09 – Environmental Performance Portfolio (EPP) 🌱

🎯 Objective


To raise environmental standards in housing delivery by ensuring that carbon intensity, energy infrastructure, and future efficiency are not afterthoughts — but central, enforceable parts of the planning test. This portfolio prevents development that undermines climate targets and embeds long-term environmental failure.

🔥 Policy Z1 – Site Carbon Intensity Threshold


What it does:
Requires every planning application to submit:

  • A projected build-phase and lifecycle carbon footprint
  • Emissions benchmarks based on site size, materials, and layout

Applications that exceed a defined carbon intensity threshold will be:

  • Automatically refused, or
  • Required to submit mitigation and redesign plans

Why it’s needed:
Planning approvals that enable sprawl, inefficient materials, or high embodied carbon undermine the UK’s legally binding net zero goals. Without carbon thresholds, even “compliant” projects can be climate failures.

International Analogy:

  • Norway and Sweden require carbon modelling in all large-scale development proposals.
  • France mandates lifecycle emissions disclosures as part of its “RE2020” regulations.

Policy Z2 – Energy Source & Demand Mapping Requirement


What it does:
Requires all major applications to:

  • Identify how the site will access renewable or low-carbon energy
  • Forecast total projected energy demand
  • Flag any potential grid strain or fossil lock-in risks

Applications must demonstrate that demand can be met without overloading infrastructure or increasing local dependency on gas.

Why it’s needed:
Too many developments are approved in areas where the grid is already stretched, or where new builds lock in reliance on high-emissions systems.

International Analogy:
Denmark requires energy infrastructure mapping for every major project, ensuring sustainability starts with the grid.

🧱 Policy Z3 – Retrofitting Viability Safeguard Clause


What it does:
Mandates that developers demonstrate — at planning stage — that buildings will be:

  • Structurally capable of retrofitting (e.g. for insulation, solar, or heat pumps)
  • Designed with future adaptation in mind (e.g. loft height, wall load, boiler conversion)

This includes submitting a retrofitting readiness statement, to be assessed alongside layout and materials.

Why it’s needed:
To stop the approval of buildings that can’t be adapted to future climate legislation — creating stranded assets, higher retrofit costs, and social displacement.

International Analogy:

  • Germany’s KfW energy efficiency codes assess retrofitting potential at design stage.
  • The EU Taxonomy for Green Buildings requires future-proofing as a green finance condition.

📘 Summary


The Environmental Performance Portfolio (EPP) transforms environmental planning from lofty policy into binding design criteria. By requiring carbon thresholds, energy demand integration, and future retrofit viability, it ensures the homes we build today are compatible with the environmental standards of tomorrow. EPP is not about incremental improvement — it is about refusing development that would bake failure into the system.