Draft London Plan 2026 consultation

The London Plan therefore sets standards that go beyond those in national Building Regulations. In doing so the Mayor is cognisant of the context of the draft NPPF which seeks to standardise energy-efficiency requirements at the national level. However reverting to national standards would not only undermine progress towards net zero and the fulfilment of his legal duties, but would represent a worsening of the current position in London which seems untenable in the context of the climate challenges facing the city. London has consistently and effectively achieved higher standards than those set by national requirements.

Section 5.19, 
GHR1 Energy efficiency, Draft London Plan

The Passivhaus Trust welcomes the climate leadership set out in the London Plan, with the strong commitment to set standards that go beyond those in national Building Regulations. The Passivhaus Trust is very encouraged by proposals being put forward in the draft London Plan and the adoption of absolute targets, such as space heating demand and Energy Use Intensity. 

The Trust also feels that the London Plan is adopting a sensible approach to measuring whether there is a need for heat networks in conjunction with low energy developments such as Passivhaus. The proposals for minimising overheating also closely mirror those put forward by the Passivhaus standard and methodology, encouraging passive cooling measures in the first instance, but accepting active cooling measures where needed ,and especially for buildings that require minimal energy to cool the building.

Ann-Marie Fallon, Co-Director, Passivhaus Trust

GHR1 Energy efficiency

Positive signs

Going beyond building regulations:  The Passivhaus Trust welcomes the fact that the London Plan is setting standards that go beyond those in national Building Regulations (5.19).

Use of absolute targets: The Passivhaus Trust welcomes the fact that absolute space heating and EUI targets are being adopted.  

Could improve

Passivhaus as ‘deemed to satisfy': The London Plan could have adopted a similar approach to what the Scottish Government is proposing and accept Passivhaus certified projects as ‘deemed to satisfy’ the energy efficiency requirements of the London Plan.

Adoption of PHPP as a compliance tool: Another improvement that could be made is that  Passivhaus Planning Package (PHPP) should be considered as an acceptable modelling route for compliance.  The London Plan’s pro-forma carbon reporting spreadsheet currently includes PHPP as an acceptable route for deriving the EUI estimates. 

GHR2 Low cost, low carbon heat

Positive signs

Introduction of Low Carbon Heat Appraisals: The Passivhaus Trust welcomes the requirement for Low Carbon Heat Appraisals to establish the lowest-cost, lowest-carbon heating solution for individual proposals and help decision-makers determine whether individual or communal systems are most appropriate.

Could improve

Make Passivhaus projects automatically exempt from having to connect to heat networks:  For certified Passivhaus projects. communal heat network systems will rarely be necessary as Passivhaus developments require minimal space heating. An automatic exemption would reduce the uncertainty about whether district heat networks are necessary for Passivhaus projects and help developer confidence.

GHR3 Whole life-cycle carbon

Positive signs

Targets for embodied carbon: The Passivhaus Trust welcomes and applauds the London Plan’s calls for developments to calculate and reduce upfront embodied carbon emissions.

GHR4 Heat risk

Positive signs

Active cooling combined with low energy requirements: The Passivhaus Trust believes that the London Plan has set out a sensible approach to minimising overheating,  In many cases, a limited and carefully considered use of active cooling may be appropriate as part of a wider overheating mitigation strategy. For energy efficient  homes such as Passivhaus, the cooling load is minimised, making it easier to deliver cooling discreetly, e.g. via a small unit.  

GHR10 Air quality

Could improve

Acknowledge the role of Passivhaus buildings in improving indoor air quality in polluted areas: Passivhaus homes and buildings have consistently good indoor air quality, thanks to the use of mechanical ventilation with heat recovery (MVHR). Pollutants from external air are filtered before entering a Passivhaus home or building. Passivhaus buildings can therefore reduce pollution exposure in buildings where external air pollution is high.