Planning Advice Note

Whole Lifecycle Carbon Optioneering

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ISSUE STATUS: FINAL

HM REFERENCE: 32412-01

Author M Schembri

Checker V Ugarow

Approver A Moore

Copyright © Hilson Moran 2022. All rights reserved. This report is confidential to the party to whom it is addressed and their
professional advisers for the specific purpose to which it refers. No responsibility is accepted to third parties, and neither the
whole nor any part of this report nor reference thereto may be published or disclosed without the written consent of Hilson
Moran.

Issue Date By Details

00 29.03. 2022 MS/ AM Draft issued for comments
01 10.04.2022 MS/ AM Second draft for comments
02 29.04.2022 MS/ AM Internal draft update
03 03.05.2022 MS/ AM Final draft for comments
04 10.05.2022 MS/ AM Updated interim Draft for member comment—
Certain sections due for completion.
05 19.05.2022 MS/ AM Final following CoL comments of 4.5.22
06 25.05.21 MS/ AM Final issue

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Contents

Executive Summary 4

The Climate Emergency 6

City Action Strategy 2020-2027 7

1. Carbon in Planning Policy 11

2. Related Reporting Requirements 14

3. Whole Lifecycle Carbon Assessments 18

4. Carbon Optioneering 20

5. Optioneering Considerations 21

6. Other Policy Opportunities 24

7. Planning Application Trends 28

8. Methodology 30

9. Dashboard 32

Appendices 36

Appendix 1: Non-Policy Related Reporting for Net Zero Carbon

Appendix 2: Detailed Building Element Scope

Appendix 3: GLA WLCA Pre-app Proforma

Appendix 4: Indicative example of completed Table A

Glossary

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Executive Summary

The City of London Corporation (CoL) has committed to Net Zero Carbon (NZC) for
both embodied and operational carbon emissions by 2040. The Climate Action
Strategy sets up a fully-funded action plan to deliver and achieve annual targets
against a decarbonisation pathway.
Hilson Moran was appointed to develop a Planning Advice Note on Whole
Lifecycle Carbon emission options. The purpose of this study is to advise on:
• The merits of a Whole Lifecycle Carbon (WLC) emission options appraisal as
part of the pre-application process to ensure that development proposals
maximise the reduction of carbon emissions;
• The scope and methodology of comparative Whole Lifecycle carbon
emission options for development proposals;
• To ensure a like for like comparison and consistency of projects submitted
for planning.
The majority of planning applications, 76%, fall under the City’s definition of Major
development. The remaining applications are varied full implications covering
change of use and extensions. This means that major development will be
responsible for a large proportion of new emissions in the City of London.
As a result The City of London Corporation expects that all major development
undertake a Whole Lifecycle Carbon Assessment (WLCA). Full applications should
aim to follow this guidance wherever possible. This is also support by GLA WLC
guidance for major applications to undertake Whole Lifecycle Carbon Assessments
(WLCA).
Recent planning applications have reported development optioneering and (WLCA
in different ways. The diversity of approaches between pre-application material
and planning application is making it very difficult for CoL to establish the level of
consistency and what to look out for in results/data being proposed alongside the
Climate Action Strategy targets.
This Planning Advice Note establishes the variety of ways by which carbon is
estimated in the current planning process, and how they can vary between them.
A methodology is proposed that requires options for different degrees of major
interventions in the commercial built environment to be considered and
presented.
The methodology establishes the minimum data required at the pre-planning and
planning stages, and the level of transparency to be disclosed to CoL. The proposal
aligns with the GLA’s new guidance on Whole Lifecycle Carbon Assessment
reporting (March 2022).
A dashboard has been created to equip CoL with easy, visual and quantified
information that is clear and benchmarkable, enabling an informed discussion
between them and the Applicant party.
Future updates of the methodology may be required as the market matures, and
industry standards and assessment tools become more robust and reliable.

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5
The Climate Emergency
‘Human activities which result in the release of greenhouse gases, including carbon
dioxide (C02), are estimated to have caused 1°C of global heating above pre-
industrial levels. As a result, there have already been sea level rises, increased
likelihoods of extreme weather events and melting of sea ice and permafrost. This
has direct and devastating impacts on society, including land loss; increased
severity and occurrence of wildfires; drought; and difficulties producing food.
Alongside this, there have been unprecedented declines in global biodiversity, with
the average abundance of native species in most major land-based habitats falling
by at least 20%, mostly since 1900. The quality of habitats which support this
biodiversity has also declined, with a 30% reduction in global terrestrial habitat
integrity caused by habitat loss, fragmentation and deterioration.’ (CIEEM, 2019)
Global emission need to decrease by 43% by the end of this decade to stay under
the 1.5 degree C, the current recommended threshold to avoid unprecedented
heatwaves, terrifying storms, and widespread water shortages. (IPCC 2022)
The built environment contributes 25% of UK greenhouse gas emissions (CO 2e) that
it has direct control over. If influenced emissions, surface transport (vehicle
emissions) are included it contributes around 42% of the UK’s total greenhouse gas
emissions, CO2e. (UKGBC ,2021)
The property and construction industry has a moral duty to act and reduce the
environmental impacts of this sector as well as mitigate the effects of Climate
Change.

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Climate Action Strategy 2020-2027
The City of London is major global commerce centre with huge influence and
opportunity to lead the Net Zero Carbon and Climate Change mitigation and
adaptation agenda.
The City of London Corporation has adopted a radical Climate Action Strategy which
breaks new ground and sets out how the organisation will achieve net zero, build
climate resilience and champion sustainable growth, both in the UK and globally,
over the next two decades. By adopting the strategy, the City Corporation has
committed to:
• Achieve net zero carbon emissions from their own operations by 2027
• Achieve net zero carbon emissions across their investments and supply
chain by 2040
• Support the achievement of net zero for the Square Mile by 2040
• Invest £68m over the next six years to support these goals of which £15m
is dedicated to preparing the Square Mile for extreme weather events
The City of London Corporation (CoL) has set out a fully funded action plan for 2020
-2027 and set annual targets. Data on progress will be shared via a programme
dashboard, expected to go live for the public mid-2022. At the end of each year CoL
will publish a report of progress against targets for that year. Stakeholders will be
invited to participate in a survey to help us understand how well they are reaching
and engaging with them.

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Climate Action Strategy 2020-2027

Headlines

Vision, aims & goals

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Actions

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1. Carbon in Planning Policy

This section outlines the ways by which carbon emissions quantification and
reduction are required to be reported for planning applications in the City of
London in the recent past.
In short, planning applications are required to report both:
• Embodied carbon emissions, i.e. carbon emissions resulting from Figure 1: The proposed amendment of the
materials, construction and the maintenance of a building lifecycle, and Building Regulations, Part Z, to regulate
embodied carbon, was launched in March 2022.
• Operational carbon emissions, from energy consumption throughout the
lifecycle of the building.
However, the scope of reporting in applications is determined by several factors
relating the type of application, the size of the building and the scope of the
intervention proposed.
There are a number of policy and guidance documents that determine reporting
requirements:
1. Building Regulations: At a national level, ‘Approved Document L2A:
Conservation of fuel and power in new buildings other than dwellings’ (‘Part
L2A’) regulates some elements of design and specification of buildings that
affect energy consumption, including insulation, solar control, the efficiency
of building services and renewable energy generation. Part L sets minimum
requirements and targets for carbon emissions and defines the carbon
intensity of fuel and power. An update being implemented from June 2022,
which tightens target requirements and introduces a minimum Primary
Energy metric to place more emphasis on reducing energy demand with
less reliance on renewable energy generation. ‘Unregulated emissions’ refer
to the elements of energy use that sit outside Part L and includes carbon
emissions from plug-in equipment and cooking.
Embodied carbon emissions are not regulated at a national level. A bill was
proposed in Parliament in February 2022 to change this based on a
proposed Part Z, developed by industry experts.
Figure 2: The draft City Plan 2036 is currently
being revised to align with policy and market
2. City of London policy: City of London’s Local Plan (2015) aligns with the changes
London Plan (see point 3) at the time of its adoption. The London Plan has
subsequently been updated (2021). The adopted Local Plan focusses on
reducing operational ‘regulated’ carbon emissions resulting from energy
used in operation, low and zero carbon technologies for on-site and local
energy generation (including existing and planned District Energy
Networks), local and national carbon offsetting mechanisms. Carbon offsets
are required for a 30-year period of operation but there is no specific
mention of unregulated carbon and embodied carbon (WLCA) in this policy
document. However policy CS 15 does state that development should
‘avoid demolition through reuse of existing building or their main
structures...’
The Local Plan is being reviewed and a replacement Plan, City Plan 2040, is
in preparation. This draft Plan refers to the London Plan’s carbon emissions
requirements towards achieving whole lifecycle net zero carbon emissions.
Further updating of the draft Plan will be undertaken during 2022 to ensure
that it aligns with the London Plan, recent Mayoral guidance and best
practice in the City development market and puts policies in place to deliver
the City Corporation’s Climate Action Strategy targets.

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1. Carbon in Planning Policy

3. Greater London Authority (GLA) policy: The Mayor of London’s London Figure 3: The new London Plan Guidance ‘Whole
Plan 2021 requires proposals referable to the mayor to be net zero carbon. Lifecycle Carbon Assessments’ March 2022, sets
out a framework of priorities and carbon
The policy requires calculation of whole lifecycle carbon emissions through information required
a nationally recognised whole lifecycle carbon assessment, and to
demonstrate actions taken to reduce lifecycle carbon emissions.
Reporting requirements and the scope of the assessment are defined in the
London Plan Guidance ‘Whole Lifecycle Carbon Assessments
(WLCA)’ (adopted 25th March 2022). WLCA reporting is required at pre-
application, application and as built stages of schemes that are referable to
the Mayor, but is also encouraged for all major developments. All studies
account for a 60-year lifecycle.
The Guidance document is recognised as industry-leading. It has a detailed
list of information to be included for materials across a number of Lifecycle
Assessment (LCA) modules (table 1) as well as including estimations for
demolition emissions and emissions from refrigerants.
The Mayor of London’s London Plan 2021 also sets out a clear energy
hierarchy for net zero operational carbon emissions. It defines the process
required for reducing these emissions, clarifying local priorities for heating
and cooling strategies, setting minimum target savings and local carbon
offsetting mechanisms. The carbon savings targets are based on regulated
operational carbon and a 30-year lifecycle. Reporting unregulated carbon is
encouraged through the design process and building infrastructure
provision. Other policy requirements are in place for on-site energy
generation and energy storage.
The Mayor of London’s draft ‘Energy Assessment Guidance (April 2020)’
clearly outlines reporting requirements for planning applications to Figure 4: Regulated target operational carbon
demonstrate that the proposed climate change mitigation measures comply emissions are reduced further by local planning
with London Plan energy policies, including the energy hierarchy. policy minimum requirements

The ‘Be Seen Energy Monitoring Guidance’, (September 2021) explains the
process that needs to be followed and reporting requirements to
demonstrate compliance with the London Plan policy addressing the
monitoring, verifying and reporting of energy performance after a building’s
practical completion (‘Be Seen’ level of the Energy Hierarchy).

Figure 5: The Energy Hierarchy defines policy priorities and

interim targets to Net Zero Carbon in operation

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The following table outlines the typical current carbon reporting scopes driven by national and local
policy requirements in the City of London.
As stated earlier (’City of London policy’), the current planning policy for major developments in City of
London do not require a WLCA. However, it does require the achievement of a minimum BREEAM
‘Excellent’ certification rating, with a provision to ideally achieve ‘Outstanding’. BREEAM does include
criteria relating to Lifecycle Assessment, Environmental Product Declarations and Circular Economy.
These aspects of design and procurement are therefore typically addressed in proposals targeting a
minimum ‘Excellent’ rating.
The BREEAM scope for Lifecycle Assessment extends between Stages A and C, but the scope of
building elements to be included is optional and limited compared to the GLA approach (see table 4,
Page 18). BREEAM does not currently require an as built review of embodied carbon performance.
The total lifecycle carbon of major, non-referable planning applications with reduced scopes, e.g.
limited to addressing BREEAM requirements for fewer building elements, are not comparable to GLA
benchmarks. Note that Modules B6, B7 and D (EN 15978: 2011 Sustainability of construction works.
Assessment of environmental performance of building) are excluded from the GLA WLCA benchmarks.

National – GLA referable Major Minor

Scope (Stages based on EN
Sub-groups Building developments developments developments
15978)
Regulations in CoL in CoL* in CoL

Product and Construction Process (Practical Completion) Stage

A1-A3 Construction
product supply, transport ✓ ✓
and manufacturing
A4-A5 Transport to site
✓ ✓
and Construction
Use Stage
B1-B5 Operational
emissions relating to
maintenance, repair, ✓ ✓
replacement and
refurbishment
✓ ✓
Whole life cycle carbon

30 years for 30 years for

✓ carbon carbon Depends on
Regulated
B6 Operational energy use 1 year offsetting offsetting scope of works
60 years for 60 years for
reporting reporting
Unregulated ✓ ✓
B7 Operational Water Use ✓ ✓
End of Life Cycle Stage
C1-C4 End of life stage
including deconstruction,
demolition, transport, ✓ ✓
waste processing and
disposal
Beyond the Project Lifecycle
D Stages beyond the life
cycle, including re-use, ✓
recovery, recycling

Table 1: Scope of whole lifecycle carbon reporting in the City of London. Major developments’ scope of works are currently dictated by 13
BREEAM requirements
2. Related reporting requirements
There are a few other carbon-related planning reports that should be taken into
consideration. They include Greenhouse Gas impact assessments, the Circular
Economy Statement, operational energy and water assessments. Where relevant,
these should be referenced or summarised in WLCA reporting, in particular to
highlight discrepancies and overlaps in design considerations and decisions.

GHG reporting in Environmental Impact Assessments

A greenhouse gas (GHG) is a gas that absorbs and emits radiant energy within the
thermal infrared range, essentially, they trap heat causing the greenhouse effect.
Very large developments, such as infrastructure projects and high-rise buildings,
usually require a GHG chapter within the Environmental Impact Assessment
scoping for a planning application.
In February 2022 the Institute of Environmental Management and Assessments
(IEMA) published an update to their guide ‘Assessing Greenhouse Gas Emissions
and Evaluating their Significance’ (2nd ed.) to align with government and industry
agendas. The methodology for writing this environmental impact assessment
chapter includes a full lifecycle scope, aligning with parts of the GLA WLCA method
above. The approach covers similar themes but may not be as detailed as a full
WLCA due to the timing of the assessment.
The differences in the approach include:
a. A range of gases is broader than carbon (Carbon Dioxide CO 2) and includes
methane (CH4), nitrous oxide (N2O), and ozone (O3);
b. The scope of emitters is broader, including for example emissions from
operational transport and leaking F-gases (refrigerants). Note, GLA requires
separate calculation of refrigerant emissions in the reporting WLCA
template;
c. The proposal is compared to a current baseline;
d. Exclusions, metrics, data quality, degree of uncertainty and mitigation
measures need to be clearly defined; and
e. They could be carried out a lot earlier than a detailed application WLCA (to
GLA standards), for example for an Outline Planning Application, and
therefore the data tends to be based on industry averages / benchmarks.
The process and content of a GHG assessment is structured by the IEMA guidance
and should not preclude the need for a WLCA. In many cases, the information in
relation to carbon in a GHG assessment may differ from that of a WLCA due to
timing and the accuracy of information available at the time of assessment.

Table 1: GHG Management Hierarchy, 2020 (Source: EIMA, Assessing Greenhouse Gas Emissions and Evaluating their Significance’ (2nd ed.) 14
GLA Pre-application optioneering

The London Plan Guidance ‘Whole Lifecycle Carbon Assessments’ (March 2022)
explains how to calculate WLC emissions and the information to be submitted to
comply with the policy, including the scope required. It also includes information on
design principles and WLC benchmarks (by lifecycle stage) to aid planning applicants
in designing buildings that have low operational carbon and low embodied carbon.
A WLC assessment template needs to be completed in four parts, namely, at pre-
application, planning submission (outline and details) and post construction (prior to
occupation).
The GLA encourages WLC assessments on major applications that are not referable to
the Mayor. The City of London is supportive of this approach. In addition to the
above, CoL will condition a more detailed update of the WLCA following the detailed
design phase (RIBA Stage 4) when more design and procurement information is
available to the Applicant team.
The GLA’s pre-application section includes a hierarchy of WLC reduction principles
(see Appendix 3 for full list). Principle 1 relates to options for ‘significant retention
and reuse of structures’ as shown in table 2 below, requiring examples to
demonstrate that:
• Options for retaining existing buildings and structures have been fully explored
before proposing substantial demolition, including incorporating the fabric of
existing buildings into the new development (aligned with London Plan
Guidance for Circular Economy Statements , March 2022);
• Carbon emissions associated with pre-construction demolition are reported
separately;
• An estimate of the percentage of the new build development which will be
made up of existing façades, structures and other key components is reported
• An optional requirement to report on the effects of future grid
decarbonisation on the development’s embodied carbon emissions.
• The WLC principles are informing the proposed development of the site.
If substantial demolition is proposed, applicants will need to demonstrate that the
benefits of demolition would clearly outweigh the benefits of retaining the existing
building or parts of the structure.
Further considerations and options in relation to the retention of building elements
and material are required by the Circular Economy principles (see following page).
Note, the GLA (and optionally BREEAM) requires the reporting of refrigerant Global
Warming Potential emissions in kgCO2e/m2GIA. This is often excluded from WLCA.
Measures can be installed to prevent and manage refrigerant leakage to atmosphere.
We recommend that CoL condition a requirement for leak detection and containment
to form part of the commissioning process.

WLC reduction principle: 1. Reuse and retrofit of existing buildings

Key benefit: Significant retention and reuse of structures is carbon efficient and reduces construction costs
Provide examples of how reduction principle has been used, or give reasons why is cannot be used.

Confirmation that options for retaining existing buildings [Outline the options that have been considered - plus an explanation
and structures have been fully explored before considering of opportunities and limitations, and why demolition outweighs the
substantial demolition benefits of retaining existing buildings/structures where applicable]

Carbon emissions associated with pre-construction [If estimates are not possible, please apply standard assumption of
demolition (kgCO2e) 50kgCO2e/m2 of the existing building/s]

Estimate of the percentage of the new build development [e.g. X% existing facades; Y% existing foundations; Z% superstructures
which will be made up of existing elements etc.]

Table 2: Retention of existing building and structures from the GLA WLCA assessment template, March 2022 15
 2. Related reporting requirements

Circular Economy Statement

The Mayor of London’s London Plan 2021 requires proposals referable to the Figure 6: The new London Plan Guidance
Mayor to calculate a development’s impacts and solutions to meet circular ‘Circular Economy Statements’ sets out the
economy principles. It sets out the aim of retaining material at their highest value principles to be adopted to demonstrate the
for as long as possible, to increase reuse and recycling, leaving minimal residual adoption of circularity in design and construction
waste.
The reporting requirements and scope of the assessment are described in a London
Plan Guidance ‘Circular Economy Statements’ (adopted 25th March 2022), which
structures a reporting framework and principles to be considered by all referable
applications. This needs to be considered alongside the WLCA.
The guidance includes requirements for a decision pathway to be outlined and for
pre-redevelopment and pre-demolition audits, which need to be communicated at
the earliest stages possible. The aim is for projects to incorporate these into a their
brief at procurement stage.
The guidance sets out six principles which are seen as critical to the design process:
1. Building in layers, ensuring that different parts of the building are accessible
and can be maintained and replaced where necessary
2. Designing out waste, ensuring that waste reduction is planned in from
project inception to completion, including consideration of standardised
components, modular build, and reuse of secondary products and materials
3. Designing for longevity
4. Designing for adaptability or flexibility
5. Designing for disassembly
6. Using systems, elements or materials that can be reused and recycled.
The principles apply the waste hierarchy to reduce or avoid waste wherever
possible and to try and ensure that materials are applied and used at their highest
value.
The concept for building in layers, attributes design life to different aspects of the
building in terms of skin, shell, structure/frame, building services, space plane
interior, stuff and contents.

Figure 7: Decision tree for design approaches to existing structures/buildings -GLA Circular Economy Guidance March 2022 16
The WLCA includes B6 Operational Energy and B7 Operational Water. CoL
planning policy currently requires energy and water consumption reporting
elsewhere. This section clarifies the requirements and overlaps between reporting
requirements. GLA benchmarks exclude stages B6 and B7.

Operational Energy modelling

NABERS UK ‘Design for Performance’ (DfP) and CIBSE TM54 ‘Evaluating operational Figure 8: The new revised CIBSE Technical
energy use at the design stage’ (2022) are increasingly being used by applicants to Manual for evaluating operational use at the
more accurately estimate and reduce operational energy during design, and to design stage provides and framework for more
inform metering, commissioning and management requirements to maintain low accurate prediction of regulated and
energy consumption throughout a building’s lifecycle. unregulated energy consumption

BREEAM New Construction’s (optional) operational energy modelling requirements

are similar. NABERS UK is the most onerous approach of the three because of
independent design reviews required during design, post completion and post
occupancy seasonal monitoring, and tuning, metering infrastructure criteria to
facilitate annual rating and annual energy rating updates. Note that the UK
Government is proposing to introduce a new obligatory energy rating disclosure,
that aligns with NABERS UK, starting with all offices greater than 1,000m 2, from
2022/23, indicatively. In addition, CIBSE TM54 has recently aligned with NABERS
UK DfP, and BREEAM is set to do the same at the next update (estimated 2023) .
The GLA requires referable schemes to evaluate operational energy as part of the
‘be seen’ stage of the Energy Hierarchy. The associated guidance sets out
parameters for evaluating performance at the planning, as built and in use stages
of a development.
The planning stage requires an estimation of the regulated and unregulated
energy. The recommendation is for the use of analysis guided by CIBSE TM54
‘Evaluating operational energy use at the design stage’, and NABERS UK DfP is
encouraged for office buildings greater than 5,000m2.
CIBSE TM54 and NABERS UK give a far more accurate and complete estimate of
operational carbon emissions than Building Regulations Part L. This approach also
aligns with the reporting requirements of Stage B6 ‘ Operational Energy Use’ under
the GLA’s WLCA Guidance (March 2022).
Figure 9: The NABERS UK Design for Performance
The GLA also requires in use monitoring of actual energy use for the first 3 years of guidance manual
a buildings operation.

Operational water use

Operational water consumption in commercial planning applications is currently

reported in 2 ways:
1. Part of the WLCA (module B7), in line with the RICS method, which requires
all carbon emissions related to water supply and wastewater treatment to
be reported, using BSRIA benchmarks initially, then estimated values once
known. Carbon conversion factors for water use and treatment as published
by the local water supplier should be used.
2. Part of the BREEAM Assessment, which aims to reduce and benchmark the
consumption of potable water for sanitary use (credit Wat 01) in new and
refurbished buildings through the use of water efficient components and
water recycling systems. City of London’s current policy refers to requiring
all BREEAM water credits to be achieved.
The latter consumption evaluation is therefore limited to potable water only,
while the former looks at all water consumption and treatment and associated
carbon emissions. BREEAM does review non potable water but in a qualitative way
(credit Wat 04).
The UK Government is proposing to introduce a new obligatory water rating
disclosure (in a similar way to energy, above) and to regulate all water
consumption for different land uses. Currently only potable water in residential
uses is regulated.
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3. Whole Lifecycle Carbon Assessments
There are currently a variety of different approaches and scopes relating to
Whole Life Carbon and what should be included within the review. Tables 3 and 4
include a comparison between industry drivers such as the UK Green Building
Council (UKGBC), GLA, London Energy Transformation Initiative (LETI) and
BREEAM scopes in terms of EN 15978:2011 Sustainability of construction works.
Assessment of environmental performance of buildings is broken down into
modules / stages and building element groups to be included.
Modules A1-A3 include the product manufacture, modules A4-A5 cover transport
to site and installation processes. Combined these is known as embodied carbon
at Practical Completion (PC). Modules B1-B5 covers operational emissions
relating to use maintenance repair, replacement and refurbishment, C1-C4
covers demolition, transport to a disposal facility, waste process and disposal.
Module D covers emissions beyond the system boundary, accounting for
consideration of what happens to material at the end of the building lifecycle. In

Scope UKGBC UKGBC RIBA BREEAM NC

GLA LETI
Full Minimum 2030 CC 2018 and RFO
(Modules based on EN 15978) WLC Guide EC Primer
Assessment Reporting Ver.2 2014

Product and Construction Process (Practical Completion) Stage

A1-A3 Raw material
extraction & supply,
✓ ✓ ✓ ✓ ✓ ✓
transport to manufacturing
plant and manufacturing
A4-A5 Transport to project
site and Construction ✓ ✓ ✓ ✓ ✓ ✓
&installation processes
Use Stage
B1-B5 Operational emissions B4 only
relating to use, 2.5 External
Wall
maintenance, repair, YES
2.6
✓ ✓ ✓
replacement and
Whole life cycle carbon

Windows &
refurbishment Doors

Optional Optional ✓ In terms of ✓

if included if included
B6 Operational energy use operational operational (SAP / kWh/m2/yr
only (not RFO)
energy (1.2) energy (1.2) TM54)

B7 Operational water Use ✓ ✓ ✓

End of Life Stage
C1-C4 End of life stage
including
deconstruction/demolition, ✓ ✓ ✓ ✓
transport, waste processing
and disposal
Beyond the Project Lifecycle
D Benefits and loads beyond
Optional /
the system boundary,
Future ✓
including re-use, recovery, development
recycling potential
Table 3: Comparison of lifecycle stages 18
 a WLCA, operational energy use, B6 and operational water use, B7, are also
included.
All the different industry drivers listed above vary in scope as shown below. It is
worth noting the source documents may change and the landscape is evolving and
continually improving at pace. The GLA methodology is currently the most
comprehensive of all the industry methods.
For the GLA method, a minimum of 95 per cent of the capital cost allocated to
each building element category should be included for at each stage of the WLCA.
This should be approved by the project Quantity Surveyor. In addition, for building
services the GLA guide includes a list from which the applicant is required to
indicate in-scope items.

UKGBC UKGBC GLA RIBA LETI BREEAM NC

Building part / Element group Full Assess- Minimum 2030 CC EC Pri- 2018 and RFO
WLC Guide
ment Reporting Ver.2 mer 2014***
YES
Demolition prior to construction
Reported separately.
Benchmarks do not
Facilitating works ✓ include these build-
ing elements.
NC credit option
Substructure ✓ ✓ ✓ ✓ ✓
RFO if in scope
NC mandatory
Superstructure (Frame, upper floors, ✓ ✓ ✓ ✓ ✓
roof, stairs, ramps) RFO if in scope
(excludes ramps)

Superstructure (External walls, windows, NC mandatory

✓ ✓ ✓ ✓ ✓
doors) RFO if in scope
NC mandatory
Superstructure (Internal walls, partitions, ✓ ✓ ✓ ✓ education only
doors)
RFO if in scope

Finishes ✓ ✓ ✓ ✓ RFO if in scope

RFO if in scope to
Fittings, furnishings
✓ ✓ ✓ CN7 limited furni-
& equipment (FF&E) ture / shop fitting
NC credit option
Building services/ MEP ✓ ✓ ✓ ✓
RFO if in scope
Prefabricated Buildings
✓ ✓ ✓ ✓
and Building Units
Work to Existing Building ✓ ✓ ✓
NC credit option
RFO if in scope:
External Works ✓ ✓ hard landscaping
and boundary
protection only

Table 4: Comparison of scopes vs building part element /group (full version including notes in Appendix 2)

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4. Carbon optioneering

It has become clear to the industry that the construction of new buildings using
current construction techniques and materials result in high carbon emissions over
the buildings lifecycle. For this reason the assessment and benchmarking of
embodied carbon to Practical Completion (Modules A1-3 & A4-A5) can be used as
an effective way to evaluate and then mitigating emissions from materials as an
initial starting point.
It is also acknowledged that the majority of the existing building stock has high
operational emissions, primarily due to inferior energy efficiency standards and
older technology at the time of their construction, compared to current ones
(insulation, air tightness, solar control glass, etc.).
Another major contributor to existing operational emissions is the common use of
natural gas combustion equipment for space heating and hot water. In recent
years, the carbon intensity of natural gas has remained relatively stable and was
once the lower carbon fuel of choice. However, investments in renewable power
generation have seen the carbon emissions of electricity decrease rapidly to
almost half that of gas and it is continuing to decrease rapidly over time.
Therefore, a feasible carbon balance needs to be explored in any intervention of
the built environment. This planning advice note recommends a hierarchy of
decision making that prioritises carbon and the City’s Climate Action Strategy, Figure 10: Investments in renewable energy have
ensuring that all primary and secondary considerations form part of the design are resulting in rapid decarbonisation of grid
process so informed decisions can be made. Considerations and constraints electricity compared to natural gas
frequently encountered in the decision process are considered in this section.
The graph below demonstrates, in general terms, the relationship between carbon
emitted at Practical Completion of a building intervention and operational
carbon saved. The decarbonisation of the electrical grid and minor maintenance
and replacement interventions during the lifecycle are also included.
The data in figure 11 is indicative and improved embodied and operational carbon
figures, and combinations, are possible. For example, a minor refurbishment can
achieve better operational savings and breakeven earlier than the examples shown
below. This may also depend on the specific project undertaking review.
Due to the number of variables and considerations, it would be beneficial to
standardise some of the assumptions used to estimate carbon breakeven for
consistency between developments at pre-applications and planning submissions.

Figure 11. Examples of initial embodied carbon payback during building operational lifecycle for different options, indicative only 20
5. Optioneering considerations

Quality of existing building: The quality of material in an existing building will be

a critical determinant of the extent of elements that can be retained in an
intervention aimed at improving an asset and bringing it up to current
performance and functional market standards.
For example a structure that was poorly constructed or maintained may require
too many lifecycle interventions to maintain structural integrity for retention to be
feasible. Very often, existing assets need to be extended to validate the CAPEX of
an intervention, therefore a structure and sub-structure need to do more then
what they were initially designed to do.
Adding piles and foundations to an existing building could mean a level of
complexity that increases cost and programme to a degree that the proposition
becomes unviable. It is likely that the quality and design of structures and sub-
structures in the City is generally of a high quality, with few exceptions such as
post war (1950s-1970s) concrete. In some cases, intrusive structural investigations
are not immediately possible due to access and leasing constraints, or as-built
information is not available to inform a design team about the structural capacity
and quality of a building.
Poorly maintained windows can be restored to improve air permeability, but
conductivity, light transmittance and solar control are difficult to achieve without
additional material or complete replacement.

Façade interfaces: As well as quality, decisions around façade retention need to

take into consideration new interfaces with the internal environment, for
example, for on-floor ventilation systems and mixed-mode ventilation
opportunities. The two examples are increasingly being adopted by commercial
buildings to improve energy efficiency, spatial adaptability (as part of a health and
wellbeing design strategy) and free up roof area for amenity uses.

Health and wellbeing: Design considerations around health and wellbeing have
become more prevalent in workspace over the past few years, and increasingly so
in a post-pandemic era. More consideration is being given to quantities of fresh air
to dilute indoor pollutants, for example through the application of enhanced on-
floor ventilation systems. Aligning a ventilation strategy to existing façade
retention can be challenging. Increased fresh air rates are also leading to
increases in operational carbon.
Other design considerations for healthier internal environments include internal
levels of daylight and thermal comfort, which may shift a decision to replacing
existing glass in a refurbishment; and the presence of toxic materials, such as
asbestos, which could result in the removal of existing building elements.

Floor to ceiling heights: Existing floor to ceiling heights could constrain the
functional adaptation of an existing structure and building services solutions. For
example, low floor to ceiling heights may not lend themselves well to laboratory
uses and optimised clear heights by transferring heating, cooling and ventilation
plant to an underfloor system is often limited by existing lift lobby levels.

Land use and building type: It is important to note that different land uses and
building types have an effect on the structural requirements of a building due to
loading expectations and flexibility requirements. A few examples include uses
that require wider clear spans, such as retail, which could make the structural
solution and carbon impact more intense; higher loading requirements and

21
5. Optioneering considerations

vibration control for uses such as science labs and gymnasiums; and lateral loading
on tall buildings.
The way a building is operated and managed also has a direct effect on
operational carbon emissions from energy consumption, for example longer
hours of operation by food and beverage establishments.

Power infrastructure: For the reason described in point 1 above, substituting gas-
fired heating systems with energy efficient electric alternatives is a very effective
way of reducing operational carbon emissions. However, in some cases, securing
enough power to serve a development’s decarbonisation initiatives can be
challenging due to utilities infrastructure constraints. This is another reason for
which reducing energy demand should be prioritised. A mitigating action could be
that a building’s systems and controls are set to prioritise electricity and thermal
storage before gas.
Buildings that apply electric heating may still have other intermittent uses of fossil
fuel, such as life safety generators and façade maintenance equipment. These
systems require on-site storage of fuel, which is frequently diesel. Alternatives
that can be explored for generators are secondary utility high voltage supply fed
from a primary network substation that is independent from that of the primary
supply, or uninterruptible power supply equipment incorporating an appropriately
sized battery installation. An alternative fuel that is considered due to low
environmental impact relative to diesel is Hydrotreated Vegetable Oil, a synthetic
diesel, manufactured from waste products comprising of a mix of vegetable oils
and animal/fish fats.

Building complexity: Design complexity and the number of elemental sub-

components increases carbon intensity. Therefore, simplification of structure,
facades, systems, etc. has carbon benefits and is encouraged.

Procurement: The options and availability of low carbon building products are
relatively limited on the market at this point in time. In some cases, lower carbon
options are available from longer distances, increasing the emissions associated
with transport (Stage A4), although these can be comparatively minor compared
to the product manufacture. However, this is changing rapidly as manufacturing
processes are adapting and supply chains recognise the high value of low carbon in
sections of the market, for real estate in London in particular.
Invariably, a limited quantity of higher value products is less attractive during a
time of economic inflation. Applicants of major developments could be asked to
state what measures they have in place to increase the probability of lowering
embodied and operational carbon in procurement processes.

Assumptions: In addition to fewer options of low carbon products, information

about the quantity of carbon in products is also limited. A requirement for EPD
certificates, or similar third party verified information, should be a requirement in
procurement. For products with no certified embodied carbon data, assumptions
and metrics should be clear and reliable market-average databases should be
used, derived from a verifiable tool or software, such as One Click LCA and eTool.
In addition supply chains can be constrained by very long lead time, impacting
construction programmes and leading to product changes with potentially higher
carbon impact.

22
Due to market fluctuations and limitations, it is recommended that, at application
stage, the WLCA is based on market averages of a committed specification, based
on a Quantity Surveyor’s bill of quantities. Product-specific Environmental Product
Declaration (EPD) certificates should not be used in early design stages (unless the
manufacturer is definitely known, sector level data e.g. EPDs that use data
covering several manufacturers could be used) because they may be giving a false
impression of future procurement opportunities. This is an area the industry needs
to improve upon over the next few years.

Commerciality: A critical factor in decision making around the level of

intervention in a building is the commerciality of the asset. In commercial
buildings, the net lettable area and lease value are imperative metrics. The market
in City of London is shifting demand for Net Zero Caron, fossil fuel free, health and
wellbeing conscious and smarter workspace. As market demands change, a
number of asset holders are racing to update their lettable spaces at the end of
the next lease term. This is to ensure that buildings don’t become stranded assets,
and equity and operating value are maintained.
The standard for what is required in a building update needs to be competitive in
the market it is trying to attract, and the cost of the intervention needs to be
justified by a likely return on investment. In most cases this balance can only be
achieved by improving quality and quantity. Quality can be improved by
refurbishments, but necessary replacement and increasing floor area are carbon
intensive.

Densification: As London tries to move towards a polycentric city to release

infrastructural pressures and improve quality of life, its existing ‘mega-centres’
remain very relevant. Urban densification is accepted as a necessary part of
limiting land take while serving population growth. Densification tends to occur in
fast growing population centres with a combination of demographic change,
economic pressure and large transport infrastructure projects. The City of London
is very well served by transport infrastructure and planning policies are in place to
limit pressures on utility infrastructure and the existing community.
Densification, e.g. extensions and taller building, tend to increase the carbon
intensity of structural elements relative to benchmarks derived from mid-height
buildings.
Striking the right balance between the environmental (and social) costs and
benefits of increasing NIA on brownfield sites is a critical factor that policy makers
have to deal with, in particular in a Climate Emergency. Resilience and
sustainability should be central priorities for increasing existing building heights.

23
6. Other policy opportunities

This section addresses circumstances where other planning policy requirements

may result in lower or higher carbon emissions. All factors need careful
consideration on a project by project basis, and policy requirements need to be
fine-tuned depending on priorities discussed at pre-application stage.
A. Circular Economy: The Mayor of London has introduced a requirement for
referable proposed developments to develop a circular economy strategy
and produce a Statement as part of an application. The approach is defined
in ‘Circular Economy Statement Guidance’ (adopted 25th March 2022). The
principles encourage building reuse, recovery of material for reuse and
recycling, material efficiency, waste management and infrastructure to
support material reuse (such as storage and collection systems).
The circular approach often aligns with the principles of low carbon
interventions. For example, it encourages refurbishment and efficient use of
materials and requires consideration of the end-of-life stage by a proposed
new building (building as a material banks/ materials passport approach).
This area is still evolving and can significantly reduce carbon.
There are, however, some circumstances where actions that align with
circular principles can increase carbon emissions. For example, on occasion,
it has been found that recovering / repurposing a material for re-use on
site frequently requires the material to be reformulated into a new high
value use (or upcycled), a process that requires transport to and from the
site and energy to repurpose the materials. Recovering material can also
lengthen construction programmes prolonging stage A5 of the lifecycle and
local environmental impact.
Therefore, it is important to compare the carbon emissions of the product
stages of recycled elements to their newly made equivalents with the
lowest carbon opportunity established.

Figure 12: Circular Economy compared to Linear Economy (Source: Circular Flanders) 24
B. Renewables: Planning policy, building regulations and the BREEAM
assessments have for years required the inclusion of low carbon and zero
carbon technology in the energy hierarchy of proposed developments. The
most viable option in the City is frequently a maximum area of roof-
mounted photovoltaics (PV). Policy prioritises operational energy and
carbon reduction in advance of renewable energy generation, but no
consideration is given to reducing the embodied carbon of PV. An array in
London can achieve carbon breakeven within a decade, but as the electrical
grid decarbonises, there is an argument the array will displace less carbon
and could never recover the embodied carbon emitted. For this reason, it is
recommended that circularity principles are applied to their specification
(e.g. reusable mounting and take-back schemes) and energy storage is
incorporated to increase the proportion of renewable energy uptake at
time of use.
It is important to note PV can bring other benefits like localised power, and
we tend not to factor in the impact or wider power networks embodied
carbon (i.e. the impact of the power plant construction upgrades, cabling
etc.)
Another local policy requirement is connecting to existing District Energy
Networks (DEN) or preparing for a future connection to a planned DEN. This
is emphasised by both the London Plan’s and draft City Plan’s heat
infrastructure priorities. The City of London includes the extensive Citigen
network, which is planned to extend south in the near future and eastwards
at a later date. However, due to the drive to remove fossil fuel combustion
from buildings, for reasons relating to both carbon reduction and air quality
targets, electrically heated buildings tend to have much lower carbon
emissions then existing heat networks. This is because the Energy Centres
that serve the DENs still run on gas systems, and while they are intended to
decarbonise over time, there is very little information about their
programme. In addition, the carbon intensity of planned networks is
unknown at this stage. Therefore, the policy can be interpreted to
contradict the Climate Action Plan and can impact lifecycle aspirations, such
as high NABERS UK energy ratings.

initial

Figure 13: Lifecycle carbon of a roof-mounted array in the City of London, to be installed in 2025 (Source: Hilson Moran) 25
6. Other policy opportunities

Public realm and urban greening: The City of London includes a network of
gardens, small open spaces and squares that are maintained by the Corporation.
Nevertheless, the area of green and open space per capita is relatively small, and
the discrepancy will increase as the population and densification rises.

Planning policy encourages urban greening and biodiversity net gain, for which the
City has adapted the London Plan’s Urban Greening Factor (UGF) calculation which
is required for proposed developments to demonstrate higher value green
infrastructure. However, urban greening does not often translate into open space,
because private roof gardens and green walls are often used to satisfy the UGF
target.

In order to increase the amount of open and green space in the City, brownfield
and lower quality space may need to be upgraded. This may result in decisions to
demolish lower quality infrastructure. In addition, the UGF can be difficult to
achieve on existing structures due to loading limits, plant requirements etc,
however all solutions to overcome this should be explored and communicated.
In addition, major developments are required to carry out ecological surveys of the
site, and propose ecological protection, enhancement and maintenance measures.

26
7. Planning application trends
An evaluation of recent planning applications and types has been undertaken
based on the City of London Development Schedule ‘Development Schedules
March 2021 _Updated Jan’ Issued to Hilson Moran by CoL
This undertaken establish trends and to provide the evidence base to support this
guidance document.
The majority of applications, 76% (of which 40% where GLA referable), fall under
the City’s definition of Major development (>1,000m2) and/or require an
Environment Impact Assessment. This demonstrates that the greatest proportion
of projects are likely to have the largest Carbon impact and therefore should be
required to mitigate it.

Number of
Project type Year(s) applica- FULMAJ FULEIA FULL GLA referable
tions

2014-March
Office 37 15 11 11 4
2021

March 2021-
Office 9 4 5 8
2022

Total 46 19 16 11 12

Percentage 100% 76% 24% 41%

Hotel / Student
2012-2021 9 5 0 4 2
accommodation

Percentage 100% 56% 44% 22%

Other (law court,

2021 1 1 1
police + commercial)

Percentage 100% 100%

Table 5: Number and types of commercial development applications in City of London

27
7. Planning application trends

The remaining applications are varied full implications covering change of use and
extensions (24%). These are broken down as follows:

Change of New Refurbishment Refurbishment

Extension
Project type Full Use - Partial Buildings with Change without
only
Building with Change of Use Change of Use

Office 11 1 4 2 2 2

Percentage by type 100 9 36 18 18 18

Table 6: Number of full planning applications, excluding major application, by type

The following is a breakdown of office applications by size. The majority have an

area above 10,000m2 (76%). This also confirms the trend for larger scale
applications with potentially bigger impacts.

1,000-5,000 5,001-10,000 10,001-15,000

Project type Total 15,000 sqm +
sqm sqm sqm

Office 46 9 2 5 30

Percentage 100 20 4 11 65

Table 7: Size of office development applications in the City of London

Three planning applications that were submitted in the past 5 years were analysed
and compared to provide a better understanding of typical WLCA approaches
adopted, carbon scopes covered, local constraints and opportunities. Key
observations are included in table 11.
More recent applications that are referable have followed the GLA approach for
WLCA. The non-referable, major application project has also reported the WLC
carbon estimations. It has loosely used the GLA approach, but has applied
estimates in the assessment. This also highlights the need for consistent policy so
comparable determinations and reviews verses benchmarks can be made.
Two of the applications reviewed building options, however both used very
different assumptions and methods. It is clear that a transparent and consistent
approach to optioneering is required.
Where a building is undergoing a minor refurbishment (or refit), it is unlikely to
require a planning application and therefore would not be required to report on
carbon emissions. However, developers should be aware of buildings services and
tenant fit-out carbon impacts wherever possible.

28
*TM54 not provided, source of operational energy use unclear
** Project is using early NABERS DfP model for operational energy use rather than the CIBSE TM54 approach
*** Multiple buildings indicated but only 1 WLCA sheet submitted for main development

Circular Whole Lifecycle Carbon Assess- Operational

Economy ment Energy

Size Refera- Building Value Value

Land use Lifecycle
Project (GIA ble/ Options elements kgCO2e/ Scope kgCO2e
class/es scope
m2) major scope m2GIA /m2GIA
Demolish and GLA (draft GLA (draft
FULMaj rebuild guidance) guidance) 670 925**
14-21 Holborn
35,948 Class E WLC spread- Estimated
Viaduct Referable Mitigate A1-A5, B1-B5, (Stage 2) (stage 2)
sheet sub-
impacts C1-C4, D mitted
768
FULMaj Demolish and GLA (draft State fol-
Class E
115 – 123 rebuild guidance) lowed GLA (+25% factor 844*
66,867 (Sui Gene- Not used) Estimated
Houndsditch Mitigate A1-A5, B1-B5, (draft guid- (Stage 2)
ris) Referable ance) (Excludes
impacts C1-C4,
module D)
GLA (draft
Demolish and GLA (draft
guidance)
120 Fleet FULEIA rebuild guidance)
61,135 Class E WLC spread- 753 Estimated 1,321
Street** Referable Mitigate A1-A5, B1-B5,
sheet sub-
impacts C1-C4, D
mitted

Table 8: WLC sample from recent projects submitted for planning to the City of London

Conclusion
On the basis of the above it is reasonable and recommended to follow the GLA
approach for a WLCA to provide a consistent approach across the CoL.
Advantages:
• Leads to consistent and more transparent results;
• Will create a uniform and well-understood approach across the industry;
• Will build consistency around the metrics used over time;
• Can be compared to GLA benchmarks for benchmarking;
• Future-proofs policy updates across London;
• Greater awareness of impacts could lead to better design decisions and to
greater carbon savings in the City of London.
Disadvantages:
• Will require additional time / detail from the design team for evaluation and
assessment.
The review of data above concludes that there is a need for emissions to be
accounted for and for options to be considered in the City of London for all major
applications. Full major applications are to consider development options and
carbon impacts, applying the methodology presented later in this document.
Within this is a requirement to review building options accounting for carbon in a
more consistent way, to ensure the correct choices are made. There will always be
some carbon emissions. However, there is a duty to try and limit them wherever
possible and for Officers to be able to make informed decisions in line with the
City’s Climate Action Strategy.

29
8 Methodology

Due to the significant impact on carbon emissions Climate Change by major

interventions and new construction, proposed developments need to demonstrate
reduction and mitigating of carbon emissions using a consistent approach. Option
reviews and their considerations should be transparent with opportunities and
constraints clearly identified.
CoL requires all major developments to consider and assess both operational and
embodied carbon emissions over a whole lifecycle. Non-major developments
should align with the GLA guidance and pre-application reporting requirements
wherever possible.
It is envisaged that this methodology will be updated from time to time to industry
learning and changes.

Pre-Applications
Pre-application discussions with the City of London should include the following:
1. Major and referable developments should demonstrate that a minor or
major refurbishment have been considered in the procurement and design
process.
2. Options should be well-considered, realistic and feasible.
3. Applicants are to complete options information in table A in the WLCA
dashboard (section 9), including:
• Gross internal area (GIA)
• Increase in net internal area (NIA)
• Embodied carbon to Practical Completion (Modules A1-A5)
• Lifecycle embodied carbon (A1-A5, B1-B5, C1-C4)
• Percentage of material retained (By volume, relative to existing
building).
• Operational carbon from energy consumption (Module B6)
• Regulated operational carbon savings relative to current Part L
Target Emissions Rate
• EPC rating
• Fuel source for operational energy (gas, electricity, other to be
defined)
• Whole Lifecycle Carbon (A1-A5, B1-B6, C1-C4) in kgCO2e/m2GIA and
tCO2e
• Opportunities and constraints, specifically in relation to carbon
emissions and other policy areas.
3. Where substantial refurbishment or demolition is not being considered, an
options appraisal is not required, but a WLCA is required.
4. The comparison of options should include like-for-like reporting, without
bias to favour one option against the others. For example, the opportunity
for energy and carbon improvement should be equivalent across all
options, except where constraints can be clearly demonstrated. For
example, the equivalent level of aspiration to reduce elemental embodied
carbon should be applied equally across all options.
5. A WLC options plot / comparison graph should be produced to compare the
options relative to the existing building. Consistent data should be used to
produce the graph, including:

30
 • Actual annual energy consumption of the existing building (whole
building annual energy meter reading)
• An equal rate of electrical grid decarbonisation over time applied to
operational energy (derived from the latest BEIS Energy and
Emissions Projection (EEP)).
• An equivalent approach to the level of assumptions and certainty
applied to embodied carbon estimates.
• Equivalent scope for the WLCA (lifecycle stage and building element
scopes)
• Embodied carbon impact of further interventions to be included, say
every 15 years of operation over the lifecycle, using lifecycle
modules B1-B5, C1-C4.
Module B7 ‘Water Consumption’ can be excluded at this stage because it does not
vary significantly between options. Any variances, in particular where an
opportunity or constraint occurs for one option and not another, should be clearly
presented.
Non-major developments should align with the GLA guidance and pre-application
reporting requirements wherever possible.
It should also be noted that the WLCA emissions fluctuate and are likely to be
different in later design and construction stages. Generally this is due to more
detail being known in developed design and cost plans. Emissions at Practical
Completion may also change due to procurement variations and the market. As
more data becomes available it will inform future projects to refine early
estimations.

Preferred option
At application stage, all major and referable developments should clarify the
following:
1. The preferred option, based on the optioneering exercise presented at the
pre-application stage and reasons to support the decision.
2. Calculate the WLCA in alignment with GLA guidance at the time of the
assessment, and complete the GLA reporting spreadsheet i.e. including all
modules and building elements.
3. Clarify the scope of the WLCA (lifecycle stage and building element scopes),
by completion of Tables B (section 9).
4. Clarify all assumptions, exclusions and level of certainty of the data used in
the assessments.
5. Plot lifecycle stages A1-A5, B-C (excluding B6 and B7) against the GLA WLCA
benchmarks (see Figure B):
• By stage for the proposed land use
• By building element for Stage A1-A5 (embodied carbon to Practical
Completion )
5. Report the total kgCO2e/m2 GIA.
The WLCA should be based on the cost plan in line with GLA guidance. The GLA
WLCA reporting template should be completed and submitted to CoL.
Non-major developments should align with the GLA guidance and planning
application reporting requirements wherever possible.
City of London will condition an update of the WLCA pre-commencement on site
and at Practical Completion based on as-built information.
31
9. Dashboard Minor Major GLA Referable

Dashboard 1: Pre-application options appraisal

Completion of Dashboard 1 is required to improve reporting consistency,
transparency and standardisation across application. Applicants are to complete it
for pre-application discussions about proposed major and referable development
proposals. Non-major applications are encouraged to complete as much of the
information as feasible. Applicants who are only considering retrofit, refurbishment
and/or + extension, only need to provide the WLCA preferred option (compared to
GLA benchmarks).

FIGURE A: Example of completed template optioneering graph over a 60yr life cycle, including whole lifecycle carbon (embodied and operational) (Source:
Hilson Moran)

For the Cumulative Carbon Emissions graph above use:

• Actual annual energy consumption of the existing building (whole building
annual energy meter reading)
• An equal rate of electrical grid decarbonisation over time applied to
operational energy (derived from the latest BEIS Energy and Emissions
Projection (EEP)).
• An equivalent approach to the level of assumptions and certainty applied to
embodied carbon estimates.
• Equivalent scope for the WLCA (lifecycle stage and building element scopes)
• Embodied carbon impact of further interventions to be included, say every
15 years of operation over the lifecycle, using lifecycle modules B1-B5, C1-
C4.

32
 Dashboard 1 continued

Major refurbishment with New build,

Applicable Minor refurbishment Major refurbishment
extension reclaim and recycle

Image Image Image Image

Gross Internal
_____ m2 _____ m2 _____ m2 _____ m2
area (GIA)

Increase in NIA _____ m2 _____ m2 _____ m2 _____ m2

Embodied
_____ kgCO2e/m2 GIA _____ kgCO2e/m2 GIA _____ kgCO2e/m2 GIA _____ kgCO2e/m2 GIA
Carbon (A1-A5)
% material
retained rel. to _____ % _____ % _____ % _____ %
existing
Embodied
Carbon (A1-A5, _____ kgCO2e/m2 GIA _____ kgCO2e/m2 GIA _____ kgCO2e/m2 GIA _____ kgCO2e/m2 GIA
B1-B5, C1-C4)
Operational
_____ kgCO2e/m2 GIA _____ kgCO2e/m2 GIA _____ kgCO2e/m2 GIA _____ kgCO2e/m2 GIA
Energy (B6)

Regulated
_____ % _____ % _____ % _____ %
carbon savings

EPC rating ___ ___ ___ ___

Fuel source  Gas  Electricity Other  Gas  Electricity Other  Gas  Electricity Other  Gas  Electricity Other

Total WLCA _____ kgCO2e/m2 GIA _____ kgCO2e/m2 GIA _____ kgCO2e/m2 GIA _____ kgCO2e/m2 GIA

Total WLCA _____ tCO2e _____ tCO2e _____ tCO2e _____ tCO2e

• A • A • A • A

Opportunities • B • B • B • B

• C • C • C • C
• A • A • A • A

Constraints • B • B • B • B

• C • C • C • C

Notes and
• • • •
assumptions

TABLE A: Optioneering outcomes to be presented to City of London at the Pre-Application stage. Where substantial refurbishment or demolition is not
being considered, an options appraisal is not required, but a WLCA is required
33
 Dashboard 2: Application WLCA Preferred option

Lifecycle stage scope Building elements scope

Proposed
Building part / Element group
development
Demolition prior to construction
✓
Facilitating works
Substructure ✓
Superstructure (Frame, upper floors, roof, stairs, ramps) ✓
Superstructure (External walls, windows, doors) ✓
Superstructure (Internal walls, partitions, doors) ✓
Finishes ✓
Fittings, furnishings
✓
& equipment (FF&E)
Building services/ MEP ✓
Prefabricated Buildings
✓
and Building Units
Work to Existing Building ✓
External Works ✓

TABLES B: Example of completed scoping template table

Comments

• ...

Justification • ...

• …

• ...

Exclusions • ...

• …

• ...

Assumptions • ...

• ...

• ...

Certainty • ...

• ...

TABLES C: Information in relation to the preferred option providing justification for preference, and
clarity on assumptions, exclusions and level of certainty of the data used in the assessment

34
Completion of Dashboard 2 is required to provide reporting consistency, improved
transparency and standardisation across application. Applicants are to complete it
and include it in the Executive Summary of the WLCA report that forms part of the
Planning Application. The GLA WLCA reporting template should also be used for
submitting the final results.

Applicant to identify reasons where

WLC benchmarking by stage (offices) benchmarks are exceeded for lifecycle
kgCO2e/m2GIA
stages and building elements, using
1200 evidence of explored improvements
where possible.
1000
Additional opportunities for
800
improvements should also be identified
600 in the application report.
400

200

0
WLC benchmarks, GLA Aspirational WLC Proposed
benchmark, GLA development

A1-A5 (excluding sequestration) B-C (excluding B6 &B7)

FIGURE B: Example of completed template table comparing the WLCA (Modules A1-A5, B1-B5, C1-C4)
to published GLA standard and aspirational benchmarks

WLC benchmarking by stage (offices)

kgCO2e/m2GIA
1200

1000

800

600

400

200

0
WLC benchmarks, GLA Aspirational WLC Proposed
Whole Lifecycle
benchmark, GLA development
Carbon ___kgCO2/
Substructue Superstructure Façade
m2 GIA
Internal finishes FFE Services/ MEP
External works (modules A1-A5, B1-B7, C1-C4, D)

FIGURES C: Example of completed template table comparing the Embodied Carbon (Modules A1-A5)
to published GLA standard and aspirational benchmarks for elemental carbon emissions

35
APPENDICES

36
APPENDIX 1 Related reporting requirements

Non-policy related reporting for Net Zero Carbon

Over the past three years, the UK property industry has done more to advance the
environmental agenda than ever before. Developers, consultants and professional
bodies have come together to declare a Climate and Biodiversity Emergency and
have taken concrete action. Together we have developed much needed clarity and
guidance on how to truly achieve Zero Carbon by 2030.
Property lenders, investors, asset managers and occupiers are all driving this shift
by demanding a very high standard of environmental, social and governance policy
as a prerequisite to any transaction. This trend is increasing rapidly across all
workplace environments, both for new and existing assets.
A number of businesses have declared that they have become Net Zero Carbon in
operation across portfolio assets and activity within their control. These
declarations in the London market tend to align with the World Green Building
Council or UK Green Building Council Definition Framework and consists of
accounting for and reducing carbon emissions, investing in renewable energy,
offsetting residual carbon through accepted credit frameworks and publicly
disclosing their pathway.
Other approaches adopted by applicants that vary in scope to planning policy
requirements include:
• The London Energy Transformation Initiative (LETI) targets and scope
• The UKGBC Net Zero Carbon Definition framework and benchmarks

37
Related reporting requirements

London Energy Transformation Initiative (LETI)

LETI has recently published a number of design guidance documents that set out a
trajectory of embodied carbon and operational energy targets required to address
the Climate Emergency. The WLCA scope associated with their targets is limited to
stages A1-A5 to Practical Completion.

38
Related reporting requirements

UKGBC Net Zero Carbon Buildings, Framework Definition

The UKGBC set out guidance in consultation with the industry to define Net Zero
Carbon. At time of writing this planning guidance, a building can claim to be Net
Zero Carbon in construction or in operation or in both. UKGBC has published
benchmarks for operational energy with a trajectory to Net Zero Carbon, but none
for embodied carbon at this time.

The framework requires third party verification of Whole Lifecycle Assessments

and operational energy assessment, includes a minimum carbon reporting tem-
plate and information needs to be publicly disclosed. Notably, key differences be-
tween the UKGBC Net Zero Carbon definition and the London Plan definition are
shown in the following table.

39
Comparing Net Zero Carbon definitions

UKGBC Net Zero Carbon London Plan Net Zero Carbon

Minimum reporting Stages A1-A5, B4 for
Whole Life Cycle superstructure ext. walls & windows / ext Modules A-D (B6, B7 and D not included in
carbon doors, B6 operational energy. benchmarks).
Full Assessment Modules A-C.
Part L2A regulated carbon assessment used to
Regulated
determine Net Zero Carbon target
operational carbon
emissions from TM54 required for ‘be seen’ (non-residential)
energy use

Includes all energy use within declarant’s Unregulated energy to be estimated and
control infrastructure in place to monitor, verify and
Unregulated report all annual energy consumption.
operational carbon NABERS UK Design for Performance (see
emissions from below) encouraged for commercial office
energy use buildings 5,000m2
TM54 required for ‘be seen’ (non-residential)
Priority for on-site renewables, but offsite
Renewable energy
On-site and off-site renewables renewables are acceptable alternative to
generation
carbon offsets (conditional)
Offset all residual carbon using an approved
international or domestic carbon offset Offset residual carbon relative to 100%
standard, applying standard market rates. regulated carbon savings only, determined by
Carbon offsetting UKGBC recommend also using higher rate Part L2A target. Carbon offset is
from HMT Green Book at the time of offset to recommended as £95/ tonnes CO2, paid in
create a Transition Fund for further advance of and for a 30-year life cycle
decarbonisation

40
 APPENDIX 2 Detailed building element scope

Table 4 compares the UKGBC, GLA, LETI and BREEAM scopes for building elements in more detail than the
table provided earlier in the main body of this guidance report.

* Building-related items are building-integrated technical systems and furniture, fittings and fixtures built into the fabric
or included in the shell and core specification. Building-related MEP and FFE typically include the items classified under Shell
and Core and Category A fit-outs.
** Non-building-related items are loose furniture, fittings and other technical equipment like desks, chairs, computers,
refrigerators, etc. Such items are usually part of Category B fit-out. Therefore, for Shell and Core construction this is not part of
the assessment scope.
***BREEAM NC = BREEAM New Construction 2018; BREEAM RFO = BREEAM Refurbishment and Fit-out 2014

Building part / UKGBC UKGBC GLA RIBA BREEAM

Element Building Element LETI
Full As- Minimum WLC 2030 CC NC 2018 and RFO
EC Primer
group sessment Reporting Guide Ver.2 2014***

Demolition YES
0.1 Toxic /Hazardous /Contaminated
prior to con-
Material Treatment Reported
struction separately.
0.2 Major Demolition Works Bench-
marks do
Facilitating 0.3, 0.4, 0.5 Temporary/ Specialist not in-
ground/Enabling Works
✓ clude
works
these
0.4 Specialist groundworks ✓ building
NC credit option, RFO if
Substructure 1 Substructure ✓ ✓ ✓ ✓ ✓ in scope
2.1 Frame
2.2 Upper Floors NC mandatory, RFO if in
Superstructure
2.3 Roof
✓ ✓ ✓ ✓ ✓ scope (excludes ramps)
2.4 Stairs and Ramps
2.5 External Walls NC mandatory, RFO if in
Superstructure
2.6 Windows and External Doors
✓ ✓ ✓ ✓ ✓ scope
NC mandatory educa-
2.7 Internal Walls and Partitions
Superstructure
2.8 Internal Doors
✓ ✓ ✓ ✓ tion only, RFO if in
scope
3.1 Wall finishes
Finishes 3.2 Floor finishes ✓ ✓ ✓ ✓ RFO if in scope
3.3 Ceiling finishes
Fittings, fur-
4.1 Fittings, Furnishings & Equipment RFO if in scope to CN7
nishings
incl. Building-related* and non- ✓ ✓ ✓ limited furniture / shop
& equipment building related** fitting
(FF&E)
5.1–5.14 Services
Building ser- NC credit option, RFO if
incl. Building-related* and non- ✓ ✓ ✓ ✓ in scope
vices/ MEP building related**
Prefabricated
Buildings 6.1 Prefabricated Buildings and Build-
ing Units
✓ ✓ ✓ ✓
and Building
Units
Work to Ex- 7.1 Minor Demolition and Alteration
Works
✓ ✓ ✓
isting Building
8.1 Site preparation works
8.2 Roads, paths, paving & surfacing
8.3 Soft landscaping, planting and
irrigation systems NC credit option
8.4 Fencing, railings and walls
External Works
8.5 External fixtures
✓ ✓ RFO if in scope: hard
landscaping and bound-
8.6 External drainage ary protection only
8.7 External services
8.8 Minor building works and ancil-
lary buildings 41
Table 4: Comparison of scopes vs building part element /group (in detail)
APPENDIX 3 GLA WLCA Pre-App proforma

WLC reduction principles Key benefits

Significant retention and reuse of structures is carbon efficient and reduces
1 Reuse and retrofit of existing buildings
construction costs.

2 Use repurposed or recycled materials Reduces waste and carbon emissions.

Appropriate material choices are key to carbon reduction. Ensuring that ma-
3 Material selection terials are selected with consideration of the planned life expectancy of the
building reduces waste, the need for replacements and the in-use costs.

A 'fabric first' approach should be prioritised to minimise energy demand and

4 Minimise operational energy use
reduce carbon and in-use costs.

Choice of materials and durability of systems, which help to avoid leakage

Minimise the carbon emissions associ-
5 and subsequent building damage, contribute to reducing the carbon emis-
ated with operational water use
sions of water use.
Designing for future disassembly ensures that products do not become future
6 Disassembly and reuse
waste and that they maintain their environmental and economic value.
Compact efficient shapes help minimise both operational and embodied car-
bon emissions from repair and replacement for a given floor area. This leads
7 Building shape and form
to a more efficient building overall resulting in lower construction and in use
costs.
Removing carbon emissions from the atmosphere through materials and sys-
8 Regenerative design
tems absorbing it makes a direct contribution to carbon reduction.
Durability means that repair and replacement is reduced which in turn helps
reduce life-time building costs. A building designed for flexibility can respond
9 Designing for durability and flexibility with minimum environmental impact to future changing requirements and a
changing climate, thus avoiding obsolescence which also underwrites future
building value.
Optimisation of the relationship be-
Optimising the relationship between operational and embodied carbon con-
10 tween operational and embodied car-
tributes directly to resource efficiency and overall cost reduction.
bon
Defining building life expectancy gives guidance to project teams as to the
11 Building life expectancy most efficient choices for materials and products. This aids overall resource
efficiency, including cost efficiency and helps future proof asset value.
Sourcing local materials reduces transport distances and supply chain lengths
12 Local sourcing
and has associated local social and economic benefits.

Waste represents unnecessary and avoidable carbon emissions. Buildings

should be designed to minimise construction waste, and to ease repair and
13 Minimising waste
replacement with minimum waste, which helps reduce initial and in-use
costs.

Efficient construction methods (e.g. modular systems, precision manufactur-

ing and modern methods of construction) can contribute to better build qual-
14 Efficient construction
ity, reduce construction phase waste and reduce the need for repairs in the
post completion and the defects period (snagging).

Lightweight construction uses less material which reduces the carbon emis-
15 Lightweight construction sions of the building as there is less material to source, fabricate and deliver
to site.

The circular economy principle focusses on a more efficient use of materials

16 Circular economy
which in turn leads to carbon and financial efficiencies. 42
Table 6: Principles from the GLA’s new WLCA template for the pre-application stage
43
 Appendix 4: Indicative example of completed Table A

Substantial refurbishment New build,

Applicable Minor refurbishment Major refurbishment
and extension Reclaim and recycle

N/A Image Image

Gross Internal
17,309 m2 m2 29,860 m2 35,948 m2
area (GIA)

Increase in NIA 0 m2 m2 12,551 m2 18,639m2

Embodied
68 kgCO2e/m2 GIA kgCO2e/m2 GIA 571 kgCO2e/m2 GIA 670 kgCO2e/m2 GIA
Carbon (A1-A5)

Embodied
Carbon (A1-A5, 176 kgCO2e/m2 GIA kgCO2e/m2 GIA 734 kgCO2e/m2 GIA 874 kgCO2e/m2 GIA
B1-B5, C1-C4)

% material
retained rel. to 88% - 20% 3%
existing

Operational
1, 813 kgCO2e/m2 GIA kgCO2e/m2 GIA 1,078 kgCO2e/m2 GIA 925 kgCO2e/m2 GIA
Energy (B6)

Regulated
_____ % _____ % 30% 42%
carbon savings

EPC rating D B A

Fuel source  Gas  Electricity Other Gas  Electricity Other  Gas  Electricity Other  Gas Electricity Other

Total WLCA
68,102 tCO2e tCO2e 54,137 tCO2e 64,757 tCO2e
carbon
44
 Major Substantial refurbishment and New build,
Applicable Minor refurbishment
refurbishment extension Reclaim and recycle

• Better operational energy

opportunities

• Retention of existing 3 • Wider social benefits

buildings • More opportunities for roof
• Retains most of substructure
Opportunities • Extends building life N/A and some structural elements space / greening (UGF)
with new build extension • Greater adaptability
• Embodied carbon lowest
for immediate future • Some foundations retained

• Some stonework to be
repurposed

• Structurally challenging.
Existing structure would need
considerable new structure to
support building which add to
the complexity of the
• Retention and
construction
intervention relies on gas
due to roof space. • Substantial temporary works
required.
• Poor floor area does not
maximise space, risk of • Quality of existing steel • Embodied carbon is highest
Constraints poorer EPC performance N/A unknown. but there is a trade of for
• other wider benefits.
• Services upgrades Services challenging
restricted due to existing • Restricted Floor to floor
space constraints. heights and level changes add
Assumes like for like plant to complexity
changes if upgrades
• Not maximising land use.

• Less roof space for planting

• Did not meet tenant space

requirements.

• Assumes no fabric
interventions.

• Pro rata carbon data

estimates based on new
build for building element • Structure recalculation: for 1 • Increase in GIA vs existing
categories, internal works Substructure, 2.1 building(s) GIA
Notes 2.7 - 8. N/A Superstructure - frame, 2.2
• Based on new build cost plan
Superstructure - upper floors.
• Does not include future so good data set for GLA
façade intervention • 2.3 - 8 estimated pro rata reporting.
which is likely to be
required. Making
embodied carbon worse
over life—cycle
45
GLOSSARY

46
Glossary
Approved Document Part L conservation of fuel and power: Part L is a building regulation that covers both new and changes
to existing dwellings and non dwellings. Part L sets minimum requirements and targets for energy performance and carbon
emissions. It also defines the carbon intensity of fuel and power.
Beyond Lifecycle (Beyond – LC): Carbon emissions arising from any benefits or burdens of materials and components beyond
the lifecycle (Module D).
BREEAM – Building Research Establishment Environmental Assessment Method: A leading and well established scheme for the
evaluation, rating and certification of the sustainability of buildings developed by the BRE. It is the main sustainability
certification standard in the UK but also is used internationally. The main schemes apply to new buildings and both non
domestic refurbishment and fit-outs and domestic refurbishments.
Carbon dioxide equivalent (CO2e): A metric expressing the impact of all greenhouse gases on a carbon dioxide basis. A
measure used to compare the emissions from various greenhouse gases based upon their global warming potential in a
common unit over a 100 year period. E.g. 1 kg of methane is converted into the amount of CO 2 needed to cause the same
effect, in this case 23 kg. Therefore 1 Kg methane has a CO2 equivalent of 23.
Climate Change: Climate change refers to long-term shifts in temperatures and weather patterns. These shifts may be natural,
such as through variations in the solar cycle. However since the 1800s, human activities have been the main driver of climate
change, primarily due to burning fossil fuels like coal, oil and gas.
Embodied carbon at Practical Completion (EC-PC): Carbon emissions arising from the product stages (A1-A3) and construction
process stages (A4-A5).
Embodied Carbon over Lifecycle (EC-LC): Carbon emissions arising from the product stages (A1-A3), construction process
stages (A4-A5), use stages (B1-B5) and end-of-life stages (C1-C4).
Environmental aspect: An aspect of construction works, part of works, processes or services related to their lifecycle that can
cause change to the environment.
Environmental impact: A change to the environment, whether adverse or beneficial, wholly or partially, resulting from
environmental aspects.
Environmental Performance Declaration (EPD): A transparent, objective report that communicates what a product or
material is made of and how it impacts the environment across its entire lifecycle. An EPD is usually valid for five years, and is
generated according to a number of relevant standards.
Global Warming: Is the long-term heating of Earth's climate system observed since the pre-industrial period (between 1850
and 1900) due to human activities, primarily fossil fuel burning, which increases heat-trapping greenhouse gas levels in Earth's
atmosphere.
Global Warming Potential (GWP): The standard metric used to calculate CO2-equivalent emissions of different greenhouse
gases in carbon budgets and the Kyoto Protocol. GWP measures the total radiative forcing over a given period (usually 100
years) after a pulse emission, relative to that from the same mass of CO 2.
Gross Internal Area (GIA): The area of a building measured to the internal face of the perimeter walls at each floor level. In the
UK this is determined according to Royal Institute of Chartered Surveyors (RICS) property measurement standards.
Greenhouse Effect: A process that occurs when gases in Earth's atmosphere trap the Sun's heat. This process makes Earth
much warmer than it would be without an atmosphere
Grid decarbonisation: The gradual reduction of the carbon intensity of electricity production.
Greenhouse Gas (GHG): A gas that absorbs and emits radiant energy within the thermal infrared range, causing the
greenhouse effect causes global warming. The primary greenhouse gases in the Earth’s atmosphere are: carbon dioxide (CO 2),
methane (CH4), nitrous oxide (NO2), ozone (O3), chlorofluorocarbons (CFCs) and water vapour (H2O).
IMPACT (Integrated Material Profile and Costing Tool): A specification and database for software developers to incorporate
into their tools to enable consistent Lifecycle Assessment (LCA) and Lifecycle Costing (LCC). IMPACT compliant tools work by
allowing the user to attribute environmental and cost information to drawn or scheduled items in the BIM. Put simply, IMPACT
takes quantity information from the BIM and multiplies this by environmental impact and/or cost ‘rates’ to produce an overall
impact and cost for the whole (or a selected part) of the design.
Lifecycle: consecutive and interlinked stages on the life of the object under consideration.
Lifecycle Assessment (LCA): is a process to evaluate the environmental burdens associated with a product, process or activity:
• By identifying and quantifying energy and materials used and wastes released to the environment;

47
 • To access the impact of those energy and materials used and releases to the environment; and
• To identify and evaluate opportunities to affect environmental improvements.
The assessment includes the entire lifecycle (from cradle to grave) of the product, process or activity encompassing extracting
and processing of raw materials, manufacturing, transportation and distribution; use and re-use; maintenances; recycling and
final disposal.
NABERS UK ‘Design for Performance’ (DfP): A building rating scheme (currently for offices only) designed to help projects
deliver against their design intent and overcome the well-evidenced performance gap between design and operation. It
requires a developer or owner to design commission a new office to a defined rating. It is a more detailed way of undertaking
an energy model with the aim of enabling better design decisions to help reduce carbon emissions once the building is
operations.
NABERS Energy: NABERS Energy measures the efficiency of an office building and rates its performance (0-6 Stars). The energy
rating works by comparing the energy consumption of a building against a set of benchmarks that have been developed using
actual data. It is based on in use data
Operational energy (modelling): A detailed energy model that attempts to reflect real world energy consumption of a building
during the design and construction stages of a development. This would include more detail than a standard model used for
building regs, and would include unregulated energy
Operational energy (use): The total energy consumption of the building during its use and operation of the building based on
measured building data.
Operational water use: Water consumption of the building as needed for the technically and functionally defined operation of
the building.
Recycling: Recycling is the process of converting waste materials into new materials and objects. A recovery operation by
which waste materials are reprocesses into products, materials or substances either for the original purpose or other purposes.
Refurbishment: Modification and improvements to an existing building in order to bring it up to an acceptable condition.
The refurbishment of something is the act or process of cleaning it, decorating it, and providing it with
new equipment or facilities.
Regulated Energy consumption: Is building energy consumption resulting from the specification of controlled, fixed building
services and fittings, including space heating and cooling, hot water, ventilation, fans, pumps and lighting.
Retrofit: The act of providing something with a feature not fitted in the original construction or a replacement of a component.
Often this refers to building systems upgrades, however if can refer to improving fabric and or glazing. This work generally
improve amenities for the building’s occupants and improves the overall building performance.
Unregulated energy: Energy consumption that is not ‘controlled’, it does not fall under Part L of the Building regulations. This
would include consumption from elements such as IT equipment, lifts and other plugin equipment such as white goods,
laboratory equipment, external lighting and audio visual equipment.
Whole life Carbon (WLC) or Whole Life Carbon over Lifecycle: The carbon emissions resulting from the materials, construction
and the operation/use of a building over its entire life, including its demolition and disposal. A WLC assessment provides a
picture of a building’s carbon impact on the environment. It comprises of modules A1-A5, B1-B7, C1-C4 and D.
Application types:
FULL EIA: any application requiring EIA in support
FULMAJ: – Any application over 1,000m2 - Major applications may include schemes for redevelopment, substantial
refurbishments, extensions or changes of use. Residential development of 10 or more dwellings or on a site of 0.5
hectares or more, and all other development of 1,000 square metres gross or more floorspace, or on a site of 1 hectare
or more.
FULL: All other full applications

48