Policy DE1 requires developers to submit Sustainability Statements and undergo BREEAM assessments or Code for Sustainable Homes for all major developments in the City of London, aiming for BREEAM 'Excellent' or 'Outstanding' or CSH Level 4.
Plain-English summary of the adopted policy text below. The full text is the rule; this is the gist.
Development proposals should follow a retrofit first approach, thoroughly exploring the potential for retaining and retrofitting existing buildings as the starting point for appraising site options.
2. All major development must undertake an assessment of the options for the site, in line with the City Corporation’s Carbon Options Guidance Planning Advice Note, and should use this process to establish the most sustainable and suitable approach for the site.
3. Development proposals should minimise whole life-cycle carbon emissions. Major developments must submit a whole life-cycle carbon assessment.
4. Where new buildings are the most sustainable and suitable approach, they should deliver exemplar low carbon development and the highest environmental sustainability quality, driving forward best practice beyond standard approaches and contributing to wider sustainability improvements in the area.
5. Innovative design, materials, construction, and technologies should be used to deliver highest standards of environmental sustainability.
6. Applicants must ensure that measures to improve environmental performance and mitigate and adapt to climate change have been integrated into the design.
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Circular economy design approaches
7.
Development should be designed to incorporate circular economy principles throughout the life cycle of the building through:
a. Flexible building design to accommodate evolving working and living patterns, reducing the need for redevelopment; b.
Floorspace adaptability to maximise the lifespan of buildings;
c.
Reuse, refurbishment and retention of existing buildings, structures and materials to reduce reliance on virgin resources;
d.
Designing for disassembly, reuse and recycling of deconstruction materials;
e.
Maximum use of recycled materials in development and off-site construction methods to reduce wastage; and
f.
Designs which enable durability, modularity, sharing of goods and services and reuse of supplies and equipment, minimising waste during the building’s operational phase.
Sustainability standards
8. Proposals for major development will be required to:
a. Achieve a minimum BREEAM rating of “excellent” and aim for “outstanding” against the current, relevant BREEAM criteria at the time of application, obtaining maximum credits for the City’s priorities (energy, water, materials, waste and pollution). Climate resilience credit should be achieved for the waste category;
Design b.
Commit to achieving a minimum NABERS UK rating of 5 stars;
c.
Demonstrate that London Plan guidance on carbon emissions and air quality requirements have been met on site. In exceptional circumstances, where standards cannot be met on site, carbon offsetting will be required to account for the shortfall. This will be secured through a S106 agreement with offsetting contributions ring fenced for carbon reduction projects;
d.
Retain existing buildings and structures where feasible to reduce embodied carbon emissions and waste;
e.
Demonstrate climate resilience in building and landscape design;
f.
Incorporate collective infrastructure such as heating and cooling networks, smart grids and collective renewable energy storage (for example batteries) wherever possible, to contribute to a net zero carbon, zero-waste, climate resilient City; and
g.
Prioritise the objectives of the City of London Local Area
Energy Plan (LAEP) to create or link into local energy networks and waste heat sources, and include opportunities for heat and cooling transfer to/from nearby developments.
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Design
Reason for the policy
9.2.0
The factors driving sustainable development are increasing, impacting both global and local businesses as well as workers, residents and visitors. The pace and prestigious nature of development in the City presents opportunities to incorporate innovative design in both new and existing buildings to provide positive environmental outcomes for the City’s priorities:
X Energy, carbon emissions and air pollutants – reducing emissions and moving to a net zero carbon City by 2040, in line with the requirements of the City Corporation’s Climate Action Strategy;
X Water – reducing water use in an area of serious water stress;
X Pollution – reducing exposure to poor air quality;
X Materials – retaining embodied carbon in existing buildings and materials, and improving resource efficiency.
9.2.1
Social and environmental responsibility is high on the agenda for many City businesses and their workforce and a working environment that supports these goals is essential for the City’s future.
9.2.2
The City of London Climate Action Strategy provides evidence for the trajectory to a net zero carbon City by 2040. The role of collective infrastructures such as smart grids, battery storage, heating and cooling networks and hydrogen infrastructure are essential elements in the delivery of the net zero carbon City, where decarbonised electricity that does not contribute to future
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Design local levels of pollution, is the main energy source. Heating and cooling networks will increasingly exploit low carbon energy from waste heat and heat pump technologies rather than fossil fuels and contribute to reductions in primary energy demand, carbon emissions and nitrous oxides. Therefore, connection to these networks is expected wherever feasible. This will also reduce the need for roof top installations such as boiler flues, cooling towers and plant rooms.
9.2.3
As new developments are large consumers of resources and materials, the possibility of sensitively refurbishing or retrofitting buildings should be considered in preference to demolition.
Proposals for substantial demolition and reconstruction should have regard to the whole-life carbon impact, resource and energy use, when compared to the existing building, and must justify why redevelopment and new build is the most sustainable and suitable approach. All development should ensure the reduction, reuse or recycling of resources and materials, and minimise energy use and emissions that contribute to climate change.
9.2.4
The application of sustainability standards through this Plan will contribute to the achievement of the objectives of the City’s Climate Action Strategy, however, guidance in the area of sustainable development is rapidly evolving and applicants should use the most up to date guidance to inform their planning proposals.
9.2.5
The circular economy is an alternative to the typical ‘linear’ way of treating resources. By finding ways of remanufacturing, reusing or recycling materials and keeping them in use for longer, waste can be reduced. The circular economy emphasises design for
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durability and modularity, making better use of under-used assets through sharing and offering products as a service.
Circular economy principles can be applied to buildings and the development cycle, reducing the demand for new materials, and to the operational phase of a building’s life to minimise annual waste arisings.
How the policy works
9.2.6
The approach to retention and/or redevelopment, built form, whole life-cycle carbon and circular economy for the development should be shaped on the basis of the insights derived from the carbon options assessment. Applicants should work collaboratively through the carbon options process to establish the most sustainable and suitable approach for the site.
Applicants should demonstrate that they have taken into account principles of sustainable design and that measures to improve environmental performance and mitigate and adapt to climate change have been integrated into the design.
9.2.7
The requirement for the highest feasible and viable sustainability standards applies to all development in the City, including major new development, extensions to existing buildings, major refurbishments and minor development. Refurbishments of existing buildings are subject to this policy where proposed works constitute development.
9.2.8
Sustainability Statements should be used to provide comprehensive evidence of the sustainability of each development.
Design
9.2.9
For major development the following information should be provided:
X A BREEAM pre-assessment or design stage assessment including a summary of the credits to be targeted in each category. Planning conditions will be used to require submission of a post construction BREEAM certificate to demonstrate implementation of the approved designs, achievement of the City’s priority credits and identify any performance gaps between design and completed development.
X An energy assessment in line with the Mayor of London’s Energy Planning Guidance.
X An options appraisal following the City Corporation’s
Carbon Options Guidance Planning Advice Note to develop a low carbon solution that optimises social, economic and environmental sustainability benefits.
X An air quality assessment to meet the requirements of the London Plan demonstrating that the development will not result in deterioration in air quality, in line with the City of London Air Quality SPD.
X Details of the proposed adaptation and resilience measures to make the building resilient to the climate and weather patterns it will encounter during its lifespan.
X Details of collective infrastructure which has been incorporated to address environmental challenges.
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Design
X Whole life cycle (WLC) carbon assessments in line with the London Plan Guidance and City Corporation’s Carbon Options Guidance Planning Advice Note, fully exploring opportunities to minimise embodied and operational carbon emissions.
Extensions
X If a development proposal includes an extension greater than
25% of the existing floorspace or consists of a distinct structure greater than 1,000sq.m, the extension on its own should be treated as a major development and assessed accordingly, including consideration of London Plan carbon emission targets, carbon options appraisal and BREEAM requirements.
For minor development
X Although minor development may provide more limited opportunities for the incorporation of sustainability features it is important that sustainability is considered at the design stage for all projects. For most minor development inclusion of sustainability information in the Design and Access Statement will suffice.
Circular design approaches
EIA development
9.2.10
For development that requires an Environmental Impact
Assessment (EIA) the Environmental Statement should demonstrate how circular economy principles have been incorporated into the development, fully addressing how Construction, Demolition and Excavation (CD&E) waste will be
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minimised, deconstruction materials will be reused or recycled and the waste arisings during the operational phase of the development will be minimised and managed. This should include consideration of on-site facilities to reduce the need for waste vehicle movements such as on-site composting or anaerobic digestion, or waste consolidation.
9.2.11
A Circular Economy Statement and the WLC carbon assessment following the London Plan guidance should be submitted for all EIA development.
Major development
9.2.12
For all other Major development proposals, the Sustainability Statement should provide evidence of the application of circular economy principles and the adherence to the waste hierarchy. This could include reuse of existing buildings and structures, provision of Site Waste Management Strategies for the construction phase and Zero Waste Plans for the operational stage of the development. Major development should aim to achieve maximum BREEAM credits for Waste.
9.2.13
A Circular Economy Statement following the London Plan guidance should be submitted for all Major development.
All other development
9.2.14
For all other development, the Design and Access statement should demonstrate how waste minimisation and the circular economy have been considered in the design of the development.