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Sustainable development planning requirements

Date updated: 26/04/2023

The Local Plan Strategic Objective 4 sets out the City of London Corporation's vision for environmental sustainability.

“To ensure that the City of London remains at the forefront of action in response to climate change and other sustainability challenges that face high density urban environments, aiming to achieve national and international recognition for its sustainability initiatives.”

The City aims to deliver this through the implementation of the core policies:

  • CS15 Sustainable Development and Climate Change
  • CS16 Public Transport, Streets and Walkways
  • CS17 Waste
  • CS18 Flood Risk

More details are in the Local Plan development management policies. The Draft City Plan 2040 should be a consideration in planning proposals.

A development's sustainability must be addressed at the earliest possible stage to ensure that these policy requirements are met.

More detailed information is in the Mayor of London’s Sustainable Design and Construction SPG (PDF) and in the Greater London Authority's (GLA) Guidance on preparing energy assessments​.

Carbon Options Guidance

All development in the City needs to minimise carbon emissions, whether they come from running the building, or from the carbon embodied in the building itself. The City Corporation has developed a Carbon Options Guidance Planning Advice Note (COG). The COG sets out how planning proposals should go through an ‘optioneering’ exercise to assess different types of development options, ranging from refurbishment to more substantial redevelopment of the site. Carbon optioneering enables the holistic consideration of carbon impacts, sustainability outcomes and wider planning objectives. The ‘Carbon Options Tool’ is an Excel spreadsheet which provides a consistent presentation of the assessment results. 

A Carbon Options Study must be reviewed by a 3rd party in the final stages of the pre-application process. A review of a carbon options study relating to any application that is live when the COG is published (April 2023) will be completed before determination of the application.

The consultation response summary provides our responses to a summary of comments received following the public consultation and expert round table events in September 2022.

Carbon Options Guidance Planning Advice Note PDF (12.5MB)
Date submitted: 24/04/23
Carbon Options Tool 01 XLSX (1.2MB)
Date submitted: 25/04/23
Whole Life Carbon PAN Consultation Response Summary PDF (250KB)
Date submitted: 24/04/23

Carbon offsetting

If the Mayor’s CO2 target cannot feasibly or viably be met on site, carbon offsetting would be required. The energy strategy must demonstrate that the maximum possible carbon reduction will be achieved on site. Carbon offsetting will be required to account for any shortfall and will be secured through an S106 agreement. More information is in the Mayor’s Sustainable Design and Construction SPD and in the City of London Planning Obligations SPD. The latter is in the Planning Policy Library.

Energy Statement

The energy strategy must include a comprehensive assessment of the energy demand of the proposed building, all relevant proposed energy efficiency measures and low and zero carbon technologies to be incorporated and proposals for carbon offsetting where relevant targets cannot be met. The proposed carbon emissions savings should be calculated and presented as demonstrated in the GLA guidance on preparing energy assessments.

The following City-relevant issues should be considered:

  • Integrating an optimised range of energy efficiency measures that would push the building performance closer to the zero-carbon target.
  • Reducing energy demand by employing a built form and low tech installations that can provide passive solutions, such as for cooling, ventilation and space heating.
  • Utilising synergy between commercial and residential uses that provide opportunities for low or zero energy technologies such as installation of shared energy centres with with decarbonised heating and cooling plant, connecting to existing decentralised energy networks and seeking opportunities for new district heating networks.
  • Utilising opportunities that large scale development and estates provide to incorporate innovative solutions, such as ground source technologies, hydrogen technologies and efficient building modelling.
  • Innovative solutions to integrate photovoltaic and solar systems with alternative colours and finishes, considering siting and overshadowing issues, glint and glare to the ground and in views of the historic townscape
  • Taking an integrated approach to the design of the roofscape to provide insulation, urban greening and biodiversity, rainwater collection, ventilation and space for renewable technologies.

Information needed for major new development or refurbishment applications

Sustainability Statement

The Sustainability Statement should include the following information:

BREEAM pre-assessment. The assessments should aim to achieve BREEAM “Excellent” or “Outstanding” and should demonstrate sustainability in aspects which are of particular significance in the City’s high density urban environment, particularly the categories Energy, Water, Pollution and Materials. The aim is to achieve the maximum possible credits towards the City’s priorities.

Climate change resilience measures, in particular addressing a warmer and more extreme climate, the urban heat island effect specific to inner city areas and local flooding which is an identified threat to the City by:

  • urban greening (green roofs, green walls, planters, trees, creating green corridors)
  • solar shading/reducing solar gain (fins, brise soleils, blades, fritting, high performance glazing, high thermal mass, cool roofs)
  • passive ventilation and heat recovery (light wells, ventilation shafts, heat recovery systems)
  • sustainable drainage systems (reduce water run-off by rainwater collection, green roofs, blue roofs)
  • managing water resources through installation of rainwater harvesting and greywater recycling

Summary of energy approach (details in separate energy statement, see below)

  • energy efficiency measures (air tightness, energy efficient plant and light installations) and demand management measures (passive ventilation and solar shading)
  • low and zero carbon technologies (district heating, combined heat and power, air source heat pumps, photovoltaic cells, solar cells, ground source heat pumps) calculations of carbon emissions savings
  • carbon offsetting proposals (if applicable)

Resource efficiency – materials, water and circular economy

  • Re-use of building fabric
  • Building deconstruction and recycling of materials on site where possible
  • Materials (local materials, materials with low embodied energy, sustainably sourced, pre-fabrication opportunities)
  • Water conservation measures through rainwater reuse and greywater recycling​

Positively addressing pollution

  • air quality
  • noise
  • light spillage
  • water quality and flood risk
  • land contamination​

Identification and consideration of opportunities and possible links to

  • street enhancement projects and other environmental schemes in the vicinity
  • district heating networks and similar communal energy infrastructure

Innovative solutions to address sustainability are encouraged to keep up to date with and support the development of sustainable technologies and initiatives that address sustainability in a wider context, such as new shared energy networks or green corridors. ​

Major refurbishment schemes

If the proposal includes an extension of more than 1,000sq.m the extension on its own must be treated as a major new development and assessed accordingly including consideration of London Plan Policy 5.2 targets. An energy assessment for both the extension on its own and the development as a whole must be submitted. Depending on the development details, carbon offsetting may be required. The refurbishment of an existing building should achieve the highest feasible and viable sustainability standards taking account of the constraints posed by the remaining structures.​

Opportunities for sustainability improvements will depend on the degree of refurbishment of the building. BREEAM Refurbishment and Fit Out criteria may be used to demonstrate the sustainability of refurbishments where appropriate.

The sustainability statement for such a scheme should address the development as a whole.

Information needed for minor development or refurbishment applications

Applicants are encouraged to address emerging London Plan and draft City Plan 2036 sustainability requirements including zero carbon, energy monitoring, whole life cycle carbon assessment, circular economy and climate resilience

The highest feasible and viable improvements to the sustainability of the building should be demonstrated by positively addressing all development management policies relating to sustainability and climate change adaptation. These can form part of the Design and Access Statement. Compliance with the various targets and standards is desirable and would support the application.​