Dear Sir/Madam,

Under EIR 2004 regulations, I would like to request information regarding the council’s implementation of London Plan policy 5.9 (on overheating risk) in planning decisions, particularly in major residential developments.

Specifically:

1. What is the council’s approach to implementing policy 5.9, and has the council developed additional local policies in this area?
2. At the pre-application stage, what advice is provided to developers to help them address policy 5.9? For example, are developers made aware of GLA guidance on energy assessments and the ‘Early Stage Overheating Risk Tool’ in Appendix I?
3. Are developers expected to carry out dynamic overheating modelling as recommended in the GLA guidance?
4. How does the council monitor the success of these policies in reducing overheating issues in new build properties?

If any of these information requests are unclear, I am happy to revise my request with your advice as required under the regulations. I would like all information to be provided in an electronic format where possible.

best wishes,
James MacDonald.

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Request for Information - LBR2021/0101 - London Plan policy 5.9

 

Thank you for your request for information received on 27/01/2021.

 

This will be processed in accordance with the appropriate access to
information regime but may be delayed due to the Council prioritising the
operational requirements of Covid-19. We remain committed to responding to
your request and will reply as soon as we are able. 

 

We apologise for any inconvenience this may cause.  Should our response to
you breach the statutory time frame you have the right to complain to the
Information Commissioner:

 

Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire, SK9 5AF. www.ico.org.uk

 

Yours faithfully

 

FOI and DPA Officer

[email address]

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References

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1 Attachment

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[1]cid:image001.jpg@01D500CE.92FE73F0

 

Request for Information - LBR2021/0101 - London Plan policy 5.9

 

I refer to your request for information received on 27/01/2021.  Please
see the information below in response to your request: -

 1. What is the council’s approach to implementing policy 5.9, and has the
council developed additional local policies in this area?

 

The Council has developed additional local plan policies to deal with
overheating.  The adopted Local Plan Policy LP 20 Climate Change Adaption
states:

 

A. The Council will promote and encourage development to be fully
resilient to the future impacts of climate change in order to minimise
vulnerability of people and property.

B. New development, in their layout, design, construction, materials,
landscaping and operation, should minimise the effects of overheating as
well as minimise energy consumption in accordance with the following
cooling hierarchy:

1. minimise internal heat generation through energy efficient design

2. reduce the amount of heat entering a building in summer through
shading, reducing solar reflectance, fenestration, insulation and green
roofs and walls

3. manage the heat within the building through exposed internal thermal
mass and high ceilings

4. passive ventilation

5. mechanical ventilation

6. active cooling systems (ensuring they are the lowest carbon options).

C. Opportunities to adapt existing buildings, places and spaces to the
likely effects of climate change should be maximised and will be
supported.

 

The council’s approach on major applications will be to implement LP 20
and also highlight the cooling hierarchy to applicants.

 

The council also has developed a [2]sustainable design and construction
checklist which refers to overheating (Section 2, 2.1 (Need for
Cooling))which applies to all new build residential.

 

 

 2. At the pre-application stage, what advice is provided to developers to
help them address policy 5.9? For example, are developers made aware
of GLA guidance on energy assessments and the ‘Early Stage Overheating
Risk Tool’ in Appendix I?

 

The council contracts sustainability consultants Climate Integrated
Solutions (CIS) to help advise on applications (normally major) that deal
with sustainability requirements and whether the applicant has achieved
the policy requirements.

 

The current approach is for CIS to review the applicant’s sustainability
and energy statements and where applicable any separate over
heating/cooling strategy report to ensure the application is in accordance
with London Plan policy 5.9.

 

Applications are flagged where they are not following the energy hierarchy
or are not designed to reduce the impact of the urban heat island effect
in London and do not adhere to the steps noted in the cooling hierarchy
outlined in policy 5.9.

 

If the application does not provide the required evidence around
overheating and cooling CIS will then request and review additional
responses as required to ensure all steps are taken to provide evidence
that the cooling hierarchy has been incorporated into designs.

 

 

 

 3. Are developers expected to carry out dynamic overheating modelling as
recommended in the GLA guidance?

 

CIS report that they typically find that a dynamic thermal model has been
completed. In cases where the modelling identifies any potential
overheating issues or where there are gaps within the modelling, these are
raised with the applicant and recommendations for amendments provided. If
the development requires CIS will recommend mitigation measures for the
applicant to consider. If a thermal model is not included in the
submission the applicant is contacted to provide the necessary, model or
detailed data before any decision can be made.

 

 

 4. How does the council monitor the success of these policies in reducing
overheating issues in new build properties?

 

The Adopted Local Plan has indicators to monitor Local Plan Policy 20. 
These are set out in the Richmond [3]Monitoring Framework and state:

LP20

‘Numbers of completed developments subject to the Sustainable Construction
Checklist incorporating cooling measures in schemes, by type of measure
(as in SCC).

Numbers of completed developments subject to the Sustainable Construction
Checklist incorporating heating measures in schemes, by type of measure
(as in SCC).’

 

The performance of the indicators are monitored in the Authority
Monitoring Report.

We trust this response satisfies your request. If you are dissatisfied
with the information provided in relation to your request, you may make
representations to the Information & Transparency Manager. Any such
request for an internal review should be made within 40 working days from
today's date. Correspondence should be addressed to: 

 

FOI and Complaints Team, Ground Floor, Civic Centre, 44 York Street,
Twickenham, TW1 3BZ. Email: [email address]

If you are not content with the outcome of the internal review, you have
the right to apply directly to the Information Commissioner for a
decision.  Details of how to contact the Information Commissioner can be
found at: 

 

[4]https://ico.org.uk/global/contact-us/

Please note, all material provided by Richmond Council in response to your
request for information is for your personal, non-commercial use. Richmond
Council reserves all rights in the copyright of the information provided.
Any unauthorised copying or adaptation of the information without express
written confirmation from Richmond Council may constitute an infringement
of copyright. Any intention to re-use this information commercially may
require consent. Please forward any requests for re-use of information to
the FOI officer.

Regards

FOI and DPA Officer

[email address]

 

IMPORTANT:
This email and any of its attachments are intended solely for the use of
the individual or entity to whom they are addressed. If you have received
this message in error you must not print, copy, use or disclose the
contents to anyone. Please also delete it from your system and inform the
sender of the error immediately. Emails sent and received by Richmond and
Wandsworth Councils are monitored and may be subsequently disclosed to
authorised third parties, in accordance with relevant legislation.

References

Visible links
2. https://www.richmond.gov.uk/sustainable_...
3. https://www.richmond.gov.uk/media/14179/...
4. https://ico.org.uk/global/contact-us/

Dear FOI LBR,

Thank you very much for this detailed response.

Yours sincerely,

James MacDonald