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How is the Energy Hierarchy set to change in the new London Plan?

With the London Plan due for its next update towards the start of 2020 and a draft consultation of changes already outlined, how might the new London Plan affect your next development?

The current version of the London Plan requires an on site carbon reduction target of 35% and already encourages developers to consider the energy hierarchy:

  • Be Lean: Reduce energy demand
  • Be Clean: Supply energy efficiently
  • Be Green: Use renewable energy

These steps dictate construction specifications, in some instances the development layouts and of course, the build cost. Considering what we know from the draft consultation, how are these steps set to change in 2020 when the new London Plan looks to come into force?


Be Lean

The Be Lean step of The London Plan Energy Hierarchy aims to encourage developers to design in a way that reduces the energy demand of a development. All Energy Strategies need to demonstrate how energy efficiency measures reduce the energy demand. In the new draft, there are two major changes to the criteria that demonstrates compliance in this step:

1. Introduction of construction emissions into the Energy Hierarchy

Under the current London Plan, only operational carbon emissions are included in our assessments. That’s the ongoing energy consumption and associated carbon emissions of a development once it is completed and occupied.

The new plan proposes that energy and emissions from the construction of the development are included in the energy hierarchy. This could include energy used by plant machinery, including energy guzzlers like tower cranes, along with site facilities and possibly the emissions from transport to and from site. Embodied emissions could also be included, being the emissions associated with the manufacture of the materials used in a development.

It’s not clear from the consultation what will and won’t be included at this stage, but what is certain is that by just including emissions from site machinery and site cabins, the total carbon emissions measured under the energy hierarchy will increase significantly. Bearing in mind that major London development also needs to be Zero Carbon, this will also increase the carbon offset required from a developer. For the introduction of construction carbon emissions to be measured consistently and fairly across London, the GLA will need to provide robust and clear guidance on how to assess construction carbon emissions, otherwise interpretation and inconsistency will reign.

2. The introduction of a minimum performance target

Under the current Plan, a development must meet the 35% carbon reduction on site, through a combination of measures. However, there are no specific performance standards for each tier of the hierarchy so get to the 35% reduction, however you can. The new plan proposes a minimum 10% reduction in carbon emissions for residential development and 15% for non-residential.

These minimum standards will require uplifts in fabric standards, including glazing specifications, lower air permeability targets and improved building services efficiency, which will likely include MVHR on the vast majority of residential schemes moving forward. Ultimately this will have an impact on build cost and will also present some challenges on heavily glazed buildings, with high heat loss.


Be Clean

Once a development has met the minimum carbon standard under Be Lean, developers must then consider how to provide heat and energy to a development. This means connecting into an existing district heating network where possible or providing an on site communal heat network.

The main policy driver behind this requirement is to futureproof London’s developments. This means that because a single energy centre could potentially serve thousands of homes, large scale heating system upgrades can be completed without replacing individual heating systems.

At present, the preferred technology of choice is combined heat and power (CHP), which generates space heating and electricity from a single gas fired engine. The New London Plan is introducing a revised heating hierarchy, which requires alternative technologies to be considered before assessing the viability of CHP. These include fuel cells, heat pumps, waste heat or other low carbon heat sources. This is not to say that CHP will not be a viable option moving forward, more that the GLA are trying to drive innovation and encourage technologies that don’t use fossil fuels. With the opportunity to use new technology there is also an inherent risk of the unknown, and many developers will prefer to stick to what they know unless they have no alternative.  

The Plan will also require developments to demonstrate that they will not have a negative impact on local air quality and CHP engines will require NOx mitigation to be acceptable. With this technology already on the market, we don’t envisage this to be an issue, although capital costs may well increase.

With significant changes to how we reduce energy demand and heat our homes under the new London Plan, you’ll need to understand how these could affect your next major London development. This will be particularly important if you’re not expecting to submit for planning permission until early 2020. Get in touch with us for a free Due Diligence review of your next site – we’ll review the Local Planning Authority policy and advise you of the potential costs and considerations for the scheme under the new London Plan.


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Stuart Clark

Author: Stuart Clark

This article was published by Stuart Clark on 24.09.2018.