States where development cannot demonstrate that it is net zero carbon at the point of determination of planning permission, it will be required to address any residual emissions via a contribution to the Council’s carbon offset fund, or via a verified local off-site offsetting scheme. The offsetting needs to be considered over a 30 year period and can take into account changing emissions over time, i.e. from the decarbonisation of the electricity network where projections are provided by the Government.
The supporting text notes that the cost of offsetting should be determined by multiplying the 30 year emissions of development by the average carbon market price for the preceding 12 month period, taken from the Carbon Emissions Allowance from the European Union Emissions Trading Scheme. As noted in the response to Section 1 the potential cost of offsetting via this route has not been considered as part of the viability assessment.
We agree with the principle of carbon offsetting as a last resort for residual emissions and where they are guaranteed to deliver carbon savings. To ensure the policy is deliverable the Council must establish a carbon offset fund and associated projects that guarantee the delivery of the quantities of carbon associated with each application.
With respect to the most appropriate guidance, The UK Green Building Council has prepared guidance on carbon offsetting as part of its Net Zero Framework which sets out clear principles for carbon offsetting. These are:
• Real;
• Avoid Leakage;
• Measurable;
• Permanence;
• Additional;
• Independently verified;
• Unique; and
• Avoid social and environmental harms.
We believe there should be greater flexibility in how the offsetting can be provided, and consideration should be given to other guidance on carbon offsetting and how it can be delivered.
We would note that the effects of carbon emissions are wider than the local area, and while offsetting locally has a benefit to the District, GHG emissions are a national and international issue, we therefore believe that the ability to offset carbon via alternative projects should not be limited by the District boundary. For example there may be opportunities outside of the area to achieve a greater carbon benefit, potentially via national decarbonisation schemes. Or alternatively there may not be any suitable local projects that can be funded.
Evidence from the application of the London Plan carbon offsetting requirements shows that while the collection of offset funds has been significant it has taken a significant period of time before some London Boroughs have been able to allocate funds or create carbon reduction projects. (ADD REF)
We would therefore suggest that the alternative offsetting option is widened to allow any project that meets the principles of offsetting within the guidance provided by the UKGBC. If the Council is intent on the creation of a local fund then we strongly believe this fund should be audited on an annual basis by an independent third party to ensure that it is achieving the carbon savings promised and if not, then funds should be returned to the developer after two years to allow the procurement of verified high quality offsets.
If contributions towards an offsetting scheme will required through S106, this will need to be considered at outline or full planning application stage, as it is not appropriate to retrospectively apply new policies to an existing permission (at Reserved Matters stage) without renegotiation or consideration of the viability impacts on development.