Many contractors and consultants still work from CMP and CEMP templates written several years ago. Several requirements have moved on since then, especially in London. Here are the changes we see catching submissions out most often.
Machinery emissions in London
London's Non-Road Mobile Machinery Low Emission Zone tightened on 1 January 2025. Stage IV engines are now required across all of Greater London, not just the Central Activities Zone and Opportunity Areas. Generators must meet Stage V. The next step is Stage V everywhere from 2030, and zero-emission machinery only from 2040.
Most sites must register their machinery on the NRMM register. A London CMP or CEMP should commit to these standards and to keeping the register up to date.
Lorry safety standards
From 28 October 2024, heavy goods vehicles over 12 tonnes operating in Greater London need a minimum three-star Direct Vision Standard rating, or the updated Progressive Safe System fitted. CMPs and CLPs that still refer only to the older one-star standard are out of date. Most London boroughs also expect commitment to CLOCS standards.
Dust assessment
The Institute of Air Quality Management updated its guidance on the assessment of dust from demolition and construction in January 2024, and published a position statement on construction monitoring in 2025. Councils increasingly expect the dust section of a CEMP to follow that method. That means a risk rating for demolition, earthworks, construction and trackout, mitigation matched to the risk, and a clear monitoring regime.
Biodiversity
Mandatory Biodiversity Net Gain applied to major developments from February 2024 and small sites from April 2024. As a result, more permissions now carry conditions for a CEMP: Biodiversity alongside the Habitat Management and Monitoring Plan. Construction-stage measures such as protected habitat fencing, timing of vegetation clearance and ecological supervision now need to appear in the construction plans.
Interaction with the building safety regime
On higher-risk buildings, the CMP no longer stands alone. The Gateway 2 application includes a construction control plan and change control plan, and the programme carries regulatory hold points. A CMP that promises a start date or construction sequence that the Gateway 2 strategy cannot deliver creates problems later. The two need to be written together.
Council templates and Codes of Construction Practice
Many councils have updated their own CMP pro formas and Codes of Construction Practice. Some now ask for:
- specific delivery booking systems
- air quality monitoring at set distances from the site
- contributions towards monitoring officers
- membership of the Considerate Constructors Scheme
Always check for the latest version before writing, rather than adapting the last one you submitted to that council.
What has not changed
The basics still decide whether a plan is approved first time:
- answer every matter listed in the condition
- show realistic vehicle routes and numbers
- commit to working hours the council accepts
- include clear drawings
A plan that someone on site can actually follow is also much easier to defend when a neighbour complains.