Tackling Climate Change in the London Plan

A roundtable discussion hosted by Siemens

Delegate Pack

Arrival

The Crystal, 1 Siemens Brother Way, London, E16 1GB

The Crystal is on the waterfront, at the western end of the Royal Victoria Dock in East London. It is easily accessible by public transport. The nearest railway station is Docklands light Railway Stations by Canning Town, Royal Victoria and Custom House. The nearest underground stations being accessed by the Jubilee Line are Canning Town and North Greenwich.

Date: Wednesday, 21th February 2018 Time: 18:00 – 20:30

Venue: The Crystal, 1 Siemens Brothers Way, Royal Victoria Dock, London, E16 1GB

What it's About London Sustainability Exchange is inviting you to a roundtable discussion of the up-coming London Plan. This is the second of two discussions regarding the London Plan, which will focus on section two, three and five of Sustainable Infrastructure: Minimis-ing Greenhouse Gas Emissions, Energy Infrastructure and Water Infrastructure.

Aims

Discuss the released draft of the London Plan and what we as a community feel is missing or needs to be altered.

Propose what should be taken into consideration when passing on our com-ments.

Connect with like-minded people. Contribute to shaping the vision for the future of London.

Participation

This roundtable event discussion will include both public and private sectors.

Agenda

Contact details

For more information please contact Nelly Defaut at N.Defaut@lsx.org.uk or 020 7234 9400

20:25

19:55

20:10

20:25

19:55

20:10

Key note speaker: Dr. Prashant Kumar

Round up and Next steps – Leonie Cooper

Perspectives on London Plan

by Mark Jenkinson - Siemens

James Higgins – SGN

Alex Nickson – Thames Water (tbc)

Lynne McDonald – UKPN

Key note speaker: Dr. Prashant Kumar

18:30

18:00 Registrations and Welcome, with complimentary Wine and snacks

Networking 20:00

19:15

Q&A Session

(Samantha Heath to Chair)

19:00

18.00

Round up and Next steps – Leonie Cooper

Debate amongst the Delegates

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20:30

Energy& Water in the new London Plan

Dear delegate,

You can refer to the draft new London Plan document and make your

comments online here: https://www.london.gov.uk/what-we-

do/planning/london-plan/new-london-plan/draft-new-london-plan/

How to comment online:

1. Register - you'll receive a confirmation email 2. Log into and select Draft New London Plan at the top 3. Find the section you'd like to comment on - you can comment

on images and tables as well as the text 4. Click the Comment button on the right and add your comments 5. If your comment does not relate only to a single section, use the

'Comment on this page' button at the top of the page 6. Your comments will automatically submit at 5pm on Friday 2

March 2018. You can edit them at any time up to this point

The current 2016 consolidation Plan is still the adopted Development

Plan. However the Draft London Plan is a material consideration in

planning decisions. It gains more weight as it moves through the

process to adoption. However the weight given to it is a matter for the

decision maker. The draft of the new London Plan is currently out for

consultation until the 2nd of March 2018.

What is being said in the new London Plan?

The concept of Good Growth – growth that is socially and economically

inclusive and environmentally sustainable – underpins the Plan and

ensures that it is focused on sustainable development. There is an

indication that energy, water, heat and gas emissions management are

included in the new plan. It sets out an integrated framework for the

development of London through to 2041, and although energy, water,

heat and gas emissions management does feature in a number of

policies, there is some way to go before developers bring it on board.

This document contains some of the key policies with our tracked changes and addition comments.

Policy SI 2 Minimising greenhouse gas emissions

Policy SI 2 Minimising greenhouse gas emissions A. Major development should be net zero-carbon. This means reducing carbon dioxide emissions

from construction and operation, and minimising both annual and peak energy demand in ac-cordance with the following energy hierarchy:

1. Be lean: use less energy and manage demand during construction and operation. 2. Be clean: exploit local energy resources (such as secondary heat) and supply energy effi-

ciently and cleanly. Development in Heat Network Priority Areas should follow the heating hierarchy in Policy SI3 Energy infrastructure.

3. Be green: generate, store and use renewable energy on-site. B. Major development should include a detailed energy strategy to demonstrate how the zero-

carbon target will be met within the framework of the energy hierarchy and will be expected to monitor and report on energy performance.

C. In meeting the zero-carbon target a minimum on-site reduction of at least 35 per cent beyond Building Regulations [117] is expected. Residential development should aim to achieve 10 per cent as a minimum and aim to achieve 20 percent, and non-residential development should aim to achieve 15 per cent as a minimum and aim to achieve 25 per cent through energy efficiency measures. Where it is clearly demonstrated that the zero-carbon target cannot be fully achieved on-site, any shortfall should be provided:

1. through a cash in lieu contribution to the relevant borough’s carbon offset fund, and/or 2. off-site provided that an alternative proposal is identified and delivery is certain.

D. Boroughs must establish and administer a carbon offset fund. Offset fund payments must be ring-fenced to implement projects that deliver direct greenhouse gas reductions. The operation of off-set funds should be monitored and reported on annually.

E. Reduce Performance Gap - all new developments will include provision for post occupancy evalua-tion. Developments not complying with agreed energy saving targets will be required to comply with offsetting procedures.

F. The Mayor may will publish further planning guidance on sustainable design and construction [122] and will continue to regularly update the guidance on preparing energy strategies for major development. Boroughs are encouraged to request energy strategies for other development pro-posals where appropriate.

[117] Building Regulations 2013. If these are updated, the policy threshold will be reviewed

LSx additional comments on SI 2 A. While the Energy Hierarchy is a good strategy and zero-net-carbon development was present in

the previous 2011 London Plan (with a target of 2016, Policy 5.2 minimising carbon dioxide emis-sion) and to date has not been achieved. How can we ensure that the same strategy will produce better results going forward?

1. Be Lean: Reduction by design 2. Be Clean: Punitive measures or the introduction of a levy (similar to Stamp Duty) should be

used to further encourage developers to use renewables 3. Be Green: 35% reduction is not zero.

There is considerable body of work outlining the process for post occupancy evaluation. This is an important element in the design cycle and will provide valuable information for all sites moving forward. Recent developments in the Internet of Things (IoT) will assure that monitoring information is accurate. Sites that do not meet agreed energy saving should be considered to be included in the offsetting procedures.

Chapter 9

9.2.5 - To meet the zero-carbon target, an on-site reduction of at least 35 per cent beyond the

baseline of part L of the current Building Regulations is required[119]. The

minimum improvement over the Target Emission Rate (TER) will increase over a period of time in

order to achieve the zero-carbon London ambition and reflect the costs of more efficient

construction methods. This will be reflected in future updates to the London Plan.

Comment: In the current London Plan this threshold was made explicit (see be-low). This new London Plan does not clearly outline by how much the TER will be raised across time to reach the 2050 zero carbon target.

9.2.7 - The price for offsetting carbon [120] is regularly reviewed. Changes to the GLA’s

suggested carbon offset price will be updated, in future guidance. New development is

expected to get as close as possible to zero-carbon on-site, rather than relying on offset fund

payments to make up any shortfall in emissions. However, offset funds do have the potential to

unlock carbon savings from the existing building stock through energy efficiency programmes

and by installing renewable technologies – typically more expensive to deliver in London due to

the building age, type and tenure.

Comment: This does not prevent stop the overuse of offset funds by developers who would rather ‘pay’ to pollute and sidestep the ‘Be Green’ element of the ‘energy hierarchy’ to reach the 35% carbon reduction target (this can be found in figure 9.2 – pyramid).

9.2.10 The Mayor may will publish further planning guidance on sustainable design and construction [122] and will continue to regularly update the guidance on preparing energy strategies for

major development. Boroughs are encouraged to request energy strategies for other development proposals where appropriate.

[122] - This will build on the 2014 Sustainable Design and construction SPG.

Comment: There should commit to the review and revise the SPG on Sustainable Design & Construction to support the implementation of the new London Plan &London Environmental Strategy.

Policy SI 3 Energy Infrastructure

Policy SI3 Energy Infrastructure A. Boroughs and developers should engage at an early stage with relevant energy compa-

nies and bodies to establish the future energy requirements and infrastructure arising from large-scale development proposals such as Opportunity Areas, Town Centres, other growth areas or clusters of significant new development.

B. Energy masterplans should be developed for large scale all development locations which establish the most effective energy supply options. Energy masterplans should identify:

1. major heat loads (including anchor heat loads, with particular reference to sites such as universities, hospitals and social housing)

2. heat loads from existing buildings that can be connected to future phases of a heat network

3. major heat supply plant 4. possible opportunities to utilise energy from waste 5. secondary heat sources 6. opportunities for low temperature heat networks 7. possible land for energy centres and/or energy storage 8. possible heating and cooling network routes 9. opportunities for futureproofing utility infrastructure networks to minimise the

impact from road works 10. infrastructure and land requirements for electricity and gas supplies 11. Implementation options for delivering feasible projects, considering issues of pro-

curement, funding and risk, and the role of the public sector. C. Development Plans should:

1. identify the need for, and suitable sites for, any necessary energy infrastructure requirements including upgrades to existing infrastructure

2. identify existing heating and cooling networks and opportunities for expanding existing networks and establishing new networks.

D. Major development proposals within Heat Network Priority Areas should have a commu-nal heating system

1. the heat source for the communal heating system should be selected in accord-ance with the following heating hierarchy:

a. connect to local existing or planned heat networks b. use available local secondary heat sources (in conjunction with heat

pump, if required, and a lower temperature heating system) c. generate clean heat and/or power from zero-emission sources d. use fuel cells (if using natural gas in areas where legal air quality limits are

exceeded all development proposals must provide evidence to show that any emissions related to energy generation will be equivalent or lower than those of an ultra-low NOx gas boiler)

e. use low emission combined heat and power (CHP) (in areas where legal air quality limits are exceeded all development proposals must provide ev-idence to show that any emissions related to energy generation will

be equivalent or lower than those of an ultra-low NOx gas boiler) f. use ultra-low NOx gas boilers.

2. CHP and ultra-low NOx gas boiler communal or district heating systems should be designed to ensure that there is no significant impact on local air quality.

3. Where a heat network is planned but not yet in existence the development should be designed for connection at a later date.

LSx additional comments on SI 3 A. Development plans should include potential areas in the map to expand existing net-

works and establish new networks.

Comment: The provisions in SI3 focuses solely focus Energy Master Plans for large scale developments. This should be expanded to include all developments. The main thrust of this New London Plan is to include provision for small sites, therefore it is important to include small sites in the development of a heat network. Stakeholders should collaborate with the relevant stakeholders to devise local energy plans that foster district heating networks for existing and future smaller scale development schemes. Heat Networks are applicable to site larger than six dwellings. The commentary in the document should refer to existing masterplans such as the Islington Master Plan (https://www.london.gov.uk/sites/default/files/energy_masterplan_for_london_borough_of_islington.pdf). This will provide guidance to boroughs and developers on what an energy masterplan could look like. Energy masterplans should include provision for renewables and energy storage in order to assure that the entire grid has power capacity required by new developments. It is essential in the transition that all new developments are connected to gas in order to assure affordability of fuel.

Energy Infrastructure

9.3.1 The Mayor will work with boroughs, energy companies and major developers to promote

the timely and effective development of London’s energy system (energy production,

distribution, storage, supply and consumption).

Comment: There is no mention of infrastructure investment in technology and data. For example, IoT (Internet of Things) and Smart City Solutions are initiatives being implemented by other cities to optimise energy, transportation and logis-tics among others.

9.3.3 - Developments should connect to existing heat networks, wherever feasible. Stimulating

the delivery of new district heating infrastructure enables the opportunities that district heating

can deliver to be maximised. The Mayor has identified Heat Network Priority Areas, which can

be found on the London Heat Map website [123]. These identify where in London the heat

density is sufficient for heat networks to provide a competitive solution for supplying heat to

buildings and consumers. Data relating to new and expanded networks will be regularly

captured and made publicly available.

[123] https://www.london.gov.uk/what-we-do/environment/energy/london-heat-map

Comment: The useful tool in the link above gives data on policy indicators (such as so-cial density fuel poverty rates etc.) yet the map only focusses on heat network priority areas & how London can satisfy future heat demand based on existing demand. Like in the Water Infrastructure chapter (9.5.7) there needs to be a proposal somewhere that mentions the measures required to alleviate fuel poverty (alongside future develop-ments in infrastructure.) This is supported by our LES consultation.

9.3.11 - Land will be required for energy supply infrastructure including energy centres. These

centres can capture and store energy as well as generate, supply and distribute it. The ability to

efficiently store energy could reduce overall energy consumption, reduce peak demand and

make renewable energy more effective.

Comment: This does not specify what land or an existing policy/plan that is ensuring energy storage. Potential future risk on building these on the green belt.

Policy GG6 Increasing efficiency and resilience

Policy GG6 Increasing efficiency and resilience To help London become a more efficient and resilient city, those involved in planning and development must:

A. Seek to improve energy efficiency and support the move towards a low carbon circular econ-omy, contributing towards London becoming a zero carbon city by 2050.

B. ensure buildings and infrastructure are designed in line with the revised SPG on Sustainable Design and Construction) which will include guidance on to adaptation to a changing climate, making efficient use of water, reducing impacts from natural hazards like flooding and heat-waves, and avoiding contributing to the urban heat island effect. Also should include proce-dures for post construction evaluation. Failure to comply with agreed standards in the post construction evaluation will result in fees being paid in line with the offsetting procedure.

C. create a safe and secure environment which is resilient against the impact of emergencies in-cluding fire and terrorism.

D. take an integrated approach to the delivery of strategic and local infrastructure by ensuring that public, private, community and voluntary sectors plan and work together

LSx response, comments & recommendations (GG6) A. Zero carbon city is a misleading term as it’s not referring to producing zero CO2 emissions

but to reduce them by 35% (target extended to be met by 2016) and actually zero carbon 2019-2050 (Sustainable Design and Construction SPG).

These targets have been also extended from the ones originally proposed. Initially 35% was to be achieved by 2016 (for non-residential buildings), currently is 2019. Also the zero carbon targets were initially year 2031 and have now been set for year 2050.

What can be done to prevent further extensions to these targets unless they are to actually improve emission standards?

What organisations are involved in defining these targets? What process and pa-rameters are being followed to define them to establish that they are achievable but at the same time stringent enough?

D. There are not behavioural/educational programmes being implemented or agreed by the energy sector to address an integrated approach that involves the public and communities.

Policy SI4 Managing heat risk A. Development proposals should minimise internal heat gain and the impacts of the urban heat is-

land through design, layout, orientation and materials. B. Both major and small development proposals should demonstrate through an energy strategy

how they will reduce the potential for overheating and reliance on air conditioning systems in ac-cordance with the following cooling hierarchy, which is set out in the SPG on Sustainable Design & Construction:

1. minimise internal heat generation through energy efficient design 2. reduce the amount of heat entering a building through orientation, shading, albedo, fen-

estration, insulation and the provision of green roofs and walls 3. manage the heat within the building through exposed internal thermal mass and high ceil-

ings 4. provide passive ventilation 5. provide mechanical ventilation 6. Provide active cooling systems.

LSx additional comments on SI4 A. More details will be required in order that developers can assure appropriate design. As with SI2,

targets should be given. All the relevant active, passive and design measures should be clearly signposted as specified by the 2014 SPG for Sustainable Design and Construction (p.37.)

B. Given Policy H2 that “Small Sites“ should play a greater role in housing, S14 Managing Heat Risk should not apply exclusively to major developments where this does not conflict with H7 “Afford-able Housing”

Offsetting options should be also included in the cooling hierarchy as a ‘last resort’ similarly to SI 2.

Policy G5 Urban Greening

8.5.2b Urban greening covers a wide range of options including, but not limited to, street trees,

green roofs, green walls, and rain gardens. It can provide a range of benefits including amenity

space, enhanced biodiversity, addressing the urban heat island effect, sustainable drainage and

amenity – the latter being especially important in the most densely developed parts of the city

where traditional green space is limited.

Comment: Policy G5 (B) Urban Greening Factor (Table 8.32) should also take account of “heat risk reduction” achieved through such measures in the scoring factor.

Policy GG6 Increasing Energy Efficiency and Resilience

Policy GG6 (A). To help London become a more efficient and resilient city, those involved in

planning and development must: seek to improve energy efficiency, reduce heat risk and

support the move towards a low carbon circular economy, contributing towards London

becoming a zero carbon city by 2050.

Comment: Heat risk reduction should be included in Policy GG6

Policy SI5 Water infrastructure A. In order to minimise the use of mains water, water supplies and resources should be protected

and conserved in a sustainable manner. B. Development Plans should promote improvements to water supply infrastructure to ensure securi-

ty of supply. This should be done in a timely, efficient and sustainable manner taking energy con-sumption into account. Designs standards set out in the SPG for Sustainable Design and Construc-tion should be met.

C. As a minimum, development proposals should: 1. minimise the use of mains water in line with the Optional Requirement of the Building

Regulations (residential development), achieving mains water consumption of 105 litres or less per head per day (excluding allowance of up to five litres for external water consump-tion)

2. achieve at least the BREEAM excellent standard (commercial development) 3. be encourage to incorporate measures such as smart metering, water saving and recy-

cling measures, including retrofitting, to help to achieve lower water consumption rates and to maximise future-proofing.

4. Where these are not possible on the site the principles of offsetting procedures will be fol-lowed.

D. In terms of water quality Development Plans should: 1. promote the protection and improvement of the water environment in line with the

Thames River Basin Management Plan, and should take account of Catchment Plans 2. support strategic wastewater treatment infrastructure investment to accommodate Lon-

don’s growth and climate change impacts. Such infrastructure should be constructed in a timely and sustainable manner taking account of new, smart technologies, intensification opportunities on existing sites, and energy implications. Boroughs should work with Thames Water in relation to local wastewater infrastructure requirements.

E. Development proposals should: 1. seek to improve the water environment and ensure that adequate wastewater infrastruc-

ture capacity is provided be designed to ensure that misconnections between foul and sur-face water networks are eliminated and not easily created through future building altera-tions.

2. be designed to ensure that misconnections between foul and surface water networks are eliminated and not easily created through future building alterations.

LSx additional comments on SI5 The relevant water saving appliances and retrofits for future proofing for both residential and commercial developments should be signposted. These could include low water fixtures such as dual flush toilets, waterless urinals and tap aerators (2014 SPG Sustainable Design & Construction P.57.)

9.5.6 Infrastructure investment is constrained by the short-term nature of water companies’

investment plans. Similar to the approach to electricity supply (see also paragraph 9.3.8), in

order to facilitate the delivery of development it is important that investment in water supply

infrastructure is provided ahead of need. To minimise wastage, water supply infrastructure

improvements should give consideration to the replacement of ageing trunk mains.

Comment: Very much producer, led no promise by network operator to ensure this investment is made

9.5.7: In the context of the significant investment needed, measures to protect and support

vulnerable customers in particular from rising water bills are important.

Comment: The specific measures required to address the both income and non-income causes of water poverty/precocity must be clarified, as well as de-lineating the (mandate/responsibility) of water operators/providers to ensure that vulnerable customers are actively engaged with critical advice, finance and support.

Policy D2 Delivering Good Design

E. Design and access statements submitted with development proposals should provide relevant information to demonstrate the proposal meets the design requirements of the London Plan including SPG such as the SPG on Sustainable Design and Construction. .

F. Boroughs and applicants should use design review to assess and inform design options early in the planning process. Design review should be in addition to the borough’s planning and urban design officers’ assessment and pre-application advice. Develop-ment proposals referable to the Mayor must have undergone at least one design review early on in their preparation, before a planning application is made, if they:

1. are above the applicable density indicated in Part C of Policy D6 Optimising housing density; or

2. propose a building defined as a tall building by the borough (see Policy D8 Tall buildings), or that is more than 30m in height where there is no local tall build-ing definition.

G. The format of design reviews for any development should be agreed with the borough and comply with the Mayor’s guidance on review principles, process and management, ensuring that:

1. design reviews are carried out transparently by independent experts in relevant disciplines including sustainability experts

2. design review comments are mindful of the wider policy context and focus on interpreting policy for the specific scheme

3. where a scheme is reviewed more than once, subsequent design reviews refer-ence and build on recommendations of previous design reviews

4. design review recommendations are appropriately recorded and communicated to officers and decision makers

5. schemes show how they have considered and addressed the design review rec-ommendations planning decisions demonstrate how design review been ad-dressed.

Comment: The SPG for Sustainable Design and Construction should be re-ferred to in the policy statement This will not only alert developers and de-signers to the expectation that sustainability must be built into all designs, but it will ensure that the SPG has status and is material in planning consid-erations. Design panels can often include the sustainability element – the design panel in the Lee Valley for the 2012 games included a sustainability panel, which proved to be extremely effective.

D4 Housing Quality and Standards

9. A minimum of 5 sqm of private outdoor space should be provided for 1-2 person dwell-ings and an extra 1 sqm should be provided for each additional occupant. This does not count

towards the minimum Gross Internal Area space standards required in Table 3.1. 10. The minimum depth and width for all balconies and other private external spaces should

be 1.5m. E. Residential development should maximise the provision of dual aspect dwellings and

normally avoid the provision of single aspect dwellings. A single aspect dwelling should only be provided where it is considered a more appropriate design solution to meet the requirements of Policy D1 London’s form and characteristics than a dual aspect dwelling and it can be demonstrated that it will have adequate passive ventilation, daylight and privacy, and avoid overheating.

F. The design of development should provide sufficient daylight and sunlight to new hous-ing that is appropriate for its context, whilst avoiding overheating, minimising overshad-owing and maximising the usability of outside amenity space.

G. Dwellings should be designed with adequate and easily accessible storage space that supports the separate collection of dry recyclables (for at least card, paper, mixed plas-tics, metals, glass) and food.

H. Dwellings should be designed with adequate and accessible drying space to ensure that laundry can be dried comfortably without causing condensation within the home, and without the requirement for energy intensive drying mechanisms.

The Mayor will produce guidance on the implementation of this policy including an SPG on Sustainable Design and Construction, for all housing tenures.

Comment: Additional space will be required for drying as well as storage of recyclates. Condensation within the home caused by drying laundry is one of the major contributions to poor air quality within the home.