Passivhaus Affiliate

London calling! Respond to the London Plan consultation

The London Plan currently pushes projects built within the Greater London Authority (GLA) to go beyond building regulations, promoting higher levels of energy efficiency. The Plan is currently out for consultation.  We need your help to ensure that these progressive policies are not watered down.

The Passivhaus Trust is submitting a response on behalf of its members and is asking supporters to submit a quick response before Sunday 22 June 2025 to reinforce the importance of maintaining the London Plan's current environmental leadership on energy efficiency.

View over London. Image credit: Pexels Nicole Rathmayr

 

The London Plan consultation

Statements within the London Plan Consultation document Section 5 'London’s infrastructure, climate change and resilience' include the following:

  • New construction in London is also a major contributor to carbon emissions. London Plan policies are currently leading to significant savings in carbon over what is required by national building regulations.
  • Several requirements in London go beyond national standards in recognition of the need to continue to drive towards net zero and tackle climate change. Many stakeholders have told us they would like the next London Plan to go further. This would avoid later costs of retrofit or replacement and recognise the wider cost to society and the economy of climate change. However, industry have also told us development costs and housing delivery can be impacted by these requirements, particularly cumulatively. Whatever policies are included, we need to look at streamlining their implementation and use assessments and measures that are already well used by industry. This will avoid unnecessary delay or cost
  • Updated national building regulations mean that energy efficiency standards for new buildings have increased since 2021. However, they are still some way from being net zero and the current London Plan still goes beyond national requirements.The London Plan could leave energy efficiency to the new national standards, and any future standards which are expected to be more stringent (although still not net zero because they do not include off-setting). Alternatively, it could retain the current approach, or amend it in line with the options set out below.
  • Under the current plan, a proportion of the carbon savings can be met off site. The London Plan could increase the proportion of carbon savings needed on site through energy efficiency measures, to reduce demand on the electricity grid.
  • The London Plan could move to different energy standards for buildings. For example, the measures emerging from industry practice or being used by boroughs in their updated local plans. It could also change the thresholds at which policies apply (for instance, applying policies to smaller developments than we currently do). Any standards should be set at an achievable level that also drives continued performance

Passivhaus Trust position

The Passivhaus Trust has developed a brief consultation response, focusing on the energy efficiency, overheating and heat network elements of the London Plan consultation. 

Download the Passivhaus Trust's London Plan consultation response

The main, overarching, response is below and relates to the overall ambitions of the London Plan: 

5.1 Energy efficiency standards

The Passivhaus Trust strongly disagrees with the suggestion to ‘leave energy efficiency to the new national standards’. It is  our understanding that the proposed Future Homes Standard will not improve the fabric energy efficiency of homes beyond current building regulations. The London Plan currently pushes projects built within the Greater London Authority (GLA) to go beyond building regulations, promoting higher levels of energy efficiency for newbuild homes & buildings.

GLA’s own 2023 Energy Monitoring Report states: “GLA’s policies continue to push beyond national Building Regulations and demonstrate that these ambitious targets can be met by applicants...Energy efficiency measures help to keep London’s homes warmer in winter, cooler in summer, and residents’ bills down. This is why local authorities must retain powers to set standards above national regulations”.  2023 Energy Monitoring Report monitoring data demonstrated the positive impact that the London Plan is having on reducing carbon emissions. 

The Passivhaus Trust argues that the current requirements within the London Plan are already doing much to encourage projects that go beyond building regulations, demonstrated by the rapid growth of Passivhaus social housing in London,

In fact, the Passivhaus Trust agrees with the proposal in the consultation that the London Plan should increase the proportion of carbon savings needed on site through energy efficiency measures, to reduce demand on the electricity grid. If absolute metrics are used to measure this, delivering to the Passivhaus standard should be an easy way for projects to achieve these savings. 

 

Respond before 22 June 2025

Please complete the survey relating to Section 5: London's infrastructure, climate change and resilience survey reiterating the Passivhaus Trust points outlined in the grey box above and disagreeing with the suggestion that the London Plan should ‘leave energy efficiency to the new national standards’. Please add it to the survey box Paragraph 5.1: Energy efficiency standardsIf you want to add anything further, you can read our longer response which includes other key recommendations.

Respond to the London Plan consultation

Further information

The London Plan Consultation 2025 - Passivhaus Trust Response

Towards a new London Plan

Passivhaus & Local Plans

Passivhaus & Building Standards

Previous PHT story: The London Plan & Passivhaus - 1 March 2025

19th June 2025


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