APPENDIX 18
Memorandum from Timbmet Group Ltd
1. Timbmet Group Ltd is the UK's leading
importer and distributor of hardwood timber and wood products.
The company is committed to pursuing a sustainable business agenda,
as outlined in its environmental policy, and seeks to provide
"responsible solutions" for a wide range of end uses.
A significant proportion of the Group's turnover is directly related
to the construction sector, through main contractors, sub-contractors
and merchants. In light of recent significant concerns over the
"legal and sustainable" sourcing of timber, particularly
through government procurement processes, and the interest of
the Committee to ensure that future building programmes are "completely"
sustainable, an experienced timber trade view on delivery of sustainable
housing should be of value to this inquiry.
OVERARCHING NATIONAL
STRATEGY
2. Given the immediate and long-term environmental
implications of the Barker Review conclusions, a national strategy
for the development of a building programme that explicitly internalises
the wide range of relevant environmental considerations is critical
to the objective of sustainable housing.
ILLEGAL LOGGING
3. The trade in illegal logging is estimated
by the World Bank to cost developing countries between $10-$15
billion annually. Illegal logging has been attracting increasing
attention since the late 1990s. It featured as one component of
the G8 Action Plan on Forests, and led to a series of Forest Law
Enforcement and Governance (FLEG) conferences coordinated by the
World Bank, including those in East Asia (Bali, September 2001)
and Africa (Yaoundé, October 2003); others are planned
for Russia and Latin America. Each of these initiatives has included
a focus on the role of consumers in world markets in fuelling
the demand for timber and thereby contributing to illegal logging.
4. Demand for timber for the UK Housing
Market needs to be placed in the context of the European Commission's
Action Plan on Forest Law Enforcement, Governance and Trade (FLEGT)
published in May 2003. The Action Plan was approved by the Council
in October 2003 and will lead to, amongst other initiatives, a
licensing system to identify legal products in partner countries
and license them for import to the EU; unlicensed products would
be denied entry.
THE PRIME
MINISTER'S
COMMISSION FOR
AFRICA
5. The Prime Minister's Commission for Africa
(due to report at the time of the UK's presidency of the G8 and
the European Union) is examining the options to re-invigorate
international efforts to address poverty in Africa. One of the
themes for the Commission is natural resources—such as timber.
Whilst the Commission will not report until next year, it is clear
that further efforts will be made to address illegal logging.
The position of the timber consuming countries will be key to
the recommendations. There is a very serious risk that unless
there is consistency across all government departments and initiatives,
such as sustainable house building, then the work of the Commission
could be undermined. It is not implausible to predict a scenario
where increased UK house building could increase demand for timber.
Unless clear standards are agreed to purchase legal and sustainable
timber this demand would be met by an increase in illegal logging
and thus fuel the illegal trade in timber. Such a scenario would
undermine the efforts of the Commission. It is therefore imperative
that procurement of timber for house building insists upon the
same basic standards that the UK government now do for it's sourcing
of timber—see section on CPET.
MATERIAL USE—TIMBER
6. Material use will have harmful impacts
on the environment. An environmentally well-managed building project
might seek to ensure no net environmental impact, a challenging
aspiration. Realising this aim might be achieved through avoidance
and minimisation/mitigation wherever possible, combined with offset
of residual impacts. Such management, which is unusual in development
projects, requires a detailed and comprehensive understanding
of the environmental impacts of the development.
SPECIFYING SUSTAINABLE
TIMBER AND
WOOD PRODUCTS
IN DEVELOPMENTS
7. It must be a fundamental requirement
of "sustainable housing" that timber and timber products
used are demonstrably from legal and sustainably managed forest
sources. Appropriate guidance covering from contract to delivery
is critical to ensuring that this requirement is met.
8. The requirement can be made through appropriate
contractual conditions, material specification, careful management
of accurate supply chain implementation of the specification (allowing,
if and as necessary, constrained flexibility to vary the specification
in prescribed ways), and monitoring of performance to ensure that
the specification has been delivered precisely.
9. The commissioning body sets the agenda:
its sustainability requirement must be clear and unambiguous and
phrased in tightly defined contractual conditions. The essential
requirement is to ensure that legal and sustainable timber and
wood products are used in projects. Guaranteeing that this is
the case is not straightforward but DEFRA's Central Point of Expertise
on Timber (CPET) is in the process of developing clarifications
and guidance (see next section).
10. Selection of architects, main contractors
and developers needs explicitly to assess their ability to deliver
a sustainable development. This task would be facilitated by an
agreed sustainable building standard that includes assessment
of the sources of timber and wood products and of the environmental
impacts of their inclusion in a development, weighed up against
other materials. The Building Research Establishment's Environmental
Assessment Method (BREEAM) provides a practical basis for such
a standard (see section below).
CENTRAL POINT
OF EXPERTISE
ON TIMBER
11. Not least because timber used in the
UK construction sector comes from around the world, guaranteeing
acceptable sources of timber and timber products can be especially
challenging. These challenges are being addressed through DEFRA's
Central Point of Expertise on Timber (CPET), which is charged
with developing guidance to be used by buyers in central government
departments and agencies and suppliers to ensure compliance with
central timber procurement policy. Consultation with DEFRA is
critical to this inquiry.
12. Government procurement policy requires
that only legal and sustainable timber and wood product be purchased
for government projects. Currently, it is a contractual condition
that timber is legal, with preference given to sustainable timber.
Evidence to support the legal, and if relevant sustainable, claim
is required. Phase I of CPET, which will report by mid-October,
will detail: what is considered to be legal and what are the documentary
evidence requirements to support the claim, including whether
the evidence needs to be independently verified; and, also what
is sustainable and what are the documentary requirements to support
the claim, including whether the evidence needs to be independently
verified. Critically, Phase I will present a methodology for assessing
forest management certification schemes, and will apply this to
the most widely available schemes in order to determine whether
and to what extent they meet the government requirements for legal
and /or sustainable timber.
13. Current policy implementation guidance
will be revised on the basis of Phase I recommendations and findings.
Phase II of CPET is critical to the successful development of
robust guidance. Phase II must set criteria for "other"
evidence, that is other than certification scheme guarantees and
recognised independent verification processes. Phase II aims also
to provide a "help" service, training and promotion.
It will also be responsible for setting and reporting against
performance targets. Consideration should be given to extending
the scope of Phase II to provide advice to the supply chain and
private sector timber users in general. Currently, funding for
CPET Phase II has not been agreed. Providing a well-funded CPET
service is critical to ensuring guaranteed legal and sustainable
timber and wood product is used in "sustainable housing".
ENVIRONMENTAL PERFORMANCE
ASSESSMENT AND
THE SETTING
OF MINIMUM
STANDARDS
14. Ensuring that legal and sustainable
timber and wood product is used in developments is an important
part of a "sustainable solution". Ensuring the highest
possible environmental performance of the building is also an
important part. This would entail establishment of agreed performance
requirements that must be met by developments and refurbishments,
set in a framework of robust assessment against prescribed criteria.
The agreed sustainable buildings standard would usefully be modelled
on the independent BREEAM standard, which is currently applied
to many building types, including homes (EcoHomes) and offices
and industrial units.
15. The BREEAM approach assesses a buildings
environmental performance on the basis of energy use, pollution,
transport, land use, ecology, materials, water, and health and
well being. Credits are awarded for each of these aspects according
to the meeting specified performance criteria. The scores are
then weighted according to overall environmental importance of
the aspect, resulting in a grand score, which is categorised as
pass, good, very good or excellent.
16. From the timber use perspective, there
are several shortcomings of the current approach, which would
need to be addressed in producing a sustainable buildings standard.
Account is taken of the source of timber in the materials aspect
of the rating system, as is the contribution of timber to the
overall sustainability of the development or refurbishment project.
As currently structured, it is possible to achieve an excellent
rating while performing very poorly in the materials aspect. A
revision to ensure that minimum performance requirements are met
in the materials aspect is necessary.
17. A further shortcoming is in the way
timber from a variety of sources is evaluated in the current rating
process. The process values certain certified timbers above all
else, and differentially values other timbers (non-certified,
or certified by excluded schemes) according to whether they are
of temperate or non-temperate source. Given the short supply of
certified timbers, the complexity of sources of timber from around
the world and the variety of credible means to independently verify
that timber is legal and from well-managed or near well-managed
sources, the current BREEAM approach is significantly limited.
A revision of the standard for the purpose of delivering sustainable
buildings needs to introduce some of this complexity into the
assessment methodology. This will certainly introduce complexity
into the standard and make the assessment process more demanding
on auditors and contractors but it is essential to achieving the
goal of sustainable construction. Any such revision will be facilitated
by the recommendations of CPET Phase I.
18. An advantage of the BREEAM standard
is the inclusion of "whole life considerations": a life
cycle assessment, from cradle to grave, of environmental impacts.
Whether timber or wood product remains as part of the building
at completion (building or finishing elements, as in the BREEAM
standard) or is a temporary works material (such as concrete shuttering,
construction site hoarding, which can be included in the BREEAM
standard as "major" building elements), environmental
assessments of their sourcing, use and ultimate disposal is essential.
For temporary usage in particular, consideration and implementation
of reuse and recycling options needs to be a requirement of sustainable
housing construction (for instance, integrated into the BREEAM
standard).
WOOD IN
CONSTRUCTION
19. Timber and wood product from legal and
sustainable forest sources can be an environmentally positive
material of choice compared with alternatives. Life cycle analyses
(LCA) indicate that a building constructed with a timber frame
(an accepted modern method of construction) outperforms comparable
steel and concrete framed buildings in terms of overall environmental
impacts.[34]
Exemplifying this, a recent study by the International
Institute for Environment and Development (IIED) indicates that
wood in construction is better for the climate.[35]
When you consider that the energy used in constructing,
occupying and operating buildings represents about half of UK's
greenhouse emissions, creative ways of reducing net emissions
associated with construction are important to efforts to reduce
and mitigate emissions.
COSTS OF
CERTIFIED TIMBER
20. In demanding that sustainable timber
is used, a trade concern is that economic considerations will
take precedence in final purchase decision-making. Based on experience
with softwoods, much of the market believes that there is no "premium"
cost for certified sustainable timber. This is not, however, true
of hardwoods. A study by Mansell plc indicated an average cost
difference of +10% between certified and non-certified softwood
and hardwood product, with marked variation in individual cost
differentials of approximately ± 30% (Simon Wright, personal
communication).
21. A recent study of available data for
tropical timber production[36]
indicates that certified South East Asian suppliers need to charge
a premium in the range 10-20% to compensate them for the net cost
of sustainable forest management certification. This cost difference
reflects, in the most part, costs of compliance with the certification
standard, increased costs of production at source, through reduced
yields (opportunity costs), as well as increased direct costs.
A commitment to sustainable timber therefore requires a commitment
to increased raw material timber cost. It is important to understand
that this cost is a very small proportion of the total costs of
a construction project, and an irrelevance as far as operational
costs, which constitute a significant part of the life time environmental
impact of a building, are concerned.
SKILL NEEDS
22. The knowledge base of public and private
sector operators is inadequate to properly take account of sustainable
timber specification. Although the private sector has a role to
play in education, central and local government needs to consider
how it can better equip its specifiers, planners and purchasers
to participate effectively in delivering sustainable housing.
23. Timbmet Group has, through collaboration
with Greenpeace, developed a training workshop for specifiers
that aims to provide them with knowledge and understanding that
will enable effective sustainable timber specification. In order
that the workshop can reach a much wider audience, an interactive
CD version of the workshop is in the final stages of development.
The CD is due to be released at the end of November and disseminated
widely, between November and January, to architects and specifiers
in private practice and in local authorities, and construction
companies, builders and joiners.
October 2004
In their "Environmental profiles of building
materials, components and buildings" study (see—collaborate.bre.co.uk/envprofiles),
the Building Research Establishment (BRE) scored timber highly
in 13 environmental impacts studied, including climate change,
pollution to air and water, waste disposal, and transport pollution
and congestion. Timber was recognised as the only building material
to have a positive impact on the environment due to the net assimilation
of carbon dioxide by growing trees.
The ATHENA Sustainable Materials Institute (see www.athenasmi.ca/index.html)
has compared the environmental impact of constructing a house
using wood framing, sheet metal framing, and concrete. The comparison
looked at 6 key measures: embodied energy (all the energy used
to extract, manufacture and deliver the product); air toxicity;
water toxicity; weighted resource use; and solid waste generation.
For the first five of these measures, the wood-frame house has
least impact on the environment.
http://www.iied.org/docs/climate/briefing—woodproducts—climatechange.pdf
(Could wood combat climate change? D Macqueen, J Mayers &
H Reid—4pp).
34 Life-cycle analysis (LCA) assesses environmental
impacts of a manufactured product at all stages of a product's
life including resource procurement, manufacturing, service life,
de-commissioning and disposal at the end of the useful life of
the product. Back
35
H Reid, S Huq, A Inkinen, J MacGregor, D Macqueen, J Mayers,
L Murray, and R Tipper (2004) Using wood products to mitigate
climate change: a review of evidence and key issues for sustainable
development. IIED, London (January 2004, 90pp.); see http://www.iied.org/docs/climate/wood-climatechange.pdf
and the summary at Back
36
Richards, M (2004) What do we know about the costs and benefits
of tropical timber certification? Draft report commissioned by
Timbmet Group Ltd (Oxford). Back
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