Tag Archives: London Plan

Merton Rule comes in for criticism

July 2012: Established by Housing Minister Grant Schapps, the Local Housing Delivery Group recently published its review of planning and also local standards in new housing development. The news release sets out that “With the reduction in central planning guidance and the forthcoming abolition of regional housing targets, the role of local authorities in planning for new homes becomes even more critical and the new National Planning Policy Framework (NPPF) poses a challenge for them to develop Local Plans which are both sustainable and viable.”

The Group has produced an interim report: A Review of Local Standards for the Delivery of New Homes. It concludes that there is “significant scope for simplification of the standards regime and recommends an urgent Government-backed review and consolidation of existing local housing standards to ensure they meet the aspirations of local communities without undermining viability.”

As such, the report looks at four key areas of standards that apply to new housing, and have included in their consideration requirements related to energy. The Group have come out critical to the ‘Merton Rule’ and similar mechanisms established by local authorities to drive the use of renewable energy through planning, stating:

“The Merton Rule was the first local planning policy to set a requirement on renewable energy for certain types of new development. It was named after the London borough that established it in 2003.

The rule required any new residential development of more than 10 units, or any commercial building over 1,000 square metres, to generate at least 10% of its energy needs from on-site renewable energy equipment in order to reduce its reliance on the National Grid and to reduce its CO2 emissions. Compliance with the policy was required as a condition of planning consent.

About half of the UK’s local authorities introduced a Merton-type rule. It also became part of national planning guidance through PPS 22.  However, the variations on the Rule have now become confusing:

  • Sometimes the targets are expressed as a percentage of energy generated (measured in kW hours).
  • Sometimes the targets are around a decrease in CO2 instead (measured in tonnes of CO2e). Some local planning authorities “expect” a developer to achieve a 10% reduction through use of micro-renewables, others “require” 20%reductions or more.
  • There are frequently different thresholds for when the policy is required – often 1,000 square metres or 10 units, but sometimes no threshold.
  • About half of all planning authorities have no policy on this issue at all.”

The 2004 London Plan (the Mayor’s spatial planning strategy for London) also had a similar type of renewable energy requirement for new development, but this has been amended over time to set instead carbon reduction targets for new development in line with the Government’s  zero carbon target for new homes by 2016. Go to the www.zerocarbonhub.org for more information on the 2016 target and read an earlier post for details on the Mayor’s current planning and energy requirements. Further information on the London Plan, including links to earlier version of the Plan, can be found on its wikipedia page here.

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Climate Change Advice to Planners

March 2012: The UK-GBC Green Building Guidance Task Group has created a number of documents to help Local Planning Authorities (LPAs) and the new neighbourhood forums to “understand sustainability issues, to ensure they achieve a balance between requiring robust sustainability standards but also ensuring development remains viable.” Notes produced cover issues on climate change adaptation, climate change mitigation and energy. Download notes from UKGBC website here.

Other useful resources for planners include:

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Monitoring the impact of London Plan Energy Policies

January 2012: The regional spatial strategy for London – the London Plan 2011 – contains a number of key sustainable energy and carbon requirements which developers must comply with when submitting planning applications for new developments in London.  Chapter 5 of the London Plan specifically addresses London’s Response to Climate Change and sets out the following policy requirements:

  • Policy 5.2 -Minimising  carbon emissions – which sets out a range of CO2 emission targets  for new developments which must be achieved through a hierarchy of ‘Be lean: use less energy; Be clean: supply energy efficiently and Be green: use renewable energy
  • Policy 5.5 – Use Decentralised Energy Systems which amongst other issues requires boroughs to develop energy master plans for specific decentralised energy opportunities
  • Policy 5.7Renewable Energy – where major development proposals should provide a reduction in expected emissions through the use of on-site renewable energy generation, where feasible.

The GLA yesterday published the latest in a series of reports providing analysis of CO2 emissions saved in relation to new developments as a result of the implementation of the London Plan’s policies.

The analysis demonstrated that substantial projected CO2 savings were secured  through implementation of London Plan energy policies in 2010 (ie the the London policies will result in buildings – when completed – which will  be less carbon intensive than requirements otherwise set out in national building regulations). Specifically:

  • average CO2 savings of 33 per cent per development over and above a baseline of a 2006 Building Regulations Part L compliant development including unregulated energy
  • a reduction of approximately 50 per cent in regulated CO2 emissions beyond the minimum requirements of 2006 Building Regulations (excluding unregulated energy)
  • The largest CO2 reductions were due to energy efficiency (EE) and combined heat and power (CHP), with a smaller saving due to renewable energy

Read the full report here. Previous London Plan energy monitoring analysis can be seen here and here.

* ‘Unregulated energy’ relates to those areas not covered by Part L of the building regulations (which is concerned with energy and emissions). These include energy used by appliances, lifts, cooking etc.

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London Plan Energy & Climate Policies

26 July 2011: After close to two years of consultation, London’s new spatial strategy has been published by the Mayor. The London Plan  forms part of the development plan for Greater London and London boroughs’ local plans need to be in general conformity with the London Plan. Its policies guide decisions on planning applications for new developments and strategies by councils and the Mayor. Chapter 5 of the strategy focuses on London’s response to climate change and building on previous versions of the London Plan (2004 and 2008), which achieved a significant impact on the carbon efficiency of new development, the new London Plan sets out a number of requirements. These include:

  • CO2 savings of 25 per cent more than national building requirements at a minimum on all new developments
  • As previously, all major development should provide detailed energy assessments on how these emission savings are to be made
  • In contrast to the Government’s recent climb-down in its definition of ‘zero carbon’, London Plan Policy 5.2Da requires energy assessments to include separate details of unregulated emissions and proposals for how these emissions are to be reduced
  • When preparing LDFs boroughs should identify opportunities for reducing CO2 emissions from the existing building stock, and also identify and establish decentralised energy network opportunities.
  • With the aid of the London Heat Map, boroughs should develop energy master plans for specific decentralised energy opportunities.

Further policy requirements for decentralised energy systems, renewable and innovative energy technologies and the overheating and cooling of buildings are also set out in the Plan.

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London Plan- Monitoring Energy and Carbon

7 February 2011: The London Plan Annual Monitoring Report has been published which provides information on two key per performance indicators of interest:
KPI 22: Reduction in CO2 emissions – which sets out a useful table showing a time series of sectoral emissions in London from 1990 to 2008, however, in relation to newer data the AMR states “No new data are available since the last AMR was published, with the most recent measurement of London’s CO2 emissions being the 2008 London Energy and Greenhouse Gas Inventory (LEGGI). It is anticipated that data on carbon dioxide emissions will in the future be published annually, but two years in arrears given the analysis required. Information for assessing the 2010 benchmark will therefore only be available in 2012.”
KPI 23: Increase in energy generated from renewable sources – the AMR states that “No new data have been collected in the last two years” but “The GLA has commissioned a new study that will investigate the potential for renewable energy and
also provide updated figures on the amount of current generation in London (the ‘London Renewable and Decentralised Energy Potential Study’).”

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GLA Guidance on Planning Energy Assessments

1 October 2010: The GLA’s Guidance on Planning Energy Assessments provides detail on addressing the London Plan’s energy hierarchy through the provision of an energy assessment to accompany strategic planning applications. The purpose of an energy assessment is to demonstrate that climate change mitigation measures are integral to the scheme’s design and evolution, and that they are appropriate to the context of the development.

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Mayor’s Draft Replacement London Plan

12 October 2009: The London Plan includes proposed revisions to the Mayor’s energy and climate policies in relation to planning as well initial indications of renewable energy potential and targets in London (Table 5.1 Targets for installed energy capacity generated from renewable).

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