The GLA have made carbon & energy efficiency requirements significantly more onerous. The requirements from 15/06/22 will require building design improvements over the tougher Part L 2021 baseline. The GLA states that their full requirements will be provided on the same day enforcement begins. We have followed up with the GLA, and development teams should consider that:
- Requirements are applicable to Stage 1 applications submitted on or after 15/06/22, presenting significant risk to energy strategies in development now. This does present questions for reserved matters applications, where loosely worded requirements could require applying the new requirements;
- There will be design and cost implications with lower U values, triple glazing and MVHR for meeting the 10%, domestic, and 15%, non-domestic, CO2 emissions reduction at ‘Be Lean’ as it is against the tougher baseline;
- The on-site requirement of 35% reduction in CO2 emissions will be measured against the new baseline, but likely to be achievable with heat pump led strategies;
- The heating hierarchy remains in place and prioritises heat networks, however CHP led schemes will find it difficult to meet requirements. There are conflicting requirements which the GLA will need to clarify, for example should connecting to a gas CHP led wider heat network be prioritised even though it could result in lower overall carbon emissions reductions, and should such a connection be penalised with greater offset payments?
- Shortfalls to zero carbon emissions will be required to offset through the cash-in-lieu payment based on the locally set carbon offset price and could be lower given the use of new carbon factors;
Contact our team to continue the discussion and talk through requirements for your developments.