After its initial publication way back in 2017, and after many modifications, the new London Plan came into effect on 2nd March 2021. One of the key directives is the use of Whole Life Carbon Assessments in an endeavour to meet net zero carbon commitments. In this article we look at what the new London Plan means for “Major Referable Projects” and how eToolLCD can be utilised in accordance with the new London Plan.
eToolLCD GLA Approved
Firstly, it is important to highlight that the GLA guidance requires that Whole Life-Cycle Carbon Assessments should be carried out using a nationally recognised assessment methodology. eTool are proud to announce that eToolLCD is one of the tools approved by the GLA. Some of the key benefits to using eToolLCD for your Whole Life-Cycle Carbon Assessments include:
- Detailed support article on how to produce results and fill out the required submission template
- SAP10 and Future decarbonisation grids already available in the software
- All life cycle modules including module D
- Biogenic carbon reported separately (EN15804 +A2 compliant)
- Various end of life scenarios to choose from
- All other software features listed in our subscriptions page
The London Plan – Overview
With an objective of becoming a net zero-carbon city by 2050, the London Plan is the statutory Spatial Development Strategy for Greater London and the 32 London boroughs, and is prepared by the Mayor of London in accordance with the Greater London Authority (GLA). All major projects are required to meet the net zero carbon target and must show an on-site reduction of at least 35 per cent beyond the baseline of Part L of the current Building Regulations.
Below references chapter 9 of the new London Plan, which covers Sustainable Infrastructure (SI). Policies SI 2 and SI 7 are the key policies with regards to the planning process for major developments.
Policy SI 2: Minimise Greenhouse gas emissions
Major development proposals should calculate and minimise carbon emissions from any other part of the development, including plant or equipment, that are not covered by Building Regulations, i.e. unregulated emissions.
Development proposals referable to the Mayor should calculate whole lifecycle carbon emissions through a nationally recognised Whole Life-Cycle Carbon Assessment and demonstrate actions taken to reduce life-cycle carbon emissions.
9.2.11 – Operational carbon emissions will make up a declining proportion of a development’s whole life-cycle carbon emissions as operational carbon targets become more stringent. To fully capture a development’s carbon impact, a whole life-cycle approach is needed to capture its unregulated emissions (i.e. those associated with cooking and small appliances), its embodied emissions (i.e. those associated with raw material extraction, manufacture and transport of building materials and construction) and emissions associated with maintenance, repair and replacement as well as dismantling, demolition and eventual material disposal). Whole life-cycle carbon emission assessments are therefore required for development proposals referable to the Mayor (more information on referable applications below).
Major non-referable development should calculate unregulated emissions and are encouraged to undertake whole life-cycle carbon assessments. The approach to whole life-cycle carbon emissions assessments, including when they should take place, what they should contain and how information should be reported, will be set out in guidance.
Policy SI 7: Reducing waste and supporting the circular economy
Referable applications should promote circular economy outcomes and aim to be net zero-waste. A Circular Economy Statement should be submitted, for all major projects to demonstrate:
1) How all materials arising from demolition and remediation works will be re-used and/or recycled
2) How the proposal’s design and construction will reduce material demands and enable building materials, components and products to be disassembled and re-used at the end of their useful life
3) Opportunities for managing as much waste as possible on site
4) Adequate and easily accessible storage space and collection systems to support recycling and re-use
5) How much waste the proposal is expected to generate, and how and where the waste will be managed in accordance with the waste hierarchy
6) How performance will be monitored and reported
Under the requirements of the London Plan, any major developments that fall under a specific criterion require a referral to the Mayor of London. The criteria include schemes of 150 homes or more. They will also cover projects over 100,000 square metres in the City of London, 20,000 square metres in central boroughs or 15,000 square metres in outer boroughs.
Buildings that are over 25 metres in height within the Thames Policy Area, 150 metres in height elsewhere in the City of London and 30 metres in height elsewhere in London will also be referable.
When to submit a Whole Life-Cycle Carbon Assessment
Whole Life Carbon Assessments should cover the development’s carbon emissions over its life-time, accounting for both operational and embodied carbon and any future potential carbon emissions ‘benefits’, post ‘end of life’, including benefits from reuse and recycling of building structure and materials. (as mentioned in London Plan Policy SI 7 ‘Reducing waste and supporting the circular economy’).
The GLA guidance on Whole Life-Cycle Carbon Assessments follows the European Standard for measuring building performance – EN 15978 and the also RICS Professional Statement: Whole Life Carbon assessment for the built environment. It is also prudent to mention that RIBA (Royal Institute of British Architects) have also adopted the RICS Professional Statement (more information can be found in this paper by RIBA).
Planning applicants are required to submit a WLC assessment at the following stages:
General information about the project site and a questionnaire with details of the Whole Life-Cycle Reduction principles.
- Stage 1 submission (i.e. RIBA Stage 2/3)
A baseline WLC assessment should cover the entirety of modules A, B, C and D to comply with Policy SI 2. With regards to grid decarbonisation , applicants should provide two sets of WLC emission figures. The first set of figures will be based on the current status of the electricity grid, and the second set of figures should be based on the expected decarbonisation of the electricity grid over the lifetime of the development. Details on material type, quantity and end of life scenarios are also required.
- Post-construction (i.e. upon commencement of RIBA Stage 6 and prior to the building being handed over, if applicable)
Update of the information provided at planning stage and actual WLC results using material quantities and site emissions during construction. Generally, it would be expected that the assessment would be received three months post-construction.
A Whole Life-Cycle Assessment draft guidance and draft template is currently under development which comprises all of the information applicants will need to submit at each stage. This template should be completed and submitted to the GLA to ensure clarity and transparency.
How eToolLCD can be utilised to conduct Whole Life-Cycle Carbon Assessment in accordance with the new London Plan
- eToolLCD provides users the ability to produce models at concept stage and provide early design advice (see this article on Target Setting)
- eToolLCD benchmarks available in the software library to assist the design team during the concept stage.
Planning submission stage
- WLC Assessment Reporting Template – At eTool, we have reviewed the WLC Assessment reporting template and have prepared an eToolLCD to GLA WLC Report Spreadsheet to help our users populate the results for Assessment 1 and Assessment 2 at the Outline Planning and Detailed Planning stages.
- EN 15978 – eToolLCD is fully compliant with BS EN 15978 including all life cycle stages A, B, C and D.
- RICS – eToolLCD allows consultants to adhere to the application of the RICS Whole of Life Carbon Assessment for the Built Form professional statement. The following link gives a detailed summary of the “Must” requirements from the standard and associated detail on eToolLCD’s compliance.
- Grid Decarbonisation – eToolLCD users can now calculate the operational impact of their projects considering the future decarbonisation of electricity grids
- Scenarios – The Scenarios feature allows branching of design improvements. It gives the user the ability to define the starting point for the scenario and explore different routes for project changes. For example, understanding the difference from using Blast Furnace Slag versus Fly Ash as cement replacement in concrete. The benefit of this feature is the flexibility to model design strategies in parallel from different starting points, instead of a linear sequential order where an improvement is fully dependent on all previous changes. As the design progresses, the model can be adjusted with the appropriate starting point scenarios and the subsequent strategies can be considered, instead of having to remodel all recommendations again from the baseline design.
- Design features – Advanced features will allow you to quantify, compare and improve the performance of your projects from early design stage through to detailed development. The following link will explain in further detail some of the advanced features in eToolLCD such as Templates, EPD, Bulk Swap, Recommendations recording and Analysis.
- Materials Inventory Summary Report – quickly extracts material type and quantity to help fill out the reporting template.
- eToolLCD Automated Reporting – Understand the modelling results at different stages of the life cycle design process through eToolLCD automated reporting functionality.
How eToolLCD can be utilised to support Policy Sl 7: Reducing waste and supporting the circular economy, in accordance with the new London Plan.
- Materials Efficiency Metric – The eToolLCD Materials Efficiency Metric was created to calculate material circularity and apply it to a whole asset analysis. The metric is calculated based on the mass of material that is virgin or reused, and the amount of renewable and non-renewable primary and secondary material.
The draft “Whole of Life Cycle Carbon Assessment Guidance”, was formally consulted at the beginning of 2021. Responses are currently being analysed, with final guidance due to be published later this year. eTool will release further information regarding this topic and what it means for eToolLCD users as the final guidance is released.
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