Tag Archives: CLG

Mayor raises concerns over CLG Allowable Solutions proposals

January 2014: The Mayor has recently posted online his response to the Department of Communities and Local Government (CLG) Allowable Solutions (AS) consultation, released last year. Allowable Solutions are central to the achievement of the Government’s commitment to delivering zero carbon homes by 2016, and have been under discussion for several years now, with significant delays in any Ministerial decisions being made (too much to go into here – see articles here and here) . The Zero Carbon Hub have also led on much of the detailed development behind the potential measures that could be used.

The Mayor raises a number of concerns to Government over their proposals, including:

  • London is less likely to benefit from them than other parts of the country, because London’s building stock and the complex logistics of working in London make it more expensive to install both retrofit and energy supply measures.
  • The current proposals are likely to mean that AS in London are uncompetitive. In combination with proposals under the Housing Standards Review, there is significant risk that the well established plans in London to support the deployment of decentralised energy and heat networks through the planning system will be undermined.
  • It is unlikely that district heating will be funded under AS without revisions to the proposals.The development of decentralised heat and power generation and district heating forms an integral part of London’s and other cities’ contribution to the delivery of Government’s heat strategy. It appears to be an ambition for AS that they should support district heating and it might often make sense for a developer to contribute to a district heating network if his/her future developments could in turn receive low carbon affordable heat from that network. However, except perhaps if the central fund route were the sole option, it is difficult to see how the proposed options would support district heating.

London boroughs are already making significant headway in establishing their own allowable solution mechanisms as a consequence of the Government’s delay in setting out their own policy – see details of  Islington’s Carbon Offset Fund here.

See article in Building magazine also detailing the Mayor’s response.

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Mayor to battle with CLG over London energy and planning policies?

December 2013:  In response to a series of Mayoral Questions (here, here and here) the Mayor has now posted his submission to the Department for Communities and Local Government (CLG) controversial (see here,  here, here and here)  Housing Standards Review report and consultation.

The MQ responses highlight that the Mayor has written to CLG’s Secretary of State, Eric Pickles, expressing concerns with proposals for a National Standards set which could limit the GLA’s ability to apply planning policy on housing design and space standards as well as energy standards in new housing“.

The Mayor has also asked Mr Pickles to meet in order “to discuss these proposals, and requested the opportunity to make further comments, once CLG reaches a clearer position on the proposals”.

The Mayor’s submission document sets out that:

  • London developments are already demonstrating that the carbon compliance level could be more stretching without undermining viability.
  • London’s ‘interim’ standards should be retained and continue to be applied in accordance with the London Plan energy hierarchy
  • Disputing the Housing Standards Review view that Government “does not believe that an interim level would be helpful to developers and is not minded therefore to set one in a nationally described standard”, the Mayor responds    On the contrary, the setting-out of a clear strategy and requirements over time in the London Plan, including ‘interim’ targets between Building Regulations and Zero Carbon has effectively created market certainty, allowing developers to innovate and to bring down costs, in a manner that serves government’s intentions from 2016.
  • That the solutions developers are obligated to consider under the London Plan ‘energy hierarchy’ do not lead to technological blind alleys. On the contrary, heat networks are fuel and technology flexible. Rather than creating ‘blind alleys’ they make the transition to zero carbon sources of heat easier” and that
  • In the absence of the [London Plan’s] approach” the Government’s proposed changes would  undermine a key tenet of DECC’s Heat Strategy for cities.

The submission importantly states that: CLG have agreed to meet with GLA officers to discuss interim arrangements which allow the Mayor to maintain London Plan 2013-2016 carbon reduction targets”

A recent assessment of the energy policies under the London Plan – undertaken and published by the GLA – sets out that a significant level of energy-related commitments have been secured including:

  • Equivalent of circa £32m investment secured through energy efficiency measures alone.
  • Circa £20 million of investment in new CHP plant able to produce 29MW of electricity and heat.
  • Circa £133 million of investment in communal heat network infrastructure for ~ 53,000 dwellings
  • Circa 55 permanent jobs created in maintaining heat network infrastructure and associated energy supply plant. Additional jobs will also be created in the supply chain

The House of Commons Environment Audit Committee undertook their own review of the Housing Standards Review document, publishing their results on 20 November. The report echoes the Mayor’s sentiments stating:

  • That local choice in favour of practical, sustainable local solutions will be radically curtailed and replaced with a lowest-common-denominator national standard
  • That the proposed replacement for CSH standards on energy and carbon emissions, the 2016 zero carbon homes standard, has been significantly diluted

and goes further [para 33]:

  • The specifications around the zero carbon homes target have been watered down to such an extent that the proposed standards in Building Regulations now fall some way short of the higher levels of the CSH.
  • There is no guarantee that further dilution will not occur in the run-up to the implementation of zero carbon homes in 2016.
  • DCLG must maintain CSH energy assessments as a tool for local authorities to lever in renewable energy until Building Regulations deliver genuinely zero carbon homes, which was the original target and is defined by CSH level 6.

There’s no information over whether the Mayor has met with Mr Pickles as yet – and CLG have as yet not indicated when they are to finalise and publish their conclusions to the Housing Standard Review’s proposals. However it’s clear that the London Plan’s energy and climate policies have – and are continuing to – create a major shift in the development of more energy efficient buildings in London. Developers, architects and sustainability experts are delivering some of the most innovative green buildings in the world here in London as a consequence of the London Plan, and hence it would be a huge surprise if the Mayor allowed his successful planning policies to be diluted by the Government’s latest – and hugely confused – zero carbon buildings proposals.

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Are EPCs a true indicator of energy efficiency?

December 2012: Jones Lang LaSalle with the Better Buildings Partnership have issued the output of some interesting work they have undertaken: “Using data gathered from over 200 buildings over the past four years, we’ve measured the actual energy performance of BBP members’ managed properties in London with surprising results…There is little or no correlation between EPC ratings and actual energy performance”. This is something often raised by EPC assessors, and so it is useful to get this comprehensive research confirming this view.

The report concludes that:
“If the commercial property industry is to succeed in achieving the Government’s ambition of cutting the associated CO2 emissions of the built environment, it is imperative for the industry, backed by Government direction, to focus on actual energy performance rather than just ‘design intent’. We have shown that there is little or no correlation between a building’s design (as measured by its Energy Performance Certificate) and its actual consumption.
The BBP members’ portfolios achieved a reduction in the associated CO2 emissions of 8% and made a saving of more than £4 million in energy bills, between 2009/2010 and 2011/2012. If the level of success achieved by BBP members were applied to the total existing office stock of Greater London, savings could be in the order of £70 million.”

Somewhat disappointingly, the publication of this research was very shortly followed by the following news report from the Government Minister overseeing this policy concerning extending the coverage of EPCs:

U-turn over compulsory energy assessments for commercial buildings
“Correspondence from building regulations minister Don Foster, confirms that plans for compulsory display energy certificates (DECs) for the private sector have been dropped. Instead, the commercial sector will be required to obtain less stringent energy performance certificates, which measure projected energy use. Display energy certificates, which measure a property’s actual energy performance, are already compulsory for public buildings.”

Continue reading…

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Statistics on new housing starts and completions in each local authority in London

September 2012: Recent parliamentary question in the House of Commons provides a useful summary on where London housing statistics are kept and collated.

Statistics on new housing starts and completions in each local authority in London, taken from the National Statistics on House Building, are published in live table 253 on the Department for Communities and Local Government’s website which is available on the following link.

These statistics show starts and completions split by tenure according to whether the organisation responsible for the development is a private company, a housing association or a local authority. The figures for housing associations and local authorities can together be used as a proxy for affordable housing starts and completions. However, these figures may underestimate affordable housing supply and overestimate private housing, as they are from building control records in which the ultimate tenure may be difficult to identify.

Statistics on the full extent of affordable housing supply by local authority are published in the Department’s live tables 1006, 1007 and 1008, which are available at the following link.

From 1 April 2012, the Mayor of London has had oversight of strategic housing, regeneration and economic development in London.

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‘Agreement struck to prepare communities for climate change’

May 2012: Defra report that “Homes, roads and parks could all be better protected from the effects of climate change after an agreement was struck between ministers and local government.
An agreement between Defra, the Department for Communities and Local Government (CLG) and the Local Government Association (LGA) called for vital public services to be better protected and emergency planning and social care made more resilient after signing a joint statement showing their commitment to adapt the country to climate change.
The agreement was reached at a Climate Summit hosted by the LGA in response to the impacts identified in the UK Climate Change Risk Assessment 2012, published earlier this year.”

The agreement states that “Councils have a critical role to play in working with partners and communities to plan and ensure the UK is better prepared and resilient to climate change” and that potential activities include:

  • planning for the long term by reflecting climate risks and sustainable development in Local Plans
  • increasing organisational resilience to extreme weather by building climate change risks into corporate risk registers

Read the Defra press release and the full commitment by the LGA, CLG and Defra here.

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Neighbourhood Plans and Renewable Energy

January 2012: An answer to a parliamentary question considering the Localism Act 2011 (which came into  being in November 2011) and its potential to support the development of renewable energy schemes. Not much is revealed…however the Act and Explanatory notes to the Act can be viewed here. Additionally a Plain English guide to the Localism Act’ produced by the Department for Communities (CLG) can be downloaded here. Friends of the Earth have also published a briefing note on ‘Planning and the Localism Act’.

Renewable Energy: 10 Jan 2012 : Column 60W

Roberta Blackman-Woods (MP for the City of Durham) : To ask the Secretary of State for Communities and Local Government what assessment his Department has made of the likely impact upon neighbourhood plans of the Government’s commitment to ensure that renewable sources will generate 15 per cent. of the UK’s energy by 2020.

Greg Clark (Minister for Decentralisation and Cities, CLG): The Localism Act gives communities new powers to plan for the future of their areas through neighbourhood planning. These are powerful new opportunities for communities to shape the development of their local areas.

It is for communities to decide whether they wish to use neighbourhood development plans or orders to deliver energy from renewable sources, provided the plans or orders meet the basic conditions set out in the Localism Act.

Our proposals strike the right balance by ensuring that neighbourhood planning proposals are in general conformity with strategic planning policies, while giving communities the flexibility to determine those issues that are rightly dealt with at community level.

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A new single ‘London Environment Strategy’

5 September 2011: The Localism Bill continues its passage through the House of Lords today, moving to Report Stage. Amongst the many changes proposed in the Bill there is a more modest, but important, clause in the Bill regarding the six environment strategies that the Mayor is currently statutorily required to produce.

Clause 212 of the latest version of the Bill calls for the Mayor to produce a ‘London Environment Strategy’ which “must contain a general assessment by the Mayor of the environment in Greater London, so far as relevant to the functions ofthe Authority or of the Mayor” containing “provisions dealing with the Mayor’s policies and proposals in relation to each of the following matters in relation to Greater London—(a) biodiversity;(b) municipal waste management;(c) climate change mitigation and energy;(d) adaptation to climate change;(e) air quality; and(f) ambient noise.”

Importantly, the Bill goes on to repeal the duty on the Mayor to publish the six separate environmental strategies. Hence it is proposed that all material/policies contained within these six individual strategies will be consolidated into the new single London Environment Strategy. The Communities and Local Government (CLG) Secretary of State may give guidance to the Mayor on the content and preparation of this new strategy and may also give the Mayor direction as to its policies. Also proposed in the Bill is a new power for the London Assembly which is the ability to reject any of the Mayor’s statutory strategies if a two-thirds majority of members vote against publication.

Despite the changes being proposed in the Bill the Mayor stated back in June that the climate change mitigation and energy strategy, the climate change adaptation strategy, the municipal waste strategy – and two further non-statutory environment strategies on business waste and waterall of which are at draft stage –  will all be published by the end of the calendar year.

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Supporting Renewable Energy through Business Rates

August 2011: The issue of how the Government’s proposals for business rate retention by local authorities could help fund sustainable energy initiatives has been highlighted previously on this website, and on 18 July, CLG’s consultation paper, Local Government Resource Review: Proposals for Business Rates Retention sets out the detailed proposals for a new rates retention scheme to replace the current local government finance system. Supporting this consultation paper, the Government has now published eight technical papers exploring in further detail how councils would be allowed to keep locally generated business rates, which should help enable them to borrow against future rate income.

In addition to this potential new investment stream into energy projects, included amongst the technical papers is a specific Government’s proposal to support communities hosting renewable energy projects by allowing them to keep the business rates generated from such projects. The paper covers issues such as:

  • the types of renewable energy that would be covered by the proposals
  • what is meant by a “new renewable energy project”
  • how different scenarios of renewable energy projects would be dealt with
  • who would be responsible for determining whether a project was covered by the scheme and, therefore, not taken into account in the setting of any levy; and
  • how the business rates from a renewable energy project might be split between different authorities in two-tier areas
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New National Planning Policy Framework

26 July 2011: As written about previously, Government yesterday released a draft of its new National Planning Policy Framework (NPPF). This, the Government says, presents a “new, simpler framework for the planning system that safeguards the environment while meeting the need for sustainable growth… replacing the current suite of national Planning Policy Statements, Planning Policy Guidance notes and some circulars …to just 52 pages of policy…and  is a key part of reforms to make the planning system less complex and more accessible, and to promote sustainable growth.”

The Government’s previous detailed guidance document has now been replaced by two paras (152 and 153). The NPPF states that: “… local planning authorities should …recognise the responsibility on all communities to contribute to energy generation from renewable or low-carbon sources… consider identifying suitable areas for renewable and low-carbon energy sources, and supporting infrastructure, where this would help secure the development of such sources… identify opportunities where development can draw its energy supply from decentralised, renewable or low carbon energy supply systems and for co-locating potential heat customers and suppliers. “

This is a draft NPPF, and a series of questions on the proposals set out in it are in the accompanying consultation document, including six specific questions on energy (14c-f,  and QB 4,5). The deadline for responses is 17 October 2011.  A consultation workshop in London is to be held on 7 September 2011. Further details are in:
CLG’s press release, a NPPF summary, the Draft NPPF, and the
NPPF Consultation document, and finally the
NPPF Impact assessment.

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Planning Guidance on Energy and Climate

18 July 2011: A leaked version of the Government’s forthcoming draft national planning policy framework (NPPF) has been reported on by Planning journal (you need to register to view the article). The NPPF is scheduled to get its proper release sometime later this month, following an announcement back in December 2010 where Planning Minister Greg Clark stated that Government would undertake a review of planning policy, designed to consolidate policy statements, circulars and guidance documents into a single concise National Planning Policy Framework (the Minister’s statement in the House of Commons gives some further background).

This consolidation was needed, it was argued, as “We have over 1000 pages of policy and guidance that have made the planning system unclear and burdensome. This creates vast amounts of paperwork and bureaucracy that burdens developers and limits the power of local people to shape their neighbourhoods around their vision. The new framework will integrate our current suite of policy statements and guidance into a single concise document. It will focus on the Government’s key priorities for planning and help deliver a more effective, decentralised system.”

Now, just ahead of the 2010 general election, the (previous) Government had released a draft of its new guidance to planning authorities on climate change. This version had significantly evolved and improved on the 2007 version, especially in relation to decentralised energy policy. It’s unclear how much of this will survive in the NPPF – the report on the leaked version summarises guidance on climate and energy issues only as:

Climate change Councils should plan for new development in locations and ways that reduce greenhouse gas emissions.

Renewables Authorities should give significant weight to the environmental, social and economic benefits of renewable or low-carbon energy projects, whatever their scale.

which isn’t that much to go on…. hopefully there will be a lot more in the final NPPF when it’s finally released…

On a related issue, the NPPF will not be covering planning in relation to major infrastructure projects such as power stations. A series of Energy National Policy Statements published by DECC on 23 June 2011 cover these. With their emphasis on – broadly – larger generating plant and associated infrastructure – it’s unclear how much impact the NPSs will directly have with respect to planning rules around new energy developments in London.

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Energy Efficiency Findings from the English Housing Survey 2009

5 July 2011: The detail behind the 2009 English House Condition Survey Headline Report published by CLG in February 2011,  has today been set out in the English Housing Survey: Housing Stock Report 2009, which involved surveying 17,042 households  between April 2009 and March 2010.

Chapter 6 of the report assesses the energy performance of the housing stock in terms of its energy efficiency and CO2 and sets out some interesting findings including that:

  • The energy efficiency (SAP) rating for the housing stock is 53 points  in 2009.
  • Some 15% of all dwellings were in the lowest Energy Performance Certificate Energy Efficiency Rating Bands F and G (SAP less than 39).However, whilst 19% of private rented and 16% of owner occupieddwellings were in Bands F or G, only 6% of all social rented dwellingswere similarly banded.
  • By 2009, half of all dwellings with cavity walls had cavity wall insulation. Solid wall insulation was far less common: only 2% of dwellings with non-cavity walls had external insulation, and almosthalf of these were in the social rented sector.
  • Only 41% of dwellings with lofts had at least 150mm of loft insulation in 2009,
  • In 2009, around a quarter (24%) of all dwellings had either acondensing or condensing combination boiler compared to only 2% in2003. Some 29% of all boilers were less than three years old although the same proportion of boilers were at least 12 years old.
  • Some 2% of dwellings had some form of solar panel system (either photovoltaic panels for micro generation of electricity or solar water heating panels) in 2009.

Chapter 7 goes on to consider the ‘energy improvement potential‘ and concludes:

  • In total 19.3 million dwellings (86% of the housing stock) could benefit from at least one of the cost effective improvements recommended through the Energy Performance Certificate (EPC).
  • The measure that could benefit the largest number of dwellings was replacing the existing conventional central heating boiler with a condensing unit (13.4 million).
  • Generally, private rented dwellings were the most likely to be able to benefit from lower cost improvement measures. The oldest stock was not necessarily the most likely to benefit from cost effective measures because many of these older dwellings have been improved over the years.
  • The average cost of carrying out cost effective improvements would be around £1,400 per improved dwelling.
  • If all cost effective improvement measures were installed, the mean energy efficiency (SAP) rating for the stock as a whole would rise by10 points to 63.
  • On the basis of this energy efficiency rating methodology, the improvement would equate to a potential 22% reduction in heating,lighting and ventilation costs of average fuel bills for households (at constant prices), CO2 emissions falling on average by 1.4 tonnes/year across the whole stock and a total saving of 32 million tonnes/year of CO2 (or 24% of total emissions accounted for by the housing stock).
  • If all cost effective improvement measures were installed, the percentage of dwellings in EPC Energy Efficiency Rating Bands A to C would more than double to almost 40% of the housing stock and the percentage in the least efficient Bands E to G would fall by more than half to 18%.

Unfortunately no breakdown for London or any other regions where these surveys were undertaken is provided. However, a lot of interesting stuff to get through here- and much more in the chapters. The fact that replacing older boilers with newer condensing models was identified as the “measure that could benefit the largest number of dwellings” it seems a bit of an oversight of Government not to have any programme in place (now that the Boiler Scrappage Scheme has now stopped (at least in England) and that the  Warm Front programme is soon to be wound up) to accelerate the take up of higher efficiency boilers. Additionally, the Green Deal, starting in October 2012,  does not include boiler replacement within the measures it will cover.

A breakdown of the statistics behind the report are presented in the English Housing Survey Housing Stock Summary Statistics Report 2009 and a summary of the findings are set out in English Housing Survey Bulletin: Issue 4, both of which were also published today.

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Energy Performance of Buildings Quarterly Data

20 May 2011: CLG release of ‘Code for Sustainable Homes and Energy Performance of Buildings: Cumulative and Quarterly Data up to March 2011‘ . Contains code certification data and SAP ratings of new homes being built. Data is available in the spreadsheet posted at link for London.

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