The expanding reach of the London Plan’s net zero requirements

20 March 2023

The London Plan, launched in 2021, sets out a strategic plan for development within the Greater London Authority (GLA). Chapter 9 is particularly important for the construction industry, as this outlines tough planning requirements and policies that need to be adopted by all major and/or referable schemes.

An application is referable if:

  • The development has 150 residential units or more
  • The development is over 30 metres in height
  • The development is on Green Land or Metropolitan Open Land

These more stringent requirements, though implemented here just for Greater London, are beginning to be replicated in the stipulations laid down by planning authorities elsewhere in the country, and it is important that landowners and developers, whether operating in London or beyond, are aware of the emerging regulatory environment.

The GLA energy hierarchy

Policy SI2 requires all major developments to be net zero carbon (in operation). The GLA energy hierarchy should inform the design, construction and operation of the building – ‘Be Lean, Be Clean, Be Green and Be Seen’.

The below diagram demonstrates the definition for ‘Be Lean’, ‘Be Clean’ and ‘Be Green’, but does not go into detail about ‘Be Seen’. This element would require a CIBSE TM54 Operational Energy Assessment to be undertaken, alongside the SAP/SBEM calculations. This is a more advanced energy modelling process, which highlights the performance gap between predicted and actual energy consumption.

Where the London Plan zero carbon target cannot be met through on-site measures, it should be achieved via carbon offset payments. However, there must be a minimum on-site reduction of at least 35% beyond Building Regulations

Whole Life Cycle Carbon and Circular Economy Reporting

Additionally, where a development is referable to the mayor, a Whole Life-Cycle Carbon (WLC) Assessment and a Circular Economy review should also be undertaken to fully capture the building’s carbon impact.

WLC emissions are the emissions associated with the construction and the operation of a development over its life cycle (with the study period set at 60 years). WLC assessments should be submitted at pre-application (where relevant), with the planning application, and post-construction (but prior to occupation of the development). Results must be reported using a tool developed by the GLA, against benchmarks also developed by the GLA. While the WLC Assessment is not subject to the net zero carbon targets, it encourages strategic decisions to reduce WLC emissions to meet the benchmarks.

Policy SI7 focuses on waste reduction and the circular economy. Referable applications must submit a Circular Economy (CE) Statement, which should demonstrate:

  • How demolition waste is reused and/or recycled
  • How functional adaptability and material efficiency has been adopted
  • Strategies to manage as much waste as possible on site
  • How the development adopted the waste hierarchy and how much waste the development is expected to generate.

The CE Statement should cover the whole life cycle of the development. This policy is intended to encourage material retention, reuse and recycling, leaving minimal waste behind. A CE approach can be adopted more easily using a ‘building in layers’ framework. Different layers should be independent, accessible and removable, where this is feasible.

Source: GLA Circular Economy Statements

Going beyond London

While these requirements have only officially come into effect in the Greater London area, we have seen other local authorities adopting similar methodologies in some cases. The stricter and more robust requirements symbolise an overall change within the industry, one which we believe to be positive, driving more innovative solutions for sustainable design. We expect to see more planning policies incorporating these changes around the rest of the UK over the coming years.

Ridge can offer a full suite of sustainability, energy and net zero carbon services to support clients in complying with these requirements. This includes:

  • Whole Life Carbon Strategies
  • Circular Economy Strategies
  • Energy Strategies
  • Building Regulations Part L Modelling
  • CIBSE TM54 Operational Energy Modelling
  • Overheating Assessments

For more information, please contact:

Xenia Kaldy
Senior Sustainability Consultant (Winchester)