Account of Forum meeting on 6 June 2022 hosted by UCL
Full minute by Riëtte Oosthuizen also at planninginlondon.com > LP&DF

London Planning and Development Forum on 6 June 2022 was kindly hosted by Dr Jessica Ferm, Associate Professor in Planning and Urban Management, Director of Undergraduate Programmes, Bartlett School of Planning, University College London at 22 Gordon Street, London, WC1 0QB.

First discussion led by Alison Bembenek Lichfields and Fred Pilbrow from Pilbrow and Partners on Material Considerations: Climate change, Embodied Carbon and the Role of Planners (prompted by the Secretary of State’s call in of the M&S Oxford Street Scheme) Alison’s presentation gave an overview of that sta-tus of climate change and embodied carbon nationally in planning policy. The London Plan is leading the way on whole life carbon assessments. Research carried out by Lichfields in 2021 on plan-ning and the climate emergency indicated that only 35 per cent of emerging local plans had poli-cies that referenced the need to address embodied carbon.

Nationally, the majority of local authorities declared a climate emergency but these aspirations do not necessarily get translated into adopted plan-ning policy. Only 59 per cent local authorities nation-ally have adopted local plans and of these only 2.7 per cent had specific targets to achieve net zero. The Government needs to do more to assist local author-ities to bring forward their net zero carbon goals. The Government is aware of this and last year a series of events took place led by the Environment Audit Committee taking evidence from sustainability experts and architects. The findings were published in May 2022 ‘Building to Net Zero: Costing Carbon in Construction’. It highlights the challenges ahead in terms of climate change. The UK’s construction sec-tor is responsible for 25 per cent of total net green-house emissions. The UK has a leading binding target to reach net zero by 2050. The carbon emissions associated with construction must be significantly reduced.

The report highlights that the focus has been on operational emissions, i.e. how to make buildings more efficient, rather than the embodied carbon costs of construction. The report concludes that if the construction sector in the UK keeps on dragging its feet, we will not meet net zero by 2050. The Report recommends that whole life carbon assessments should become mandatory for buildings over 1,000 sqm or schemes larger than 10 homes. It should be introduced no later than by December 2023. This is to be done through Building Regulations and reflected in the planning system through amendments to national planning policy.

The Report recommends a ratcheted approach to carbon zero so that carbon reduction increases to match the pathway to net zero.

What do we mean by whole life carbon emis-sions? These are the emissions attributed to a build-ing across its whole life time, split between opera-tional and embodied carbon (building materials, transport, installation on site and disposal at end of life).

Whole life carbon is operational and embodied carbon assessed together. Embodied carbon emis-sions should be tackled alongside operational car-bon. This has implications for design, materials selec-tion with lower carbon impact and resourcing. Materials with the best performance should be cho-sen for their lowest whole life impact. Materials with higher embodied carbon if reduction in operational carbon over the lifetime of the building can be achieved.

There is no national policy on embodied carbon at present. The London Plan has Policy SI 2 is a hook that requires the reduction of Green Gas Emissions. It requires all schemes referable to Mayor to calcu-late Whole Life Cycle Carbon Emissions through a nationally recognized assessment. It also encourages other major developments to assess how the whole life cycle circular economy has been taken into account. Earlier this year the Mayor also published guidance on Circular Economy and Whole Lifecycle Assessments. Noticeably, at the Environment Audit Committee events, the London Plan approach has been described as exemplary by those who gave evi-dence to MP’s.

Being discussed early makes it possible for key decisions on carbon to be incorporated into the whole development of buildings. The GLA approach requires whole carbon to be looked at during pre-app, planning and post-construction phase. Assessments are based on benchmarks evaluated during the appraisal, whole building design, con-struction and disposal process. Alison referred to the appeal decision on the The Tulip – 20 Bury Street. Foster + Partners had ambitious plans for a 305 meter high tourist attraction, but it was rejected, deemed not to be of the highest architectural quality due to heritage impact on the Tower of London and its poor perceived lifetime sus-tainability. The Inspector remarked that although considerable effort has been made to adopt all avail-able techniques to make the construction and opera-tion of the scheme as sustainable as possible, fulfill-ing the brief of a tall reinforced concrete lift shaft, however the result is a very unsustainable whole life cycle. The Secretary of State agreed. Very little thought went into how the building would function over its life cycle. There were no plans for its re-use; it could not readily be adapted for anything else. The conclusion: it has very little overall benefit to Londoners.

In summary the implications for planning are the following:

  • Climate change considerations are increasingly central to planning and decision making
  • Revisions to national policy?
  • Emphasis on retrofit and reuse over new build
  • More use of vacant buildings essentially through Permitted Development Rights although ongoing concern over quality of spaces created through permitted development
  • A balance needs to be struck regarding the mate-rial considerations and weighing up decisions when buildings are retained as you are constrained by the structure
  • Embodied carbon vs operational savings via more efficient buildings is a constant battleground that needs to be watched.

Whole life carbon: Is refurbishment always the right approach?

Fred Pilbrow of architects, Pilbrow and Partners, presented two current projects that he hoped might shed light on the current debate about the merits of refurbishment against that of new build.

Mr Pilbrow maintained that the decision to refurbish or replace existing buildings must be informed by context: in the majority of cases refurbishment is the right approach but there are circumstances where the quality of the existing buildings constrain their reuse to an unacceptable degree – here replacement is appropriate.

The two projects : 127 Kensington High Street recently completed for Ashby Capital, and 458 Oxford Street, designed for M&S, have similarities – both provide excellent retail below highly per-forming and flexible workspace. They share an ele-vational palette of white Roman brick and Portland stone which make reference to historic depart-ments store neighbours – at Kensington the Grade II* Derry and Toms , at Oxford Street the Grade II* Selfridges. Both make ambitious contributions to enhancing the quality of the public realm through new permeability, active frontages, and landscaped public space.

Yet the building in Kensington is a refurbish-ment and the Oxford Street a new build. Why?

Mr Pilbrow explained that the principal differ-ence was the quality and layout of the existing buildings. At Kensington, the refurbishment remodelled and extended a 1970’s department store. This was a single robust structure, with reg-ular and open structural grids, generous floor loading and ample ceiling heights. It could be stripped back to the frame, extended and new facades and cores added to deliver really high quality retail and office space.

By contrast at 458 Oxford Street, M&S had grown though organic expansion to occupy three entirely separate buildings, none of which had been designed for their present retail function. They were characterised by dense and irregular structural grids, low floor to ceiling heights, poor interconnectivity and configured with inefficient servicing arrangements that severely compromised the quality of the public realm.

127 Kensington High Street

The existing building was constructed by Pontings in the 1970s to serve as a department store. The building was later converted to office. The refur-bishment addresses the shortcomings of this bru-talist building. New elevations to Kensington High Street and Wrights Lane restore the historic street alignment infilling awkward residual spaces left by the original building’s orthogonal plan. The new elevations of brick and stone enhance the build-ing’s contribution to its historic context.

The building was extended vertically with three new floors of accommodation which are set back behind a sequence of richly landscaped garden ter-races. The building addresses both sustainability and wellbeing considerations through new facades which passively moderate the external environ-ment and are designed to allow natural ventila-tion. A displacement ventilation system delivering generous air volumes is allied to tall ceilings and exposed thermal mass. Operational energy use is anticipated to be 105kwh/m2/annum. Embodied carbon was 700kgc02e/m2 GIA. Floorspace was increased by 50%. The offices are designed to achieve BREEAM excellent certification.

The building’s recent construction date and excellent archival information on its structure and construction assisted its reuse. We were able to exploit the high live loadings originally required for retail to support the additional accommodation.

458 Oxford Street

Visitors to M&S’ Marble Arch store will recall it provides a confusing and awk-ward environment. M&S initially leased a ground floor retail unit at Orchard House, a speculative office building by Treharne and Norman, expanding over time to occupy its upper floors. In the mid-70s M&S constructed a retail and hotel wing to the north at 23 Orchard Street. At the time of this extension Westminster widened Orchard Street driving the pavement into the ground floor of Orchard House. The legacy for pedestrians is unfortunate, a low dark tunnel set between the street and the long blank frontage of the building’s core.

The store then expanded west on Oxford Street into the upper floors of Neale House. Neale House is a 1980s speculative development without architectural merit.

Of the three buildings, Orchard House is the only one of any interest (although Pevsner was dismissive of its quality). It has however been extensively altered externally and internally and a recent application to have the building listed was rejected by Historic England and the Secretary of State. All three of the buildings are excluded from the con-servation areas that surround the site.

Our initial design research explored whether a refurbishment could deliver an appropriate quality of retail environment to allow M&S to continue to trade successfully at Marble Arch. Oxford Street, in common with other high streets, has faced signifi-cant challenge from the rise of internet shopping, compounded by the pandemic. Debenhams and House of Fraser have closed, John Lewis is down-sizing and many smaller shops are vacant. M&S believe that a step change in the quality of cus-tomer experience, allied to improvements in oper-ational efficiency and flexibility, is critical for long-term success.

We concluded that a refurbishment of the three buildings would be compromised to an unacceptable degree and M&S concurred that a new building was essential to meet their objec-tives.

This new building delivers a transformed retail environment for M&S set below new workspace designed to the highest sustainability and wellbe-ing standards. The building will achieve BREEAM Outstanding and WELL Platinum certifications – a level of performance matched by less than 10% of new offices. The new building underpins signifi-cant public realm enhancement. Today, Granville Place is a desolate, service dominated environ-ment, hostile to pedestrians. We were struck by the example of St Christopher’s Place on the oppo-site side of Selfridges which is an attractive oasis space where shoppers go for lunch or a coffee in an attractive landscaped setting. The new building allows servicing to be discreetly but efficiently planned away from Granville Place and a new arcade will connect Orchard Street through to a landscaped garden animated by ground floor retail and cafes. Inflected elevations draw the building line back from Oxford Street and Orchard Street, replacing the low dark tunnel with high-quality public space.

M&S are committed to environmental sustain-ability and tasked the team to minimise embodied and operational carbon in the new development. Working closely with environmental consultants Arup, we achieve embodied energy levels of 651kg/c02e m2 GIA and operational carbon, inclu-sive of tenant allowances of 88kwh/m2/annum. Embodied energy levels are reduced through the use of post-tensioned concrete with high GGBS content, integrated with zones of structural timber. Pilbrow & Partners worked with Arup to extensive-ly reduce solar gain through bespoke brise soleil. On this basis, Arup predict an embodied energy pay back of 16 years, after which time the overall carbon impact will be lower for the new build than a refurbishment. The building is designed with a 120-year life span so these benefits will accrue long into the future.

Circular economy principles inform every aspect of the design including how the existing structures will be recycled. 95 percent of the exist-ing buildings will be reused including the Portland Stone façade of Orchard House which will be inte-grated into the new building elevations.

Discussion: Brian Waters remarked it might be useful to give the presentation to Michael Gove. Fred said the scheme was judged by Westminster Council and the Mayor. Everyone who has looked at the scheme carefully is on board with its approach. Mr Gove issued a holding decision to Westminster so there is optimism that it would be given proper consideration.

Peter Eversden asked if a public enquiry could be called. Fred felt the issues at stake has not been com-municated appropriately so a chance to present would be good but a public inquiry would take another 18 months which would jeopardize the con-tinued presence of M&S on Oxford Street. 400 jobs would be at stake. Jim Monahan enquired whether M&S was the sole financier of the development. Fred explained that they have a lease interest on the site. Ultimately it is a Portland Estate freehold. Part of the site – Neale House – is a sub-lease to Royal London Asset Management who was engaged with in the develop-ment of the scheme. M&S won’t fund the scheme; they will find a developer partner. They are confident there would be demand for it; what is developed is market facing.

Jim Monahan wanted to clarify the lifespan of the building. Fred mentioned that Simon Sturgess did critique of the scheme and some confusion came in that the façade cladding has only been allowed a design life of 30 years. The RICS has an embodied carbon measuring methodology requires you to assume certain life spans. It is not the case in the M&S building where it has been designed for 120 years.

The M&S store is located in the International Centre in Westminster. Pilbrow and Partners talked to Westminster about a mixed use scheme at the outset but the response was that residential was inappropriate here. It was important to create big and generous spaces. Scale is the right thing for buildings to survive a long time. Optimised 1960s buildings where everything is squeezed to the opti-mum do not tend to have long lifespans.

There was a discussion that followed on light touch refurbishment with very good embodied car-bon vs deep refurbishment – deep cut and carve with even more embodied carbon than new build. Different design teams might come up with differ-ent answers.

Riette Oosthuizen remarked there might some-thing interesting happening on considerations of the future of buildings and whether the technical justifi-cation of this sits within the Building Regulations regime and/or planning policy. A recent court case in Lambeth where residents – through JR – questioned whether a building could take extra stories on top was dismissed by the Court who found that matters of structural integrity reside with Building Regulations and therefore whether a project is deliv-erable because of its structural deliverability is not a matter for a planning officer to consider as it does not fall under planning policy. As such, whether it is a better approach to refurbish or not, must become more aligned with planning policy as otherwise there are cases which might slip through and build-ings might get demolished without being given ade-quate consideration. Fred remarked that a lot of the knowledge with how to reduce embodied carbon lies in the construction sector.

Brian Waters remarked that the ACA have always lobbied that all measurable things should be in the Building Regs. We are in a world now where some of the measurable things are fundamental to whether you can do it or not. It is not unique that planning permission is given for something that is unbuild-able under the Building Regulations. However, would you not want to say that what you propose at pre-application stage is buildable? We would not expect building regulation skills in planning departments but there are questions about what planners need to deal with: safety and embodied carbon may require more technical knowledge. Fred remarked that daylight and sunlight have become highly tech-nical and planners need to deal with this.

In terms of tracking environmental performance, the London Plan publishes a rich data set of environ-mental performance of schemes assessed. ESG cer-tification is now so important many developers would like to publish their credentials.

John Monahan remarked there is a climate emergency but that is not at the forefront of the discussion. It will take a long time before knowledge on environmental performance will be to such an extent that it becomes a tick in the box.