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December 2013:  In response to a series of Mayoral Questions (here, here and here) the Mayor has now posted his submission to the Department for Communities and Local Government (CLG) controversial (see here,  here, here and here)  Housing Standards Review report and consultation.

The MQ responses highlight that the Mayor has written to CLG’s Secretary of State, Eric Pickles, expressing “concerns with proposals for a National Standards set which could limit the GLA’s ability to apply planning policy on housing design and space standards as well as energy standards in new housing“.

The Mayor has also asked Mr Pickles to meet in order “to discuss these proposals, and requested the opportunity to make further comments, once CLG reaches a clearer position on the proposals”.

The Mayor’s submission document sets out that:

• London developments are already demonstrating that the carbon compliance level could be more stretching without undermining viability.
• London’s ‘interim’ standards should be retained and continue to be applied in accordance with the London Plan energy hierarchy
• Disputing the Housing Standards Review view that Government “does not believe that an interim level would be helpful to developers and is not minded therefore to set one in a nationally described standard”, the Mayor responds    “On the contrary, the setting-out of a clear strategy and requirements over time in the London Plan, including ‘interim’ targets between Building Regulations and Zero Carbon has effectively created market certainty, allowing developers to innovate and to bring down costs, in a manner that serves government’s intentions from 2016.“
• That the “solutions developers are obligated to consider under the London Plan ‘energy hierarchy’ do not lead to technological blind alleys. On the contrary, heat networks are fuel and technology flexible. Rather than creating ‘blind alleys’ they make the transition to zero carbon sources of heat easier” and that
• “In the absence of the [London Plan’s] approach” the Government’s proposed changes would  “undermine a key tenet of DECC’s Heat Strategy for cities“.

The submission importantly states that: “CLG have agreed to meet with GLA officers to discuss interim arrangements which allow the Mayor to maintain London Plan 2013-2016 carbon reduction targets”

A recent assessment of the energy policies under the London Plan – undertaken and published by the GLA – sets out that a significant level of energy-related commitments have been secured including:

• Equivalent of circa £32m investment secured through energy efficiency measures alone.
• Circa £20 million of investment in new CHP plant able to produce 29MW of electricity and heat.
• Circa £133 million of investment in communal heat network infrastructure for ~ 53,000 dwellings
• Circa 55 permanent jobs created in maintaining heat network infrastructure and associated energy supply plant. Additional jobs will also be created in the supply chain

The House of Commons Environment Audit Committee undertook their own review of the Housing Standards Review document, publishing their results on 20 November. The report echoes the Mayor’s sentiments stating:

• That local choice in favour of practical, sustainable local solutions will be radically curtailed and replaced with a lowest-common-denominator national standard
• That the proposed replacement for CSH standards on energy and carbon emissions, the 2016 zero carbon homes standard, has been significantly diluted

and goes further [para 33]:

• The specifications around the zero carbon homes target have been watered down to such an extent that the proposed standards in Building Regulations now fall some way short of the higher levels of the CSH.
• There is no guarantee that further dilution will not occur in the run-up to the implementation of zero carbon homes in 2016.
• DCLG must maintain CSH energy assessments as a tool for local authorities to lever in renewable energy until Building Regulations deliver genuinely zero carbon homes, which was the original target and is defined by CSH level 6.

There’s no information over whether the Mayor has met with Mr Pickles as yet – and CLG have as yet not indicated when they are to finalise and publish their conclusions to the Housing Standard Review’s proposals. However it’s clear that the London Plan’s energy and climate policies have – and are continuing to – create a major shift in the development of more energy efficient buildings in London. Developers, architects and sustainability experts are delivering some of the most innovative green buildings in the world here in London as a consequence of the London Plan, and hence it would be a huge surprise if the Mayor allowed his successful planning policies to be diluted by the Government’s latest – and hugely confused – zero carbon buildings proposals.