Memorandum submitted by the Energy Saving
Trust
This response should not be taken as representing
the views of any individual member.
BACKGROUND
The Energy Saving Trust was established by the
UK Government after the Earth Summit in Rio in 1992, to help the
tackle climate change. We promote mass-market sustainable energy
across the UK. This essentially means: domestic energy efficiency;
small-scale renewables; and cleaner road transport.
Housing accounts for some 27% of UK carbon dioxide
emissions. Accordingly, much of the Energy Saving Trust's effort
goes into helping householders, local authorities, energy companies,
and others to improve the energy efficiency of existing housing.
However, we also run an Energy Efficiency Best Practice programme
that addresses issues around new housing, and there is potential
for a greater role in this area for our Local Support Teams and
regional programme.
THE ROLE
OF NEWBUILD
The Government's Energy White Paper sets a very
challenging, but achievable, goal for carbon reductions by 2050.
In any one year, improvement of the existing housing stock will
yield far greater carbon reductions than anything that can be
done on newbuild. However, over successive years, emissions from
the new build stock are cumulative. That is to say: if 200,000
homes are built in one year, then that leads to one million homes
over five years—or 4% of the total stock. Some one-third
of our housing stock by 2050 is yet to be built. The impact on
carbon emissions of newbuild clearly cannot be ignored.
Good energy performance is fundamental to the
development of sustainable housing. The Energy Saving Trust sees
high-performance newbuild as playing a number of roles:
— It represents high-quality construction,
with increased comfort, reduced fuel bills, and minimal maintenance
requirements for the occupants.
— It directly reduces carbon emissions
over the lifetime of the home.
— It paves the way for successively
tougher Building Regulations in future years, with the prospect
of mainstreaming zero-emission homes over the next decade.
— It sets standards that will be adopted
in the refurbishment market, thus multiplying the carbon savings.
Government recently announced a 20% improvement
in newbuild performance under the Building Regulations Part L.
This was a welcome development, although it was less than the
25% that had been proposed and expected since summer 2004.[14]
Given the importance of newbuild energy performance as set out
above, we believe it is important to continue to improve on this,
both through successively tighter Building Regulations and through
other support mechanisms.
A. CODE FOR
SUSTAINABLE BUILDINGS
1. Can a voluntary code possibly deliver
the degree of change needed in the building industry to achieve
well-designed, energy efficient sustainable buildings which have
minimal impact on the local environment?
Yes. A voluntary code should introduce market
differentiation in a credible manner. It should allow a process
whereby:
— local authorities set authoritative
requirements in their planning policies;
— developers understand these requirements
and are able to invest in them for regular use;
— the requirements are audited once
the development is finished, to ensure compliance;
— home buyers know the property is
independently accredited as sustainable; and
— the building industry as a whole
sees the direction of regulation in the medium-term.
However, this approach will only work if the
code sets meaningful standards; if the Government commits to introducing
regulation further down the line, that is roughly in tune with
the higher levels of the code (on energy, this is a 25% improvement
by 2010);[15]
if the Government leads by example, by ensuring that the higher
levels of the code are built to in all publicly funded developments;
and if support schemes, incentives, and further requirements are
put in place that are linked to the code, to ensure its relevance
within the context of a joined-up policy environment.
Examples of elements of a wider framework that
could prove useful are:
— a Builders Obligation, based on the
code, to ensure that the building sector delivers a minimum proportion
of high performance buildings—rather like the current Renewables
Obligation on energy suppliers;
— a Low-Carbon Buildings Programme,
offering financial incentives for developments to exceed planned
performance standards, combining microgeneration technologies
with energy efficiency (such a programme has recently been consulted
on);
— an information and advice programme,
such as the Energy Saving Trust's Best Practice programme, offering
information, advice, and training on building to higher standards;
and
— fiscal measures (see question 3 below),
as an incentive to build to high standards under the code regime,
where this would otherwise not happen.
Each of these elements would need to be developed
in more detail, depending on the actual content of the Code and
Government's intentions with it.
2. Is the Government doing enough to promote
the code, with the industry and the general public, ahead of its
imminent introduction early in 2006?
No. We are not aware of any Government promotion
of the code.
We understand that the Code will be mandatory
for all Government funded newbuild as of April 2006. This is welcome,
provided the energy performance standard under the code is meaningful.
Provided the energy performance standard under
the code is meaningful, we would like to see Government promote
it in:
— Central guidance on planning—for
instance, best practice guidance on PPS1,[16]
as recommended by the Sustainable Buildings Task Group in May
2004.
— Information on the Energy Performance
Certificate for newbuild, to be introduced in 2006-07 under the
European Directive on the Energy Performance of Buildings.
— Other support schemes and policies—whether
fiscal incentives, grant support, or other.
We believe it is important for Government to
utilise established organisations such as the Energy Saving Trust
to promote a robust code, rather than invent new delivery vehicles
and different messages for it. The Energy Saving Trust already
provides extensive support to the industry on how to achieve higher
energy performance standards. Provided the energy performance
standard under the code is meaningful, the Energy Saving Trust
would be keen to promote this, using the established channels
under our existing Best Practice programme.
3. Should the Government be introducing fiscal
measures to reward higher building quality and greater environmental
performance?
Yes. There are no fiscal mechanisms in place
to encourage developers to build to higher standards than those
in the Building Regulations. Neither a voluntary code nor the
Energy Saving Trust's Best Practice programme are likely to transform
the market on their own and additional fiscal measures could encourage
developers to build to higher standards by
(a) making building to higher standards more
financially attractive for developers, and
(b) making sustainable homes a more attractive
financial option for home buyers.
The Energy Saving Trust's recent fiscal report[17]
concludes that stamp duty incentives and modification of planning
gain supplement would both be effective fiscal mechanisms to encourage
higher performance newbuild. Between them they could yield carbon
savings of 8,400tC pa by 2010. The carbon savings in the following
decade would be still higher and more significant.
A further option is the introduction of a sustainability
connection charging policy. According to this concept, the more
sustainable the home, the lower the connection charge to energy
utility services. There is an element of fairness in charging
more for the connection of less sustainable homes to infrastructure
that they will utilise to a greater extent than will more sustainable
homes. Ofreg, the Northern Ireland energy regulator, are currently
considering this mechanism.
B. SUSTAINABLE
COMMUNITIES: HOMES
FOR ALL
4. Does the ODPM Five Year Plan, Sustainable
Communities: Homes for All, demonstrate a greater recognition
of, and greater commitment to tackling, the impact of increased
house building on the environment or does it merely pay lip service
to it?
Yes. The Five Year Plan does make specific proposals
on addressing environmental issues. The question is whether these
proposals will be delivered in policy initiatives and on the ground.
On energy, the plan made firm statements about
introducing tougher energy performance standards for newbuild,
and this was welcome. In particular, it committed to:[18]
— raising the energy performance standards
under Building Regulations by 25%;
— reviewing Building Regulations at
least every five years;
— establishing excellence for energy
and water efficiency under the Code, and ensuring this is adopted
in publicly supported sites; and
— demonstrating the code in the Thames
Gateway and a range of other areas from 2005.
Clearly there has been slippage both on the
Building Regulations (20%, not 25%, with the danger of the figure
becoming even lower if the proportion of electrically heated flats
were to increase); and on the development of the code (no announcement
on its content as yet). We believe what is important now is to
make up for lost ground and reconfirm the original intentions,
ie:
— set in place mechanisms to deliver
a further 25% improvement in Building Regulations by 2010;
— ensure the code sets meaningful energy
and water efficiency standards that do establish "excellence"
and pave the way to the Building Regulations for 2010; and
— ensure that publicly funded developments
comply with the standards of "excellence" under the
Code, not just the lowest rung.
Overall, we are concerned that the Code for
Sustainable Buildings seems to be the main tool for ensuring high-performance
developments in terms of energy, but that the content of the code
is still not public, nor has it been connected with wider policy
and funding criteria for private developments. The next few months
will reveal whether our concerns are justified.
5. To what extent does the Five year Plan
address the environmental implications of the geographical distribution
of demolition versus new build?
In the current socio-economic climate, it is
probably fair to say that the energy perspective is a secondary
consideration when it comes to the geographical distribution of
housebuilding. However, we are concerned that option appraisals
should take into account the energy implications of demolition
as against refurbishment. Given that the cost of building a new
home is some £70,000—enough to insulate an existing
home many times over—on pure energy grounds, it will almost
always be more sensible to refurbish a home, rather than demolish
it and build a new one.
C. LPS 2020
6. The Government has consulted on the new
construction standard for dwellings (LPS2020). On the basis of
that consultation, is it possible to determine whether the new
standard will be a positive force for change and add value to
the construction process?
As the standards required of new homes become
ever higher, new designs and construction methods will have an
increasingly important role to play. We believe there is a need
for LPS2020 as a mechanism for reassuring the insurance industry,
investors, and others that these new designs are viable. As such,
we welcome the LPS2020 initiative. We would urge Government to
take it into account as it develops the code for Sustainable Buildings.
This would help simplify, not make more complex, the framework
within which developers must operate.
D. INFRASTRUCTURE
7. Is the Government doing enough to secure
sufficient funds for the timely provision of infrastructure, such
as transport links, schools and hospitals in the four Growth Areas?
The Energy Saving Trust does not have detailed
knowledge of the development of infrastructure in the growth areas.
However, we do believe that full life-cycle costing would reveal
a number of opportunities for low-carbon developments at a lower
cost than new energy supply infrastructure. Examples include low-demand
developments that reduce the need to reinforce grid connections;
and distributed generation that reduces the need for extending
gas and electricity networks.
It is clear that this issue is not set out as
a consideration in the Sustainable Communities Plan. It should
be addressed, not only to help minimise environmental impact,
but also to maximise cost-efficiencies in delivering the new developments.
8. Are the water companies doing enough to
secure the supply of water resources to the four Growth Areas?
And is concern about security of water supply, in the south-east
of England in particular, a valid one or simply a knee-jerk reaction
to a few hot, dry summers?
Water supply is outside our core area of expertise.
However, from our expertise and experience on energy, we can draw
the following parallels:
— There is a need to undertake a full
lifecycle costing for the provision of services, whether energy,
water, or other. Demand-side efficiency, or more localised production
will often be cheaper than building large, centralised plant,
and will have less severe environmental impacts.
— Extreme weather conditions will inevitably
raise concerns about longer-term climate change, even if individual
weather incidents cannot be causally linked. Given the general
acceptance by the scientific community that man-influenced climate
change is happening, and that this will lead to unpredictable
weather, it does not seem unreasonable to prepare for this in
the case of water supply.
9. Is there sufficient effort being made
by the Government, the Environment Agency, and the water companies
to educate people about water efficiency?
From our expertise and experience on energy
we can again offer the following insights:
— There is a need for an overall communications
programme on climate change, as the framework for more specific
messages on energy, water, and other resource issues.
— Communications in this area need
to be long-term and consistent; they need to lead to culture change,
which does not happen overnight.
— The opportunity should be taken to
"move people along the process"—if someone is
interested in taking action on climate change, they should be
helped to take action in all areas—energy, water, and other,
rather than "lost" after each point of contact.
— Raising awareness on resource efficiency
needs to be accompanied by a call to action.
— Such action must be easily achievable;
people will not do it if it requires a lot of effort. This means
that the right infrastructure must be in place, and easily accessible,
for delivering the necessary changes.
November 2005
14 See "Proposals for Amending Part L of the
Building Regulations," p 31, ODPM, July 2004. Also see "Sustainable
Communities: Homes for All" p 69, ODPM, January 2005. Back
15
"Proposals for Amending Part L of the Building Regulations,"
Section 6: Possible Future Performance Standards for Part L, ODPM,
July 2004. Back
16
"Planning Policy Statement 1: Delivering Sustainable Development,"
ODPM, 2005, puts sustainable development at the core of the planning
system, but there is no detailed guidance on the tools and methods
available to achieve this. Back
17
"Changing Climate, Changing Behaviour: Delivering Household
Energy Saving Through Fiscal Incentives," Energy Saving Trust,
2005. Back
18
"Sustainable Communities: Homes for All," p 69-71,
ODPM, January 2005. Back
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