The new GHR chapter at a glance
The GHR chapter retains the ambition for net zero development but shifts from percentage carbon reduction targets to absolute performance standards, whilst the approach to low-carbon heat marks a notable shift from the default steer toward heat networks. The removal of the carbon offsetting scheme, resulting in a typical saving of £500 - £1,000 per home will be welcomed by housebuilders. Elsewhere in the chapter, flood risk and drainage policies are merged, requiring greenfield-equivalent discharge rates on referable schemes and expressly permitting off-site, area-based Sustainable Drainage System (SuDS) contributions. Car parking standards move to a new Sustainable Access Measure (SAM) and Optimisation Framework, reinforcing a 'car-free' and 'car-lite' approach, with car clubs provided in SAM 4 and below locations - i.e. everywhere except the best-connected SAM 5 areas.
Eleven policies sit within the chapter:
- GHR1 – Energy efficiency
- GHR2 – Low-cost, low-carbon heat
- GHR3 – Whole life-cycle carbon
- GHR4 – Heat risk
- GHR5 – Flood risk and drainage
- GHR6 – Trees, biodiversity and geodiversity
- GHR7 – Green Infrastructure and the Urban Greening Factor
- GHR8 – Accessible green space
- GHR9 – Clean and healthy waterways
- GHR10 – Air quality
- GHR11 – Cycle and car parking
From percentage targets to absolute performance metrics
The single biggest technical change in the chapter is in energy policy. The current Plan's Policy SI2 requires major development to be net zero-carbon, achieved via a minimum 35% on-site carbon reduction beyond Building Regulations, following the "Be Lean, Be Clean, Be Green, Be Seen" energy hierarchy, with any shortfall paid into a borough carbon offset fund. Improvement in carbon performance beyond Building Regulations has become less meaningful, with the decarbonisation of the electrical grid and all-electric development being effectively mandated.
Draft Policy GHR1 Energy Efficiency thereby, replaces that relative reduction with absolute performance standards: a Space Heating Demand (SHD) target of 20 kWh/sq m/yr (baseline) or 15 kWh/sq m/yr (aspirational) applying to all typologies. This is set alongside typology-specific Energy Use Intensity (EUI) targets - for example 40 (baseline)/35 (aspirational) kWh/sq m/yr for residential, 90 (baseline)/70 (aspirational) kWh/sq m/yr for offices, and 120 (baseline)/80 (aspirational) kWh/sq m/yr for hotels. The link with Passivhaus certification emerges again, with the aspirational target of 15 kWh/sq m for space heating demand, shifting the focus back on building fabric as the primary route for compliance. Turley’s recent inputs to ‘Planning Representations’ have highlighted the cost and compliance burden this imposes on development at scale, not to mention that it prescribes a façade design without the flexibility to balance daylight and enhanced natural ventilation for overheating.
Developments must also maximise on-site renewable generation and monitor and report actual in-use energy demand for at least five years post-construction. This seeks to tackle the long discussed ‘performance gap’, a challenge that the voluntary new Net Zero Carbon Buildings Standard[2] has also sought to address.
Carbon offsetting is removed from the Plan altogether and notably plan-making authorities are explicitly mentioned in that they "should not set their own energy-efficiency or emissions reduction standards in local plans", a clear and deliberate move towards London-wide standardisation, which the chapter's own rationale explains is intended to avoid "a multiplicity of separate standards and a ratcheting up of requirements and costs on development". This will be welcome news to housebuilders, with typical offset contribution savings ranging from £500 - £1,000 per home.
Low-carbon heat: a more technology-neutral approach
Draft Policy GHR2 Low-cost low-carbon heat provides a more technology-neutral approach to heat: all major developments must submit a Low Carbon Heat Appraisal to establish "the optimum low carbon and low cost" heating solution for their specific site, assessed against communal versus individual systems and different heat source technologies on "a level playing field", rather than being steered towards a fixed hierarchy of preferred technologies.
This is a more pointed change than it first appears. The outgoing 2021 Plan's energy hierarchy structurally steered development towards heat networks: in designated Heat Network Priority Areas, connection to an existing or planned network was the expected default, not the output of a neutral appraisal against alternatives.
That default had the unintended consequences of steering development in some cases towards higher carbon alternatives, a point which Barny Evans, Director of Sustainability and ESG has made for over a decade[3].
This policy also exposed a serious consumer-protection gap. Heat networks had no economic regulator until Ofgem was appointed as the statutory regulator on 27 January 2026 under the Energy Act 2023. Yet London was planning mandating residents onto a technology with no price protection, no ability to switch supplier, and limited statutory ombudsman protections[4].
Whole life-cycle carbon
GHR3 Whole life-cycle carbon addresses embodied and whole-life carbon - arguably the chapter's most consequential policy. There is still a requirement for a "pre-redevelopment audit" before demolition is accepted, explicitly because retention "is typically the lowest-carbon option". The complexity of this topic, balancing heritage, placemaking, planning and sustainability considerations is something we have extensively explored with the industry through our Love it or Level it Roundtables.
Where new build does proceed, baseline upfront carbon targets are now set by building type: 500 kgCO₂e/sq m for residential schemes under 11-storeys, rising to 700 kgCO₂e/sq m for taller residential, and 700 kgCO₂e/sq m for Use Class E (commercial, business and service) development. Whilst housebuilders and commercial residential developers have been moving towards lower upfront carbon targets, the 500 kgCO₂e/sq m target currently represents top-quartile performance rather than the norm. This will undoubtedly add to the viability dilemma with recent publications from the Home Builders Federation[5] citing that building costs have risen by £76,000 per home since 2020, driven by inflation, new taxes, and green rules.
In summary, the move to EUI and SHD standards, the more tech-neutral heat approach, new upfront carbon targets and the removal of offsetting emerge as among the most significant technical changes in the whole document.
Heat risk, flooding and a hotter city
Overheating is addressed through a dedicated standalone policy in the draft Local Plan - GHR4: Heat Risk - reflecting its significance as a distinct planning consideration to create a Heat Ready London, in the wider reality of London temperatures breaking records for two consecutive days in May 2026.
Policy GHR4 requires major development proposals to minimise their contribution to the Urban Heat Island effect and to demonstrate, through a clearly defined hierarchy of passive design measures, that overheating has been addressed at source. This hierarchy prioritises limiting solar gain and maximising natural ventilation before considering mechanical cooling, thereby ensuring that passive design solutions are exhausted before reliance is placed on active cooling systems.
Head of ESG, Snigdha Jain, has previously contributed directly to the evidence base commissioned by the Greater London Authority to inform its Urban Heat Island planning policy, with broader findings published within ‘In Practice’ Magazine[6]. It’s also worth noting that some commentators have argued that the Urban Heat Island effect is often more nuanced, and its risks sometimes overstated[7].
The policy is explicit that air conditioning is not banned, and the rationale specifically flags that it "is likely that it will need to be provided in heat-sensitive uses such as hospitals, care homes, and schools". Where it is included without a demonstrated need via CIBSE overheating assessment (TM52, TM59 and TM49 are all referenced directly), applicants must still show all feasible passive measures have first been incorporated. Notably, the policy continues to apply to all building uses, not just residential; therefore, going beyond current Building Regulations, which only address overheating in homes.
Flood risk and drainage (GHR5) consolidates the current Plan's separate flood risk and sustainable drainage policies into a single policy. Development is expected to minimise increases in impermeable surfaces and manage surface-water runoff through capture, reuse, infiltration and attenuation in accordance with a defined drainage hierarchy. Referable schemes are expected to achieve greenfield-equivalent discharge rates wherever practicable, using a combination of on-site measures and, where equivalent on-site performance cannot reasonably be achieved, contributions to off-site sustainable drainage infrastructure.
Trees, biodiversity, greening and open space
Trees and biodiversity (GHR6) and green infrastructure/the Urban Greening Factor (GHR7) are two distinct policies in this draft, not one combined "greening" policy.
GHR6 covers the protection of designated nature sites, veteran trees and ancient woodland - continuing the current Plan's protections - alongside requirements for new tree planting that prioritises larger-canopied and climate-resilient species where site constraints allow. Biodiversity gains must now be delivered in accordance with the national Biodiversity Net Gain (BNG) requirements introduced under the Environment Act 2021. New to this draft, London's Local Nature Recovery Strategy (LNRS) - a mechanism created by the Environment Act 2021 and finalised by the GLA in 2026[8] is now woven through the policy: it informs Sites of importance for Nature Conservation (SINC) designation, identifies nature recovery opportunities ahead of formal designation, guides habitat creation proposals, and specifically drives a "strategic significance" uplift within BNG calculations.
GHR7 carries the Urban Greening Factor (UGF) forward as the principal tool for evaluating on-site greening, with the principal change impacting industrial schemes. Previously exempt Classes B2/B8 will now need to meet a UGF target of 0.2. Given that large parts of these sites are already needed for operational yard space and vehicle circulation - and that the wider policy emphasis is on optimising every square metre for intensification - hitting the 0.2 target through ground-floor landscaping alone may prove challenging. If carried forward in its present form, therefore, Policy GHR7 could have the unintended consequence of pushing developers towards increased green roof coverage instead.
GHR8 (Accessible Green Space) forms a third, separate strand. The requirement for no net loss of designated public green space carries forward from the current Plan's Policy G4, as does the practice of mapping deficiency against a size/catchment hierarchy of green space categories. Whilst the policy reads as ‘absolute’, in our experience, enforcement in practice hinges on a ‘case by case’ equivalent or better judgement call.
Cycle and car parking
GHR11 (Cycle and Car Parking) - Car parking standards move to a new Sustainable Access Measure (SAM) and Optimisation Framework, reinforcing the 'car-free' and 'car-lite' approach previously adopted, with car clubs provided in SAM 4 and below locations - i.e. everywhere except the best-connected SAM 5 areas.
Summary
On balance, the draft Plan represents a mixed picture rather than a straightforward easing or tightening of requirements.
There is some relief. GHR1 removes the system of carbon offset payments for residual emissions, GHR2 removes the presumption in favour of heat-network connection whilst GHR5 formalises and makes explicit a route to off-site SuDS - helpful for certainty and negotiating position.
However, this is counteracted with newer requirements under GH3 for upfront carbon which will represent a design and supply chain challenge for the majority of the market. A Space Heating Demand limit under GHR1 set close to Passivhaus certification levels, shifts the focus firmly back onto fabric performance and presents technical and viability challenges. The enforcement of the Energy Use Intensity limits under GHR1 remains to be seen, as it has previously lacked real teeth, and, underperformance has triggered a corrective action plan, not a financial penalty or fine.
Whether this combination of measures is sufficient to get London back on track to deliver the housing and commercial development it needs remains to be seen.
If you would like to discuss the impact of the Draft London Plan, please get in touch with Snigdha Jain and Lizzie Bolton from our London office.
28 July 2026
[1] Draft London Plan (2026), Chapter 5 — "Creating a greener, healthier, and resilient city" — Greater London Authority, published 16 July 2026 (policies GHR1–GHR11)
[2] https://www.nzcbuildings.co.uk
[3] https://www.cibsejournal.com/general/wrestling-with-the-future-of-heat-debate/
[5] https://www.hbf.co.uk/news/new-taxes-and-policy-costs-add-76000-to-the-cost-of-building-a-new-home/
[6] https://gala.gre.ac.uk/id/eprint/25088/7/25088%20BARTLETT_Cool_Towns_Project_%28Pub%29_2019.pdf
[7] https://www.building.co.uk/comment/the-urban-heat-island-is-actually-pretty-cool/5130921.article
[8] https://www.london.gov.uk/sites/default/files/2026-03/MoL_LNR_Strategy_FA.pdf
