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Sustainability statements in planning applications

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Sustainability statements in planning applications

We adopted revised local area requirements in July 2018 and are currently in the process of updating this guidance page. Check the list of Local Area Requirements July 2018 for the most up to date information before submitting your application.

The information below provides further details about:

  • when a sustainability statement is needed
  • what information this document should include
  • how to submit it to us
  • where further information can be found.

When is a sustainability statement needed?

A sustainability statement should be sent with applications for:

  • All new build residential houses and flats
  • Multi-occupation residential buildings with 10 or more rooms/units or occupiers
  • Residential refurbishments, conversions and change of user for:
    • 5 or more dwellings, or
    • 500sqm or more of floorspace
  •  Non-residential development of 500sqm or more of floor space (including offices, retail and industrial)

What information should be included in a sustainability statement?

You must provide details of sustainable design and construction measures. This must show how you propose to reduce the energy, water and materials used in design and construction.

The sustainability assessment tools that Camden uses is:

The assessment that should be provided is:

Energy – new and existing development

Sustainability and energy proforma

Complete and submit with all major planning applications

Complete and submit with all minor non-domestic planning applications and domestic planning applications in which 1-9 new units are being created and are less than 1000 square metres GIA.

Sustainability considerations following the Ministerial Statement March 2015

Following the Ministerial Statement 25 March 2015, Camden wants to clarify its position on sustainability considerations in connection with existing policies:

  • CS13 Tackling climate change through promoting higher environmental standards
  • DP22 Sustainable design and construction
  • DP23 Water.

The Ministerial Statement sets out the Government’s national planning policy on the setting of technical standards for new dwellings. The Housing Standards Review sought to rationalise differing standards. In doing so it has withdrawn the Code for Sustainable Homes (except for legacy cases). It has set a new system of optional Building Regulations on water and access as well as a new national space standard.

The 2015 – 2016 Minor Alterations to the London Plan was prepared to bring the London Plan in line with the national housing standards. The Minor Alterations are available here.

Sustainable design and construction measures

London Plan policy 5.3 ‘Sustainable design and construction’ removes requirements for the Code for Sustainable Homes. However, it continues to need developments to show that sustainable design standards are integral to the proposal. This includes its construction and operation. The Council will continue to require you to submit a Sustainability Statement with applications for new residential development. This should show how the development mitigates against the causes of climate change and adapts to the effects of climate change. This is in line with existing policies contained in:

  • Camden’s Core Strategy CS13 Tackling climate change through promoting higher environmental standards
  • Development Policies document DP22 Sustainable design and construction.

Proposals should show how sustainable design and construction principles have been incorporated into the design and proposed implementation. This includes the relevant measures as set out in DP22 page 104.

Acceptable new residential schemes must ensure that the measures stated in the Sustainability Statement are secured and implemented.

Water

New residential developments must show that the development is capable of achieving a maximum:

  • internal water use of 105 litres per person/day
  • an additional 5 litres person/day for external water use.

Energy

The Council will continue to apply policies which need compliance with energy performance standards until the Planning and Energy Act 2008 has been amended (likely late 2016). The Code Level 4 equivalent in carbon dioxide emissions reduction below part L Building Regulations 2013 is 20 per cent. New residential dwellings will be required to demonstrate how this has been met by following the energy hierarchy in an energy statement.

The London Plan policy 5.2 for on-site carbon reduction measures will still apply for new residential major applications.

Please note that policy CS13 also requires that all developments (existing and new build) achieve a 20 per cent reduction in on-site carbon dioxide emissions through renewable technologies, unless demonstrated that such provision is not feasible.

London Plan target for carbon dioxide emission reduction

From January 2020

The London Plan requires major developments to achieve zero carbon (with at least 35 per cent reduction achieved through on-site measures). New development is expected to get as close as possible to zero-carbon on-site, rather than relying on offset fund payments to make up any shortfall in emissions.  The remaining carbon emissions (to 100 per cent) are to be offset through a cash in lieu contribution.

For further information and guidance see Energy Planning - GLA Guidance    

In view of the Viability Study (pdf) undertaken for the London Plan, the Council considers £95 per tonne for 30 years to be appropriate.  This would equate to £2,850 per tonne.

From October 2016 until December 2019

From October 2016 London Plan policy 5.2 requires major residential developments to achieve zero carbon (with at least 35 per cent reduction achieved through on-site measures). The remaining regulated carbon emissions (to 100 per cent) are to be offset through a cash in lieu contribution. For further information and guidance please see this link. Major developments for non-domestic development will still be expected (as above) to achieve 35 per cent reduction against Part L 2013 Building Regulations.   

In view of the Viability Assessment undertaken for the Minor Alterations London Plan the Council considers £1,800 per tonne of carbon (30 years) to be appropriate (both residential and non-residential development). The viability assessment can be viewed here, under the heading ‘Evidence base’.

Up to October 2016

London Plan policy 5.2 requires that major developments meet carbon dioxide emissions reduction. From 2013 to 2016 this emissions reduction is 35 per cent against Part L 2013 Building Regulations for both domestic and non-domestic buildings. Where evidence demonstrates that this target cannot be achieved on-site, the policy allows for any shortfall to be provided off-site or through a cash in lieu contribution. Contributions will secure the delivery of carbon dioxide savings elsewhere in the borough.

The Mayor’s Sustainable Design and Construction SPD states that boroughs should develop and publish a price for carbon dioxide based on either: a nationally recognised carbon dioxide pricing mechanism; or the cost of reducing carbon dioxide emissions across the borough. The Mayor’s guidance states that where boroughs do not have an established price a figure of £60 per tonne for a period of 30 years should be applied. However, the August 2013 zero carbon consultation suggested three possible price caps for carbon £30, £60 and £90. Camden’s inner London landscape will make it more challenging and expensive to deliver carbon reduction measures, and therefore we would expect that the highest price of £90 per tonne is appropriate for this target. This will equate to £2,700 per tonne of carbon (30 years).

Flooding

See the Water and Flooding planning guidance on this page.

How do I submit a sustainability statement?

If you apply for planning permission online using the Planning Portal, you will be given the opportunity to upload your sustainability statement. This is after you have completed the relevant application forms.

Before uploading any files, please read our guidance notes for submitting electronic files with planning applications (PDF).

If you choose to submit a paper-based application instead, you will need to provide:

  • four copies of your sustainability statement
  • four copies of the relevant application forms.

Where can I find out further information?

For further information on preparing and submitting a sustainability statement, please see the links below: