More than ever before, a spotlight is being shone on the role of the built environment in mitigating the challenges of climate change. Earlier this year, we highlighted opportunities within the Circular Economy through the medium of real estate. In this article, I will build on these opportunities and reflect on how we can continue protecting our historic environment and adapt for a more sustainable future.
SUSTAINABILITY IN THE HISTORIC ENVIRONMENT
The UK is one of the global leaders in its commitment to reducing carbon emissions. Over 300 local authorities have now pledged to reduce their output, with many setting ambitious plans for carbon neutrality by 2030. We have also seen new and emerging planning policies, setting ambitious targets for net-zero developments and the promotion of retrofit over rebuild. Politically, ‘cracking down’ on unsustainable development has featured in the manifestos of many recently-elected Councils.
Major landowners are also committing to reducing carbon emissions from their existing estates. The Grosvenor Estate, for example, has undertaken a retrofit programme across 100 buildings contributing to a 25% carbon saving since 2013. The Government has also published a Government Property Sustainability Strategy to help reduce direct emissions from public sector buildings by at least 50% by 2032.
Of our existing building stock, more than a third of buildings were built over a hundred years ago. Many of these buildings are sensitive, and we rightly have robust laws and policies to promote the conservation of around 500,000 listed buildings, and there are many more thousands within our 9,900 conservation areas.
Plainly, these historic buildings have a crucial role to play in reducing emissions. Historic buildings can perform well, and often simple and sensitive adaptations can reduce emissions from many of them. However, is there a bigger contribution to be made by historic buildings? Does the protection of heritage assets sometimes act as a ‘brake’ on the delivery of sustainable technology in sensitive settings? As planning policies increasingly require ambitious environmental targets, how does one balance this against the need to protect heritage assets?
This tension between the preservation of the historic environment and the benefits of renewable technology has been starkly illustrated in Medway. The Council applied itself to install solar panels to its own Grade II listed HQ. The Council’s planning officers considered there to be harmful to the special interest of the building arising from the visibility of the panels and recommended that they be refused. While this was a great source of amusement to the tabloids, this tangle demonstrates the challenge of balancing the special interest of the building and the need to contribute to ambitious environmental targets.
Imagine another example, which entails the refurbishment of a large redundant listed building in a conservation area. Should one favour, for example, roof-mounted, air-source heat pumps, which might be visible to a greater or lesser degree? Do the benefits of meeting energy-related policies outweigh the potential harm? Or is the character of the building and area so important that efficient gas boilers are more suitable in this instance, at the cost of higher emissions and air quality? Until there is a consistent policy-led approach, uncertainty will discourage tenants from occupying such space, resulting in poor-performing historic buildings running the risk of vacancy, a lack of investment and eventual disrepair.
THE POLICY DILEMMA
Here lies the dilemma – the NPPF gives great weight to the preservation of the special interest of a listed building but doesn’t accord an equivalent weight to carbon emissions reductions. While decision-makers can consider whether the benefits of a proposal outweigh the harm, is this type of proposal destined to lose out where the carbon gains might be relatively small at a site level? This is a problem as it is difficult for the planning system to take account of a number of small site benefits that add up to a cumulative whole.
It sometimes feels like planning policies are not always equipped to facilitate these fine judgements that would enable the aspirations of major estates and individual homeowners to undertake seemingly sensible alterations to their properties.
There are, however, encouraging signs that planning authorities have recognised and are thinking about how to navigate these tensions. The Royal Borough of Kensington and Chelsea (RBKC) has adopted a listed building consent order that allows solar panels on all Grade II and some Grade II* listed buildings. Interestingly, the order acknowledges that there may be some harm to the special interest of buildings, but this will be outweighed by the production of renewable energy. Each building will make a small contribution but imagine the cumulative benefits of solar panels on the roofs of the Royal Borough’s museums, department stores, churches and houses.
At the same time, the Council’s emerging local plan is promoting a more relaxed approach to the sensitive use of double-glazing – a traditional difficulty in listed buildings. In fact, RBKC is currently consulting on a new Listed Building Consent Order, which will allow the installation of secondary glazing and double glazing in Grade II listed buildings in some circumstances.
At the time of writing, we are expecting an NPPF prospectus - the Department of Levelling Up, Housing & Communities has promised that this will be ‘radical’ on net-zero. We would advocate for new drafts to give proper weight to the consideration of environmentally sustainable designs. Similarly, the National Development Management Policy (NDMP) posited in the Levelling up, and Regeneration Bill could potentially deliver a consistent national and weighted approach to sustainability policies.
While the NDMP provides an opportunity to put national sustainability policies on a statutory footing as part of the development plan, legislation contained within the Planning (Listed Buildings and Conservation Areas) Act 1990 will continue to give considerable statutory weight to the preservation of designated heritage assets. No doubt, this will be rich territory for appeals and the courts to unpick the weight given to certain issues in planning.
All of this goes hand in hand with the need for built environment professionals to enhance their knowledge of sustainability matters along with more nuanced assessments of a building’s significance, which is going to mean examining orthodox thought.
This RBKC approach is just a start but a welcome one. It shows remarkable foresight in considering what is important about our valued spaces but also accepting that there may be some harm to them solely in pursuing the greater good. Rightly, we place enormous value on the preservation of our most treasured historic spaces. Equally, there is an awareness of the need to act urgently on climate change. It is a sensitive point, but one that we need to grapple with – we will increasingly need to consider or even challenge the notion that a strict preservationist approach is the right one.
If the Government is serious about climate change and protecting historic buildings, it needs to start thinking about whether the current framework can deliver on both grounds.