Policy NZC2(D): Carbon Offsetting

Whilst I welcome tree planting for many reasons I question whether the scale of planting, and the required growth rate, can be acheieved for significant carbon offsetting. This must not be seen as a get out option for avoiding zero-carbon buildings. We don't want developers, or the council, to see slipping some money into a WDC fund as a way of easing past the zero carbon requirements.

In my experience of how developers interpret planning conditions, this offsetting will happen far more often than this policy will expect. It will end up being used as a 'cash incentive' for councils to allow a development that should be refused on the basis of this policy. In Bishop's Tachbrook, AC Lloyd was allowed to offset 'biodiversity' losses by setting aside land far away, in a different district. This cannot be allowed under this policy. The carbon offset MUST benefit the immediate local people so people living in hugely affected areas benefit from the reduction in carbon.

'The delivery of any such scheme must be local and guaranteed.' But also local must be defined as 'no more than 1 mile' from the development so developers do not claim to be unable to offset it any more locally than the next district (see Bishop's Tachbrook Warwick District AC Lloyd biodiversity offsetting in Stratford District)

'As such the Council considers offsetting to be an option of final resort. ' This must be absolutely adhered to with a target of 0% of developments using offsetting per year and a public KPI linked to this measure. The council should freely and willingly publish details of decisions where offsetting has been allowed, and publicly justify why the exemption has been permitted. WDC must hold developers to account on this and the public must be able to hold WDC to account on this 'final resort'.

Necessary alas, but I am glad to see that monitoring of the funds and progress made by adopting this policy will be included in the Authority Monitoring Report.

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.

Please see attached.