8. KEY CONSIDERATIONS AND SUBMISSION REQUIREMENTS
Introduction
Planning applications pass through a planning process that covers all RIBA stages and can be particularly complex for major applications. The planning application process concentrates on RIBA stages 1-5, however, there are important considerations and actions to be addressed throughout all RIBA stages that impact on the success of both the application and the completed development.
This section provides details and examples of those considerations and actions that are recommended for applications in the City of London. The following pages outline the required application documents and recommended supplementary information to demonstrate exemplary practice that would support an application and contribute to a high quality outcome.


KEY CONSIDERATIONS AND SUBMISSION REQUIREMENTS
CONCEPTION / RIBA STAGE 0
Application stage
Key considerations
Conception/ RIBA Stage 0
• Detailed building survey to assess the opportunities and constraints of the existing structure and fabric
• Applicant’s sustainability aspirations for the City location
• Engaging creative and experienced architects, engineers and designers that can develop the optimal sustainable, attractive and bespoke solution for a site
• The City’s priorities and focus relating to environmental, social and economic sustainability aims
• Opportunities and constraints from heritage and townscape impacts on the proposed design
• Local context, such as relating to
• availability of energy infrastructure and energy sharing opportunities
• contact with supporting Business Improvement Districts
• existing and emerging green infrastructure and biodiversity networks
• local climate resilience measures to include SuDS, urban greening and cool routes
• requirements for on-site climate resilience measures
• other synergy opportunites
• Opportunities for the re-use of materials and building elements from applicant’s/ construction company’s other projects or material exchange websites to inform the design of new building elements
• Expert audit of existing biodiversity value and safeguarding existing on-site habitats
Submission requirements and recommendations
CONCEPTION / PRE-APPLICATION / RIBA STAGE 1
Application stage
Key considerations
Conception / Pre-application / RIBA Stage 1
• Entering into a Planning Performance Agreement, or a series of relevant preapplication meetings relating to the topics Carbon Optioneering, Sustainability, and Climate Resilience (to be agreed with planning officers).
• Alignment of the proposal with planning officers’ recommendations on:
• priorities relating to the locality, the City as a whole and connectivity within the City and with the wider London context
• specific environmental sustainability policies and the CoLC’s vision
• the contributions to the environmental quality of the site context and expected public benefits from the proposals (see application stage below)
• health and well-being issues
• Development of the concept options, application proposal and identification of sustainability issues to be developed in more detail and, if applicable, those that need to be mitigated to achieve solutions of the highest quality
• Discussion of the requirements of optioneering in accordance with the Carbon Options Guidance Planning Advice Note (2023). In order to make informed decisions about the proposed circular economy and whole life-cycle carbon strategy, development options must be tested for carbon impacts and evaluated in terms of alignment with the CoLC’s vision, the applicant’s brief, and potential viable alternatives to the brief
• Design to be informed by a pre-redevelopment audit (aligned with the carbon options) exploring opportunities for maximum retention and material use
• Development of a circular economy strategy, prioritising the retention, re-use and recycling of building elements, materials and fit-out items, to include for example deconstruction strategies and including fit-out take-back schemes, before designing any new build elements for maximum flexibility and adaptability
• Adopting an embodied, operational or whole life-cycle carbon standard, such as LETI’s embodied carbon primer, the UKGBC’s EUI targets or the UK Net Zero Carbon Buildings Standard to demonstrate commitment for exemplary net zero performance
• Prioritising the objectives of the City of London Local Area Energy Plan (LAEP) to include creating links to or extensions of local energy networks and waste heat sources; and consider waste heat transfer from commercial to other uses nearby.
Submission requirements and recommendations
All development
• Pre-application documents on topics such as:
• Existing site and buildings analysis
• Site context – opportunities
• Project aspirations on sustainability
• Technical solutions
• Others as required depending on site
Major development (including applications referable to the Mayor):
• Carbon options assessment and Excel tool as required by Carbon Options Guidance Planning Advice Note 2023 to carry out 3rd party review.
• Draft pre-redevelopment audit & pre-demolition audit in line with GLA guidance 2022
• Study of opportunities to incorporate collective infrastructure such as energy networks, smart grids and energy storage (e.g. batteries) where possible
Recommended material to demonstrate exemplary practice:
• Existing building survey and analysis of context in as much detail as possible to inform opportunities and constraints
• Public engagement material
8. KEY CONSIDERATIONS AND SUBMISSION REQUIREMENTS
CONCEPTION / PRE-APPLICATION / RIBA STAGE 1 (CONTINUED)
Application stage
Pre-application/RIBA
Stage 1 (continued)
Key considerations
• Consultation with specialist officers as required, such as with regard to
• environmental resilience
• biodiversity
• building services and structural engineers
• circularity principles
• air quality
This will be particularly advisable where bespoke and innovative solutions are sought, e.g. initiatives to
• deliver the objectives of the biodiversity action plan
• achieve the highest quality balance between benefits of amenity, urban greening, biodiversity and climate resilience
• integrate climate resilience and energy infrastructure (to include solutions for noncombustible fuel energy back up technologies). The CoLC will support developers in implementing proposals and interventions to support heat networks in the City, including through meetings, initiatives and further City-specific guidance.
• drive forward low embodied carbon design and construction such as timber/CLT building elements (or other bio-based materials) and construction methods
• Commitment to certification schemes and targeted ratings
• Discussion about public consultation and engagement arrangements and content
• Confirmation of required application documents
Submission requirements and recommendations
KEY CONSIDERATIONS AND SUBMISSION REQUIREMENTS
PLANNING APPLICATION / RIBA STAGE 2-3
Application stage
Key considerations
Planning application / RIBA Stage 2-3
• Incorporation of refinements and amendments into the proposals, resulting from the:
• carbon optioneering process
• pre-application process
• public consultation responses
• Ensuring all issues identified in the pre-application, carbon optioneering process and public engagement phase are comprehensively and prominently covered in the application documents
• Ensure that any public benefits of the development include environmental benefits for the local area and City as a whole. These should be clearly laid out and demonstrated in the application documents
• Designing for loose fit - Identification of opportunities of the application design for future proofing of the proposed development including improvements to the sustainability performance before and after practical completion, such as from the design, fit-out, repair and maintenance and end of life phases of a development.
Future proofing in this context is designing in flexibility and adaptability to incorporate measures or to alter development details as easily as possible to improve its environmental performance. Examples are replacing proposed materials or building element systems, enabling natural ventilation at a later date, adapt the building services strategy for new, leaner technologies.
• Further development of an offer for innovative measures to be tested, in particular where they can provide solutions for site specific issues and concerns. This could include mitigation measures, material optimisation through design of building elements to perform multiple functions, design for deconstruction strategies, renewable energy generation, energy storage solutions and testing new materials, building element systems and services.
• Include separate operational carbon emissions for refurbishments with new build extensions over 1,000m2. For deep refurbishments, also provide calculations using a new build baseline for the whole development.
• Include green leases/clauses for tenanted floorspace to ensure energy efficiency design and low carbon fit-out and operation across the whole development
• Publication of pre-demolition audits in suitable online databases and other media as early as possible in order to support reuse marketplaces
Submission requirements and recommendations
Major development (including applications referable to the Mayor):
• Sustainability Statement to include a summary of all relevant separate technical assessments, and detailed information on how the development addresses climate resilience risks
• Carbon Options Assessment (standalone document preferred) - clearly labelled and presented
• Whole Life-Cycle Carbon Assessment (in accordance with GLA guidance and including spreadsheet) (standalone document preferred), to include provision of data through the GLA WLCA template and including updates where applicable
• Energy Assessment (in accordance with the GLA guidance, and including spreadsheet) (standalone document preferred)
• ‘Be Seen’ Energy Monitoring- upload information and performance data and confirmation of subsequent metering plan and portal updates
• BREEAM pre-assessment – minimum ‘Excellent’ rating, expected ‘Outstanding’ rating, with maximum credits for the Energy, Materials, Waste, Pollution and Water categories including credit Wst05 ‘Adaptation to climate resilience’. To include a BREEAM pre-assessment tracker indicating achievable, possible and non-achievable credits and rationale
• Commitment to a minimum NABERS UK 5 Star certification
• Circular Economy Statement (in accordance with GLA guidance), to include:
• pre-redevelopment audit with options appraisal
• pre-demolition audit
• the exploration of options (agreed as part of the Carbon Options Assessment) with regard to optimising circularity principles
• Preliminary Ecological Appraisal Report (PEAR), including details of biodiversity baseline assessments, and Defra Biodiversity Metric (DBM) spreadsheet
• Landscape Strategy, including details of proposed greening, irrigation system, and other supporting measures to enhance biodiversity, and Urban Greening Factor (UGF) plans and calculations
• SuDS and Drainage Plan
• Flood Risk Assessment
• Flood Emergency Plan, where applicable
8. SUBMISSIONS REQUIREMENTS AND CONSIDERATIONS
PLANNING APPLICATION / RIBA STAGE 2-3 (CONTINUED)
Application stage
Planning application
/ RIBA Stage 2-3 (continued)
Key considerations
• Considerations of development details that potentially can be optimised at later design stages and confirmed through appropriate conditions that allow for flexibility, improvements and incorporation of latest technologies, materials and building element and services systems into the design
• Make use of GiGL data search reports to inform urban greening and biodiversity proposals and upload any new biodiversity data gathered as part of the planning application to GiGL
Submission requirements and recommendations
Recommended material to demonstrate exemplary practice:
• Presentation of innovative solutions and best practice outcomes to reduce energy use, carbon emissions, demolition and construction waste and other exemplary sustainability features under the relevant topics
• Maintenance and Deconstruction Strategy, to demonstrate how waste is reduced during the lifetime of the building, and how material recovery is maximised at end of life
• Reuse or Upcycle Catalogue, to demonstrate material resource efficiency
• Axonometric drawings to clearly visualise which parts of the structure are retained/reused/new
Minor Development
• Design & Access Statement to include a Sustainability section for all relevant design measures and actions to address the sustainability issues as listed in the list of documents for major applications, to include carbon optioneering as required
Or alternatively
• Sustainability Statement with all information relevant to the proposed works
Recommended material to demonstrate exemplary practice for applications where carbon optioneering is not required:
• Demonstrate consideration of different development options and their carbon impacts, with prioritisation of lower whole life-cycle carbon options wherever possible.
All applications:
List of approved drawings, to include (where applicable):
• (Future) connection to a heat network
• Details of urban greening and biodiversity measures including type and extent of proposed greening
• Green/bio-solar and blue roofs, green walls
• Heat pump ventilation surfaces
• PV panels
• Natural ventilation intake areas and ventilation panels
POST APPLICATION CONDITIONS / POST OCCUPANCY / RIBA STAGE 4-7
Application stage
Post application, conditions / Post occupancy / RIBA Stages 4-7
Key considerations
• Entering into a Conditions Planning Performance Agreement to ensure resources are available to discharge conditions relating to details of the highest quality
• Demonstrating how further details have been developed, to include reasons for changes to details or performances in relation to whole life-cycle carbon and circular economy considerations and confirmation of reuse and recycling of building elements and materials on site and in other construction projects. This should include actions to limit carbon emissions from unnecessary extent of CAT B fit out needed for marketing.
• Developing the energy strategy in accordance with up-to-date technologies and insights, to achieve the best outcome for energy efficiency and carbon emissions, and to reduce offsetting requirements as much as possible. Consider providing a tenant manual or drafting a tenant agreement to optimise the system operation and tenantrelated carbon emissions.
• Reviewing extent and quality of urban greening, biodiversity and climate resilience measures on site in accordance with updated opportunities and constraints
• Provision of a case study of, or a report setting out the lessons learnt from, the scheme to share important insights and contribute to the promotion of best practice in the City
• Engaging with the City’s Clean City Awards Scheme (CCAS) to drive sustainability amongst member businesses in key areas related to waste, such as communication and engagement, resource efficiency and circular economy practices and reducing plastic waste. Best performances are awarded and Environmental Best Practice meetings and workshops are hosted.
Submission requirements and recommendations
All developments
• Detailed drawings and studies as required by planning conditions
• ‘ Be Seen’ Energy Monitoring – update contextual data and upload energy performance predictions
• Post completion Climate Change Resilience Sustainability Statement (CCRSS)
• Post completion Circular Economy Statement
• Post construction Whole Life-Cycle Carbon assessment
• BREEAM assessment final certificate
• NABERS UK final certificate
• Biodiversity Gain Plan (BGP)
• Habitat Management and Monitoring Plan (HMMP)
• Confirmation of maintenance requirements for urban greening, rainwater collection and other relevant installations
Recommended material to demonstrate exemplary practice, to include:
• Material passports e.g. via the Circuland platform
• Confirmation of availability/performance of materials and components (e.g. recycled content of steel products, associated emissions, test certificates), such as an EPD (Environmental Product Declaration) certification
• Evidence confirming method for overcoming regulatory, insurance or other issues outside planning required for development proposals
• Case study for publication.
• Submit project information to the Built Environment Carbon Database (BECD)