Draft London Plan 2026 consultation

The London Plan therefore sets standards that go beyond those in national Building Regulations. In doing so the Mayor is cognisant of the context of the draft NPPF which seeks to standardise energy-efficiency requirements at the national level. However reverting to national standards would not only undermine progress towards net zero and the fulfilment of his legal duties, but would represent a worsening of the current position in London which seems untenable in the context of the climate challenges facing the city. London has consistently and effectively achieved higher standards than those set by national requirements.

Section 5.19, 
GHR1 Energy efficiency, Draft London Plan

The Passivhaus Trust welcomes the climate leadership set out in the London Plan, with the strong commitment to set standards that go beyond those in national Building Regulations. The Passivhaus Trust is very encouraged by proposals being put forward in the draft London Plan and the adoption of absolute targets, such as space heating demand and Energy Use Intensity. 

The Trust also feels that the London Plan is adopting a sensible approach to measuring whether there is a need for heat networks in conjunction with low energy developments such as Passivhaus. The proposals for minimising overheating also closely mirror those put forward by the Passivhaus standard and methodology, encouraging passive cooling measures in the first instance, but accepting active cooling measures where needed and especially for buildings that require minimal energy to cool the building.

Ann-Marie Fallon, Co-Director, Passivhaus Trust

GHR1 Energy efficiency

[PLEASE SELECT SOME OF THE FOLLOWING & PUT THEM INTO YOUR OWN WORDS]

GHR2 Low cost, low carbon heat

[PLEASE SELECT SOME OF THE FOLLOWING & PUT THEM INTO YOUR OWN WORDS]

• Support the proposal for 'Low Carbon Heat Appraisals' to establish the lowest-cost, lowest-carbon heating solution for proposals BUT it needs to be made available to industry ASAP, to test its assumptions and outputs before adoption

• If a development achieves full Passivhaus certification, this should provide a clear and preferably automatic route to exemption from heat-network connection or future heat-network-readiness requirements (with the GLA providing a clearly defined exemption route)

• At a minimum, certification should create a presumption in favour of exemption, with any decision to require connection supported by clear evidence from the Low Carbon Heat Appraisal.

GHR3 Whole life-cycle carbon

[PLEASE SELECT SOME OF THE FOLLOWING & PUT THEM INTO YOUR OWN WORDS]

• Support the Draft London Plan’s calls for developments to calculate and reduce upfront embodied and whole life carbon emissions.

GHR4 Heat risk

[PLEASE SELECT SOME OF THE FOLLOWING & PUT THEM INTO YOUR OWN WORDS]

• Support introduction of an overheating strategy, aligned with the Passivhaus methodology which maximises passive design measures and minimises the energy associated with cooling.

• Agree that active cooling likely to be increasingly needed, after passive measures are explored and investigated first.  

• Passivhaus Standard includes detailed summer comfort  guidance. Summer comfort stress testing is an integral part of PHPP. The GLA should require all projects to take a similar level of stress testing of design to limit overheating risk

• GLA policy 3.108 (ceiling height reduction option) potentially in conflict with providing cooling or good ventilation measures for indoor air quality

GHR10 Air quality

[PLEASE SELECT SOME OF THE FOLLOWING & PUT THEM INTO YOUR OWN WORDS]