From October 2016 zero carbon homes in London has been GLA planning policy, however a recent review of the latest planning submissions shows developments are avoiding, at least in part, the cost of this additional requirement.
London Plan policy 5.2. requires that new homes built in London are built to a zero carbon standard with any residual emissions being offset by payment to Boroughs; for most projects this will result in around £1,500/dwelling being secured by means of a S106 agreement.
Between October and December 2016 six major residential developments referable to the GLA were submitted with accompanying Energy Statements.
According to GLA guidance, the Energy Statements should declare the cash contribution for any emissions shortfall required to meet with the zero carbon policy standard. Of the six reports submitted, only one included a cash value for carbon emissions offset. This would suggest that either consultants are not up to speed with the new policy landscape or design teams are withholding known values from their reports.
Discussions with planning consultants on live projects has illuminated an approach that many are taking to the new policy – the increased cost felt by the introduction of the zero carbon policy leads to emissions offsets being brought together, possibly with other S106 payments, and the total figure used to negotiate a viable proportion of affordable housing being offered to the LPA. Whilst this is perhaps an understandable approach, it is nevertheless a poor execution of policy if the ‘zero carbon homes’ that will be marketed to the consumer are not, in fact, zero carbon.
In a coincidence of timing, the Government published a report in December 2016 highlighting ways to protect and inform consumers who install energy efficiency or renewable energy measures in their homes.
The Bonfield Review, or ‘Each Home Counts – An independent review of consumer advice, protection, standards and enforcement for energy efficiency and renewable energy’ was commissioned in July 2015 following the collapse of the Green Deal. While the Bonfield Review offers an excellent framework to protect consumers, it remains to be seen whether London homes promoted as ‘zero carbon’ from 2017 would meet the qualifying standards.
To positively safeguard projects we recommend that S106 agreements and planning negotiations are reviewed before marketing material for new residential developments is published to avoid a VW-style emissions scandal for housebuilders.
If you would like to hear more about these issues or discuss a particular project then please contact Iain Fraser on 0203 544 firstname.lastname@example.org.