Design and sustainability - Further guidance

Policy SI.2.C of the London Plan requires all developments of 10 or more homes to be net zero-carbon. This must include at least a 35% reduction in on-site carbon dioxide emissions against Part L 2013 of the Building Regulations, of which there must be at least a 10% reduction from energy efficiency measures. Any shortfall in emissions to net-zero must be paid into the borough’s carbon offset fund.

The Mayor’s Energy Hierarchy - ‘Be Lean, Be Clean, Be Green, Be Seen’ - is set out in Policy S1.2.A of the London Plan. The Energy Hierarchy should inform the approach to achieving the minimum 35% reduction against Part L 2013. ‘Be Lean’ prioritises efficiency of the building fabric and other energy efficiency measures minimising the overall energy demand of the building. Of the minimum 35% on site reduction, a minimum of 10% should be achieved by building fabric and energy efficiency measures.

Investment partners must demonstrate, through an Energy Assessment, that on-site carbon emission reductions have been maximised with a minimum 35% reduction in on-site carbon dioxide emissions against Part L 2013 being achieved, and confirm the offset payment that will be made to the borough to cover any shortfall to net zero.

Read the GLA Energy Planning guidance, which includes guidance on undertaking an Energy Assessment.

Policy SI.2.F of the London Plan requires all referable development proposals to calculate whole life-cycle carbon emissions through a nationally recognised Whole Life-Cycle Carbon Assessment and demonstrate actions taken to reduce life-cycle carbon emissions.

Whole Life-Cycle Carbon emissions are the carbon emissions resulting from the materials, construction and the use of a building over its entire life, including its demolition and disposal. A Whole Life-Cycle Carbon Assessment provides a true picture of a building’s carbon impact on the environment.

Investment partners must demonstrate, through a Whole Life-Cycle Carbon Assessment, the life-cycle carbon emissions of the development, a comparison against the GLA’s benchmarks and actions taken to reduce life-cycle carbon emissions.

Read the GLA Whole Life-Cycle Carbon Assessments guidance, which explains how the assessment of these carbon emissions should be approached and presented, and includes a Whole Life-Cycle Carbon Assessment template which partners are expected to use.

Policy SI.2.A.4 of the London Plan requires all developments of 10 or more homes to monitor, verify and report energy performance for at least five years post-construction.

Monitoring the actual operational energy performance of buildings and comparing this with early design estimates will enable the industry to work towards bridging the ‘performance gap’ between their design and actual energy use, helping to achieve truly net zero-carbon buildings.

Investment partners are required to submit data to the GLA’s 'Be Seen' monitoring portal at the planning stage, as-built stage and for at least five years post construction.

Read the GLA 'Be Seen' Energy Monitoring guidance, which explains the ‘Be Seen’ stage of the Energy Hierarchy set out in the London Plan, and includes the 'Be Seen' reporting template which partners are expected to use.

Policy SI.1.B.2.a of the London Plan requires all developments of 10 or more homes to be at least Air Quality Neutral.

An Air Quality Neutral development is one that meets, or improves upon, the air quality neutral benchmarks published in guidance from the GLA. The benchmarks set out the maximum allowable emissions of NOx and Particulate Matter based on the size and use class of the proposed development.

Investment partners must demonstrate, through an Air Quality Assessment, that developments are at least Air Quality Neutral. This assessment must indicate potential pollutant sources and how these can be mitigated against, to assess the proposed developments impact on air quality.

See the Air Quality Neutral LPG  for information on the  Air Quality Neutral benchmarks for buildings and transport. 

The GLA does not publish guidance on Air Quality Assessments. However, industry best practice is set out in the Planning for Air Quality guidance provided by the Institute of Air Quality Management. Read the GLA Air Quality Positive guidance, which explains explains how to apply the air quality positive approach to large scale developments.

Policy G5.B of the London Plan requires all developments of 10 or more homes to meet relevant borough Urban Greening Factor target scores or, where none exist, the interim score of 0.4 set out in the London Plan.

The Urban Greening Factor is a tool which uses a simple calculation to assess the amount and quality of new urban greening provided by a new development. To calculate the Urban Greening Factor, each surface type in the development is given a factor score, which is multiplied by the area of that type of cover. The full method is set out in detail in the new London Plan and Table 8.2 sets out the assigned factors for different types of cover.

Read the GLA Urban Greening Factor guidance, which provides guidance on how to apply the Urban Greening Factor to proposed developments.

Policy SI.4.B of the London Plan requires all developments of 10 or more homes to demonstrate, through an Energy Strategy, how they will reduce the potential for internal overheating in accordance with the cooling hierarchy.

Overheating mitigation should be considered at the early stages of design development. Investment partners must demonstrate, through an Energy Assessment, the results of dynamic overheating modelling and how they will reduce the potential for internal overheating in accordance with the cooling hierarchy, which is as follows:

1. Reduce the amount of heat entering a building through orientation, shading, high albedo materials, fenestration, insulation and the provision of green infrastructure
2. Minimise internal heat generation through energy efficient design
3. Manage the heat within the building through exposed internal thermal mass and high ceilings
4. Provide passive ventilation
5. Provide mechanical ventilation
6. Provide active cooling systems

Read the GLA Energy Planning guidance, which includes guidance on identifying and mitigating potential overheating risk.

This exemption recognises that there will be schemes bid through the AHP 2021-26 that are at varying stages through the planning process, which may mean that it is not possible to meet all of the design and sustainability funding criteria. The acceptable Planning exemption scenarios are detailed in the table below:

Planning exemption guidance

Category P1 – this is a blanket exemption for all design and sustainability standards. Please state the date of validation, and the date of the decision notice in the text box on OPS, and attach the relevant documentation to support this exemption request.

Category P2 – within the text box on OPS, detail what conditions are contained in the decision notice, or obligations contained within the S106 that impede compliance with the relevant design and sustainability standards. Please attach the relevant documentation to support this exemption request. The text submitted on OPS should provide detail on the unachievable standards with an explanation of why they cannot be met, and evidence to support this. This is not a blanket exemption.

Category P3 - either present a record of the pre-app meeting and /or the stage 1 report from the GLA where referable, with supporting evidence of date of planning submission, for example a Planning Performance Agreement (PPA) agreed between the Partner and the Local Planning Authority. This exemption is for schemes at an advanced stage of design, and have undergone advanced pre-application discussion, with Partners on-track to submit a planning application by 1st July 2021 latest. Please detail the unachievable standards and explain why they cannot be met. This is not a blanket exemption.

This exemption recognises that there will be schemes bid through the AHP 2021-2026 that are located in sensitive heritage contexts, and this may give rise to material factors mean that it is not possible to meet all of the design and sustainability funding criteria.

Partners need to provide strong and convincing evidence, corroborated by heritage experts and/or the Local Planning Authority, to explain why any design and sustainability standards cannot be feasibly met, due to heritage reasons. Heritage exemption guidance

Evidence may be contained within a Heritage Statement, a Planning Statement, the Planning Committee/delegated planning report, or a representation by Historic England, or other relevant heritage body. Please refer to and include relevant information to allow Area Teams to assess.

Alongside the evidence submitted, Partners should provide a supporting explanation to set out why certain elements of the design and/or sustainability criteria cannot be met. The text explanation submitted on OPS should provide detail on the unachievable standards with an explanation of why they cannot be met, and evidence to support this. This is not a blanket exemption.

This exemption recognises that a small number of schemes bid through the AHP 2021-2026 may already be built, prior to the introduction of new planning policy and this programme, which will mean that it is not possible to meet all of the design and sustainability funding criteria.

Off the Shelf exemption guidance

Homes under the two Off the Shelf categories above will need to be entered under this route to count under this exemption; no other definition of Off the Shelf will be able to rely on this exemption. Supporting information, such as planning information, is required for new build private for sale homes proposed to be converted to an affordable tenure on projects that were built without the need for grant coupled with a supporting note to confirm these are eligible to be considered off the shelf and therefore exempt.

Projects that comprise the refurbishment of non-residential properties bought off the shelf will be counted as new supply and not be eligible for reliance on this exemption.

This exemption recognises that there will be schemes bid through the AHP 2021-2026 that are for specialist use, or for vulnerable residents and specific design requirements for this use, may mean that it is not possible to meet all of the design and sustainability funding criteria.

Specialist Housing exemption guidance

Partners will need to discuss exemptions in conjunction with the GLA’s Supported and Specialist Housing team and the assumption is that during the bid these discussions will have taken place. Evidence will be required to specify what design or sustainability standard is not possible in general or where the project involves refurbishment or remodelling.

This category caters to a small number of circumstances that are unforeseen or exceptional, which may justify an exemption.

Other exemption guidance

Partners are required to discuss such exemptions with Area Teams, and to clearly explain the reasons why any design or sustainability standards could not be met. Partners are responsible for setting out the case and providing relevant supporting information.

It is envisaged that only a small number of ‘other’ exemptions will be authorised.

Some illustrative examples of potential ‘other’ exemptions, that could be considered acceptable are described in the table below. Partners will need to demonstrate how the quality of the residential units are not compromised, and how compensatory mitigation has been put in place to protect residents’ amenity.

Investment partners in the Affordable Homes Programme 2016-2023 are required to self-certify compliance or non-compliance at practical completion stage only. Compliance with the housing design and sustainability standards is not a contractual requirement within the Affordable Homes Programme 2016-2023.

In 2010 the Mayor published the interim London Housing Design Guide, establishing a common set of housing design standards across all tenures in London. The London Funding Standards Framework applied to the Mayor’s affordable housing investment programmes for 2011-2015 and 2015-2018.

The London Housing Design Guide was implemented through the submission of the London Design Pro-forma at specified stages in the development of funded schemes. Compliance with the London Housing Design Guide was not a contractual requirement within the 2011-2015 and 2015-2018 investment programmes.

The London Housing Design Guide has now been superseded and the London Design Pro-forma is no longer used.