A Code for Sustainable Buildings
134. Following the Better Buildings Summit in October
2003, the Government set up the Sustainable Buildings Task Force
to identify ways in which Government and industry could improve
the quality and sustainability of new and refurbished buildings.[134]
The Task Force published its report and recommendations in May
2004, which the Government responded to in July 2004. The main
recommendation of the Task Force was to set up a Code for Sustainable
Buildings (CSB), based on BRE's EcoHomes and BREEAM codes. This
Code would be non-statutory and would set standards above and
beyond those set out in the Buildings Regulations. The Task Force
also recommended that the Government should lead by example and
adopt the Code as a requirement for all new buildings in the public
sector.
135. Further recommendations from the Task Force
include revising the Building Regulations to specify a minimum
percentage by value (at least 10%) of recycled material in buildings,
together with a 25% saving in water use, energy use and the provision
of collection facilities for recycling in multi-occupancy buildings,
all by 2005. It also flagged up the issue of ensuring reliable
post-completion checks for the Building Regulations. Some of the
recommendations, such as improving energy efficiency in buildings
by 25% and improving enforcement of the Building Regulations are
being taken forward in the current consultation on the Building
Regulations. Other measures proposed by the Task Force such as
improving water efficiency, the level of recycled materials used
by the construction industry and fiscal measures, such as a reduced
stamp duty for energy efficient homes, are being considered further
by Government. Although in the Government reply, ODPM, DTI and
DEFRA stated that they wholeheartedly supported the principle
of the Task Force's recommendations and the majority of the means
for delivering these, the detailed response to the actual recommendations
placed a great deal of emphasis on the cost of implementing any
measures, stating for example that "it is essential that
any Code is practical, cost-effective and flexible enough to be
achievable by all." This raises concerns that the Code,
when agreed, could be so soft as to allow house builders to gain
the credit of compliance without any significant environmental
improvements being achieved.
136. The Code for Sustainable Buildings is a real
opportunity for innovation and this must not be lost by the wish
to set up something quickly and simply. BRE's approach was to
establish something to work within an industry that is not particularly
receptive to innovation or change. Whilst it is to be commended
for its success, the EcoHomes standard allows trade-offs that
result in no minimum requirements being achieved in some of the
areas it covers. This was acknowledged by the Task Force and we
support its recommendation that the Code should set minimal standards
in certain key areas that would have to be achieved to meet its
requirements.
137. We very much welcome the work of the Sustainable
Buildings Task Force and agree that there is a real urgency for
change and reform in how buildings are designed and constructed.
We generally support the approach of the Task Force, although
as its proposals stand they will result in a Code for Sustainable
Buildings that will not be as stringent or cover as wide a range
of areas as we would like to see.
138. Simply taking the Building Research Establishment's
standard forward in the proposed Code could result in a missed
opportunity to achieve the step change that is required in construction
practices to reduce the environmental impacts of all buildings,
including houses.
139. The Government committed itself in its memorandum
to us to publishing a draft Code for Sustainable Buildings by
January 2005: "The Senior Steering Group will be established
as soon as possible and we aim to publish a first outline of the
Code in time for the Sustainable Communities Summit in January
2005. Our aim is to complete the Code by the end of 2005, and
to take action on the national rollout by early 2006".[135]
The Task Force recommended that the body to develop this Code
should be set up by August 2004. We were therefore very concerned
to find that ODPM had not set up the proposed steering group by
the end of November 2004 despite the fact that the Group is supposed
to report by the end of January 2005.[136]
We were told in evidence by ODPM at the beginning of November
that there was still plenty of time for an outline of the Code
to be produced. We disagree. The Government finally announced
the composition of the steering group on 15 December 2004, together
with the intention that the group will present a first outline
of the new Code at the Sustainable Communities Summit in January
2005. We do not see how ODPM and other departments can claim
to be making credible efforts to improve the environmental performance
of buildings when they set a target of what will effectively be
six weeks or less for the outline of the Code for Sustainable
Buildings to be agreed. The Code is a vital opportunity for
ensuring the environmental performance of buildings is improved
and it is important that all options are considered carefully.
This will not be the case if the work of the Steering Group is
curtailed or hurried for the sake of meeting the January deadline;
nor would it be acceptable for the role of the Group to be simply
to rubber stamp the approval of the BRE's approach to environmental
standards.
140. There is ample representation from industry,
Government and social housing groups on the Steering Group. Having
being told in evidence that organisations such as BRE and the
Energy Savings Trust would be invited onto the Group, we were
surprised to see that there is no representation from any organisations
that are directly involved in how to improve the environmental
performance of buildings.[137]
It is incredible that the Government has not thought it important
to have any representation from the organisations that have the
greatest expertise in this area. This omission does not inspire
us with confidence that the Code will result in significant and
meaningful improvements in how houses are built or how their impacts
on the environment are minimised.
141. So far the Government has committed itself to
using the Code for Sustainable Buildings in "a number
of demonstration projects; including one in a Market Renewal Pathfinder
project and another in the Thames Gateway growth area".[138]
We would like to hear further details from the Government on
the expected levels of uptake of the Code and how, other than
the various demonstration projects that have been mentioned, it
will be encouraging uptake by house builders.
SCOPE OF THE CODE
142. In our view the proposed Code could and should
go further than the Task Force recommended and that BRE's EcoHomes
standard does, taking advantage of the fact that the new remit
of the Building Regulations, under the Secure and Sustainable
Buildings Act 2004, would allow much broader ranging requirements
to be eventually included within the Building Regulation, such
as those set out below:
- that all buildings should be designed to achieve
a minimum set lifetime of use, and meet a resilience and durability
standard that ensures that damage and repair costs of new homes
are affordable throughout their use;[139]
- that any new materials used in construction should
meet minimal recylability standards to encourage their re-use
once a building is demolished; and
- that minimum standards of safety and design quality
for housing should be incorporated with minimum environmental
requirements.
143. It is vital that when buildings are dismantled
as many materials as possible should be re-used and recycled.
The National Federation of Demolition Contractors told us that
although "average demolition recycling figures are high,
between 70% & 85% by weight of structures demolished, the
remaining fraction of un-recycled material would appear to be
increasing, particularly when the more recently constructed buildings
are demolished using modern deconstruction methods".
The Task Force proposed that the Building Regulations should
require 10% of materials in the construction of new building to
be recycled. We welcome this, although we would prefer to see
a higher figure. In addition, we would like to see the Code include
a requirement for any new materials used in construction to meet
minimum recylability standards.
144. The Countryside Agency is in the process of
developing what it calls a new kind of "vernacular architecture"
which it summarised as an approach that seeks to re-connect the
design and construction of new buildings with the environment
and promote modern, sustainable, high quality buildings that enhance
local character.[140]
This is the kind of approach to new housing that we very
much support. We would like to see included in the Code minimum
standards of safety and design quality, together with environmental
requirements, integrating the kind of work being carried out by
the Countryside Agency, Secured by Design, CABE and BRE.
145. With regards to the issue of design it is worth
noting that ODPM is exploring the use of urban coding to speed
up the planning system. Urban coding allows planning applications
that comply with particular design principles for an area, as
set out by planning authorities, to go through a speeded-up approval
process. This was an approach supported by the Barker Review.
Whilst this may have benefits it would be an issue of great concern
if the increased use of urban coding restricted the use of innovative
design and materials aimed at reducing environmental impacts,
or lead to a reduction in other environmental considerations being
applied.
146. Sustainable, recycled or recyclable, andwhere
possiblelocally sourced materials should be used in all
construction. The Task Force did address this issue though it
simply recommended that the feasibility should be examined of
introducing an environmental product declaration for sustainable
construction products and materials. This is not ambitious enough.
BRE already produces a Green Guide to Specification which
rates 250 different types of materials according to their environmental
impact.[141] There
is more than sufficient information already available to allow
the Code to include minimal environmental requirements for materials
and how they are sourced. A product declaration or labelling scheme
would be helpful but not a prerequisite and, in actual fact, including
minimum requirements in the Code would in itself generate a strong
incentive for such a scheme to be created.
147. Sir John Egan pointed out to us the significant
improvements seen in commercial sector construction over the last
five years. He was of the view that this has not been mirrored
in housing because the overwhelming majority of house buyers are
non-repeat customers which means that there is no incentive for
builders to improve their product.[142]
It is difficult to see private house builders taking up the Code
in the absence of any incentive to do so. Indeed the lack of take
up of BRE's voluntary EcoHomes standard supports this view. The
Task Force recommended the Code should be set up to work in conjunction
with the Building Regulations. We agree; and ODPM must make clear
that the requirements of the Code are precursors to more stringent
Building Regulations. It would also help the building industry
if the Department set out a clear timeframe for the standards
in the Code to be met or to be translated into the Regulations.
This is the only way a voluntary Code will have any significant
impact on house builders.
148. The best practice guide for PPS1 called for
by the Task Force should give clear indications as to how the
Code could be used by local authorities to require improved standards
from developers.
149. One of the more interesting recommendations
of the Egan Review is that "the Government should look
at incentivising progress, with the longer term aim of meeting
developments that achieve carbon emissions and waste minimisation
standards consistent with a sustainable one planet level within,
say eight years". In evidence Sir John told us that
from an engineering perspective it would be relatively straightforward
to lower CO2 emissions from households. Although the
supply chain was not yet capable of delivering sustainable new
houses, he suggested that the problem could be overcome within
eight years, if standards were tightened gradually. The Government
should set out a clear timetable for achieving zero carbon emission
homes through the proposed Code for Sustainable Buildings.
104 Ev21 Back
105
House of Commons Library, Research Paper 04/10, 'Sustainable
and Secure Buildings Bill', 29 January 2004 Back
106
Ev53 Back
107
Q141 Back
108
Ev54 Back
109
Aberdeen Council, Thermal performance of housing in the Aberdeen
Area, October 2004 Back
110
Energy Savings Trust, Assessment of energy efficiency impact of
Building Regulations compliance, November 2004 Back
111
Ev54 Back
112
Q349 Back
113
The award is given to whole developments rather than individual
homes, which means that some part of a development can be more
sustainable than others, with the overall rating achieved calculated
as an average of the development as a whole Back
114
Ev66 Back
115
Ev277 Back
116
Telegraph Online ,'Million-pound house sales reach 13 a day',
08 November 2004 Back
117
In the same period the average price of a house in England and
Wales was £187,971 Back
118
Entec, Study of the Environmental Impacts of Increasing the Housing
Supply of the UK, April 2004 Back
119
DEFRA, Energy Efficiency: The Government's Action Plan, April
2004 Back
120
U - value is the measurement of rate of heat transfer through
a given building material. The lower the U-factor of a material
the higher its energy efficiency. Back
121
WWF, Z-squared: Enabling One Planet Living in the Thames Gateway,
October 2004 Back
122
Carbon associated with building on dwelling are 9.54 tonnes of
carbon or 35 tonnes of carbon dioxide. Back
123
The ODPM consultation on the amendment of part L of the Building
Regulations estimates that at current replacement rates the requirement
for condensing boilers could reduce emissions by 0.1MtC a year,
which would be a total of 2.5MtC per year by 2030. Back
124
EAC, Ninth Report of Session 2002-03: Budget 2003 and Aviation,
HC672, July 2003 Back
125
DEFRA Press release 504/04, 'UK climate change programme review:
consultation launch', 8 December 2004 Back
126
Q 135 Back
127
Ev306 Back
128
Q 137 Back
129
Ev87 Back
130
Q 230 Back
131
Q 151 Back
132
Ev306 Back
133
Ev320 Back
134
DEFRA Press Release,' Sustainable Buildings Task Group line-up
revealed',12 November 2003 Back
135
Ev84 Back
136
ODPM Press Release 04/320, 'Towards more sustainable housing',
15 December 2002 Back
137
Q824 Back
138
ODPM Press Release 04/320, 'Towards more sustainable housing',
15 December 2002 Back
139
It is generally accepted that houses are built with an expected
lifetime of 60 years, whereas the Barker Review estimated that
homes would have to last an estimated 1200 years at current stock
replacement rates. Back
140
Ev139 Back
141
BRE, Green Guide to Specification, January 2002, Blackwell
Publishing Back
142
Q 589 Back