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How to meet London Plan requirements

Whole Life Carbon Assessments and Circular Economy Statements are now mandatory for large-scale developments in London under the London Plan 2021. Learn what this means for your work and how One Click LCA can help you meet its requirements.

What is the London Plan?

With a vision of creating a net-zero carbon city by 2050, the London Plan is the Spatial Development Strategy for the Greater London region, comprising the City of London and the 32 London boroughs. It’s written by the Mayor of London, Sadiq Khan, and published by the Greater London Authority (GLA). The latest version of the London Plan came into effect in March 2021.

Which sections of the London Plan affect low-carbon construction?

Architects, engineers, sustainability advisers and contractors may wish to start with three core policies. One of which appears in chapter 3 of the plan, which covers Design (D), the other two are part of chapter 9 on Sustainable Infrastructure (SI).

1. London Plan Policy D3: Optimising Site Capacity: A Design-led Approach. This policy states that designs must consider building longevity through the use of appropriate construction methods and materials, as well as incorporating circular economy principles and aiming for high sustainability standards.

2. London Plan Policy SI 2: Minimising greenhouse gas emissions. Whole Life Carbon (WLC) emissions should be calculated for each project via a life-cycle assessment (LCA) and the actions taken to reduce WLC emissions should be demonstrated.  Whole life encompasses both embodied and operational carbon, so an energy simulation and LCA is required. This is mandatory for referable applications,  but it should be noted that GLA guidance on WLC encourages LCA to be done for all projects in London.

3. London Plan Policy SI 7: Reducing Waste and supporting the Circular Economy. This policy sets out the need for circular economy principles to be applied and in a bid to reach net zero-waste goals, requires a Circular Economy Statement to be submitted.

Referable applications

The requirements of the London Plan apply to major developments only, which are known as ‘referable applications’ as these proposals need to be referred to the Mayor of London.

Broadly speaking, referable applications are residential developments of more than 150 units or buildings over 30 m in height and commercial buildings over 2,500 m2. Precise criteria for whether an application is considered referable depend on factors such as whether the proposed development will be located within the City of London, inner London or the outer boroughs, adjacency to the river Thames and whether the proposed site is on green belt land. Your planning consultant can advise on whether your project is referable or not.

Policy SI 2: Minimising greenhouse gas emissions

Policy SI 2 requires that development proposals should calculate whole life-cycle carbon (WLC) emissions through a recognised life-cycle assessment and demonstrate actions taken to reduce life-cycle carbon.

Read the London Plan Guidance on Whole Life Carbon Assessments

IMPORTANT: Although Whole Life Carbon (WLC) assessments are only mandatory for ‘referable’ development proposals, the GLA encourages WLC assessments for ALL new projects in London and boroughs may choose to apply the policy and the guidance to non-referable applications.

What is required under London Plan Policy SI 2?

The GLA defines WLC as including operational carbon (heating, lighting and appliances), as well as embodied carbon from manufacture, maintenance and end-of-life.

The GLA guidance on WLC assessments follows EN 15978 (the European standard for measuring building performance) and the 2017 RICS (Royal Institute of Chartered Surveyors) Professional Statement: Whole life carbon assessment for the built environment (which has also been adopted by RIBA, the Royal Institute of British Architects).

It requires the WLC Assessment to be done in three stages:

  • Pre-application: at this stage no LCA is needed, just a broad outline of the expected emissions.
  • Planning submission: this is the most critical stage, as it can affect whether or not planning is approved. A WLC assessment is needed for each life cycle. Applicants also need to provide two WLC scenarios: one with current energy needs and one based on future energy predictions.
  • Post-construction: this needs to be submitted within three months of project completion using actual as-built data.

How can One Click LCA help you meet the requirements of London Plan Policy SI 2?

One Click LCA has a solution to support each stage of the process.

Pre-application stage

Planning submission stage

  • One Click LCA Building LCA for the UK is based on the RICS  guidance, so you can be confident that your LCA will comply with their standards.
  • One Click LCA’s GLA tool corresponds closely to the GLA Excel spreadsheet, making it much easier to complete.
  • One Click LCA’s eco-design capabilities help designers to see where measures such as using alternative materials (for example with improved insulation) can lower embodied carbon.
  • We will shortly offer a Future Energy Scenarios (FES) database too, enabling you to provide both sets of emissions data, current and predicted.

Post-construction stage

  • With One Click LCA, assessment is easily done by using as-built data in the form of BIM, drawings, and real quantity data.

Policy SI 7: Reducing Waste and supporting the Circular Economy

The new London Plan supports development proposals that apply circular economy principles and aim to be net zero-waste and requires a Circular Economy Statement to be submitted.

The GLA has recognised that half the waste material in London arises from the built environment. Policy SI 7 aims to move away from a linear construction process – where materials are extracted, used and then thrown away at end-of-life – to a more circular one – where materials are retained in use at their highest value for as long as possible and are then reused or recycled, leaving a minimum of residual waste.

Read the London Plan Guidance on Circular Economy statements

What is required under London Plan Policy SI 7?

Referable applications are required to submit a Circular Economy (CE) statement at the following stages:

  • Pre-application (where relevant).
  • Planning application submission (both outline and detailed). At this stage it should be confirmed who will be providing the information at post-construction stage.
  • Post-construction: expected to be submitted within three months of project completion.

The CE statement must include a written report and the CE template spreadsheet, as well as any supporting evidence, such as detailed technical studies or calculations. Compiling the required information is likely to need at least one workshop during the pre-application phase of the development involving at least the planner, developer, design team and sustainability adviser. The CE workshop should then inform design.

The GLA guidance requires proposals to set out how three core circular economy principles will be achieved:

  • Conserving resources, increasing resource efficiency and sourcing sustainably
  • Designing to eliminate waste (and for ease of maintenance)
  • Managing waste sustainably and at the highest value

How can One Click LCA help you meet the requirements of London Plan Policy SI 7?

One Click LCA’s Building Circularity tool can be used as a base for your Circular Economy Statement.

It offers mass-based assessment of building materials and helps you to calculate the amount of reused and recycled materials and determine end of life processes and the benefits to designing for adaptability and disassembly.

Interested in Building Circularity?

Read our introduction to Circular Economy principles in construction design

European Circular Construction - From voluntary to mandatory

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One Click LCA has the GLA seal of approval

The London Plan Guidance requires that assessments should be carried out using a nationally recognised assessment methodology and One Click LCA is proud to be one of the approved tools. One Click LCA can support you through all stages of the submission from pre-application stage to post-construction.

In order to keep global temperature rise under 2 degrees in line with the Paris Agreement, architects and designers need to look beyond operational energy and also address embodied carbon. Both the RICS Professional Statement and the London Plan put this at the heart of carbon reduction efforts and making the shift to a whole life carbon approach is easier with One Click LCA.

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