Zero Carbon Homes - Changes to the London Plan Requirements

What is the London Plan? The London Plan is the statutory spatial development strategy outlining six core objectives for the Greater London area. First published in 2004, the Plan has been amended and added to. Most relevant to the construction industry is Chapter 5, London's response to Climate Change, which includes requirements for sustainable development within the Greater London area

What's happening to it?

As of October 1 2016, the London Plan requirements for energy statements are changing, with a significant revision to section 5.2 “minimising carbon dioxide emissions”. The adjustment to the policy requires all major developments will be required to be ‘zero carbon' however if this cannot be achieved then a cash in lieu contribution will be sought. In addition to the ‘zero carbon' targets, further emphasis is to be placed on district heating networks and a new requirement to follow the cooling hierarchy, which includes an in depth overheating risk analysis, will be introduced. This blog will focus on the ‘zero carbon' element of the GLA guidance¹ on preparing energy statements.

How will this affect developers?

All major developments within the Greater London Authority (GLA) currently have to submit an energy strategy to comply with policies 5.2 to 5.9 of the London Plan. These policies cover a range of topics including but not exclusive to: sustainable design and construction, decentralised energy networks and renewable energy.

The area most developers are aware of is Policy 5.2 Minimising Carbon Dioxide Emissions, which involves following the energy hierarchy: Be Lean, Be Clean and Be Green. The Be Lean stage requires major developments to meet or exceed Part L of the building regulations through energy demand reduction methods alone. Be Clean requires the viability of district heating and combined heat and power (CHP) systems to be assessed.

The final stage, Be Green, requires a feasibility study for renewable or low/zero carbon technologies to be undertaken with a commitment to reduce CO₂ emissions through onsite generation. The current level of this commitment is to demonstrate a minimum 35% improvement over Part L of the 2013 Building Regulations.

Although the Government announced in July 2015 that it does not intend to pursue the zero carbon homes target at present, it remains in place within the London Plan and will be applied to all major residential developments received on or after October 1 2016. The “zero carbon” target requires the new developments to follow the energy hierarchy as outlined above (still meeting the 35% reduction in CO₂ at the Be Green stage) but with the remaining emissions to be off-set through a cash in lieu contribution to the relevant borough.

These funds will then be ring-fenced to secure carbon dioxide savings elsewhere. The cash in lieu payment is to be £60 per tonne of carbon dioxide for a period of 30 years based upon The Mayor's Housing Standard's Viability Assessment, although this figure can be decided at a borough level.

What will the developers make of this?

First and foremost it is likely to come as a surprise to a majority of developers as there has been very little so far in the way of announcing the ‘zero carbon' targets. The target was included in the updated guidance on preparing energy assessments (March 2016) and has stayed largely unreported.

With developers unaware problems could be caused with planning applications being rejected for not including a strategy on how the target will be met or a calculation demonstrating the cash in lieu contribution. Although the target will lead to increased costs it is unlikely this will lead to development stalling as was one of the major concerns with the governments zero carbon homes target which were scrapped earlier in the year.

This is partly being attributable to the buoyancy of the London property market which isn't seen elsewhere.

Can you give a cash in lieu example?

A carbon offset payment has been calculated for a previously completed project which comprised of 14 residential flats with a combined floor area of 993.50 m². The flats were designed to exceed Part L requirements using individual gas boilers for heating and hot water. Then a 15 kWp solar PV system was installed to achieve a 42% improvement over the Building Regulations standard. 

After the PV at the Be Green stage, the site wide emissions stood at 10.664 tonnes CO₂/year. Assuming the offset price of £60 per tonne, this works out at £640 per year and multiplying the figure to cover the 30 years gives a total of £19,200 to be paid to the Carbon Offset Fund.

What do you make of the changes?

It is pleasing to see the Greater London Authority adhering to previous commitments on carbon dioxide reduction, with viability assessments indicating the “zero carbon” targets will not compromise future housing development. The target is seen as essential to ensure London is ready for the Energy Performance of Buildings Directive introduction of zero energy buildings by 2020.