RedSix Commentary – June 2025
The draft London Plan, set to be adopted in 2027, outlines ambitious objectives to meet the city’s net zero by 2030 goal while also tackling the housing crisis and supporting economic growth. The consultation proposes:
- Energy Efficiency:
A review of existing standards, with options ranging from maintaining current targets to aligning with national Future Homes and Buildings Standards (FHS/FBS) or raising on-site energy efficiency requirements. - Heat Networks:
A shift toward alignment with national Heat Network Zones and a focus on low-carbon and waste-heat sources, phasing out gas-powered systems. - Overheating Policy:
Potential removal of bespoke overheating policies in favour of aligning with Part O of Building Regulations, with a more flexible approach to design. - Whole Life Carbon & Circular Economy:
A stronger emphasis on embodied carbon, with proposals for a retention vs. demolition framework, benchmark targets and streamlined reporting requirements. - Offsetting:
A review of the role of carbon offsetting, questioning its long-term future due to large amounts of unspent funds and concerns over effectiveness. - Planning Simplicity & Viability:
A wider goal to reduce duplication with national policies, simplify reporting requirements and avoid policies that could compromise housing delivery and viability.
These proposed changes aim to recalibrate London’s planning framework to ensure climate action, growth, and housing can be delivered side by side.
As the Greater London Authority (GLA) moves toward the adoption of a new London Plan in 2027, developers, architects and sustainability consultants alike are watching closely. The consultation period offers insight into the future of planning and sustainability policy in the capital, where net zero ambitions, housing demand and economic growth must now work in unison.
At RedSix, we work at the intersection of practical delivery and progressive sustainability. While we welcome the London Plan’s continued emphasis on climate action, we’re equally aware of the pressures our clients face in balancing ambitious targets with viability and programme risk. Here, we outline our reflections on the consultation’s key themes from whole life carbon and overheating to energy policy and the evolving role of heat networks, and share what developers and design teams should be considering next.
1. Net Zero by 2030: Necessary but Not Without Compromise
The headline: London aims to be a net zero city by 2030, a timeline just five years away. As the consultation outlines, this will require deeper emissions cuts across regulated energy, embodied carbon and operational performance.
We fully support this direction. However, our concern is less with the ambition and more with the clarity of execution. To move meaningfully toward net zero, we need a policy framework that rewards smart, integrated strategies rather than simply layering on more requirements.
The risk? A well-intentioned policy could unintentionally favour ‘tick-box’ compliance over outcome-led design. This is where our role becomes crucial, helping teams find the balance between regulatory alignment and practical implementation that genuinely reduces emissions, adds value and avoids delays at planning stage.
2. Heat Networks: A Time to Reset
Heat networks have long been a priority in London, but the consultation rightly acknowledges the changing landscape. With the electricity grid decarbonising rapidly, many gas-powered networks now offer higher carbon intensities than all-electric schemes.
We agree that alignment with national Heat Network Zoning is a logical move, but with a caveat: any new connections must be to low-carbon or waste-heat networks only. The era of defaulting to gas-fed networks for policy compliance is over. This is an opportunity to reframe heat networks not just as planning obligations, but as smart, flexible assets that can genuinely support long-term decarbonisation.
Our advice to clients: interrogate the carbon performance of any proposed network early and ensure commercial and technical feasibility aligns with net zero principles, not just planning requirements.
3. Overheating and Passive Design: Still an Urban Challenge
Part O of the Building Regulations now provides a national framework for addressing overheating risk and the consultation hints at aligning the London Plan more closely with it.
This seems sensible, yet, we caution against losing sight of London’s unique urban heat island effects and increasingly hot summers. Passive cooling strategies, orientation and design flexibility remain critical. What’s needed is not a retreat from overheating policies, but smarter integration, particularly in high-density and mixed-use schemes where dual aspect, daylighting and noise can be in tension.
Our approach prioritises early-stage design input and simulation-led decision-making to meet both comfort and efficiency targets, without compromising on layout or liveability.
4. Energy Efficiency: More Isn’t Always Better
Energy efficiency remains a cornerstone of the consultation, with several options proposed, from maintaining current London Plan requirements to aligning with national Future Homes and Future Buildings Standards (FHS/FBS).
We see merit in both perspectives. On one hand, continuing to exceed national standards helps London lead the way. On the other hand, the law of diminishing returns is real, especially for non-residential buildings, which are already close to optimised in terms of fabric performance.
What’s missing from the conversation is perhaps the most important element of all: smart energy management. As we move toward all-electric buildings, the ability to respond dynamically to grid demand, incorporate battery storage and manage peak loads will be essential. Efficiency alone will not unlock net zero, flexibility and technology will.
We urge policymakers to place greater emphasis on smart systems, controls and storage and we encourage developers to embed these strategies into their energy and MEP planning from day one.
5. Whole Life Carbon and Circular Economy: A Defining Shift
One of the strongest and most encouraging signals from the consultation is the focus on whole life carbon and circular economy principles.
The plan proposes clearer benchmarks, optioneering frameworks and streamlined reporting. This is critical. Embodied emissions, particularly from demolition and new materials, are now a key driver of carbon impact in a world of low-operational-energy buildings.
At RedSix, we’ve already seen clients benefit from scenario modelling and carbon-led retention strategies, particularly where heritage, viability and planning risk intersect. A robust framework for evaluating retrofit vs new-build is not only overdue, but essential to delivering both sustainability and housing growth in tandem.
6. Offsetting: Reassessing Its Role
With over £288 million in carbon offset funds unspent, the consultation’s review of offsetting is long overdue. As a mechanism, offsetting is only meaningful when funds are deployed transparently and strategically to deliver measurable carbon savings.
We believe offsetting should remain part of the toolkit, but as a last resort, not a design shortcut. Projects must demonstrate genuine efforts to reduce emissions on site before turning to offsets and any future offsetting scheme must be better monitored, regionally impactful and ringfenced for built environment improvements.
Where Do We Go From Here?
The next London Plan must walk a tightrope. It must be ambitious enough to drive meaningful change but realistic enough to enable delivery. In our view, that means:
- Avoiding unnecessary duplication with national policy
- Prioritising outcome-based strategies over prescriptive checklists
- Embedding smart energy management as a core component of compliance
- Providing clarity and consistency around whole life carbon and retrofit decisions
- Streamlining reporting to avoid planning delays and reduce uncertainty
At RedSix, we’re already supporting clients through this transition, optimising developments to meet evolving requirements while maintaining focus on deliverability, viability, and design quality. As more detail emerges from the consultation, we’ll be continuing to engage and advise on the best path forward.
If your project is in planning or early design and you’re unsure how the emerging London Plan could affect your strategy, our team can help.
Contact RedSix to discuss how policy shifts will affect your development pipeline and how to futureproof your sustainability strategy.
