RTPI NI's response to Draft Climate Action Plan 2023-2027
This is Northern Ireland’s first draft Climate Action Plan 2023-2027. It sets out 52 policies and proposals designed to reduce emissions across nine sectors: energy production and supply; transport; business and industrial processes; residential buildings; public buildings; waste management; agriculture; land use, land-use change and forestry; and fisheries. The full policy document can be found here.
Relates to Chapter 5: Quantification Summary
Q1. To what extent do you agree with the quantification methodology used to calculate emissions reductions from policies and proposals?
Neither agree nor disagree
Q2. Do you have any comments on the quantification methodology used to calculate emissions reductions from policies and proposals?
No
Relates to Chapter 6: Sector Policies and Proposals
Q3. To what extent do you agree or disagree that the proposed policies and proposals will effectively reduce emissions for the energy sector?
Agree
Yes the proposed policies and proposals will reduce emissions for the energy sector, however, only if the renewable connections and infrastructure can be delivered. The Plan states on page 62 that there have been 'very few new renewable connections and therefore emissions savings have plateaued in recent years.' The adequate resourcing of the planning system is a key factor in delivery of renewable energy infrastructure permissions and how NI meets renewable energy targets for climate action. This means that the planning system requires resources and capacity to deliver climate action outcomes efficiently, effectively, and equitably. Financial support to increase the number of public sector planners employed, funding for specialist knowledge in renewable and low carbon infrastructure, and investing in efficiency-saving digital technologies can help support the shift from a largely reactive, regulatory planning system, to a proactive and strategic planning system.
Part of the role of the Royal Town Planning Institute as a learned institution is to promote and advance the training and education of planners in all areas of planning, but now there is the need to extend this training and education into areas such as energy. Our planners (across all aspects of planning: local planning authorities, Department for Infrastructure, Planning Appeals Commissioners, and private planning consultancies) will need to undergo significant training and working with specialists in the energy sector to deal with planning issues that they have never seen before. RTPI Scotland is currently working on a New Ways of Working paper that will cover the upskilling of Scotland's planning sector to facilitate an effective consenting regime for renewable energy infrastructure.
With the ambitious target to be met for NI, there will be significant opportunities for growth in the planning system and, most importantly, whilst we have lots of planning graduates coming through from our two RTPI accredited planning programmes in the University of Ulster and Queen's University Belfast, there is a significant skills gap for this type of work. There is an increased need for knowledge, training, CPD and upskilling for existing planners but also for new graduates. It is also expected the PAC will have new work from appeals or public inquiries. All agencies will need to work with the accredited planning schools more closely to come up with CPD, Post-graduate qualifications and other training courses to prepare our planners for future renewable energy projects that will be coming forward.
Q4. To what extent do you agree with the proposed approach to achieving a just transition in the energy sector?
Agree
Relates to Chapter 6: Sector Policies and Proposals
Q5. To what extent do you agree with the proposed policies and proposals to reduce emissions for the transport sector?
Strongly disagree
The proposed approach is to firstly switch fuels to zero emissions or low emissions vehicles, secondly shift car journeys to sustainable transport modes and, thirdly, reduce the need to travel altogether through land use planning. This approach is fundamentally flawed - it is the opposite to accepted research and practice in modern transport and land use planning. On page 72, the Plan even notes that transport emissions increased by 13.9% between 2020 and 2022 due to people returning to pre-Covid travel habits. This shows that the behaviour change effected by Covid, was instrumental in reducing emissions.
The fuel-switch-first approach maintains the need for private vehicles (and the carbon impact of producing them/the energy to run them), the need for road space (which has a detrimental impact on place-making, streetscape, and surface water flooding), and encourages the continuation of unhealthy lifestyle choices. Also, any fuel switch needs a just transition. People without off-street parking (often in the most deprived areas) will have to pay to use expensive commercial chargers rather than benefit from cheaper home energy tariffs.
Research published by the RTPI in 2021 on 'Net Zero Transport' emphasized a place-based approach to policy-making which prioritises measures to reduce the overall need to travel, followed by those which shift trips to active, public and shared transport, and FINALLY those which switch vehicles to cleaner fuels. By following this hierarchy, decarbonisation acts as a catalyst for reducing car dependency and creating healthier, safer and more equitable communities. By contrast, the switch to cleaner fuels only accounts for just over half of the necessary emission reductions and does not tackle other negative impacts of car dependency such as poorer health outcomes, increased strain on public services, and economic resilience.
Achieving this requires a decisive break with the conventional approach of meeting predicted changes in travel demand with new road capacity. The scale of this challenge requires a truly integrated approach that unites transport and land use planning to deliver place-based visions which meet ambitious targets for trip reduction, modal shift and carbon reduction, alongside other economic, social and environmental objectives. We need a fundamental shift in our approach in Northern Ireland to transport and land use planning, with a place-based, holistic approach from the outset.
The planning system in Northern Ireland should prioritise development that enables growth whilst achieving a substantial reduction in travel demand. This should focus on maximising the potential for local living by ensuring that most people can access a wide range of services, facilities and public spaces by walking and cycling. Increased home working, digital service delivery, and new forms of flexible work and community spaces will play a key role, alongside investment in place.
Achieving these place-based visions requires a policy framework that puts the reduction of carbon at the heart of decision making, and enables the planning, funding and delivery of the necessary interventions to create genuinely sustainable communities. Planning policy provides a strong mechanism and guide to managing development with a place-based approach, ensuring that the local context is considered and opportunities are utilised to ensure maximum benefits for climate mitigation. Therefore local planning services need to be suitably resourced, technical and financial support provided to planners to address any barriers to delivery, investment in data sharing prioritised for digital collaboration and engagement, and the professional decision-making of planning officers respected as they seek to make holistic place-based decisions that are equitable and climate conscious.
Q6. To what extent do you agree with the proposed approach to achieving a just transition in the transport sector?
Strongly disagree
Page 83 notes that 'affordability is a key concern for people'. This is at odds with a focus switching fuels to zero emissions or low emissions vehicles, which are generally more expensive than other vehicles. For people for whom affordability really is a key concern, they may not even own a car, in which case good public transport and active travel provision is paramount. A focus on sustainable forms of transport is also vital for an ageing population, who may not be able to drive any more due to sight or cognitive difficulties. Improving public transport provision is therefore key to achieving a just transition.
Bus infrastructure must be co-designed with user groups such as the Alzheimer's Society, to ensure that simple but vital provisions are in place (e.g. seats in bus shelters, clear timetables, clear system of route numbering etc) to enable older people to use the bus network confidently and independently. Effective integration between bus and rail timetables is also vital.
The success of Transport for Ireland's Local Link service could be taken as inspiration. The TFI network of scheduled and demand-responsive bus services now plays a vital role in addressing rural isolation, improving access to services, and supporting local economies. TFI Local Link operates more than 1,000 routes - around 300 of which run to set timetables, while the rest are pre-booked demand responsive transport (DRT).
In the current climate crisis, public transport provision and uptake should be improved and become the more attractive option compared with use of the private car, if we are to reduce emissions and reach our climate action goals. Public transport is also absolutely vital to social inclusion and so the approach to switching fuels first is not compatible with a 'just transition'.
Relates to Chapter 6: Sector Policies and Proposals
Q7. To what extent do you agree with the proposed policies and proposals to reduce emissions for the business and industrial processes sector?
Agree
We support the application of resource efficiency circular economy principles.
Q8. To what extent do you agree with the proposed approach to achieving a just transition in the business and industrial processes sector?
Agree
We support the approach of decoupling emissions from economic development, and actually decarbonisation being the better approach economically.
Relates to Chapter 6: Sector Policies and Proposals
Q9. To what extent do you agree with the proposed policies and proposals to reduce emissions for the residential buildings sector?
Agree
We agree with the proposed approach to: Reduce energy consumption, use low carbon options for heating, and raise standards.
The RTPl's research 'Planning for Smart Energy' Uuly, 2019) considers 'smart energy' in relation to national planning policy/guidance and the gap between what happens on the ground and the opportunities offered by smart energy, using the south west of England as a study area. It explores how the planning system can take a proactive, forward-looking and positive approach to supporting the UK's transition to a smart energy future. This research found that the planning system has an important role to play in identifying how new development can integrate with existing assets, such as ensuring new developments connect to district heating systems or that electricity storage can be co-located with existing generation assets. Maximising the use of existing assets and the integration of low carbon energy sources with smart technology could significantly reduce the need for new infrastructure, and avoid contentious proposals being hard-fought through the planning system, as well as offering the most cost-efficient solution.
Therefore, the planning system in NI has an important role to play, and should:
- facilitate the integration of sustainable building design principles in new development;
- optimise the location of new developments to allow for efficient use of resources; and
- optimise energy
Little is said of the location of new development or of sustainable building design principles in the current policy proposals.
Q10. To what extent do you agree with the proposed approach to achieving a just transition in the residential buildings sector?
Agree
RTPI NI supports the approach to: Make homes more energy efficient, Collaborate and build capacity, and Protect consumers.
A 'whole systems' approach promotes an understanding of the interactions between different parts of the system, and how these can combine to affect the desired outcome. A place-based systems approach would align local plans with the national sustainability agenda, create mechanisms which enable planning across boundaries, level up by addressing regional disparities in productivity and access to energy-saving infrastructure, provide technical and financial support to planners in local authorities to address internal barriers to delivery across NI, and harness the power of data sharing to promote access to information about residential energy efficiency (e.g. platforms for digital collaboration and engagement).
Relates to Chapter 6: Sector Policies and Proposals
Q11. To what extent do you agree with the proposed policies and proposals to reduce emissions for the public buildings sector?
Agree
RTPI NI supports the approach to reduce energy consumption and invest in greater energy efficiency and performance with more rigorous standards. We also support the use of more renewable forms of energy for heating, cooling and hot water.
Q12. To what extent do you agree with the proposed approach to achieving a just transition in the public buildings sector?
Agree
We support the approach of investing in people and skills i.e. upscaling training provisions in low carbon heating, renewable technologies and in the installation of energy efficiency measures.
Relates to Chapter 6: Sector Policies and Proposals
Q13. To what extent do you agree with the proposed policies and proposals to reduce emissions for the waste sector?
Agree
RTPI NI supports the proposed two-pronged approach to: 1. Reduce Landfill Emissions (through improvements to the separate collection of food waste from households and a new proposal to divert biodegradable waste from landfill) 2. Increase Recycling Rates and Improve Quality of Materials (including an increase in household recycling and the introduction of mandatory recycling for the commercial and industrial sector).
Q14. To what extent do you agree with the proposed approach to achieving a just transition in the waste sector?
Agree
Relates to Chapter 6: Sector Policies and Proposals
Q15. To what extent do you agree with the proposed policies and proposals to reduce emissions for the agriculture sector?
Neither agree nor disagree
The planning system should be used to effectively plan for, monitor and measure land use change to enable the best use of land to mitigate against climate change and create resilient rural communities. This could be done through strategic planning policies that can be developed and adopted region-wide.
The farming economy is a significant source of carbon emissions. However, if new forms of farming are required, these could be costly for farmers to implement, and their impacts also need to be mitigated. The transition of the agriculture industry towards a more agroecological approach and encouraging biodiversity net gain of land use changes and development could be facilitated through planning policies that support diversification of farm businesses. An agroecological approach would also help address issues of nutrient pollution and algae blooms.
Q.16 To what extent do you agree with the proposed approach to achieving a just transition in the agriculture sector?
Neither agree nor disagree
Research published by the RTPI in 2022 on Rural Planning in the 2020s, found that planning needs to balance a myriad of competing claims in rural space, from housing to habitat protection, flood management, biodiversity protection, and tree planting, as well as the effective management of landscape designations and the promotion of economic diversity. The report asserted that many rural areas need to urgently transition from where they are now - from locked-in carbon dependency and unsustainable patterns of development and energy use - to where they need to be very soon - places of economic diversity and adaptation. A framework is needed in which to make sense of competing needs and land uses, and the plan-led system which is in place in Northern Ireland is an opportunity to deliver a balanced approach to development that can set out a pathway for resilience in rural areas that reduces dependency on fossil fuels and supports innovation and economic resilience. However, local authorities require the skills, expertise and resources to deliver local development plans in a timely manner that can support this transition.
The idea of 'just transitions' seems to offer a way forward, as it argues that local people's livelihoods, and their future prospects and prosperity, cannot be overlooked. Ideas on how local populations share in the benefits of 'just transitions' emerged from a number of case studies in the research report. The Talking about our Place toolkit (developed by NatureScot in 2012), for example, illustrates the central role of communities in identifying the values and benefits arising from key assets. The Toolkit was developed to empower rural communities in particular to represent their needs and preferences in planning. The toolkit has been followed by a wider move towards place-based approaches in Scotland in recent years, such as the Climate Ready Places initiative (2016) and the Place Standard Tool with a climate lens (2022), both of which were developed by Adaptation Scotland. In order to ensure a just transition, an integrated approach towards mitigation and adaptation planning should take place, to ensure decisions on net zero support, rather than work against, efforts to protect vulnerable communities from the consequences of climate change.
Relates to Chapter 6: Sector Policies and Proposals
Q17. To what extent do you agree with the proposed policies and proposals to reduce emissions for the LULUCF sector?
Neither agree nor disagree
There needs to be a word of caution relating to dramatic afforestation plans - there needs to be a holistic approach which ensures that programmes of afforestation actually provide environmental benefits and do not result in the unintended sterilisation of local biodiversity in order to plant trees, which can thereby exacerbate other environmental degradation issues. Greater evidence is required on ecosystem baselines and potential strategies' effectiveness to gauge whether this approach will help achieve in reality the reductions in emissions required.
The role of other habitats and their effective management is supported (such as peatlands). Again, taking an ecosystems-based approach and focusing on outcomes rather than solely focusing on afforestation will ensure that the right approach is taken for a particular place, and that multiple co-benefits can be realised such as enhanced climate resilience, improved biodiversity and biosecurity from the importing of tree stock to fulfil targets.
Q18. To what extent do you agree with the proposed approach to achieving a just transition in the LULUCF sector?
Neither agree nor disagree
Relates to Chapter 6: Sector Policies and Proposals
Q.19 To what extent do you agree with the proposed policies and proposals to reduce emissions for the fisheries sector?
Agree
Q.20 To what extent do you agree with the proposed approach to achieving a just transition in the fisheries sector?
Agree
Relates to Chapter 7: Impact Assessments
Q.21 To what extent do you agree with the key findings of the Financial, Social and Economic Impact Assessments that have been carried out on the policies and proposals within the draft Climate Action Plan?
Agree
Q.22 To what extent do you agree with the key findings of the overarching Financial, Social and Economic Impact Assessment of the draft Climate Action Plan?
Agree
Q.23 To what extent do you agree with the key findings of the Equality Screening and Equality Impact Assessment?
Agree
Q.24 To what extent do you agree with the key findings of the Rural Needs Impact Assessments that have been carried out on the policies and proposals in the draft Climate Action Plan?
Disagree
In rural areas, there is not the same access to public transport that is available in urban areas, so there is more reliance on the private car to access vital amenities. Higher density mixed-use development supports the viability of public transport networks, which are difficult to justify on a cost-benefit ratio in rural areas. Therefore, outside of urban areas, increasing people's ability to live local, use active travel for short trips, and improve access to affordable, integrated public transport hubs or new forms of shared mobility can help achieve the same climate action goals whilst ensuring access to essential goods and services, thereby helping to build more resilient rural communities. This focus on transport and land use planning working together to achieve climate action goals has not been emphasized in the report, rather there is a focus on a shift to cleaner fuel types. This assumes everyone has access to a private car.
The historic pattern of planning permissions for single dwellings in the countryside has resulted in unsustainable, car-dependent development. Tighter policies via new LDPs need to ensure that single dwellings in the countryside are allowed only for those who are employed or were last employed in agriculture, forestry or a rural enterprise. Otherwise, development should be directed towards towns and villages with amenities to reduce the need to travel and in particular the need to travel by car.
Q.25 To what extent do you agree with the key findings of the overarching Rural Needs Impact Assessment of the draft Climate Action Plan?
Disagree
The Rural Needs Impact Assessment asserts that 'Access to bus, rail and motorway networks is more limited in rural areas. The policies outlined in draft Climate Action Plan provide an opportunity to improve access to public transport in rural areas.' Where are the policies which provide an opportunity to improve public transport in rural areas? They do not seem to be in the Climate Action Plan.
Q.26 To what extent do you agree with the key findings of the Strategic Environmental Assessment?
Neither agree nor disagree
Q.27 To what extent do you agree with the key findings of the Habitats Regulations Assessment?
Neither agree nor disagree
Q.28 To what extent do you agree with the key findings of the Regulatory Impact Assessment?
Neither agree nor disagree
Q.29 To what extent do you agree with the key findings of the Child Rights Impact Assessment?
Neither agree nor disagree
Q.30 Can you provide any further information which will help to supplement the completion of these impact assessments?
No further comment.
Relates to Chapter 8: The Natural Environment and Climate Change
Q.31 To what extent do you agree with the proposed target for Soil Quality?
Agree
Q.32 To what extent do you agree with the proposed target for Biodiversity?
Agree
Q.33 To what extent do you agree with the proposed target for Air Quality?
Agree
Relates to Chapter 8: The Natural Environment and Climate Change
Q.34 Can you provide any further information which will help us to incorporate Nature-based Solutions into our policies and proposals?
No
Relates to Chapter 9: Governance for Delivery
Q.35 To what extent do you agree with the proposed governance arrangements to support the delivery of the Climate Action Plan?
Agree
Relates to Chapter 1O: Monitoring and Reporting
Q.36 To what extent do you agree with the proposed approach to monitoring and reporting on policies and proposals?
Agree
Relates to Chapter 11: Public Sector Leading by Example
Q.37 Do you have suggestions about other actions that we should be taking across the public sector?
No
Relates to Chapter 12: Enabling the Transition to Net Zero
Q.38 To what extent do you agree with the actions that we are taking to enable the transition to Net Zero?
Agree
RTPI NI supports the section on how Planning can enable the transition to Net Zero. We agree with the principles set out in section 12.5, however we are disappointed not to see the importance of planning highlighted throughout the rest of the document. Research published by the RTPI in March 2021 on 'Place-Based Approaches to Climate Change' showed that a place-based approach is essential to climate action, adaptation and mitigation policies, in order to avoid sectoral thinking and acting in silos, which can have a disproportionately negative impact on some communities. A place-based approach would mean that policies relating to climate action and adaptation are integrated into land use policies and development decisions from the outset, as well as investment decisions, and behaviour change of all individuals in society towards sustainable choices is encouraged through the creation of environments that encourage low carbon lifestyles.
The RTPI research also suggests that while there are significant opportunities for joint working between planning officers and climate and sustainability colleagues, there is also a skills and knowledge gap within the planning profession that needs to be addressed so planners can play a leading role in the place-based response to the climate and ecological emergency from within local authorities. Shared outcomes, integrated climate and planning policies, skills and training, and area-based commitments (such as the Belfast net zero carbon roadmap) could support a more effective model for reducing emissions and building climate resilience.
Relates to Chapter 13: Investing in Climate Action
Q.39 To what extent do you agree with the assessment of the costs of implementing this Climate Action Plan?
Neither agree nor disagree
Q.40 Do you have any other information to inform this cost assessment?
No
Relates to Chapter 13: Investing in Climate Action
Q.41 To what extent do you agree with the proposed approach to establishing a Just Transition Fund for Agriculture?
Neither agree nor disagree
