Policy information sourced from the Richmond Upon Thames Local Plan

Policy 4 Minimising Greenhouse Gas Emissions and Promoting Energy Efficiency (Strategic Policy)

A. To achieve the borough’s target of net-zero carbon by 2043 at the latest, all proposed development will be required to demonstrate that the fullest contribution to minimising greenhouse gas emissions has been made on site.

This will be achieved by requiring:

B. All development:

  1. to reduce greenhouse gas emissions on-site in accordance with the London Plan’s Energy Hierarchy:
    • Be lean: use less energy and manage demand during operation.
    • Be clean: exploit local energy resources (such as secondary heat) and supply energy efficiently and cleanly.
    • Be green: maximise opportunities for renewable energy by producing, storing and using renewable energy on-site
    • Be seen: monitor, verify and report on energy performance
  2. to make the fullest contribution to supplying energy efficiently and cleanly, and to maximise renewable and low carbon energy generation, storage and use, through the deployment of appropriately selected, sized and sited technologies;
  3. to promote a more ambitious use of available roof space to deliver multi-functional benefits (such as the co-location of renewable energy and green infrastructure);
  4. to adopt a circular economy approach to building design and construction to reduce waste, to keep materials and products in use for as long as possible, and to minimise embodied carbon (see Policy 7 ‘Waste and the Circular Economy (Strategic Policy)’).

C. All conversions and changes of use that result in the creation of 1 or more dwellings:

  1. to provide an Energy Strategy demonstrating how emissions savings have been maximised on site at each stage of the energy hierarchy;
  2. to achieve net-zero carbon with a minimum of 35% on-site reduction beyond Building Regulations (2021) (or any future updating successor to these standards).

D. New-build residential development of 1 or more dwellings, and major residential development of 10 or more dwellings (including changes of use, conversions and major refurbishments), and non-residential development of 100sqm or more (including changes of use, conversions and refurbishments):

  1. to achieve net-zero carbon with a minimum of 60% on-site reduction;
  2. to provide an Energy Strategy demonstrating how emissions savings have been maximised on site at each stage of the London Plan’s Energy Hierarchy;
  3. to use low carbon heat and hot water supply; there can be no gas boilers in new dwellings or new non-domestic development in Richmond from 2024;
  4. to demonstrate how energy demand, including regulated and unregulated uses (including plant or equipment), has been minimised on site through passive measures and by maximising the efficiency of building form, fabric and systems;
  5. to reduce the potential for internal overheating and reliance on air conditioning systems in accordance with the London Plan’s Cooling Hierarchy (Policy SI 4 Managing Heat Risk) and meet the requirements of Part O of the Building Regulations (TM592 (domestic) and TM529 (nondomestic));
  6. to meet the requirements of Part F of the Building Regulations (Ventilation);
  7. to assess viability of on-site renewables and target solar technologies equal to 40% of building footprint area (unless it can be clearly demonstrated that this is not practical);
  8. to disclose the anticipated Energy Use Intensity and space heating demand at design and pre-occupation stage, and over at least the first five operational years.

E. Zero carbon and the Council’s Carbon Offset Fund

  1. New development proposals will be required to get as close as possible to zero-carbon on-site, rather than relying on offset fund payments to make up any shortfall in emissions. A cash-in-lieu contribution to meet net-zero carbon will only be considered acceptable in instances where it has been clearly demonstrated with robust and credible evidence that no further savings can be achieved on-site, due to site constraints or limitations. Off-site provision instead of a cash-in-lieu contribution is only acceptable if an alternative proposal is identified, delivery of that proposal is certain and subject to agreement by the Council.
  2. The London Plan’s carbon offset price is currently set at £95/t. This is generally considered too low to actually deliver equivalent carbon savings and therefore does not incentivise sufficient on-site savings. Therefore, it is a perverse incentive for developers to offset carbon emissions via a cash-in-lieu contribution rather than achieving the actual savings on site.

In order to incentivise developers to implement on-site lower carbon strategies where possible, and to ensure that any remaining carbon shortfall can adequately be addressed off site, the carbon shortfall for the assumed life of a development (e.g. 30 years) will therefore be offset at a rate of £300/t as at 2021.The price for offsetting carbon is regularly reviewed. Any changes to Richmond’s suggested carbon offset price will be updated in future guidance.

Table 16.1 Summary of net zero carbon and on-site carbon emission reduction requirements:
Development TypeMinimum on-site total reduction in CO2
Major residential development of 10 or more dwellings (including new build, change of use, conversions, and major refurbishments).Net-zero with minimum 60% on-site reduction; with a maximum of 40% to be offset at a rate of £300/t
Minor new-build residential development of 1 or more dwellings.Net-zero with minimum 60% on-site reduction; with a maximum of 40% to be offset at a rate of £300/t
Minor residential change of use and conversions resulting in the creation of 1 or more dwellings.Net-zero with minimum 35% on-site reduction; with a maximum of 60% to be offset at a rate of £300/t
Non-residential development of 100sqm Gross Internal Area (GIA) or more (including new build, change of use and refurbishments).Net-zero with minimum 60% on-site reduction; with a maximum of 40% to be offset at a rate of £300/t

For more information please see the Richmond Upon Thames Local Plan