘Permission in Principle’ to speed-up building. Today, 6 August 2020, the Government has launched two Open Consultations on the new planning reforms, not including the PDR changes that are coming into force in September.
ACAN is disappointed by the shortcomings of the consultation documents(7). The proposals and associated questions are inadequate and misleading and not in line with the recent research conducted by Royal Town Planning Institute towards a sustainable and inclusive recovery post COVID-19(8). The approval of the proposed changes would remove power from the Local Authorities and further delay achieving the net zero carbon homes to beyond 2025 and do not adhere to the climate change mitigations, some of which have been highlighted in this statement. We are preparing our consolidated response to the consultation documents and will be campaigning against the new changes to the planning system to be aligned with clear carbon reduction targets.
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1. Government commissioned research by UCL academics concludes that new housing created through PDR in England since 2013 is more likely to be characterised by worse quality than housing created under the full planning permission process, 21 July 2020, Retrieved 5 August 2020,
2. TCPA Campaign and Open Letter to Prime Minister voicing concerns about the extension of permitted development rights risks creating ‘slums of the future’, 3 August 2020, Retrieved 5 August 2020
3. LGA calling on permitted development rules to be scrapped and local communities to be allowed to have a vital say on new developments in their area, 13 January 2020, Retrieved 6 August 2020
4. RIBA reacts to disgraceful extension of PDR, 3 August 2020, Retrieved 5 August 2020
5. Design for Circular Economy Primer, Retrieved 5 August 2020
6. Architects Climate Action Network, Retrieved 6 August 2020
7. Consultation Documents: ‘Changes to the Current Planning System’ and ‘Planning for the Future’, Retrieved 6 August 2020
8. RTPI, The contribution of planning to a sustainable, resilient and inclusive recovery”, Retrieved 6 August 2020
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