City and metropolitan level policy
Devolution of climate change policy and target setting to a regional or local authority level, has largely remained voluntary in the UK. However spurred on by the Localism act of 2011 there has been a number of bottom up initiatives, such as the Nottingham Declaration, where a number of UK local authorities in 2000 pledging to tackle climate change at the local level.
A number of the larger city level authorities have also developed distinct and autonomous planning policy arrangements and target setting, most notably in the case of the GLA. Indeed argues that;
‘Capital cities such as London face in an exaggerated form the common urban problem of lacking autonomous control over the resources required to maintain their economic roles and satisfy the social needs of their citizens’
The London Plan
This identification of the unique character and challenges for London and a desire for global leadership, led to the development and revision of a strategic ‘London Plan’. The London plan introduces relatively prescriptive guidelines for the development of Local Development Frameworks (LDF), within the London boroughs.
The London Plan Policy 5.1 includes an overarching target overall reduction in London’s carbon dioxide emissions of 60 per cent (below 1990 levels) by 2025. The Policy 5.2 – Minimising CO2 Emissions, describes that development proposals should make the fullest contribution to minimising carbon dioxide emissions in accordance with the following energy hierarchy: 1. Be lean: use less energy 2. Be clean: supply energy efficiently 3. Be green: use renewable energy These targets are expressed as minimum improvements over the Target Emission Rate (TER) outlined in the national Building Regulations leading to zero carbon residential buildings from 2016 and zero carbon non-domestic buildings from 2019. For Major Developments (above 10 residential units) Residential buildings: Year Improvement on 2010 Building Regulations 2010 – 2013 25 per cent (Code for Sustainable Homes level 4) 2013 – 2016 40 per cent 2016 – 2031 Zero carbon This include a requirement that, major development proposals should include a detailed energy assessment to demonstrate how the targets for carbon dioxide emissions reduction outlined above are to be met within the framework of the energy hierarchy.
The London Plan most recently updated in 2015 is the Spatial Development Strategy for London. Section 5 of the Plan covers the mitigation of, and adaptation to climate change and the management of natural resources.
The carbon dioxide reduction targets should be met on-site. Where it is clearly demonstrated that the specific targets cannot be fully achieved on-site, any shortfall may be provided off-site or through a cash in lieu contribution to the relevant borough to be ring fenced to secure delivery of carbon dioxide savings elsewhere. Policy 5.4 describes retrofitting the environmental impact of existing urban areas through policies and programmes that bring existing buildings up to the Mayor’s standards on sustainable design and construction. In particular, programmes should reduce carbon dioxide emissions, improve the efficiency of resource use (such as water) and minimise the generation of pollution and waste from existing building stock. LDF preparation Within LDFs boroughs should develop policies and proposals regarding the sustainable retrofitting of existing buildings. In particular they should identify opportunities for reducing carbon dioxide emissions from the existing building stock by identifying potential synergies between new developments and existing buildings through the retrofitting of energy efficiency measures, decentralised energy and renewable energy opportunities. Policy 5.6 – Decentralised Energy in Development Proposals Development proposals should evaluate the feasibility of Combined Heat and Power (CHP) systems, and where a new CHP system is appropriate also examine opportunities to extend the system beyond the site boundary to adjacent sites. Major development proposals should select energy systems in accordance with the following hierarchy: 1. Connection to existing heating or cooling networks 2. Site wide CHP network 3. Communal heating and cooling. Policy 5.7 – Renewable Energy The Mayor seeks to increase the proportion of energy generated from renewable sources, and expects that the projections for installed renewable energy capacity outlined in the Climate Change Mitigation and Energy Strategy and in supplementary planning guidance will be achieved in London. Section 5.42 of the London Plan states that: Individual development proposals will also help to achieve these targets by applying the energy hierarchy in Policy 5.2. There is a presumption that all major development proposals will seek to reduce carbon dioxide emissions by at least 20 per cent through the use of on-site renewable energy generation wherever feasible.
Whilst the GLA has been at the forefront of a more prescriptive and progressive approach to energy consumption in buildings, a significant proportion of non-London borough LAs across the country have also adopted stringent requirements for new buildings in particular.Taken together these guidelines can be seen a prescriptive set of standards to which all major development proposals within the city must adhere. It can be seen that the requirements place significant CO2 mitigation targets, above and beyond what is required by Part L building regulations. Alongside the TER mitigation targets, developments are required to produce comprehensive energy strategies, demonstrating the appraisal of a range of solutions and technologies, following a hierarchy that prioritises energy conservation in the first instance. This increased regulatory burden has seen the rise of specialist consultancies that undertake energy strategies and sustainability statements for planning applications.