So, what’s in the new plan? Well, from the energy efficiency perspective, there are a number of changes to this London Plan from the previous 2016 version that architects, specifiers, developers and end clients need to be aware of. The first of which is that the section on energy efficiency and reducing greenhouse gas emissions has moved from Chapter 5 to Chapter 9 (in case you end up wondering why you’re reading about public toilets), with the most notable changes having come in Policy SI 2. It’s worth pointing out here that the majority of these changes apply to Major Development only.
Policy SI 2 essentially picks up where the previous Policy 5.2 left off. We have the familiar Be Lean, Be Clean, Be Green mandate in the energy hierarchy, but we now have an additional Be Seen section. This adds in post occupancy monitoring. The energy performance will need to be monitored, verified and reported via an online portal following completion of the development. The relevant procedures will need to be put in place early on to confirm who will be responsible for this.
Also, reflecting policy for the UK as a whole, London is striving to become a net zero-carbon city by 2050. This means all major developments will now be zero carbon, a directive that previously only applied to residential developments. The mandatory 35% reduction in CO2emissions over Building Regulations (2013) remains but there is now a specific policy for fabric performance. All new residential developments will need to achieve a 10% reduction through energy efficiency measure alone, with non-residential developments requiring a 15% reduction. Extra care and early consultation with your energy assessor will be key during early design stages to ensure the fabric is robust enough to support these reductions. Solar PV can no longer swoop in to save the day!
Following the fabric improvement, district heating or low and zero carbon heating needs to be seriously considered. If the development is near a district heating network, it will be expected to connect to it, otherwise low-carbon heating through heat pumps will be the next best option to help move towards to the 35% reduction. Renewables would then be expected to make up the difference to the minimum 35% reduction, with the remainder of the net zero-carbon target coming through a cash-in-lieu payment to the council. It’s worth noting that some councils have very high carbon offset prices so it may be more cost-effective to reduce the emissions by more than 35% through energy efficiency, heating and renewables, thereby keeping your offset payments low.
A quick side note, for large planning applications that are referable to the Mayor, a whole life-cycle carbon emissions study is now needed to demonstrate how action has been taken to reduce the life-cycle carbon emissions of the development. This new whole life cycle thinking is a refreshing addition and one that we suspect will spread to other parts of the UK in the near future.
For the energy calculations presented in the energy and sustainability statements, we are still encouraged to use the SAP 10 carbon factor to accurately reflect the decarbonisation of the national grid. The updated building regulations, currently in consultation, will account for this, but until then the London Plan requires the conversion of Part L 2013 figures to reflect this. The reduction in emissions from electricity now puts heat pumps very much front and centre. Significant benefits can be achieved in relation to emission reductions if efficient air or ground source heat pumps are utilised. The sturdy gas boiler and solar PV option will be eroded by the reductions that can be obtained through heat pumps, and then renewables can be used, if they are even needed at all. (More information on the new SAP 10 can be found in a previous blog post: SAP 10 is Coming. Here are Seven Changes to Plan For).
Regarding the further changes requested by the Secretary of State this week; he has criticised the New London Plan for lack of ambition, and given several directions for change, including instructions on the appropriate mix of housing, and the policies on use of industrial land and small sites. It remains to be seen how these directions will cause the New London Plan to evolve further. Unfortunately though, it now seems certain that it will be some months before the official document is approved and comes into circulation. (You can read the full response letter here.)
Here at Darren Evans Assessments we are well positioned to help you navigate these new policies and ensure the stress (or at least some of it!) is taken out of the planning application. We can provide expert advice to ensure the building fabric, heating and hot water services, and renewables contributions are optimised, ensuring your development transitions smoothly through the planning process and building regulations. Please feel free to contact a member of our team if there is a project that we can help with.
Senior Sustainability Consultant