GLA Delays use of New Energy Statement Guidance Until 01/08/2022

The GLA have delayed use of their new energy strategy guidance requirements until 31^st July 2022.  The information we provided last month remains correct except the go-live-date, which has been pushed back until the new software is available, on the 31^st July 2022.  The GLA have however added additional requirements and benchmarks. The following summarises the changes:

• The new requests include reporting energy use intensity (EUI) and targeting an overall onsite 50% CO₂ emissions reduction for dwellings. These two are not policy requirements, but an explanation will be expected if they can not be attained;
• EUI is an annual area weight measure of all building energy use and is linked to Be Seen. The GLA have set benchmarks for heating and overall energy use by building type;
• Overheating assessments are expected to be conducted in compliance with Approved Document O. The GLA have an expectation that even in the hotter conditions, most spaces will comply using passive measures. This is contrary to their own statement which acknowledges the challenge. Planning applications will therefore have to consider this carefully, potentially considering adaptive measures;
• The GLA’s guidance states it is not expected that active cooling will be proposed for any residential development. This raises questions for compliance with Part O especially in situations when windows cannot be opened, passive measures have been maximised and there are significant noise and/or air quality concerns. Could this lead to restricting development locations?
• Connection to existing heat networks is still to be prioritised but two added conditions will make CHP led networks challenging. The first condition is ensuring compliance with Part L 2021 minimum existing heat network parameters. The second would require existing heat networks to have a transition plan. Where this plant is not operational by 2027,
• As previously noted, the assessment methodology is now fully in alignment with Part L 2021.
• Dwellings must target a 10% reduction in CO₂ emissions through energy efficiency measures. This should be largely possible when achieving the Part L 2021 fabric requirements.
• Commercial units must target a 15% reduction in CO₂ emissions through energy efficiency measures. This is going to be very challenging as building services’ (heating, cooling, lighting, ventilation) efficiency drives the improvement. Part L 2021 utilises what current typical practice considers as very efficient and introduces solar photovoltaics (PV) to the comparison.
• Heat pump heat networks will continue to be prioritised for larger developments. Though the guidance still considers ambient loop technology as the lowest technology to consider on the heating hierarchy. This position may change should more developments require cooling. This is because currently the GLA guidance suggests that separate heating and cooling networks would be prioritised, which could be considered inefficient.
• The GLA policy requires maximising renewables therefore PV continues to be a requirement, though it will have less of an impact on the CO₂ emissions offset payment. It should be noted that new roof designs may be required to change to allow commercial units to have access to PV to allow them to comply with Part L requirements.
• Be Seen is a greater feature in the requirements linked through the energy hierarchy. The requirements to consider all energy use will require greater consideration as there are now formal metrics that are required to be reported.
• Whole Life Cycle Carbon Assessment (WLCCA) is a requirement for referable schemes and is discussed lightly in the guidance. The energy strategy results will be fed into the WLCCA assessment. The new requirements are not expected to have a significant impact on the WLCCA as the current benchmark do not consider energy use but require reporting.