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Home / News and Insights / Blogs / Planning Act 2008 / 920: Net zero strategy, DCO decision and blog news

Today’s entry looks at the Net Zero Strategy, recent DCO decision deadlines and the future of this blog.

Not the Net Zero Strategy

On 19 October 2021 the government published the Heat and Buildings Strategy and the long-awaited Net Zero Strategy. The former doesn’t have many implications for infrastructure projects but I note that the £450 million allocated towards heat pumps over three years would only pay for 5% of the target of 600,000 heat pumps per year.

The Net Zero Strategy isn’t a net zero strategy. The clue to this is on page 4: ‘presented to Parliament pursuant to Section 14 of the Climate Change Act 2008’. Section 14 requires the government to publish a strategy as to how it will achieve the latest carbon budget it has proposed, which is currently a 78% reduction from 1990 carbon levels by 2033-2037, and that is what the document mainly does. It talks a lot about net zero but doesn’t actually cover the final 13 years on that road to any extent. For a typical example, the graph on page 18 of emissions reductions stops at 2037.

The first of four ‘key principles’ is that ‘no one will be required to rip out their existing boiler or scrap their current car’. That is a valid position, but if it were a true Net Zero Strategy there should then be a forecast as to how many households will still have CO2 emitting boilers and cars by 2035 and how there will be equivalent sequestration of carbon some other way to reach net zero on that front by 2050 and there isn’t. The given reason is that a ‘systems approach’ is being adopted (see page 62) where rather than a net zero end-state being designed now, a more dynamic approach is adopted, ie we’ll see how it goes and adjust accordingly later. There is overtly expressed only an indicative delivery pathway to 2037 (page 74).

In line with it really being a Carbon Budget 6 Strategy rather than a net zero one, I have only found three mentions of targets beyond 2037 other than net zero itself: the first net zero industrial cluster by 2040 (page 121), 280,000 of restored peatlands by 2050 (page 167), and 75-81 MtCO2 of greenhouse gas removals by 2050 (page 189).

Full decarbonisation of electricity generation by 2035, mentioned in recent speeches, has been enshrined in a strategy for the first time (page 19), although on page 78 it appears that an 80-85% reduction is expected by 2035, with emissions continuing from carbon capture plants, unabated gas and energy from waste. Huh?

The 40GW of offshore wind by 2030 (’40 by 30′) is mentioned a few times, but nothing on steps to achieve it. Consented projects, those in progress plus those in the Crown Estate’s Round 4 only add up to about 30GW of capacity – where is the other 10GW coming from? And based on experience of Round 3, not all of Round 4 will be developed in the end so we need a bit of contingency on top.

Figure 14 on page 81 assumes energy demand will reduce from about 1950 terawatt hours to about 1350 by 2037 through energy efficiency (not just electricity generation, which is expected to double, but all energy demand). That’s pretty ambitious and doesn’t have much detail attached.

International aviation and shipping emissions are not expected to reduce between now and by 2037, and even by 2050 are still estimated to be 21-36 million tonnes of CO2 equivalent (page 155). UK aviation and shipping will, however, reach net zero by 2050 (page 156).

Tucked away on page 160 is what I think is a new commitment to require car manufacturers to set a target of a percentage of their sales to be zero emission vehicles. On smart charging, a presumably fictional Amir has a charge point installed on his driveway and sells energy back to the grid when he doesn’t need it (page 161). Good for him, but most of us don’t have driveways.

One area I am particularly interested in is greenhouse gas removals (GGRs), where CO2 is removed from the atmosphere but not at the point that it is emitted by something. This will be necessary to address the ‘net’ part of net zero for those areas that aren’t fully decarbonised. The Net Zero Strategy does focus on this for what I think is the first time.

The government has set an ambition to deploy at least 5 MtCO2 of GGRs per year by 2030, and its chart on page 188 shows 15-45 MtCO2 being removed by 2037 (which would have been nothing if it hadn’t been for the Net Zero Strategy). The two main ways of achieving GGRs are nature-based (eg planting trees) and engineering based (eg direct air capture plants). Legislation changes will be needed to recognise GGRs in carbon budget calculations. The government will consult on a business model for GGRs next spring and is thinking of including them in the UK Emissions Trading Scheme. There’s not a great deal of detail for such a significant ambition, but at least there’s an ambition.

There are later sections on finance and education, and ’embedding net zero in government’. The section on ’embedding net zero in government decisions’ does nothing of the sort, it refers to the five environmental principles in the Environment Bill as the main lever for this, but although tangentially to do with climate change that is more about protecting the environment in terms of species and habitats. What I’d like to see is an obligation to consider the effect of a project on achievement of net zero, just like there is presently an obligation to consider the effect on achieving air quality targets.

In summary, I think the Net Zero Strategy covers the right subject matter, eg demand as well as supply in all the right areas, but does not go far enough, stopping as it does in 2037, to be called a true Net Zero Strategy.

Not DCO decisions

This week saw three deadlines for decisions on Development Consent Order applications come and go.

First, on 19 October 2021, the decision on the MetroWest railway line near Bristol was due. Instead, it has been delayed for six months to April 2022 ‘to allow further consideration of environmental matters’.

Secondly, on 21 October 2021, the decision on the M54 to M6 Link Road was due. It has also been delayed for six months to April 2022 ‘to allow further consideration of environmental matters’. Those pesky environmental matters.

Finally, also on 21 October 2021, the decision on the Aquind Interconnector from near Portsmouth to France was due, having already been delayed for a month. It has been delayed for another three months, to 21 January 2022. The Secretary of State has decided that ‘further work is necessary to consider the application in detail including whether further information is required, and this requires an extension to the deadline’. An even more anodyne reason.

So there you have it. There now hasn’t been a decision on a DCO for over eight months, the last being the Kemsley Power DCO on 19 February 2021 – which the applicant challenged. Furthermore, nine of the last 12 decision deadlines have not been met (and that’s only counting each delayed decision once – several have been delayed more than once). This really isn’t good enough.

How it started: the National Infrastructure Strategy was published in November 2020 and ‘set an ambition to cut timescales by up to 50% for some projects entering the system from 2023’.

How it’s going: since the NIS was published three applications completed their examinations in six months and three were decided on time (not the same ones); the other 10 were delayed in each case by between two weeks and four months in case of examinations and by between four and 16 months (and counting) in the case of decisions. I will let the Planning Inspectorate off for the examination delays because those were entirely down to adapting to COVID-19, but the two Secretaries of State do not have that excuse.

Not the blog

Finally, I am making some changes to the Planning Act blog – yes, the blog is getting it, and it’s all your fault. I am shortly going to share writing responsibilities with a colleague, Mustafa Latif-Aramesh, and also going to share in writing a new Net Zero blog with another colleague, Richard Marsh. Watch this space!

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