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London Energy Planning Guidance

Energy Planning Guidance

General Guidance

As you will no doubt know, energy planning guidance for new properties is dictated by Part L of the Building Regulations (BRs).  Part L1 is for domestic properties using SAP software which is broken down into L1A for new builds and L1B for existing properties.  Part L2 is for commercial (or non-domestic) buildings using SBEM software which is broken down into L2A for new builds and L2B for existing buildings.  Naturally Part L BRs show only the limiting factors and is not a prescribed way to achieve a 'pass'. 

Each time a BR is updated (normally every 4 years or so) a percentage increase over previous regulations is added with the goal of reaching 'zero carbon' i.e. 100% better than building regulation targets/emissions.  Most local authorities/building control officers up and down the country are happy to receive compliance documents using SAP/SBEM software showing compliance has been achieved at the design and as-built stages of the development.  Remember compliance is broadly achieved once the percentage increase over BR has been achieved (assuming your local planning authority hasn't set a higher value).  In the case of London, the Mayor is responsible for setting out 'guidance' to local authorities within London.

London Energy Planning Guidance

From 1st October 2016 all 'major projects' (see below) need to reach 'zero carbon' for domestic properties (100% better than Part L BRs).  To be fair a developer only needs to comply with a 35% reduction in regulated carbon dioxide emissions (both domestic and commercial properties) beyond 2013 Part L Building Regulations.  The remaining difference of 65% (100 - 35%), for domestic properties only, is to be off-set through a 'cash in lieu' contribution (i.e. an additional 'fee', see below) to the relevant borough.

The Mayor’s own Housing Standard’s Viability Assessment assumes an off-set ('cash in lieu') price of £60 per tonne of carbon dioxide for a period of 30 years (£60 x 30 = £1,800).  This means that for every tonne of carbon dioxide short of the 100% target, a 'cash in lieu' will have to be paid.  Possible total costs for zero carbon off-setting are (totals are indicative only):  £1,000 for Apartments, £1,400 for Mid-terrace, £1,700 for Semi-detached and £2,500 for Detached properties.  Each local authority can choose a different price from the Mayor's £60 per tonne over 30 years.

Major Projects

Different local authorities can choose to have a different number of dwellings for 'major projects' though most have chosen to define this as 10 or more dwellings or 1,000m2 for commercial properties.  The exception is Islington (current practice as of 1st October 2016) which applies this to all developments.  Other exceptions are Hackney and Westminster which are GLA referable schemes and some local authorities who have not yet decided.

Off-set (through a 'cash in lieu')

Once again each local authority seems to have chosen a different path to off-setting fees and some have not announced their off-setting fees as of 1st October 2016 (see bottom of page for full list)

Off-set Payment Due Date

Once again, most Local Authorities are looking to condition the payment through the S106 mechanism based on 'Design Stage' Part L calculations.  Hence payment will be due at the start or completion stage of construction depending on the Local Authority preference (Hounslow intend to charge 50/50).  

Energy Assessments

This must set out the key measures and CO2 reductions (i.e. 35% or greater) identified as part of the application for each stage of the 'energy hierarchy' (see below).  It must clearly indicate the performance of the domestic and non-domestic elements of the development in relation to the London Plan reduction targets.  Naturally if the carbon savings are not achieved, the annual remaining carbon emissions figure is multiplied by the assumed lifetime of the development’s services (e.g. 30 years) to give the 'cumulative shortfall' i.e. the off-setting fee.  The cumulative shortfall is multiplied by the carbon dioxide off-set (depending on the Local Authority) to determine the required 'cash-in-lieu' fees.  We can prepare the necessary SAP and SBEM calculations to achieve these targets cost effectively.  Please let us know if this is something we can help with.

Please note:  For commercial projects where an existing building or group of buildings is refurbished it is still expected that developers provide an energy assessment demonstrating how the individual elements of the energy hierarchy have been implemented within the project and how reductions in regulated CO2 emissions have been achieved.

Energy Hierarchy

1.     Be Lean

We can show you how to exceed Building Regulations requirements (Part L 2013) through ‘building fabric' and demonstrate the extent to which they meet and then exceed Building Regulations.  Measures typically include both architectural and building fabric measures (passive design) and energy efficient services (active design).  Note:  The greater the improvement over BRs from building fabric, the less investment you’ll need in renewable energy or district heating.

2.     Be Clean

This stage looks at heating and cooling equipment for the building, and how energy demand can be reduced through more efficient services.  All Local Authorities have been producing or commissioning 'heat map' studies to explore the viability of decentralised heat networks, and developers are required to explore the viability of connecting to these now or in the future (the focus here is to create 'heating networks' that can be upgraded in a cost effective, low impact way should lower carbon heating systems become available in the future).

Some existing 'District Heating' networks do exist, namely: Barkantine Heat and Power, Bunhill Energy Centre, Citigen, Olympic Park, The Pimlico District Heating, University College London and Bloomsbury and Whitehall District.  If the site cannot be connected to any of these 'district heating' systems, future connections to planned networks need to be explored.  These can all be viewed in the London Heat Map (click here to open).

The developer must also consider the viability of ‘Combined Heat and Power’ (CHP), a tried and tested means of generating electricity on site, although CHP may not be viable for developments of less than 300 domestic properties.  As an alternative to CHP, a developer could consider gas fired community heating, with heat exchangers to each dwelling.  We can explore all possible options on your behalf.

3.     Be Green

This is renewable energy.  The energy assessment must consider a variety of renewable technologies before justifying their inclusion or exclusion from the building.  Photo-Voltaic (PV) panels are one of the most commonplace solutions, though any technology which contributes toward the 35% (or greater) reduction can be considered.

The London Plan assumes that 20% of a development’s CO2 emissions will be off-set by renewable energy.  However, this figure is only for guidance and each Local Authority will have their own percentage (if one exists) so it will be vital to establish any flexibility with the planning officer.  Some of the renewable energy consists of Ground, Water and Air Source Heat Pumps, PV, Solar thermal, Wind turbine and Biomass & Biofuel.

The technology you choose to go with will depend on site constraints and the strategy adopted for the Be Lean and Be Clean stages of the Energy Hierarchy.  We can help you review all the renewable technologies to establish which is best suited to the development.

Final Note

If it is impossible to achieve the 35% reduction, you may well be asked to make a carbon off-setting financial contribution.  EPC Expert Ltd has never completed an energy assessment where we have not been able to achieve the minimum percentage reduction.

Furthermore, it is important to note that we have previously seen numerous early stage assessments (SAP and SBEM calculations) which have been carried out by energy assessors not Accredited (and hence not insured) to carry out the final part of the calculations process namely the Energy Performance Certificate (EPC).  This means that the SAP and SBEM calculations need to be repeated by an Accredited Assessor.  Please make sure you choose one that is not only Accredited but can save you £000's per property.

Off-set Payment Due Date (for each LA)

Local Authority

Off-set cost per tonne of CO2

Barking and Dagenham

£60 x 30 years = £1,800


£60 x 30 years = £1,800


£60 x 30 years = £1,800


£60 x 30 years = £1,800


£60 x 30 years = £1,800


£90 x 30 years = £2,700

City of London

£60 x 30 years = £1,800


£46 x 30 years = £1,380


£60 x 30 years = £1,800

Enfield (1)

£75 x 30 years = £2,250


£60 x 30 years = £1,800


£60 x 30 years = £1,800

Hammersmith and Fulham

£60 x 30 years = £1,800

Haringey (1)

£90 x 30 years = £2,700


£60 x 30 years = £1,800


£60 x 30 years = £1,800

Hillingdon (1)

£60 x 30 years = £1,800

Hounslow (1)

£60 x 30 years = £1,800

Islington (2)

Currently £920 (one off)

Kensington and Chelsea

£60 x 30 years = £1,800

Kingston upon Thames

£60 x 30 years = £1,800


£60 x 30 years = £1,800


£104 x 30 years = £3,120


£60 x 30 years = £1,800


£60 x 30 years = £1,800


£60 x 30 years = £1,800

Richmond upon Thames (1)

£60 x 30 years = £1,800


£60 x 30 years = £1,800

Tower Hamlets

£60 x 30 years = £1,800

Waltham Forest

£60 x 30 years = £1,800


£60 x 30 years = £1,800


£90 x 30 years = £2,700

(1) Policy indicates all developments should meet the energy targets of the London Plan but carbon offset only applies to major developments

(2) Offset payment includes both regulated and unregulated CO2

All relevant Mayor's London Energy Planning Guidance can be found below:

2018 GLA Energy Planning Guidance.pdf

2016 GLA Energy Planning Guidance.pdf

2016 03 - Housing Standards - Minor Alterations to the London Plan.pdf

2016 03 - Housing - Supplementary Planning Guidance.pdf

2014 Sustainable Design & Construction SPG.pdf

2014 gla_energy_planning_monitoring_report_approved_final

Commercial New Build (SBEM)
Commercial Extensions or Conversions
Domestic New Build (SAP)
Domestic Extensions or Conversions

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