The draft London Plan introduces clearer energy targets, but does it provide a consistent basis for decision-making?

If we are serious about decarbonising real estate, planning policies that prioritise reducing energy and carbon should be welcome. The new draft London Plan reflects the direction the industry has already been moving in, largely through setting energy intensity limits for new and major refurbishment projects.

Rather than assessing performance solely through a percentage improvement over Building Regulations Part L baseline values, as the current London Plan does, absolute targets should make as-designed performance easier to understand, compare and communicate. For example, a building either achieves an EUI of 70 kWh/m² per year, or it does not.

This however, raises a familiar question: How should the draft London Plan’s figures be interpreted alongside net zero carbon reduction pathways already being used by the industry?

The proposed London Plan targets

The draft plan proposes baseline and aspirational EUI targets for several major development types across both regulated energy (energy used for the building operations, e.g., HVAC systems) and unregulated energy (energy used by the occupier).

The move to absolute energy targets is more closely aligned with the direction of travel established by frameworks such as Carbon Risk Real Estate Monitor (CRREM) and the UK Net Zero Carbon Buildings Standard (UKNZCBS). However, once the different figures are placed side-by-side, the picture becomes less straightforward.

A plan to 2050

The Greater London Authority (GLA) describes the draft plan as looking ahead to 2050 and therefore to ensure buildings built or refurbished today are net zero aligned, but are they future-proofed through to 2050? Consider an office achieving the London Plan baseline target of 90 kWh/m² per year, which would outperform the CRREM pathway in 2030. It would, however, then exceed the CRREM limit from 2040 and would not meet the UKNZCBS pathway at any of the three comparison years.

These inconsistencies are not limited to offices. Based on the current comparison, multi-family residential is the only development type for which both London Plan targets stay under the applicable CRREM and UKNZCBS pathways through to 2050. Part of the apparent inconsistency arises because the frameworks have different purposes. The London Plan is a planning policy. Its baseline values need to establish a practical minimum standard that can be applied across major developments of varying challenges.

On the other hand, CRREM is primarily a transition-risk pathway. It helps owners understand whether an asset’s energy or carbon intensity is likely to remain aligned with a country’s top-down decarbonisation trajectory over time. The UKNZCBS is intended to establish whether a building can credibly be described as net zero carbon aligned. Its requirements extend beyond a single EUI value and include matters such as embodied carbon, refrigerants and renewable energy.

Best practice approach

For a development, the clearest assessment is therefore not a single comparison. Each assessment should state:

• Planning compliance: Does the development meet the London Plan baseline?
• Best-practice design: Does it meet the London Plan aspirational target?
• Transition alignment: How does it compare with CRREM in 2030, 2040 and 2050?
• Net zero alignment: How does it compare with the applicable UKNZCBS pathway and wider standard requirements?
• Energy resilience: How effectively does the development generate, store, manage and use renewable energy on-site after demand has been minimised?

This would allow clients to understand why the figures differ, rather than being left to decide which number is ‘right’.

The draft London Plan’s move towards absolute operational energy targets should be welcomed. It creates a clearer basis for discussing how much energy a building should use and strengthens the link between planning-stage design and real operational performance. But it also demonstrates that introducing clearer targets does not, by itself, create a consistent basis for decision-making or actual in-use net zero aligned buildings.

Andy Crowther is Cundall’s building performance services associate