London Plan carbon/energy consultations

January 2021: A bit late highlighting – but there are two key GLA planning guidance document out for consultation, linked to new energy policies in the new 2020 London Plan. Both documents have a deadline for response of 15 January 2021.

Whole Life Carbon Assessments London Plan Guidance
This document provides advice on the preparation of Whole Life-Cycle Carbon Assessments, which are required for certain planning applications that measures the carbon emissions resulting from the materials, construction and the use of a building over its entire life, including its demolition and disposal. The consultation document is available here; respond via the following webpage.

The assessment should cover the development’s carbon emissions over its life-time, accounting for:

  • its operational carbon emissions (both regulated and unregulated)
  • its embodied carbon emissions
  • any future potential carbon emissions ‘benefits’, post ‘end of life’, including benefits from reuse and recycling of building structure and materials. See also London Plan Policy SI 7 ‘Reducing waste and supporting the circular economy’.

The document sets out guidance to comply with Section F of London Plan Policy SI 2 (Minimising greenhouse gas emissions – page 385 of the London Plan 2020), setting out that applicants should follow BS EN 15978 using the RICS Whole Life Carbon (WLC) assessment as the methodology for their planning application assessment, which will inform their content into a WLC template which the GLA will provide. It’s good to see that the GLA states that achieving the maximum WLC reductions for a proposed building begins early on in a development’s design. Table 2 of the guidance document sets out principles for reducing WLC emissions, including actions such as the reuse and retrofit of existing build structures; the use of recycles or repurposed materials and the choice of materials to be used in the development.

The second document under consultation provides guidance to comply with London Plan policy S1 2 (4) ‘be seen: monitor, verify and report on energy performance‘. ‘

Be Seen’ Energy Monitoring Statements London Plan Guidance sets out the requirements for the new stage of the London Plan energy hierarchy; the ‘be seen’ stage, which requires monitoring and reporting of the actual operational energy performance of major developments for at least five years post construction.

The guidance document rightly sets out that “To truly achieve net zero-carbon buildings we need to have a better understanding of their actual operational energy performance. Although Part L calculations and Energy Performance Certificates (EPCs) give an indication of the theoretical performance of buildings, it is well established that there is a ‘performance gap’ between design theory and measured reality.” The new ‘be seen’ policy establishes post-construction monitoring as good practice, enabling developers and building owners to better understand their buildings and identify methods for improving energy performance from the project inception stage and throughout the building’s lifetime. The guidance sets out the various stages where data will be required to be submitted to the GLA, the types of data to be reported, and who has responsibility for reporting. The consultation document is here – and respond here.

The GLA have hosted some online consultation workshops on these consultations – which can be viewed on the London Plan youtube page..

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