M67 Sustainable Infrastructure 29 March

Sustainable Infrastructure
Minimising Greenhouse Gas Emissions, Energy Infrastructure and Managing Heat Risk
Written statements in response to M67 may be up to 3,000 words in length.

Panel questions:  M67. Would Policies SI2, SI3 and SI4 assist in creating a healthy city in accordance with Policy GG3 and provide an effective strategic context for the preparation of local plans and neighbourhood plans? How would they affect the implementation of Policies GG4 and GG5 on delivering the homes Londoners need and growing a good economy? Are these policies and their detailed criteria justified and necessary and would they provide an effective basis for development management? In particular:
a)  In seeking to minimise greenhouse gas emissions does Policy SI2 provide sufficient clarity about the zero-carbon target and how and when it is to be achieved? Is the target justified and consistent with national policy and other policies in the draft London Plan? Are all the criteria and supporting text necessary
b)  How are unregulated emissions and whole life-cycle carbon at Policy SI2 DA and DB to be calculated and is this justified?
c)  Are the provisions in Policy SI3 relating to energy masterplans justified? Should they be limited to large-scale development locations and is the list of items to be identified comprehensive?
d)  Are the provisions in Policy SI3 relating to major development proposals within Heat Network Priority Areas justified? Is the sequence and content of the heating hierarchy justified having regard, amongst other things, to greenhouse gas emissions?
e)  Would Policy SI4 adequately address the contribution of the design of outdoor space to urban cooling without creating other adverse impacts and does it consider overall thermal comfort?
f)  What is the justification for the cooling hierarchy as set out in Policy SI4B?
g)  Do the policies place sufficient emphasis on the use of renewables and energy efficiency?
Just Space submission in full: M67 Greenhouse emissions Just Space

Policy SI2 to start with. Panel asks Mayor: What is “NET zero carbon”? GLA speaker gabbles. Zero = Net zero. Same thing. Panel: 2050 target is not in the Plan; it’s elsewhere. Too slow? Too fast? Milestones on the way. The target for the LP is for new development. London Env Strategy is for the whole city… (another gabbling GLA speaker). On interim targets: the LES does set 5-year interim targets. SI2 applies only to major developments: why not all? GLA: boroughs can take an approach to smaller ones. And we’d like to see the building regulations updated to cover these.  Panel: why was construction omitted? GLA says it’s covered by other parts of the policy. What about JS’s call for more detail on monitoring. GLA: we are working on that and will publish…  Panel: offsetting? GLA: it’s in use already and we are doing more. Something about costs…  Panel: MHLG advice on retrofitting? GLA: major refurbishments should be covered by the plan. Outside of the LP the Mayor has other instruments to use on existing building.

Kate Gordon FoE: offsetting price too low, not a strong enough incentive. // Promise of later guidance n design and construction is too vague: make it stronger. // Need a strong statement on non-major development, not leaving it all to boroughs. // 2050 taget too late //

JS  2030 target should replace 2050. IPPC report conservative…  National policy is anyway under review, and other cities M/c, Bristol, Reading have already deviated. Progress alreaday made (ref to a Mayoral document) shows that a much more ambitious approach is feasible. // Offsetting must be a last resort, and price much higher.

Fuel Poverty Action: support JS and FoE. Reject fuel poverty being used in some places to justify less ambitious policies. // Offsetting: far too easy for developers to pay to pollute. Breeds cynicism too. // Worried about offsets used to pay for district heating – can just boost the profits of for-profit firms..

Mr Simon Sturgis:

London Energy Initiatives: Support the policy but made some detailed suggestions.

Public and Social Services Union PCS: Net zero and Zero are NOT interchangeable. // we think more analysis is needed on what companies are doing about their offsetting.

CIBSE: there were problems with offset initially. too soon to judge and it’s a useful mechanism.  Do not agree with Sturgis: we should keep operational carbon and embodied carbon separately. //

Cory: policy not consistent with NPPF which just calls for LOW, not Zero…

Levitt Bernstein: very important to reduce initial embodied energy (?). Fabric improvements also reduce other costs (plant rooms etc); the more we do on site, the less we need to use offset. Must avoid reducing on-site improvements.

London First: Practical problems: unintended consequences: detail required in energy strategies is onerous; requirement to achieve 15%…too broad for all non-domestic buildings. SI2Ac.  revise so 15% just becomes an “aim”

Assembly labour group: methodology should be in SPG so everyone knows what the Zero / Net zero distinction is.//  Refers to an Assembly Resolution calling for 2030 to be the deadline. // Mistake to apply the policy only to major development.  Can’t leave to  boroughs or wait for building regs // Plan must refer explicitly to details in Env to add weight. // Must include embodied carbon. // Refers to Assembly research and reports.

Panel asks GLA: definition ? include embodied carbon? GLA don’t want to confuse the established practices; but embodied and whole-life emissions to be developed separately. Panel: JS points to unambitious targets. GLA: It is ambitious enough as the 35% will become harder to achieve (? as gas/elec mix changes?) .

Now on to Da Db. Panel: This is all over and above NPPF standards. GLA: govt has expressed no view on this policy. It’s in line with the (turbulent) way govt thinking is going. Unregulated and whole life emissions are an ever-growing share of total. Panel: can a spatial development strategy help? GLA: yes…..

Whole life cycle: is there a RICS methodology which should be referenced? GLA gabbles. Panel: why limit it to referrable cases? GLA: it’s a new policy and we want to get it right on a limited range of cases.

Demolition: Panel asks. It will be covered in later detailed advice. Inspector Smith: it would be clearer if the policy makes that clear. Retrofitting should thus be given priority over demolish (esp estate regen).

Labour Group: Calls for post-completion estimates for effective monitoring and offset charging. // Support priority for retrofit over demolition. //  MUST require all schemes to…and not just the biggest ones. //  Mayor should be (tougher) on unregulated emissions.  // Do favourthe RICS approach to whole life cycle.

London First: Fine…  but so difficult and uncertain to predict life-cycle energy… (trying to soften it).

Veolia: plan should signpost to methodology.  We support life-cycle evaluation.

Cory: Need transparency for all such evaluations.

CIBSE: agree should refer to RICS, though others may emerge. //  supports Assembly view that on-completion reports are needed as well as early-stage ones.

Env Services Assn: (can’t follow speech.)


RIBA/RICS: Embodied energy now likely to exceed emissions in use. Savings are immediate, not spread over the years. Treasury supports view that low carbon buildings save money too. Professional procedures etc are now very advanced, stabilised, and there is no justification for delay. So we urge that embodied and life-cycle assessment should be done – with post-completion part- in an integrated way from the outset. Include medium size schemes.

Fuel Poverty: Stresses post-completion assessments: yes residents do know… Nothing in here about consultations with residents post-Grenfell. //  should be provision for requiring district heating pipework to be built in to estate designs…  Maybe it should be built in everywhere but…


Just Space: Wording should be stronger:  ”’required..  ”   // Not just large developments . // Stress role of workers in workplaces and residents in homes can contribute to unregulated emission reductions.  Must stress working with unions and residents.

FoE. Agree.

GLA: asked to comment on JS inclusion of workplaces: policies apply to everything needing planning permission.

GLA sees carbon assessment and circular economy assessments will develop in parallel.

Policy C (gap in blog – discussion between panel and GLA on heat networks)

GLA will look at how heat networks can be monitored.

CIBSE: Support monitoring. Fast-=changing technology and plan needs to allow for that.

Assn for decentralised energy: good networks operated well can contribute well. Updated code of practice forthcoming and could usefully be mentioned. Low temp networks may not always be best. Retrofit important to develop. // Add ref to on-site generation.

xxx  We’d especially like to see Mayor backtrack on public energy company. There should be a London-wide energy strategy, and one way round terrible things like the Myatts Fields North which locked residents in to a PFI contract removing ay choice.  Must be done with workers, union and communities. Swedish experience is that only publicly-owned models can bring rapid emissions reductions with workers and residents fully contributing. Has important implications for skill development for fitters(merging elec/gas and usage skills. We welcome no new connections to gas after 2025.

Env Services Association. We do see energy from waste as one of the elements in a solution, sometimes linked to CHP. New developments should be CHP-enabled. Perhaps GLA could guarantee demand to encourage providers.

London Energy Transition Network: (couldn’t hear)

Fuel Poverty Action: we see nothing in the Plan to prevent a repeat of Myatts Fields North. Call for planning consent stage to take full account of prices for final consumers. All too vague. No provision for cost to residents to be considered in Heat priority Networks. Accountabilities and incentives are NOT designed to produce good outcomes for existing or new ones.  Southwark has many out of date systems. One Elephant Park building has logged outages..  The Heat Trust is not up to the job, can’t deal with cost. Audits secret. Ombudsman also useless – dealing only with individual, not estate-wide schemes.  Mayor is the only possible source of effective regulation. Also a training issue where a strong public role is needed. Clearer criteria needed for CHP…

Just Space. we agree on 5 ///  ref grantham Institute on need for upskilling for carbon transition. SI3a. Retrofitting must be included in this policy section, aligns Good Growth, workforce development, equity and climate change. (Adds new wording.) Importance of small developments also be included. Ref Assembly report on scope for solar PV on half of London rooftops.

FoE is very specific. We need a policy requiring ALL development to contribute to zero energy. Need to add material on how the layout and design of developments should also contribute. Could boroughs be asked to do more? Why can’t they be got to

(leaving now. Others will add.)