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The new London Plan – How to meet its requirements

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

Referable applications

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:

  • Pre-application 

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

Pre-application stage

  • 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. 

Post-Construction stage

  •  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.

eTool Webinar (Youtube)

 

References

https://etoolglobal.com/eblog/design/londonplanpolicy/
https://www.london.gov.uk/sites/default/files/the_london_plan_2021.pdf
https://www.london.gov.uk/sites/default/files/wlc_guidance_consultation_version_oct_2020.pdf
http://content.tfl.gov.uk/referable-criteria-mayor-london-order.pdf

 

RapidLCA App for Housing

eTool has recently delivered a new app for rapid life cycle assessment of houses. RapidLCA streamlines the sustainability assessment of lower density residential buildings. It is aligned with ISO standards for Life Cycle Assessment and CEN standards for the sustainability assessment of buildings.

We are extremely excited about this very ambitious project, the goal was to deliver a mobile app that could conduct a comprehensive, standards compliant LCA in under 20 minutes.  Incredibly that’s what we’ve achieved and we think there’s still a lot of room for making even easier and/or faster.

We expect there is a great application at the local government level as well to support planning requirements and decarbonise residential buildings. Because the assessment is performance based and not prescriptive it enables the largest environmental improvement at the lowest capital cost to development applicants (and often lower life cycle costs).

Simply navigate to RapidLCA.com in any browser to access the app.

Download the RapidLCA presentation here.

Please see the below videos that explain the background, showcase the app in action and present a couple case studies:

 

Background:

RapidLCA Demo:

 
 Case study (Land developer) – Witchcliffe Ecovillage:
 
 
  Case study (Local Government) – City of Vincent WA AU:
 
 
 

 

London Plan Policy – Targeting a reduction in building life cycle carbon emissions.

 

In response to the latest Draft London Plan Policy, eTool takes a closer look at the importance of Whole Life-Cycle Carbon Assessments (WLC) and the latest guidance.

Draft London Plan Policy SI 2 sets out a requirement for developments to calculate and reduce WLC emissions. This requirement applies to planning applications which are referred to the Mayor, but WLC assessments are encouraged for all major applications. Guidance has been published to explain how the assessment of these carbon emissions should be approached and presented, and all planning applications referred to the Mayor must include a WLC assessment prepared in accordance with the WLC guidance document.(¹)

National Building Regulations and the Mayor’s net zero-carbon target for new development currently only account for a building’s operational carbon emissions. As methods and approaches for reducing operational emissions have become better understood, and as targets have become more stringent, these emissions are now beginning to make up a declining proportion of a development’s WLC emissions. Attention now needs to turn to WLC to incorporate the embodied emissions of a development.(2)

Whole Life-Cycle Carbon (WLC) emissions are the carbon emissions resulting from the materials, construction and the use of a building over its entire life, including its demolition and disposal. It is widely accepted that a WLC assessment provides a true picture of a building’s carbon impact on the environment.

Applicants should use benchmarks figures provided as a guide for the design team. Projects with higher emissions should discuss design improvements to reduce emissions early in the concept stage. Aspirational targets are encouraged in line with the World Green Building Council reduction of 40% embodied carbon emissions by 2030. 

eTool makes the Office Benchmark model available online for all eToolLCD users, including Open Users, to encourage design teams to engage LCA early in the design process. eTool Benchmark figures are closely aligned with the Policy Benchmarks as detailed below.

TableClick here to create an account and check the model online for more details. eToolLCD Benchmark model available online includes all modules.

What methodology should be used?

WLC assessments should be carried out using a nationally recognised assessment methodology.

In the UK, the recognised framework for appraising environmental impacts of the built environment is BS EN 15978. This standard was adopted for use by eTool since its release in 2011 (this article expands on EN 15978 further: https://etoolglobal.com/eblog/environment/en-15978/ ).

Supporting the BS EN 15978 is the now widely used RICS Professional Statement: Whole Life Carbon assessment for the built environment(3). It is this RICS policy that should be used as the methodology for assessment when developing a WLC assessment for compliance with Draft London Plan Policy SI 2 (this article explains how eToolLCD adheres to the RICS Professional Statement: Whole Life Carbon assessment https://support.etoollcd.com/index.php/knowledgebase/etoollcd-and-rics-whole-of-life-carbon-assessment-for-the-built-environment/ )

Both BS EN 15978 and the RICS Professional Statement: Whole Life Carbon assessment for the built environment, set out four stages in the life of a typical project and It effectively defines the goal, scope and method of the system boundary.

EN-15978-Diagram

A WLC assessment should cover the entirety of modules A, B, C and D to comply with the London Plan Policy SI 2, with a reference study period (assumed life expectancy of a building) of 60 years.

What about materials and products?

With regards to acceptable sources of carbon data for materials and products, there is an emphasis on EPD’s and equivalent datasets in accordance with EN 15804, ISO 21930, ISO 14067, ISO 14025, ISO 14040/14044 and PAS 2050.

When it comes to biogenic carbon from the use of timber, this should be assessed in accordance with Clause 3.4.1 of the RICS Professional Statement: Whole Life Carbon assessment for the built environment, and included within the reported totals for modules A1-A3.

Grid decarbonisation

Figures should be based on the current status of the electricity grid, in order to provide a point in time assessment, however it is also important to consider the possible long term decarbonisation of the grid and how it could impact design decisions. Therefore, a second set of figures should be provided based on the expected decarbonisation of the electricity grid over the lifetime of the development (i.e. 60 years). This should be done in accordance with the ‘National Grid’s Future Energy Scenario: Slow progression’, including in relation to the EPDs of all materials (UK and non-UK, for simplicity)(4)

eTool will continue to work with UK Industry Bodies and working groups to offer our ongoing support on the above subject and guidance relating to Life Cycle Design.

References:

(1)https://www.london.gov.uk/sites/default/files/wlc_guidance_april_2020.pdf
(2) https://www.london.gov.uk/sites/default/files/wlc_guidance_april_2020.pdf
(3) https://www.rics.org/globalassets/rics-website/media/news/whole-life-carbon-assessment-for-the–built-environment-november-2017.pdf
(4) https://www.london.gov.uk/sites/default/files/wlc_guidance_april_2020.pdf
 

LCA in Sustainable Infrastructure

This article provides an insight into the latest sustainability policies and regulations that have integrated the Life Cycle Design approach. Continue reading

LCA and UKGBC Net-Zero Framework

Given the recent movements in the climate justice campaign, the release of UKGBC Net-Zero Carbon Framework in April this year has been very timely. Although we have seen various “net zero” definitions in the UK in the past (such as the scrapped zero-carbon homes targets under building regs over 10 years ago) it feels this time the general idea has more industry backing with 100s of architects, structural engineers and councils formally declaring a climate emergency.

The UKGBC definition is an interim step on the pathway to assessing full life cycle impacts. It introduces embodied carbon in materials (A1-A3), their impacts for transport (A4) and constriction (A5) alongside operational energy (both regulated and unregulated emissions).

ukgbc net zero

Figure1: UKGBC Net Zero Carbon definition (April 2019)

 

Unfortunately, it does not go as far as full LCA yet with the idea that it simplifies the work and encourages uptake. However, module B1-B5 presents a large chunk of CO2e that will be missing from the calculations. Typically B1-B5 can be responsible 500-1000 kgCO2e/m2 over 60 years and ignoring these impacts will lead to good potential design opportunities being missed. Onsite renewables such as PV will be replaced over the life cycle and whilst the energy that they offset will be included in B6 the embodied impacts of their replacements are not. There are plans to increase the scope in future updates and it is encouraging to at least see some level of joined-up thinking between operational energy and construction embodied carbon. This will no doubt drive some improved design outcomes as design teams can assess the relative merits of strategies that impact on both energy and construction impacts such as thermal mass or triple glazing.

Modelling in eToolLCD
There are two choices of dataset groups in eTool currently. Either BRE IMPACT data or eToolLCD default data (regionalised data available for UK, EU, Aus, NZ and USA regions). Both can be used to model net-zero under the current definitions however if future expansions include modules C and D then eTool default data would be preferred.

 

ModuleUKGBC Net Zero ConstructionUKGBC Net Zero OperationalUKGBC Net Zero Whole of Life (Yet to be Finalised)BREEAM 2018 (IMPACT)eTooLLCD
ConstructionA1-3 Product Stage 118698-32  118698-32 118698-32 118698-32
A4 Transport of Equipment and Materials 118698-32  118698-32 118698-32 118698-32
A5 Construction 118698-32  118698-32 118698-32 118698-32
Use StageB1 Products in Use 118698-32 (1) 118698-32 118698-32
B2 Maintenance  118698-32 (1) 118698-32
B3 Repair  118698-32 (1) 118698-32
B4 Replacement  118698-32 (1) 118698-32
B5 Refurbishment  118698-32 (1) 118698-32 (1) 118698-32
B6 Integrated Energy Use 118698-32  118698-32 118698-32 (1) 118698-32
B6+ Non-Integrated Energy Use (Plug Loads) 118698-32
B7 Water Use & Treatment  118698-32 (1) 118698-32 (1) 118698-32
End of LifeC1 Deconstruction & Demolition  118698-32 (1) 118698-32
C2 Transport of Waste Offsite  118698-32 (1) 118698-32
C3 Waste Processing  118698-32 (1) 118698-32
C4 Disposal  118698-32 (1) 118698-32 118698-32
Benefits and Load Beyond the System BoundaryD1 Operational Energy Exports  118698-32 (1) 118698-32 (1) 118698-32
D2 Closed Loop Recycling  118698-32 (1) 118698-32
D3 Open Loop Recycling  118698-32 (1) 118698-32
D4 Materials Energy Recovery  118698-32 (1) 118698-32
D5 Direct Re-use  118698-32 (1) 118698-32

Figure 2: Scope of Carbon Assessments

Below are the impacts in kgCO2e/m2 for a typical medium density office building. (Note B6 energy impacts assume today’s grid (0.25kgCO2e/kWh) applied over the 60 year life cycle. Note the RICS Whole Life Carbon for the Built Environment Professional Statement is provided as a reporting reference, this level of reporting is simple to pull from eToolLCD using our All Impacts Report

Results

Figure 3: Typical medium density low rise office building 

 

Impacts associated with construction represent a third of the total.  This is significantly higher now than in previous years when the UK grid was 0.6kgCO2e/kWh and usually made up 80-90% of life cycle impacts had that the grid has a lower.  However, there is still a large chunk impacts missing from the guidance in the form of replacement and maintenance (B2-B5) which can be 500-1000 kgCO2e/m2.

Once quantified the design team can start to consider strategies, some examples are shown below.  Without strategies, 1.755 tonnes/m2 of CO2e would need to be offset in a typical office. For net zero the cost of implementing these strategies will need to also be weighed up against the cost of purchasing offsets.

Strategies

Offsets come with varying degrees of quality, cast and “additionality” arguments. The offset schemes referenced by UKGBC (Gold standard and Clean Development mechanism) carry a cost of between £0.6/tonne and £14/tonne. In an average office this could result in up to an extra £24/m2 or 1-2% of construction costs. However, the Greater London Authority recommends a price of £60/tonne. It will be interesting to see whether this gives the industry further incentive to implement low carbon strategies (in particular timber) early on in the design process. Furthermore, the onus will be on us LCA practitioners to improve the accuracy of our LCAs with the total kgCO2e figures resulting in a significant increase to net-zero development costs.