Circular Economy Statement, what do you need to know?

A circular economy seeks to use resources for as long as possible to reduce waste to a minimum, either through reusing, repurposing, repairing or recycling to extend the life cycle of the resource. A Circular Economy Statement (CES) accompanies a planning application to outline how a development intends to reduce waste over the entire life cycle of the project, from inception to decommission and deconstruction, through designing in circular economy principles from the earliest possible stage and following the advice of qualified environmental experts.

With the publication of the London Plan Guidance (LPG) in March 2022, information on how the London Plan should be implemented is now publicly available and can be applied to relevant developments across the Capital. While certain measures are to be applied to all developments, some are only applicable to ‘referable’ developments. These are usually larger developments that need to be referred to the Mayor of London and require an Environmental Impact Assessment (EIA).

Circular Economy Statements are required for ‘referable’ developments and there is now London Plan guidance outlining when and how to complete a CES and what information should be included to ensure the CES is appropriate for the development.

The five main aspects of CES outlined in the newly published guidance are:

1. The six key principles of the circular economy

There are six fundamental circular economy (CE) principles that are outlined in the LPG and that should be the backbone of the design process. These principles support the waste hierarchy by prioritising avoiding waste. They are:

• Building in layers
• Designing out waste
• Designing for longevity
• Designing for adaptability and flexibility
• Designing for disassembly
• Using materials that can be reused or recycled

2. Two parts – written report and CES template spreadsheet

Circular Economy Statements are comprised of two parts: a written report and a completed CE template spreadsheet. The spreadsheet requires information relating to each planning stage of the development, while the report should contain details not recorded in the spreadsheet, such as how measures reflect the objectives of the London Plan and any benefits a measure might have with evidence to support, where a design approach benefit cannot be easily quantified.

3. Submission at different planning stages

A Circular Economy Statement should be submitted at the following stages of a development’s life cycle: Pre-application (where relevant), Planning application submission and Post-construction. The initial CES submitted at the pre-application stage will include less detail but will outline the circular economy principles and design approaches to be used. When the planning application is submitted the CES will confirm what approaches are to be used and will fill in some of the gaps/assumptions made concerning the details included in the pre-application CES. The post-construction submission will include accurate details on materials and methods used as well as looking at the performance of the circular economy targets.

4. Level of ambition? Compliant or Pioneering?

Circular Economy Statements can either be compliant or pioneering. A compliant CES does what is expected of a CES, is acceptable and meets the requirements of the LPG. A pioneering CES goes above and beyond the LPG and shows creativity and innovation in achieving the aims of circularity. A pioneering CES will exceed the minimum requirements of the policy and will work to higher standards than the policy outlines. A pioneering approach may also set additional targets, such as reuse or recycling targets during the construction of the development. As a result, it could lead to beneficial impacts on the wider community and potentially even further afield. The LPG includes examples of what a pioneering approach might be for different elements of a CES.

5. Who should be involved?

Discussions should be held with as many of the design team as possible to ensure circular economy targets and design approaches are considered from the earliest possible stages of the development. This will avoid the need to redesign around the circular economy at a later date. Workshops involving the project’s design team, planners and environmental consultants should be arranged at the earliest opportunity to put circular economy principles at the forefront of the design discussions. By ensuring circular economy principles are considered from the earliest stages, appropriate measures can be designed for the development which will be cost effective, efficient and as beneficial as possible to the future occupiers and general locality in the development is built.

Time for Temple

Temple’s Climate, Carbon and Air Quality team are experienced in the preparation of circular economy statements, and our consultants are well placed to offer advice on the unique design principles that could be appropriate and applicable to development. We ensure early engagement with the design team, such as holding workshops to go over the project’s unique challenges, what design ideas would be suitable for the project and what can be achieved through implementing circular economy principles.