Our response to the Draft London Plan 2026

The draft plan broadly addresses the concept of Good Growth, defined as growth that drives economic productivity while being socially inclusive and environmentally sustainable, across four main categories:

• Making best use of land (MBUL): including density, tall buildings, utilities, transport, design and heritage. 
• Delivering homes and neighbourhoods (HN): including housing supply, affordable housing, housing design and accessibility. 
• Growing London’s economy (GLE): including employment space, industrial land, data centres, culture, workplaces, circular economy and waste.
• Creating a greener, healthier and more resilient city (GHR): covering the environmental and sustainability policies particularly relevant to building design.

We work regularly on housing delivery, reducing carbon, and improving energy efficiency, and felt that some areas of the plan could use additional consideration. See our responses to the specific plan sections below:  

Relating to the section Delivering homes and neighbourhoods (HN), we oppose the proposals to reduce requirements associated with ceiling heights, natural light and passive ventilation for kitchens as well as the relaxation of restrictions on single-aspect dwellings. These changes could increase overheating and energy use while reducing residents’ comfort and wellbeing. 

Our response to section HN8: housing design 

• We do not support the reduction to the minimum floor to ceiling height to 2.4m. This is not consistent with sustainable development and the aim of Good Homes Alliance policy GHR4 to reduce and mitigate overheating impacts on occupants. For example, the GHA ‘early stage overheating risk tool’ checklist referenced in the Implementation section of GHR4 requires a minimum floor to ceiling height of 2.8m to allow for ceiling fans to be install in the future.
• We do not support the proposed exclusion of kitchens from the ‘residential habitable rooms’ which should receive natural light and have openable windows, where they form part of an open-plan room that receives natural light. Kitchens without natural light and ventilation to the working area will need additional lighting and ventilation utilisation and may be more prone to overheating, which is not consistent with policy requirements to reduce energy use, reduce overheating by passive means, and to improve wellbeing of residents and create high quality homes by providing good natural daylight.
• We do not support the softening of language around single aspect dwellings. The current London Plan 2021 states these should be 'avoided', while the proposed draft London Plan states, housing development should maximise the provision of dual-aspect dwellings and  seek to minimise the provision of single-aspect dwellings. Dual-aspect dwellings have multiple benefits, including ventilation, outlook, the possibility of a window to the kitchen and bathroom to allow better air movement, moisture and odour control, and provide more options for how and which spaces are used at different times of day.

Relating to the section Growing London’s economy (GLE), the Circular Economy Statement should actively promote retrofit, retention and reuse. Substantial demolition should be subject to a clear Retrofit First test. Reuse and recycled content should be assessed separately to reflect their distinct circularity benefits. The policy should distinguish between different forms of retention, reuse and recycling. Strategic waste targets should also incorporate a broader circularity metric.

Our response to section GLE 11: circular economy

• The Circular Economy Statement should be a mechanism for influencing the development, not principally a reporting exercise. We recommend a clear hierarchy similar to retrofit first policy.
• Where substantial demolition is proposed, London should introduce a proportionate Retrofit First sequential test. Westminster provides an established model whereby applicants have to justify substantial demolition using sequential evidence rather than simply demonstrating that retention was considered.
• Direct reuse should be distinguished from recycled content. Grouping reused and recycled content within a single percentage does not adequately recognise their very different resource and circularity outcomes.
• The policy should separately measure:
  • building/structure retained;
  • materials/components reused in situ;
  • materials/components recovered for reuse elsewhere;
  • reclaimed materials brought onto the development;
  • recycled-content materials; and
  • recycling/recovery.
• We support the strategic waste stream targets, but consideration should also be given to a circularity metric.

Relating to the section Creating a greener, healthier and more resilient city (GHR), we broadly support the proposed approach to energy efficiency and low-carbon heat, including the move to energy use intensity (EUI) and space heating demand (SHD) standards, renewable energy provision and post-construction monitoring. However, EUI and SHD requirements need a consistent methodology, realistic baselines and greater clarity around regulated and unregulated energy, whole-building assessment and occupancy. We would also proposed allowing Passivhaus certification as an alternative route to compliance. 

Although we support the direction of the whole life carbon policy, particularly the shift from reporting towards reducing embodied carbon, we believe it should apply to all major developments and that the proposed upfront carbon limits require a more robust evidence base. Whole life carbon assessment should influence early design decisions, prioritising retention, lean design and material efficiency, with a Retrofit First test for substantial demolition and clearer alignment with RICS WLCA 2nd Edition and the UK Net Zero Carbon Buildings Standard. Carbon commitments should then carry through design, procurement and construction, with monitoring and as-built verification rather than relying on planning-stage reporting alone. 

We believe stronger action on heat risk is required, including passive design, reduced glazing and external shading, and recommend dynamic modelling against current and future climate scenarios to demonstrate performance.

Our response section GHR1: energy efficiency

• We mostly support this policy and the proposed move to EUI and SHD standards.
• However, a consistent and effective methodology for calculating these metrics needs to be defined, and we would like to see the baseline standard referred to as a requirement rather than a target.
• The EUI methodology should be consistent in terms of how both regulated and unregulated energy are calculated, and whether the methodology covers the whole building (including communal areas and landlord's systems) or residential areas only. The strategy should also consider occupancy density which can increase EUI.
• We do not consider the residential EUI targets to currently be deliverable, with the baseline target corresponding with the 2050 limit in the UKNZCBS. Our view is that the residential EUI targets are particularly unrealistic for high-density apartment blocks if unregulated energy use (used by dwellings and common areas) are accurately included in the modelling.
• We would propose allowing Passivhaus certification as an acceptable alternative approach to fulfilling the minimum EUI and SHD standards.
• We support maximising the opportunities for the provision of renewable energy and monitoring and reporting annual in-use energy demand post-construction.

Our response to section GHR2: low-cost low-carbon heat

• We support this policy.

Our response to section GHR3: whole life-cycle carbon

• We do not support this policy although the direction and evidence base are strongly supported. 

• GHR3 requirements which apply only to referable applications allow many major developments to be undertaken without consideration of embodied carbon. Requirements should be applied to major development, as well as referable ones. 

• We welcome the move from simply reporting embodied carbon towards requiring reductions. The submitted LPNZ Evidence-Embodied carbon concludes that reporting and benchmarking alone are insufficient and identifies lean design, material efficiency and upfront carbon requirements as mechanisms for achieving reductions. 

• We do not consider the policy fully justified or effective in its current form. The targets need to be demonstrably achievable across the building typologies to which they apply and linked to a process that influences design decisions rather than simply reporting performance. 

• The evidence base for the Upfront Carbon limits appears flawed. Judging from Hawkins Browns graphs, MEP is estimated as ~70-80 kgCO₂e/m², so around 80-92 kgCO₂e/m² when including a 15% WLCA uncertainty factor. MEP is very difficult to model accurately at early stages, however, our models suggest an average more akin to 110-140kgCO₂e/m² (incl 15% contingency). This has been backed up by other peers in our industry with in-house MEP expertise. When attempting to mitigate the Upfront impact of MEP, you have to be extremely careful not to just 'shift' the carbon into B1 or B6. We've been doing optioneering focused on reducing Whole-life impacts of HVAC strategies for a number of years now, and the Upfront result has never dropped below 100 kgCO₂e/m² GIA - and these tend to have unique features not replicable on every project. Our concern is that this appears to be a dramatic underestimate of MEP upfront carbon and will simply 'punish' any project that employs a WLC assessor with better access to detailed quantity information of building services systems. Or in simple terms, it will punish projects that employ more realistic WLC assessors.  

• WLC assessment cannot turn into a race-to-the-bottom where the poorer models are rewarded with less planning push-back. In addition to the above, the evidence base relies dramatically on cement replacements. The only mainstream replacement available is GGBS, whose use in higher-than-averagely-available proportions for carbon reductions has been thoroughly debunked by the building industry, see IStructE The efficient use of GGBS in reducing global emissions. While other replacements are available - and the hope is Calcined Clays gain market uptake - presenting an evidence base that reaches intermediate and aspirational targets through over-specifying an extremely scarce resource does not represent an acceptably robust, or valid, conclusion.  

• Our takeaway is that the upfront targets are set quite low with flawed evidence in the background. Better quality models will almost certainly exceed the limits for 'reasonably good buildings', and most projects are going to be indirectly forced into over-specifying cement replacements that we know have no net-benefit to the climate issue at hand. 

• The targets should also be explicitly calibrated to RICS WLCA 2nd Edition. The evidence base acknowledges that reported emissions have changed partly because of developing calculation methodologies and recommends moving from RICS WLCA 1st Edition to 2nd Edition. 

• Greater clarity is also needed on the relationship with the UK Net Zero Carbon Buildings Standard (UKNZCBS). The evidence base identifies its Performance Level 3 as aligned with UKNZCBS for upfront carbon, while noting that UKNZCBS does not set whole-life carbon limits. 

• Most importantly, WLC assessment (in particular upfront carbon) should influence decisions while change is still possible. The evidence base itself states that embodied carbon should not simply be reported and that clients and design teams should work together to reduce upfront and lifecycle carbon from early design stages. 

• Requirements for referable application to ‘assess the potential for retaining existing buildings’ do not go far enough in preventing unnecessary demolition of buildings which could be reused. The London Plan should undertake a sequential test to establish justification for demolition, including analysis of structural soundness, requirements of use, whole life carbon and public benefit, similar to the process set out in Westminster Retrofit First policy.

• Westminster Council’s Retrofit First Policy Guidance for Environment SPD provides a useful precedent: it sequentially considers structural feasibility, requirements of use and carbon options and requires deliverable development options to be compared. 

  • We recommend that GHR3 establish a clear process for policy implementation from basebuild, optioneering, tangible planning commitments, monitoring and as-built verification 

  • WLC optioneering should occur while major decisions remain open, particularly those relating to retention/demolition, structural strategy, façade, material efficiency and building services. 

  • Lean design and material efficiency should be given greater policy weight. The evidence base specifically identifies these as means of reducing embodied carbon through existing building retention, good design and material efficiency. 

  • Where targets are not achieved, applicants should demonstrate why and identify the measures undertaken to minimise the result. This would provide a more meaningful assessment of performance than simply recording whether a target has been achieved.

  • Planning-stage carbon commitments should then be translated into detailed design, specifications/Employer's Requirements and procurement requirements, with actual performance verified at completion. Introduce pre-construction submission to make the applicants' carbon commitments serious. 

Our response to section GHR4: heat risk

• We do not believe this policy will be effective. Whilst we support the introduction of measures such as ‘…maximising passive design measures…’ and ‘…minimising unnecessary glazing; and providing external shading compatible with window design…’ within the policy, we do not believe this policy goes far enough.
• Guidance should require using dynamic modelling to use current and future climate scenarios and meet the relevant CIBSE compliance criteria for all weather files.