London Plan 2028 - Consultation
The London Plan, which sets strict planning requirements for building projects across the capital, is having its five-yearly makeover. 💄
The consultation is open until October 15th 2026, with adoption expected in early 2028.
As usual, I’m focusing on the energy performance section only. This is listed under the ‘Creating a Greener, Healthier and Resilient City’ section – GHR for short.
⚡ GHR1 – Energy Efficiency:
The Energy Hierarchy, which has been setting emission targets since the Merton Rule (ask your parents) has gone. No more Be Lean, no more Be Clean, and no more Be Green.
This is probably a pre-emptive move by the GLA... We’re expecting an update soon to the National Planning Policy Framework which could block local authorities from setting targets above Building Regulations. The logic here is the new Part L targets (under the Future Homes Standard) will be enough of a challenge for developers.
So instead of targeting carbon emissions, the proposed GHR1 targets Space Heat Demand and Energy Use Intensity on all major development. This is a similar approach to Manchester and bypasses any potential rules on exceeding Building Regulation requirements.
Refurb projects will also be expected to report on SHD and EUI figures and minimise them where possible.
New projects should maximise opportunities for renewable tech and storage in ways that benefit the occupiers, not the owners.
And post-occupancy monitoring of energy use for 5 years (previously known as ‘Be Seen’) remains in place.
🏙️ GHR2 – Low cost, low carbon heat
Doubling down on London’s ambitions to increase District Heat Networks throughout the city, all major development will need a Low Carbon Heat Appraisal; not just to review the carbon emissions of any heating system, but to also consider for the running costs for occupants.
♻️ GHR3 – Whole Lifecycle Carbon
The proposal sets a target of 500kgCO2/m2 for standard residential buildings, and 700 for high-rise.
Referable applications including existing buildings will need to consider the best lifecycle option between demolition and repurposing.
☀️ GHR4 – Heat Risk (aka Overheating)
Taking care not to tread on the toes of Part O, this requirement includes a new hierarchy of design features to naturally cool new homes, and states that TM59 modelling (the Dynamic route) must be used for checking overheating risk.
The new hierarchy has four tiers, starting with ways to provide cool spaces and shade, using light colour surfaces for roofs and walls, orientation and solar gains, and minimising waste heat, including the warm blast you get from standing too close to a heat pump condenser.
📚 Other GHR sections focus on flood risk, a new Drainage Hierarchy, biodiversity, green infrastructure, providing green spaces, protecting waterways, improving air quality, car parking and cycle storage.
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