Consultation on the National Planning Policy Framework | Brussels Blog

Consultation on the National Planning Policy Framework

posted by on 13th Feb 2023

The Government have asked for views on their approach to updating to the National Planning Policy Framework.

This is Part 1 of my submission.

The National Planning Policy Framework &

a House of Commons report

NPPF Clause 1

This says the National Planning Policy Framework “provides a framework within which locally-prepared plans can provide for sufficient housing and other development in a sustainable manner”.

NPPF Clause 7

This includes “The purpose of the planning system is to contribute to the achievement of sustainable development”.

Clause 7 uses the definition of sustainable development from United Nations Resolution 42/187: “the objective of sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs”

NPPF Clause 110

Clause 110 includes “Maximum parking standards for residential and non-residential development should only be set where there is a clear and compelling justification that they are necessary for managing the local road network, or for optimising the density of development in city and town centres and other locations that are well served by public transport “

The House of Commons Clean Growth Technologies report

The House of Commons Science and Technology Committee produced a report, Clean Growth:Technologies for meeting the UK’s emissions reduction targets (HC 1454, Published on 22 August 2019). Under the “Recommendations for change” the report says:

“The transport sector is now the largest-emitting sector of the UK economy. The Government should bring forward the proposed ban on sales of new conventional cars and vans to 2035 at the latest. This ban should explicitly cover hybrid as well as internal combustion engines.”


“There are significant emissions associated with the manufacture of vehicles. In the long-term, widespread personal vehicle ownership does not appear to be compatible with significant decarbonisation. The Government should not aim to achieve emissions reductions simply by replacing existing vehicles with lower-emissions versions.”

A contradiction in the NPPF

Clauses 1 and 7 of the NPPF demand sustainable development and the House of Commons Clean Growth Strategies indicates that widespread personal vehicle ownership cannot be sustainable. This means the bulk of housing development should be car free.

Clause 110 of the NPPF restricts car free housing development by demanding “clear and compelling justification” for setting maximum targets to car parking. The “clear and compelling justification” does not include sustainability.

Clause 110 seeks to restrict car free housing, embedding “widespread personal vehicle ownership” in the planning system against the recommendations of the House of Commons Committee.

Clause 110 contradicts the requirement for sustainable development.

Electric vehicles and the remaining carbon budget

Polestar have estimated the greenhouse emissions from making their Polestar2 electric car as 26 tonnes CO2e.

According to the Global Carbon Project the personal remaining carbon budget to give a 50/50 chance of the Earth remaining below a 1.5C rise in surface temperature is 47 tonnes CO2e[1]. At the current rate of emissions there are 9 years left before this limit is reached.

The HoC S&T Committee noted that there are significant emissions associated with the manufacture of vehicles. This makes “widespread personal electric vehicle ownership” a barrier to decarbonisation. It is unlikely that these manufacturing emissions will be substantially reduced soon. For example steel made using “green hydrogen” seems decades away. [2]

Although electricity to power these cars in the UK will decrease in carbon intensity it will not be zero carbon for several years – probably after the personal remaining budget has been exhausted.

The Committee’s recommendation to phase out cars driven by fossil fuels has been accepted by the Government – even speeded up. However, the Government ignores the recommendation that it “should not aim to achieve emissions reductions simply by replacing existing vehicles with lower-emissions versions.”

This NPPF shows the Government has it’s aim as“widespread personal electric vehicle ownership”.

This is a climate disaster.

[1] 47 tonnes CO2e is 380 billion tonnes CO2e divided by a global population of 8.01 billion people.

[2] As noted in Green Growth or Degrowth, carbon intensity is a measure of the amount of CO2 emitted (in grams CO2) for each unit of economic output (e.g. in £). Worldwide it’s presently over 500 grams CO2 for every £ of economic output produced. It is slowly declining and if the current trend continues it will reach zero in about 40 years. If economic growth is zero carbon emissions will trend to zero too. However, the Government is aiming for positive rates of growth in the economy, which will increase emissions.

The Global Carbon Project 2021 noted “Emission intensity has steadily declined but not sufficiently to offset economic growth.”

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