Environmental Audit CommitteeWritten evidence submitted by Daniel Scharf

I have worked as a town and country planner for over 30 years in public, private and voluntary sectors. I also work as a trainer and tutor in planning. I have run a transport NGO for the last 15 years concentrating on the environmental impacts of vehicle speeds on both road transport, and the transport system as a whole.


Any suggestion that the UK should limit its ambition to reduce carbon emissions in accordance with the Climate Change Act 2008 due to the scale of the global problem should be rejected. It is the responsibility of all sovereign states to do everything in their own power to minimise domestic emissions. This is both a moral and practical imperative if the UK is to engage in international negotiations on this matter.

The profile of the Committee on Climate Change (CCC) should be increased and given proper respect and attention by all Government Departments. The treatment of CCC recommendations by both the DfT and DCLG is deplorable and brings the Climate Change Act itself into disrepute. This is particularly noticeable in respect of recommendations addressing carbon emissions from cars and the construction of new dwellings.

The Government should defer to the expertise of the CCC in respect of the specific matter on which they have been set up to give independent advice. One of the most important factors which has persuaded British citizens that climate change is not a matter of much importance is the apparent indifference of its Government. One of the most important factors in delaying and inhibiting business investment in low carbon technologies is the equivocation of the Government. The roles of both the CCC and the EAC are critical to changing Government attitudes in this matter.


1. Low Carbon Building

1.01 The lack of rigour and urgency in the way in which Government is managing the reduction in carbon emissions can be seen from the regulation of emissions from new housing. Its adopted standards can be found in the Code for Sustainable Homes which contains measures available to be applied voluntarily by local planning authorities and/or developers. Whilst the Government has accepted the target of requiring all new dwellings to be zero carbon by 2016, there have been unexplained delays in the introduction of building regulations that would continue the trajectory of carbon reduction. In the 2013 Budget Speech the Chancellor announced the delayed introduction of Part L will be in May 2013. Although no advances in technology or building methods are expected by 2016 there is no intention of requiring the necessary carbon reductions dependent on a further increase in energy efficiency reflected in a further upgrade to Part L before that date. The housing built to a lower standard will continue unnecessarily to add carbon to the atmosphere until 2050.

1.02 In May 2012 the Committee on Climate Change drew attention to the lack of progress in reducing carbon in its Report How local authorities can reduce emissions and manage climate risk. Since then Central Government has indicated that it is inclined to rely on building regulations rather than the planning system and the adoption of the Code for Sustainable Homes to manage carbon reduction from dwellings. In fact, this Report from the CCC explained why the building regulations were not “fit for purpose” in that respect. The current position is that developers, planning authorities (including those engaged in neighbourhood planning) and other interested parties (including businesses engaged in low carbon technologies) are in a state of confusion. Whilst there is no difficulty in respect of either the cost or technologies in the provision of zero carbon homes (equivalent to CHS6), it is the equivocation of the Government which is primarily responsible for the continuation of the building of sub standard dwellings.

1.03 One of the reasons why CCC wish to see planning authorities engaged in the process of reducing carbon from buildings is that conditions can be applied to planning permissions addressing the problem identified as the “performance gap” between the design and the end result. Planning conditions can be applied to require the use of low carbon materials and inspections during the building process to ensure the proper installation of insulation and of achieving necessary levels of airtightness. Conditions can also require post-occupation evaluation to assist residents in achieving the design standards and to identify any faults in carrying out the building works. The introduction of Part L of the building regulations will not achieve these necessary improvements to the construction process.

1.04 Another reason for the CCC wanting to see greater efforts in reducing carbon emissions from buildings is because of the comparative ease with which this could be achieved. Transport is seen as a very difficult sector—partly due to air travel and partly the addiction to personalized motor vehicles (see next section). Manufacturing and associated carbon emissions have largely been exported (this should be accounted for in the UK budgets). Agriculture is extremely difficult without a revolution to low input organic systems. Electricity generation is being put on a fossil fuel path by the current Government. In these circumstances the failure to deal rigorously with the relatively straightforward matter of new buildings is inexcusable. The Code for Sustainable Homes explains that the upgrading of new buildings would be difficult if not impossible and it is indicative of the Government’s approach to carbon reduction to be complicit in the erection of new buildings that are adding to the problem rather than being part of the solution.

1.05 Ironically, the DCLG introduced the “presumption in favour of sustainable development” in the National Planning Policy Framework in March 2012. However, it has left the development industry in a state of uncertainty as to whether new buildings must be sustainable, that is emitting the lowest possible level of carbon. Given that zero carbon building is within the capability of the development industry, it is difficult to understand how anything less than zero carbon could satisfy the “presumption”. It should be a simple matter of a Government Minister (Mr Pickles and/or Mr Boles) making it clear that any development that continues to emit carbon would not be considered to be sustainable. This would be entirely consistent with the recommendations being made by the CCC. The industry (including responsible developers such as Barratts) would be pleased to see a level playing field where all the developers are brought up to the same and necessary standard.

1.06 Whilst not directly a matter of carbon reductions, energy efficient buildings are an essential part of reducing fuel poverty which is a growing blight on our housing system.

2. Low Carbon Transport

2.01 The EAC should be aware that in 2005–06 (Reducing carbon emissions from transport) it recommended a reduction in the national speed limit. Whilst accepting that the Government at that time might be reluctant, to the extent of being, “…running scared of critical tabloid headlines”, the committee supported such a reduction on the basis that it would, “…help to raise awareness of the reality of climate change, and of the need for everyone to take action on it.” The corollary of the failure to take this action (repeatedly recommended by the CCC) is that the general public is being made very aware that climate change is not a sufficiently serious problem for their Government to take effective action.

2.02 Extraordinarily, the Government has a proposal to increase the national speed limit on some if not all motorways, reinforcing the view that it is unnecessary or even undesirable to attempt to reduce carbon emissions from transport. In fact, the Department for Transport understand very well the benefits that would accrue to the transport system as a whole, were speeds limited to 60 mph or preferably 50 mph. This would benefit coaches and trains (without the need for increased speeds), planned journey times would be reduced, less fuel would be used, less carbon and other greenhouse gases emitted, wear and tear on vehicles, tyres and passengers would be reduced and the NHS would benefit hugely from the reduction in the number and severity of accidents. The only explanation for maintaining (or increasing) the national speed limit is the very substantial income to the Treasury from fuel duty. However, the Department of Transport has become aware that this will be reduced in any event in the power shift to electric vehicles. It is reasonably clear that a reduction in the national speed limit would facilitate the change from the internal combustion engine to electrical power drives.

2.03 The Government should not place the CCC (or the EAC) in a position where it has to repeat its message in respect of the damaging effect of speed in respect of carbon emissions. A systemic view of transport would show that not only would reducing car speeds encourage low carbon modes of travel but that speed is also a major component in causing congestion and stop-start driving which is disproportionately responsible for greenhouse gas emissions. The variable speed limiting of parts of the motorway system prone to congestion shows that the Government is fully aware that lower speeds increase capacity and efficiency. The case for a reduction in the national speed limit, as recognised by the EAC in 2005–06, is overwhelming, and the failure of its implementation gives the strongest possible signal to the public that this Government, like its predecessor, is oblivious to the problems of climate change or simply afraid of adverse publicity.

2.04 The Government has delegated the issue of lower urban speed limits (normally 30 mph to 20 mph) to local authorities. However, the necessary traffic orders and signing makes this very expensive and the ubiquitous use of overpowered cars results in flagrant abuse and difficulties in enforcement and discrediting these initiatives. A benefit of reducing and enforcing a lower national speed limit would be a power shift to lighter, more efficient and generally smaller vehicles that would also be both easier to drive and less polluting at the lower speeds which are becoming commonplace in urban areas. With this change in technology Central Government could and should make 20 mph the default speed in urban areas.

3. Recommendations

3.01 That the Government accept the recommendations of the CCC in respect of increasing the energy efficiency of new buildings. This should be done by endorsing the Code for Sustainable Homes (and rigorously enforce BREEAM “excellent” for commercial building) and requiring all new dwellings to meet Code 6 (encouraging local planning authorities to identify “allowable solutions” to achieve the highest standard). This could be done immediately by making it clear that lower building standards would not benefit from the presumption in favour of sustainable development in the Framework.

3.02 That the Government accept the CCC recommendation that the national speed limit be reduced to 60 mph (or lower, based on evidence in the US and the Netherlands) and that the police receive instructions that this is the level to be strictly enforced. This would be completely equitable (possibly disadvantageous owners of unnecessarily fast and powerful cars) and could be done immediately and at virtually no expense.

3.03 The Prime Minister should take responsibility for preventing the interference of the Chancellor/Treasury in forestalling the delivery of both zero carbon buildings and an integrated, reliable, efficient and low carbon transport system. This interference has done nothing but cause confusion, additional costs and delay in achieving necessary carbon reductions.

29 March 2013

Prepared 3rd October 2013