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The London Plan switches to SAP 10 – will this end CHP dominance in the capital?

The GLA’s changes – coming into force in January – are set to end CHP dominance in the capital. Jon Ponting from the Energist Technical Team explains why.

The Greater London Authority (GLA) has surprised many in the construction industry by announcing changes to the London Plan; starting this January.

The seemingly small adjustments will change how developers invest in heating systems on large projects, and without so much as a fanfare to announce these changes, many could be caught out by this policy change.

Meanwhile, the London Plan is currently going through a major rewrite, which isn’t due to go live until the end of 2019 or later.

These latest announcements apply to the current London Plan which means sites currently getting ready to go into planning will need to follow the new guidance. It’s primarily focused on ‘referable’ schemes (which is the bigger housing developments), however the changes are being encouraged on smaller sites also.

The big change is the adoption of SAP10 emission factors. This will significantly change the result of the SAP and SBEM models which are used in planning strategies.

To unpack what this means we need to rewind to 2012, and the launch of the current Approved Document Part L. This building regulation requires all new homes and businesses to meet a strict Target Emission Rate, based on how much energy is needed for heating, hot water, ventilation and lighting.

The energy use is multiplied by the emission factors of relevant fuel types used (gas, oil, electric, wood) to create the Building Emission Rate. The higher the emission factor of a fuel, the higher emission rate a dwelling will have.

In 2012, the emission factor of electricity was 2.5x higher than gas. This was because of the UK’s reliance on coal power stations.

Six years on and we still use the same set of Building Regulations, which means we still use these emission factors.

In reality, the CO2 associated with the National Grid has plummeted. Every year we are breaking records for energy produced by wind and solar technology, which means the emission factor of electricity is much lower than what Building Regulations suggests.

Earlier this year, the BRE released a draft revision of the SAP calculator. In it, the emission factors were updated, and electricity was shown to no longer be the fly in the ointment. However, with no confirmed date for Part L to change, these emission factors have been left to sit on the shelf.

The GLA has taken the unprecedented move of asking for all new planning submissions to use SAP10 emission factors for calculating energy use, while still using the rest of the current SAP2012 methodology.

Under this adjustment, the use of electricity on site will provide much lower CO2 readings, which means electric heating systems will be more viable than before.

The GLA is still keen to promote District Heating Networks (DHN), but this change means gas is no longer the only contender.

Greener electricity won’t just change the way we assess heating options in our buildings – it also means generating your own energy on site won’t result in as big a carbon offset as we see currently. That could discourage developers from systems such as PV and CHP.

With such a significant change coming into force so quickly, it makes sense to work with a team who are on top of the changes, who commit to your deadlines, and who are ready with the answers.

The Energist Planning Team is on hand to do just that, with a new-look Energy Strategy which fully complies with these London Plan changes.

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 and the new draft Plan proposes 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 focus on zero (on-site) emission heat sources, including waste secondary heat and heat pumps. 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.

A further key consideration driving the use of CHP is the new emissions factors proposed under SAP 10, which the GLA is looking to introduce under new energy planning guidance from January 2019. These emissions factors will more than half the associated carbon emissions from grid electricity, meaning that the carbon emission offset from CHP, will also be halved, making the technology less carbon efficient and ultimately less viable as a solution. On large scale scheme, financial viability of a district heating network may depend on the financial payment from on-site electricity generation, so CHP will still be considered here. However, on smaller schemes we expect a shift towards heat pump lead or hybrid energy centers to comply with the new energy planning guidance.

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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Please note: This article was updated on 2 November 2018 to reflect additional guidance issued.

Introducing the new London Plan

The recent public consultation on the new London Plan revealed the cost of carbon offset payments is set to increase by over 50%, with other significant changes to the London Plan that are likely to have considerable impact on the design of future developments in the capital.

Driving energy efficiency standards above and beyond those set by the building regulations, London has always been at the forefront of sustainable design in the UK. Since its first introduction in 2004, The London Plan has helped shape the future of sustainable development in the capital and has been used by every London Mayor to provide guidance and direction to the individual Boroughs. Over this time, The London Plan has seen several revisions, with the standards outlined gradually becoming more stringent where energy efficiency is concerned; something that is due to become even more challenging with the next revision in late 2019/ early 2020.

What’s changing in the new London Plan?

The current version of the London Plan requires all new build major developments to reduce their carbon emissions by 35% over the Building Regulations baseline and achieve the Zero Carbon standard on residential developments. In addition, developers also need to consider district heating, renewable energy, acoustic and air quality concerns, along with broader sustainability issues, such as water consumption and overheating risk. These current standards are certainly no walk in the park, so what impact are the proposed changes likely to have?

The Greater London Authority recently consulted on its proposals for the new London Plan and although the consultation itself was high level, there were some energy and sustainability highlights that are set to change.

Here’s the 9 highlights for energy and sustainability that you need to know:

  • A minimum carbon reduction target to be met through efficient building fabric only
  • A new heating hierarchy, encouraging zero emission solutions for energy supply
  • Increased emphasis on air quality constraints and how this will affect your energy strategy
  • Consideration for energy storage to reduce reliance on the national grid
  • Requirement for all non-domestic developments to meet Zero Carbon
  • Significant increase in the cost of carbon, increased carbon offset payments by over 50%
  • Energy monitoring post-occupation
  • Consideration to future-proofing towards on-site Zero Carbon
  • Life cycle carbon analysis on GLA referable developments

These changes amount to a considerable impact on not only the design of your development, but also on the cost. With a scheduled introduction of 2019/ 2020, these standards could well apply to your next development, especially if you’re expecting a long lead-time on land purchase and planning submission. While there are still plenty of unknowns and missing details at this stage, the Examination in Public, scheduled for Winter 2018/early Spring 2019, should fill in some of this detail.

What can you do?

In the meantime, it’s important to be aware of the potential future requirements and, most importantly, the costs associated with the new London Plan. With some of the key highlights for energy and sustainability set to have a considerable impact, what can you do now to prepare and help reduce future costs?

Our team of Technical Specialists work on major London schemes daily and with a thorough understanding of the public consultation are identifying potential solutions now for the latest set of challenges. Over the coming weeks we will explore the changes in more detail with a focus on how the new London Plan will affect you and the new cost of Zero Carbon.

If you would like to understand what these changes will mean for you, then contact our team of specialists who will be happy to help.


Please note: This article was updated on 2 November 2018 to reflect additional guidance issued.

The Top 10 Things You Need to Know About Planning in London

The London Plan targets have a huge impact on both design and build costs for new developments and need to be addressed before submitting a planning application.

Here’s our Top 10 summary of what you need to know:


1. The on-site Carbon Target

The London Plan requires that a major new build development improves on the carbon target in the Building Regulations by 35% on site. This means efficient building services and enhanced building fabric, impacting your layouts and design.

2. The Zero Carbon Target

London boroughs are now asking developers to meet a Zero Carbon target for residential developments, and although possible, it is rarely achieved on site. Carbon Offset Payments are used to compensate for not reaching a Zero Carbon target and the money raised is invested into local green projects. The payments can be considerable so make sure you’re aware of the impact.

3. Noise considerations

In London it’s hard to avoid the noisy environment and almost 2.4 million people in the capital are already exposed to noise levels that exceed international guidelines.1 If you are building near an underground station, railway line or busy road, you may need to commission an acoustic survey. Although not part of building regulation requirements, it will likely be requested by the local planning authority and will affect your overheating and ventilation strategy.

4. Overheating risk

In the summer, London can be up to 10°C warmer than the rest of the country2 and the risk of overheating is therefore much higher. Overheating leads to uncomfortable and sometimes unhealthy internal temperatures and the London Plan will require thermal modelling to ensure that a building’s design minimises this risk.

5. Local Variations

Are there additional requirements that have been requested by your borough? Although the London Plan has been adopted by all boroughs, individual councils have the power to set tougher targets in their own planning documents if they consider there is a local need for more stringent targets. It’s always best to check what is expected before submitting a planning application.

6. Natural Daylight

With tightly packed buildings emerging in the densely populated capital, ensuring that your building will receive ample levels of daylight can be a challenge. Equally, the construction of your building may negatively impact a neighbour’s access to sunlight. The use of 3D modelling can help to show the daylight and sunlight impact.

7. District Heating and Combined Heat and Power

As part of the London Plan Energy Hierarchy, energy must be supplied efficiently to a development. This can either be achieved by connecting to a District Heat Network (DHN) or installing on-site Combined Heat and Power (CHP). However, the viability of these will be assessed depending on the type and size of the development and whether is network is available in the area.


Most London Boroughs require a BREEAM Assessment on non-residential developments. Credits are based on up to 52 different considerations ranging from site waste management and responsibly sourced materials, to ecological improvements and transport links. BREEAM needs to be considered from day one, so it’s vital to appoint an approved assessor early in the planning process.

9. Water Efficiency

The London Plan sets a water efficiency target of 105 litres per person per day and these targets mean you need to consider flow rates as part of the design. This can be achieved by using efficient fittings. If you have a tougher, local requirement, this may push you towards rainwater harvesting systems.

10. Plan Ahead

When you consider all of the above, it becomes clear just how much thought and preparation is needed right from the beginning. You may need to submit reams of reports to the authority before you can put the first spade in the ground. Planning ahead is key to making sure you don’t get caught out later on. It’s never ideal to be forced into making retrospective changes half-way through construction.


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Top Sustainability Tips for Developing In London

The London Plan sets a stringent carbon dioxide emission target: a 35% reduction over the requirements of Part L 2013. This target can influence all aspects of your design so here are our top tips to ensure you don’t fall short of London’s sustainability expectations.

The London Plan sets a stringent carbon dioxide emission target: a 35% reduction over the requirements of Part L 2013. This target can influence all aspects of your design so here are our top tips to ensure you don’t fall short of London’s sustainability expectations.

1. Fabric First

The first tier in the Energy Hierarchy of the London Plan is be Lean; reduce energy demand. Focus on the building fabric, improve insulation and design for air tightness. The greater your reduction in CO2 from building fabric, the less you’ll need to invest in low carbon fuel and renewable energy sources

2. Ventilation

Consider how you’ll ventilate the development. Pollution and noise constraints may force you down the route of whole house mechanical ventilation with heat recovery.

3. Manage solar gain

Make the most of the sun’s rays. Free heat from the sun can greatly reduce a dwelling’s energy consumption and carbon emissions, but it can also lead to a risk of summer overheating. This can be controlled through a combination of appropriate ventilation and the solar gain value (g value) of glazing. You need to strike a balance with the g value to ensure that you reduce the risk of overheating, whilst maximising solar gain. For non-domestic developments with comfort cooling, aim to reduce solar gain to minimise the cooling demand.

4. Consider your heating strategy

The London Plan requires that all apartment blocks and non-domestic developments are provided with some form of low carbon heat network. Will you connect into an existing district heating network, provide site wide Combined Heat and Power (CHP) or regular gas fired community heating? Be careful when sizing your CHP system – too large and the system won’t run continuously meaning you’re not getting maximum return on investment. Once your heating strategy is finalised, you can then size your plant room accordingly.

5. Renewable Energy

Whilst the London Plan assumes a 20% reduction in carbon emissions from renewable energy generation, the overall goal is to meet the 35% reduction over the Part L 2013 standards. Provided you meet this overall target there will likely be flexibility in the amount of renewable energy you need to provide. So focusing on building fabric and low carbon heat sources will reduce any reliance on renewable energy.

6. Carbon offset payments

If it’s not viable or feasible to meet the 35% reduction on site, then consider a carbon offset payment to the Local Authority. The standard cost is £60 per tonne over a 30 year period, but check with the Local Authority as some set their own cost of carbon. You may have to go down this route for large houses where compliance with Part L 2013 can be challenging. Smaller developments that cannot utilise CHP are also likely to have to explore this route.

7. Any other requirements?

Many London Borough’s will also require additional sustainability standards to be met; Code for Sustainable Homes for residential developments (if they were granted planning permission after 31st March 2015), BREEAM for non-domestic developments or BREEAM Domestic Refurbishment for household extensions, including basement developments. All of these standards need to be integrated into your design and must be considered pre-planning.

8. Don’t leave it too late

Before you put pen to paper to design your development, make sure that you’ve checked out the sustainability requirements of your Local Planning Authority and have a plan in place to address them. These standards can no longer be considered as an afterthought and must be considered pre-planning to avoid any costly re-designs and program delays.

Would you like to know more? If you have any concerns about developing in London, please contact us today. We advise you at every stage possible and give you the best possible solutions in your development. We always bring our considerable experience to help you to save money on your build, ring us on 08458 386 387 today.