KJ Tait

London Plan: Polices that Impact on Sustainable Building Design

London Plan
Date
1 September 2025


London Plan | Energy, carbon and planning success

London Plan policies that impact sustainable building design in 2026

By KJ Tait. Last updated

The London Plan sets the route to net zero‑carbon for major developments. This guide explains what design teams must do to comply with Policy SI 2, integrate heat networks under SI 3, manage overheating under SI 4, and deliver Whole Life‑Cycle Carbon and Circular Economy statements that pass GLA scrutiny. It also shows how KJ Tait streamlines pre‑app to decision with the right evidence at the right time.

What the London Plan requires in 2026

Major developments must be net zero‑carbon in operation by following the energy hierarchy and demonstrating a minimum on‑site reduction of at least 35 percent beyond Part L 2021. Any shortfall is paid into the borough carbon offset fund. Residential schemes are commonly expected to exceed the minimum through fabric‑first design, efficient services and on‑site renewables.

  • SI 2: Net zero‑carbon, energy hierarchy and ‘Be Seen’ operational performance reporting
  • SI 3: Heat network connection or future‑proofed low‑carbon heat
  • SI 4: Cooling hierarchy and dynamic thermal modelling to manage overheating
  • WLC: Whole Life‑Cycle Carbon assessment at pre‑app, planning and post‑construction
  • SI 7: Circular Economy Statement with clear targets and post‑construction reporting

Tip Submit the GLA Carbon Emissions Reporting Spreadsheet with your Energy Strategy and budget the borough’s carbon offset price early to avoid surprises at committee.

Useful guidance GLA Energy Planning Guidance ·
Energy Assessment Guidance (June 2022)

The energy hierarchy Be Lean, Be Clean, Be Green, Be Seen

The energy hierarchy must drive decisions from RIBA Stage 1. Reduce demand first, then optimise systems, add renewables, and plan post‑occupancy monitoring and reporting.

Diagram showing the London Plan energy hierarchy with typical KJ Tait measures for Be Lean, Be Clean, Be Green and Be Seen
London Plan energy hierarchy with typical KJ Tait measures to de‑risk planning and delivery.

For planning, include a concise Energy Strategy, EUI and space‑heating‑demand reporting, the GLA spreadsheet, and a metering plan that enables ‘Be Seen’ reporting at as‑built and in‑use stages. See
‘Be Seen’ energy monitoring guidance.

Heat networks and heat pumps under SI 3

Assess connection to existing or planned heat networks, particularly in Heat Network Priority Areas. Where connection is not feasible, design systems that are low‑carbon today and future‑proofed for connection tomorrow. Align return temperatures, diversity, metering and controls with the London Heat Network Manual.

Reference London Heat Network Manual II

Managing heat risk under SI 4

Follow the cooling hierarchy to avoid reliance on active cooling. Provide dynamic thermal modelling against CIBSE criteria, optimise glazing, shading and ventilation, and use urban greening to mitigate urban heat island effects.

Reference Policy SI 4 Managing heat risk

Whole life‑cycle carbon and the circular economy

Submit the GLA WLC template at pre‑app, planning and post‑construction. Pair it with a Circular Economy Statement that demonstrates material retention, design for adaptability and disassembly, and >95 percent diversion of construction and demolition waste from landfill.

References Whole Life‑Cycle Carbon guidance ·
Circular Economy Statement guidance

Our process, deliverables and programme

  1. Pre‑app strategy. Energy, WLC and CE scoping with route‑to‑consent risks highlighted
  2. RIBA 2/3 energy model. EUI, space‑heating demand, overheating analysis and heat‑network feasibility
  3. Planning submission. Energy Strategy, GLA spreadsheet, WLC template, CE Statement, metering and Be Seen plan
  4. Post‑decision. S106 and conditions support, as‑built updates and Be Seen reporting setup

Explore our related services Energy strategy for planning ·
Whole life‑cycle carbon ·
Circular economy ·
Overheating and climate resilience

Ready to discuss a live scheme or pre‑app route to consent talk to one of our sustainability experts.

Frequently asked questions

What is the minimum on‑site carbon reduction required

At least 35 percent beyond Part L 2021 for major developments, with residual emissions offset via the borough fund. Many residential schemes are expected to exceed this through fabric‑first measures, efficient services and on‑site renewables.

Do I have to connect to a heat network

You must assess connection feasibility where networks exist or are planned. If connection is not viable, the design should be future‑proofed for a low‑carbon network and comply with performance factors set out in the Energy Assessment Guidance.

What does ‘Be Seen’ change for my project

You must submit performance estimates at planning, then provide as‑built and five years of in‑use energy reporting through the GLA process. Plan metering, data points and ownership early to avoid conditions risk.

How do Whole Life‑Cycle Carbon and Circular Economy statements interact

They are two halves of the same planning test. The Circular Economy Statement sets the strategy to retain existing structure where appropriate, minimise new materials, and design for adaptability and disassembly. The Whole Life‑Cycle Carbon (WLC) assessment then quantifies the carbon effect of those choices across the full life cycle (A1–A5, B1–B7, C1–C4 and D).

  • Data flow. Your CE bill of materials and reuse or recycled content targets feed the WLC material quantities and end‑of‑life assumptions. WLC optioneering should compare retention and refurbishment versus rebuild to evidence the CE approach
  • Staging. Both are submitted at pre‑app, planning and post‑construction. At post‑construction, the CE outcomes and the as‑built WLC should reconcile with actual material quantities and site data
  • Outcomes. CE measures