Does the focus on embodied carbon involve a more restrictive approach in the planning system to brownfield development?

Brownfield development

Planning policies have long supported brownfield development, which is the re-use of previously developed land.

The focus on embodied carbon, flowing from net zero/ climate emergency policies, turns attention to the re-use of the buildings on that land. Whole life-cycle carbon assessment is becoming more important. 

Exemplars are emerging – eg. the Oxford Street decision (below) mentions the redevelopment of the former Fraser’s department store on an iconic corner site at Princes Street, Edinburgh to the Johnnie Walker Edinburgh Princes Street Experience.


Scotland has the benefit of recent national policy: National Planning Framework 4 policy 9 d) states that reuse of existing buildings will be supported, taking into account their suitability for conversion to other uses. Given the need to conserve embodied energy, demolition is regarded as the least preferred option.

This policy is not to be read in isolation – the decision-maker has to take into account all the NPF4 and other development plan policies.

For example, in a recent appeal decision , permission was granted for demolition of a two storey office building at Minerva Street, Glasgow, and erection of an eight storey building with 59 flats. The Scottish Government reporter concluded the desirability of conserving the building's embodied energy was outweighed by the sustainability benefits of a higher density development in an accessible location.

Oxford Street - what happened?

The approach to embodied carbon in England has received a lot of attention, following the long awaited decision on the application by Marks and Spencer PLC to demolish 3 buildings at Oxford Street in London, and construct a replacement building.

The Inspector recommended that approval be granted: the harm to heritage and transition to a zero-carbon economy was outweighed by the strong probability of closure and partial vacancy of the buildings, intensifying concerns for the vitality and viability of Oxford Street.

The Secretary of State refused permission. He disagreed with the inspector on aspects of the harm to heritage; on the conclusion that there is no viable and deliverable alternative; and on the level of harm to the vitality and viability of Oxford Street. 


The relevance of embodied carbon is very circumstance-specific. Although the Oxford Street application did not involve demolition of listed buildings, the heritage value of those buildings was an important factor. 

The Minerva Street decision, and the Oxford Street inspector's recommendation, shows that demolition, rather than re-use, can still be justified. 

A key issue is the sufficiency of the evidence base, either on the planning advantages of the proposed new building, and/ or the non-feasibility of re-use of the existing building - it was the Secretary of State's approach to the latter which underpinned his decision to refuse permission for the Oxford Street application.


Neil Collar