Circular Economy · Planning Policy

A reuse-first audit standard, adopted city-wide.

The City of London Corporation wanted redevelopment in the Square Mile to start with deconstruction and material reuse, not demolition. KEES designed a suite of pre-deconstruction audit templates, now formally adopted into the City's Supplementary Planning Document and issued to every major development at RIBA Stage 2 or earlier.

Client
City of London Corp.
Sector
Public Sector · Planning
Project
Pre-Deconstruction Audit
Delivered
2 Templates

Outcomes, across the placement

Project summary · Delivered 2025 · Adopted 2025
2
Templates · interconnected

A Pre-Deconstruction Audit Template and a matching Audit Report Template, now issued city-wide.

9levels
Material reuse hierarchy

A nine-level hierarchy from Retained to Landfill, letting the City set ambitions per material.

10
Existing audits benchmarked

Ten pre-demolition audits reviewed — six from the City, four from KEES — to set the baseline.

01 · The Challenge

Reuse ambitions with
no standard to run on

Everyone agreed reuse mattered. But there was no shared way to capture it, and by the time most audits happened, it was already too late.

The City of London Corporation recognises that redevelopment in the Square Mile is inevitable, and wants to encourage deconstruction and material reuse over demolition to support the circular economy. The obstacle wasn't ambition, it was process.

No standardised pre-demolition audit existed across the industry. Most audits were carried out post-design, too late to influence decisions, and often only after the demolition contractor had already been procured, closing off deconstruction options entirely.

The material marketplaces that could rehome components used inconsistent data fields, so information couldn't move between them. And the two key policy instruments, the Circular Economy Statement and Whole Life-Cycle Carbon Assessment, weren't being used in a coordinated way.

02 · The Framework

A nine-level hierarchy, from retained to landfill.

L1Retained in situBest outcome
L2Reused on-siteSame development
L3Reused off-siteDirect reuse
L4RemanufacturedBack to as-new
L5RefurbishedRestored to use
L6RepurposedNew function
L7RecycledMaterial recovery
L8Energy recoveryLast resort
L9LandfillAvoid
Aligned to City ambitions

Set an ambition against every material.

Rather than a single reuse percentage, the hierarchy lets the City set a target outcome for specific materials, components and equipment, and hold a development to it through design.

It was built by reviewing ten existing audits and every relevant circular-economy policy requirement, then aligned to BREEAM and RIBA stage gates so the audit becomes a live design tool, not a closing formality.

PreferredAvoid
03 · Key Findings

Five gaps between reuse intent and reuse in practice.

F.01

No standardised audit process

No shared pre-demolition audit existed across the industry, every submission looked different.

F.02

Audits run too late

Most were carried out post-design, after the moment when findings could still influence decisions.

F.03

Procurement closed the door

Many audits happened after the demolition contractor was appointed, limiting deconstruction options.

F.04

Marketplaces couldn't talk

Reuse platforms used inconsistent field requirements, preventing easy transfer of material data.

F.05

Policy used in isolation

Circular Economy Statement and Whole Life-Cycle Carbon requirements weren't coordinated.

F.06

Data captured too shallow

Teams didn't record enough material detail early enough to embed reuse into cost and programme.

04 · The KEES Approach

Benchmark the field. Then build the standard.

The template had to satisfy planning policy, work for design teams, and hand clean data to the reuse marketplace, so we designed it against all three from the start.

STEP 01

Review ten existing audits

We benchmarked ten pre-demolition audits, six from the City of London, four from KEES, to understand what worked, what was missing, and what to standardise.

STEP 02

Audit every policy requirement

We mapped all circular-economy requirements, CES, WLCA, City Plan 2040, the London Plan 2021, NPPF and the Westminster SPD, so the template is compliant by construction.

STEP 03

Build the nine-level reuse hierarchy

We developed a material reuse hierarchy aligned to the City's ambitions, spanning nine levels from Retained through to Landfill, so ambition can be set per material.

STEP 04

Align to BREEAM & RIBA stages

We aligned the template to BREEAM and RIBA stage requirements across Stages 0, 2, 4 and 6, so it is completed early and refined through the life of the project.

STEP 05

Meet the marketplace suppliers

We met with reuse-marketplace suppliers, Maconda, Material Index, EME and Circuland, to make sure captured data maps cleanly onto their platforms.

STEP 06

Two interconnected documents

We delivered an Audit Template and a matching Audit Report Template, reviewed and approved by City of London Sustainability Officers ahead of publication.

05 · What we delivered

Two documents, one workflow.

RIBA Stages · 0 · 2 · 4 · 6
Document 01

Pre-Deconstruction Audit Template

Captures material, component and equipment data against the nine-level reuse hierarchy — completed at RIBA Stage 2 or earlier and refined through the project.

Stage 0Stage 2Stage 4Stage 6
Document 02

Audit Report Template

Standardises how findings are submitted to the planning department, so every application is consistent, comparable and marketplace-ready.

Standardised submissionMarketplace-ready
05 · Compliant by construction

Every relevant policy, mapped in.

6 frameworks aligned
Circular Economy StatementWhole Life-Cycle CarbonCity Plan 2040London Plan 2021NPPFWestminster SPDBREEAM
06 · The Outcome

Adopted into the City's Supplementary Planning Document, and issued to every major development.

Formally adopted

Part of the SPD

The templates are now a formal part of the City of London Corporation's Supplementary Planning Document requirements.

Issued city-wide

Every major development

The Planning Department issues the templates to all major developments, to be completed at RIBA Stage 2 or earlier.

Industry reference

A base for others

Shared extensively with industry and used as a base for further audit development, piloted by planning applicants.

07 · Timeline

From policy review to adopted standard.

Initial placement · 12 weeks · extended to delivery
Wk 0–4 · ReviewBrief & policy reviewTen audits benchmarked; all reuse policy audited.
Wk 4–10 · DesignTemplate & consultationDesign with planning & sustainability teams; marketplace supplier meetings.
Apr 2025 · Sign-offApprovedReviewed & approved by City of London Sustainability Officers.
Next · PublishCity-wide rolloutPublished on the CoL website following pilot on 2+ projects.
Brief & policy review
4 weeks
Design & consultation
6 weeks
Marketplace suppliers engaged
4
See our services
08 · Client testimonial
Kiro identified the main obstacle that severely limits deconstruction material reuse: teams don't record material detail early enough to integrate reuse into the programme and cost plan. His idea, a detailed pre-deconstruction audit template, means we're now confident the planning process can practically and procedurally support the circular economy.
KK
Kerstin Kane & Charlotte O'Farrell
Sustainability Team · City of London Corporation
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