City pushes ahead with ‘pioneering’ whole-life carbon policy

The City of London Corporation is introducing new planning guidance that will require developers and their design teams to submit specific information about the comparative carbon impact of a range of alternatives for proposals at pre-application stage.

Members of the City’s Planning and Transportation Committee this week agreed to adopt the guidance, which is brought together in the Whole Life-Cycle Carbon Optioneering Planning Advice Note.

Previously, major applications submitted to the City did not require a whole-life carbon assessment, although they were supposed to achieve a minimum of BREEAM “excellent” certification rating for sustainability.

Under the new guidance, developers will be expected to carry out a detailed review of the carbon impact of development options before submitting an application.

Square Mile planners said the review should consider refurbishing existing buildings rather than demolishing and replacing them.

At the application stage, developers will also be expected to provide details of how their proposed building will operate as energy efficiently as possible. The analysis will be taken into account by City planners when determining planning applications.

The new guidance applies to major developments – those greater than 1,000sq m of floorspace – and smaller developments that propose knocking down most of an existing structure.

Planning and Transportation Committee chairman Shravan Joshi said the guidance was “pioneering”. He said it would put the City at the forefront of the growing drive to give detailed consideration to retaining and refurbishing buildings rather than knocking them down and starting again.

“It will provide clarity for developers, who are themselves in increasing numbers looking to explore the environmental and financial advantages of retrofitting or refurbishing,” Joshi said.

“In an area as dynamic and well-connected as the City, there will always be the potential for new builds, but this guidance, which supports our ambitious sustainability targets, will promote lower carbon alternatives where appropriate and assist developers in putting carbon considerations front and centre when preparing an application.”

A draft version of the planning guidance put out to consultation over the summer said pre-application discussions with City planning officers should be able to demonstrate that minor or major refurbishment options had been considered in the procurement and design process.

It said options should be “well-considered, realistic and feasible” and include a range of specified data, such as embodied carbon to practical completion, lifecycle embodied carbon, and whole-lifecycle carbon in kgCO2e/m2GIA and tCO2e.

The draft planning advice note specifies a range of data required for clarification at the application stage, including confirmation of the preferred option based on the earlier optioneering exercise and reasons to support the decision.

It also seeks a clarity on all assumptions and exclusions, and the level of certainty of the data used in the assessments.

A report to Tuesday’s meeting of the Planning and Transportation Committee said some changes had been made to the draft planning guidance following last year’s consultation exercise.

They included a request for independent third-party verification for all schemes that undertake optioneering to ensure accuracy and setting “minor refurbishment” as the baseline scenario for comparing options for a building.

In the draft guidance, the existing building with no intervention was used as the baseline. City planning officers said the minor-refurbishment option was seen as “more realistic”.