Why The New NPPF Consultation (PM13) Risks Higher Costs and Slower Climate Action
Jessica Ambrose, Graduate Sustainability Consultant
A Summary of Our Submission
On 6th March, MES Building Solutions submitted a final response to the most recent National Planning Policy Framework (NPPF) consultation. We expressed our concerns relating to Policy PM13 of the Plan-Making Policies chapter which proposed restricting local authorities from setting local energy efficiency standards in buildings.
In line with similar concerns expressed in the Low Energy Transformation Initiative (LETI) response, made in collaboration with the Town and Country Planning Association (TCPA), Good Homes Alliance (GHA), Chartered Institute of Building Service Engineers (CIBSE) and local authorities, our response highlighted three core consequences of PM13 being accepted.
1.
National minimum standards do not align with recognised climate change strategies
Standardising energy, carbon, and sustainability targets to national minimums significantly inhibits the planning system from encouraging the delivery of buildings aligned with the Intergovernmental Panel on Climate Change (IPCC)’s carbon-reduction trajectories. Since current Building Regulations do not yet impose strict targets for these areas, a minimum standard would only permit the construction of buildings not designed to mitigate against climate change. PM13, therefore, undermines a Local Plan’s ability to enforce conditions catered to the climate vulnerability of their catchment.
2.
Lower fabric efficiency means higher costs
Specifying a lower minimum standard for fabric efficiency risks locking end users into higher energy costs since poorly performing buildings demand greater energy input. This is compounded by the longstanding volatility of oil and gas prices, which continue to fluctuate in response to wider geopolitical and market dynamics. It also raises the issue of retrofit. Prolonging a building’s lifespan will be more expensive and onerous further down the line. Establishing higher, localised performance targets from the outset therefore helps reduce long-term inefficiencies and alleviates the financial burden placed on end users.
3.
A standardised approach stalls innovation
Manufacturers and construction developers are already advancing various materials and technologies whose performance levels align with a 2050 net-zero pathway. PM13, therefore, would only create uncertainty among these supply chains around what the sector requires in terms of skills and product lines. This uncertainty may stall the pace of innovation needed to meet net-zero requirements, widening the gap between current industry capabilities and those necessary for long-term climate objectives.
Final Remarks
Manufacturers and construction developers are already advancing various materials and technologies whose performance levels align with a 2050 net-zero pathway. PM13, therefore, would only create uncertainty among these supply chains around what the sector requires in terms of skills and product lines. This uncertainty may stall the pace of innovation needed to meet net-zero requirements, widening the gap between current industry capabilities and those necessary for long-term climate objectives.
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