First it was the City of London leading the charge on adopting a ‘retrofit first’ approach to new development. Then it was Camden. Now Westminster is adopting the same approach.
Retrofit first means retaining and re-using existing buildings before pursuing other development options, including substantial demolition or total redevelopment where retrofit is not viable. Retrofit first involves understanding which development options would have the lowest embodied carbon intensity and operational carbon emissions. A retrofit first approach does not exclude other development options, but retention and re-use is the default position.
There is an increasing focus on the retention of existing buildings, particularly their structures and foundations, which is where most carbon is stored. Such deep retrofitting is a feature of high profile schemes including Fleet House on new Bridge Street in the City where we obtained planning permission for Antenor in January 2023. A similar approach was adopted by the developers of 65 Gresham Street for a mixed use scheme in the City of London, which obtained planning permission in January 2024.
Image credit: HOK Architects
Westminster commenced consultation on its City Plan 2040 at the end of March, with the aim of becoming a ‘retrofit first’ city. It proposes a dedicated policy on the ‘retrofit first’ approach; setting out a priority for the reuse and retrofit of buildings before demolition and redevelopment, and guidance on how different carbon options will be assessed within planning applications. The accompanying ‘
Retrofit First and Reducing Embodied Carbon’ Topic Paper is clear that only GLA referrable schemes are currently required to submit a Whole Life Carbon Assessment, when the cumulative impact of lots of small and medium scale schemes could still be significant. As such, introducing restrictions on demolition, together with clear benchmarks on embodied carbon performance, will have a considerable impact in meeting wider net zero objectives in Westminster.
The City of London was the first authorities to move towards a retrofit first approach when it published its draft
Carbon Options Guidance Planning Advice Note in 2022. It provides a framework within which developers assess and appraise lifetime emissions for different development options; including a deep retrofit, a refurbishment scenario or complete demolition and redevelopment. Developers are required to report, through a standardised dashboard, on how each option would reduce embodied carbon and operational carbon emissions.
This approach standardises carbon reporting at pre-application and planning application stages. The City of London was lauded for taking a pragmatic approach putting retrofitting first but with a clear acknowledgement that it is not always suitable or viable. The City will be consulting on its Regulation 19 Local Plan later this year which will propose a retrofit first policy, requiring all major developments to undertake an options appraisal exploring the potential for retaining and retrofitting, in accordance with the guidance set out in the Carbon Options Guidance Planning Advice Note.
LB Camden was the second to propose a retrofit first policy, through its draft
Regulation 18 Local Plan published earlier this year. Development proposals will be required to undertake a feasibility assessment to demonstrate that retrofit, refurbishment and extensions have been explored before demolition is pursued.
Westminster now follows suit. The
Regulation 19 Local Plan introduces New Policy 43 (Retrofit First- Prioritising Retrofitting Over Demolition) which states that development should adopt retrofitting and retention of existing buildings before considering demolition. Development proposals which involve substantial or total demolition will be required to justify the approach by an appraisal of construction options including refurbishment, retrofit, deep retrofit and newbuild- presenting the carbon costs and public benefits for each. The policy states demolition will be resisted unless certain conditions are met.
The GLA has also taken note. In February 2024, it stated that lessons should be learnt from the City of London on its retrofit first approach in its ‘
Retrofit vs Rebuild’ paper (February 2024). Are we about to see the whole of London becoming a retrofit first city? Clearly it will be some time before the GLA is able to adopt such an approach, as this would need to come through the London Plan Review. In the absence of such a strategic policy and a very loosely worded NPPF, it is clear from the above that London boroughs are now taking matters into their own hands. So, who is next? We examine what is in the pipeline across London below
Other London Boroughs are coming forward with a similar approach. Specifically;
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Ealing, Enfield, Kingston, Merton, Richmond and Tower Hamlets are bringing forward policy or guidance adopting a ‘retrofit first’ approach. Overall, 9 out of 33 authorities (inc. City of London Authority) across London are seeking to adopt a retrofit first approach.
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Bromley, Hounslow and Kensington and Chelsea do not have an emerging policy or guidance coming forward on retrofit first; however, local plan reviews reference the potential for retrofit first principles in future iterations of policy.
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Of the 9 LPA’s with emerging policy or guidance on a retrofit first approach; 3 require submission of a carbon optioneering appraisal of different development options including retrofit, deep retrofit and demolition and redevelopment (City of London, Camden, Westminster).
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The remaining 6 LPA’s emerging policy relies on Whole Life Carbon Assessments. However two LPA’s (Ealing and Enfield) indicate within its draft local plans that further supplementary planning guidance will be prepared on ‘Carbon Optioneering’ methodologies.
We expect more local authorities to follow suit at pace before the London Plan Review picks things up at a strategic level. Underpinned by a desire and need to respond to the challenges presented by climate change in the property sector, retrofitting make sense, as long as it is presented only as a priority, with clear parameters set for when demolition is appropriate.
Many developers assess the relative merits and values of refurbishment versus redevelopment, whether or not they are required to by policy, but retrofit policies will inevitably constrain some developers from doing what they might want to do, and require more upfront detailed design development and appraisal work to be prepared and shared through pre-application processes if wholesale redevelopment is proposed.
For further details of this borough-level research and our experience and insight into this, please do get in touch.
