Creating change in carbon policy – what’s happening in London?
Jonathan Hoban & Nancy Stuart30 Aug 2023
With the recent opposition to the expansion of ULEZ throwing a spotlight on how hard and fast Government can run with progressive climate change policies we examine how London Boroughs are pushing the agenda through local plans.
We have focussed this solely on local plan policies relating to operational carbon because it represents the largest portion of the UK’s Green House Gas (GHG) emissions, and the built environment is one of the biggest contributors.
Why London Boroughs? Well, there is already a plethora of planning policy relating to net zero, largely stemming from the London Plan 2021. If London is a frontrunner, it will give us a good indication of what might follow elsewhere in England.
Those working in London will be aware of Policy SI2 (Minimising greenhouse gas emissions) of the London Plan (2021) which sets the Energy Hierarchy. For operational carbon, the policy targets a minimum on-site reduction of carbon of at least 35% beyond the current Building Regulations Part L[1].
The London Plan (2021) sets strategic policy and the Boroughs then set their own policies, provided they are in general conformity. Given 96% of London Boroughs have declared a Climate Change Emergency, including 33% with targets to achieve Net Zero borough-wide by 2030 (Figure 1), it is clear that London Boroughs want to play a part in tackling climate change. But we wanted to explore whether London Boroughs are using their Local Plans to strive for more than the Building Regulations and the minimum targets set by the London Plan?
Figure 1: Borough wide targets for reaching net zero or carbon neutral
The map below illustrates which London Boroughs have set policies for carbon reductions requiring developers to comply with the London Plan targets, and who is going beyond this benchmark. Using the arrows at the side you can see both the adopted and emerging policy targets.
What is the London Plan policy? Policy SI2 of the London Plan says ‘A minimum on-site reduction of at least 35% beyond Building Regulations is required for major development. Residential development should achieve 10%, and non-residential development should achieve 15% 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, in agreement with the borough, either:
1) through a cash in lieu contribution to the borough’s carbon offset fund, or
2) off-site provided that an alternative proposal is identified and delivery is certain.’
Most boroughs are sticking comfortably with the London Plan when considering adopted and recently adopted plans. This is expected given the lag between the London Plan being adopted and emerging plans coming forward. Southwark is the exception and is aiming for well above the London Plan targets.
When considering the emerging Local Plans, a much more mixed-picture emerges.
Our key findings are:
Out of those boroughs where data is available (24), 11 are targeting becoming zero-carbon boroughs by 2030, 20 years earlier than the Government and GLA goal.
Four adopted Local Plans are above the London Plan requirements (Tower Hamlets, Southwark, Richmond Upon Thames and Sutton). Of these four:
Two (Richmond Upon Thames and Sutton) keep the requirement for a 35% reduction but apply this to minor residential developments as well as major.
Two (Tower Hamlets and Southwark) strive for well beyond the 35% requirement with Southwark seeking a 100% on site carbon reduction.
Seven (Enfield, Bexley, Merton, Kingston Upon Thames, Richmond Upon Thames, and Wandsworth) out of sixteen emerging local plans, are aiming towards more ambitious targets. Of these:
Four (Merton, Richmond Upon Thames, Kensington & Chelsea, and Enfield) are seeking higher on site carbon reductions, with Richmond and Merton seeking the highest, both applying the same standards at 60% for all residential and 50% for all non-residential over 500sqm.
Three (Kingston Upon Thames, Bexley, and Wandsworth) are seeking to be more ambitious by applying the threshold to include minor residential developments as well as major.
100% (Southwark) is the maximum target above building regulations that London Boroughs are targeting.
45% (Enfield and Tower Hamlets) is the minimum operational emissions policy target above the London Plan.
Islington is the only borough with an emerging Local Plan which seeks a lower on-site carbon reduction. At 27% this is eight percent lower than the London Plan target. Ealing does not have a policy target within its emerging plan; however, we expect that as per its adopted plan, a carbon policy will be included in the Regulation 19 draft.
Geographically, there seems to be a pattern emerging where Local Plans in southwest London appear to be more ambitious. When combined with Southwark’s adopted plan, there seems to be a clear pattern working westwards[i].
It is clear from the maps that the majority of the London Boroughs are following the London Plan requirements. However, as emerging plans come forward, some, particularly in the southwest and in some outer boroughs such as Enfield and Bexley are going beyond the London Plan requirements.
Where London Boroughs have gone well beyond the London Plan requirements, such as Tower Hamlets and Southwark, they are explicit that that there is still scope to offset the difference through carbon offset payments. Although Southwark has published a number of planning FAQs advising that applications must still deliver to reductions against the 2021 Part L and securing shortfalls offsite or as a financial contribution should only be used in ‘exceptional circumstances’. Interestingly, we note that Newham state that shortfall payments ‘will only be accepted where it can be demonstrated that the reduction targets are impossible to meet in full on-site’.
Like these, Westminster also requires evidence to be demonstrated before accepting an off-setting payment. However developers in Westminster may be more inclined to deliver the policy requirements onsite in the future, with the LPA currently consulting on it’s new Planning Obligations SPD which proposes to increase its carbon offset payment from £95 to £880/tCO2 over a period of 30 years. This is more than 9 times the price recommended by the Mayor, showing another way in which local boroughs are pushing the climate agenda beyond the status quo.
We would expect this trend of higher targets to continue at a greater pace. What we have noted is that there is limited correlation between those London Boroughs that have declared a climate change emergency and set ambitious targets to become a carbon neutral borough, and how they have translated this into policy. For example, Southwark has set the highest policy targets, and is targeting 2030 to be a carbon neutral borough – earlier than the UK and GLA targets by 20 years.
The Mayor and his policies in the London Plan upped the ante on controlling the impacts of operational carbon from what went before in the Capital, and are ahead of most other towns and cities in England. As Local Plans catch-up with changes at strategic level, a clearer picture is emerging about which boroughs want to be at the vanguard of the climate change agenda and others which are moving their policy bars upwards but within more cautious parameters. The Capital’s policy response to the Climate Emergency that many boroughs have called, is now really starting to take shape. Lichfields has significant knowledge and expertise advising on highly sustainable schemes through the planning system. Please get in touch if you need help navigating planning policy or with one of your developments proposals.
[1] The GLA has confirmed the ‘Part L’ changes to the Building Regulations which came into effect in June 2022[1], will be applied to its policy targets - GLA Part L and the Energy Assessment Guidance 2022 – Cover Note [Energy Planning Guidance | London City Hall
