Memorandum submitted by John K Preston
The following reflects my 33 years' professional
experience of dealing with historic and traditional buildings,
currently as Historic Environment Manager for Cambridge City Council,
and also as Education Secretary for the Institute of Historic
Building Conservation (IHBC). My experience ranges from East Anglian
timber-framed historic buildings, to the conservation of listed
1930s and 1960s buildings. I have also represented IHBC on the
steering group for the English Heritage Interim Guidance on Part
L of the Building Regulations, and on the Sounding Board for the
Unification of Consents study by Halcrows. It also reflects my
recent personal experience as a home buyer.
In the following, I respond to the issues as
raised by the Committee, but in turn I pose four key questions
for the Committee members to consider:
— How to translate good intentions
into effective appropriate action?
— How, in doing so, to avoid unnecessary
harm to this country's special historic environment?
— How to make best practice widespread?
— How to monitor and measure improvements
to performance in the existing building stock?
1. THE SIGNIFICANCE
OF EXISTING
HOUSING COMPARED
TO NEW
BUILD AND
THE DIFFERENT
LEVELS OF
PERFORMANCE EACH
DISPLAY
1.1 Government initiatives in, and training
for, the construction industry have for too long been disproportionately
focused on new construction, when 50% of construction activity
relates to repairs, refurbishment and maintenance of existing
buildings. I therefore welcome the Government's new focus on tackling
climate change impacts in existing buildings (the great majority)
as well as the new. However the efforts that have been made so
far to improve the performance of existing buildings, through
Part L of the Building Regulations, have not been as well directed
as they could have been because:
(a) Part L does not take a "whole life
cycle" approach, instead focusing only on energy performance
in use while overlooking energy / resource costs of the works
involved, and disposal costs / impacts (eg of upvc) afterwards;
(b) Part L is based on modern construction
methods, and overlooks the different (and often more sustainable)
performance characteristics of traditional buildings (pre-1919),
which make up approximately 25% of the total stock.
(c) Part L does not take account of the embodied
energy aspects of existing construction, in terms of both whole
buildings and re-usable fired or quarried materials, or the fact
that traditional construction in lime mortar allows such materials
to be re-used in a way which would be impossible with modern cement
mortar.
1.2 A more holistic approach, based on whole
life cycles and taking account of the different characteristics
of traditional construction, could avoid inappropriate and wasteful
works.
2. THE RESPECTIVE
ROLES OF
RESIDENTS, HOMEOWNERS,
LANDLORDS, LOCAL
GOVERNMENT, CENTRAL
GOVERNMENT AND
THE ENERGY
INDUSTRY IN
PROMOTING AND
DELIVERING GREATER
ENERGY EFFICIENCY
2.1 Behaviours—everyone
2.1.1 Changing the behaviours of building
occupants has the potential to be the greatest single factor for
change; this is a task primarily for government education initiatives
(formal and informal), building on the existing groundswell of
public opinion.
(a) Some progress is being made in relation
to lighting etc, but there is potential for much more in terms
of reducing energy demand through optimizing the use of heating
systems etc (home information packs / building log books, if sufficiently
detailed to include all relevant instructions could be extremely
helpful in this context [I have direct experience of this problem
in my present house, bought 5 years ago; we have had major difficulties
because the previous owners passed on inadequate information about
the heating and electrical systems].
(b) To be sustainable, buildings need to
be maintained. People expect to service their cars and boilers
regularly; they need to be encouraged to maintain their homes
on the same regular basis.
2.1.2 Government has not as yet adequately
addressed the issues and opportunities associated with behaviours
of building occupants (in all types of premises).
2.2 Works to buildings—residents, homeowners,
landlords, local government, central government and the energy
and construction industries
2.2.1 Appropriateness / effectiveness
Building "improvements" are all too
often been carried out in response to sales pitches by promoters
of individual products, rather than with an understanding of what
would be the most cost-effective and appropriate solution for
either the building or its owner.
To highlight four issues:
2.2.1(a) Embodied energy—"maintain
and repair, rather than replace"
Traditional buildings, well-maintained, have
extremely long lives. However we live in a culture of replacement
rather than repair. Repairs and re-use, rather than replacement,
would avoid wasting embodied energy. At the most basic level,
promoting the use of lime mortar would allow the re-use of bricks
(energy-intensive fired materials). With 3.5 billion bricks being
made each year in the UK, and 2.5 billion destroyed, changing
building practices to enable re-use (impossible with OPC cement
mortar, possible with lime) could make a great difference to the
national carbon footprint.
Locally, I was involved in the Ely Preservation
Trust's successful initiative to re-manufacture traditional gault
clay peg tiles. This followed the Dean of Ely's 1987 proposed
re-roofing, in new tiles, of the ancillary cathedral buildings—which
would have involved discarding thousands of sound tiles (all at
least 150 years old) simply because they had no guarantee. New
handmade tiles on the traditional pattern are now in production,
so enabling traditional "salvage and making up" and
avoiding wastage of the embodied energy in fired materials.
2.2.1(b) Replacement of timber windows
In spite of longstanding evidence of the relative
benefits (in terms of effectiveness and financial payback) of
a hierarchy of measures starting with improved insulation, use
of heavy curtains, secondary glazing, draught exclusion, and double
glazing well down the list, owners have often been persuaded to
replace windows first of all. This has had serious implications,
in terms of both sustainability and visual impacts:
(i) timber windows (environmentally friendly,
and often repairable without needing complete replacement) have
been replaced with uPVC (not environmentally friendly, irreparable,
involving major pollution issues when discarded). The adverse
environmental impacts of uPVC have not as yet been adequately
addressed by Government at national and local levels.
It is only very recently that my employers,
a very environmentally-conscious Council, discontinued their uPVC
window manufacturing facility.
(ii) owners have been unaware that pre-1919
windows (hardwood) are intrinsically far more durable (provided
that they are regularly maintained) than modern fast-grown, pressure-impregnated
softwood.
(iii) owners have been swayed by false claims
that uPVC is "maintenance-free" [if that is the case,
why have B&Q been selling a product called "uPVC window
restorer"?].
The impacts of the "maintenance-free"
myth were highlighted for me by houses in Milton Keynes, whose
residents had been persuaded by a double glazing salesman to take
out the original highly-efficient and durable windows (hardwood
double glazed with argon), and replace them with uPVC. That was
15 years ago, the same myths continue to be peddled now.
2.2.1(c) External insulation
Insulation has always been highlighted as the
most effective improvement measure in terms of achieving conservation
benefits. The increasing performance standards expected following
the Energy White Paper are likely to bring increasing demands
for external insulation. This has very particular practical issues
for historic and traditional buildings, in that modern impervious
coatings prevent buildings from "breathing"—leading
to build-ups of moisture internally, frost cracking of render,
and decay of historic fabric. I have been working for over 30
years (my entire professional career) to persuade owners, contractors,
and (sometimes) architects not to use these damaging impervious
coatings on old buildings. This involves re-educating people trained
in modern building practices: construction industry training,
at all levels, is focused almost exclusively on new work—even
though 50% of construction work is carried out to existing buildings.
Now there is a real risk of mistakenly further encouraging the
same damaging practices, in the name of countering climate change—unless
those responsible for promoting, regulating, and implementing
realize that, for at least the 25% of the existing building stock
which dates from before 1919, different principles have to be
understood and different approaches may need to be applied.
2.2.1(d) Micro generation
Government efforts have been concentrated more
on adding micro-generation (solar, wind, heat pumps etc) than
on the basics of insulation and behaviours that could make the
real difference. This has been particularly unfortunate in that
the focus has been on adding bits of "kit", sometimes
of limited productive value (eg micro wind turbines) by comparison
with conservation measures, to buildings—and often in highly
visible and obtrusive locations.
2.2.2 Impact/design quality
2.2.2(a) Windows
Look at any window in a pre-1945 building, and
it will almost always be symmetrical in appearance, with well-proportioned
window panes, and opening lights accommodated without unbalancing
the appearance. In contrast, the typical post-war EJMA timber
windows are badly-proportioned, with chunky softwood frames with
double thicknesses around opening lights, and smaller panes within
them, all reinforcing the asymmetric appearance. The need to accommodate
double or triple glazing in timber does lead to thicker sections,
but there is no functional reason whatever for new high-performance
windows not to have the symmetry and good proportions of their
pre-1945 predecessors. These failings of the timber window industry
have been perpetuated and compounded by upvc manufacturers. upvc
offers little or no possibility of matching the appearance of
timber windows because of the nature of the material: it is impossible
to match extruded plastic to thin timber sections.
It is particularly frustrating that UK manufacturers
have still barely begun to address the aesthetics of window design,
when Scandinavian manufacturers have been making well-proportioned
high-performance windows for at least 20 years.
2.2.2(b) External insulation
External insulation would have a dramatic adverse
impact on the appearance of pre-1919 traditional and other historic
buildings. The colours and textures of brickwork, the relationships
between doors, windows, walls and roof, and the detailing of arches,
doorheads, eaves etc are all vital parts of the appearance of
a building. All could be masked by external insulation. Such impacts
need to be very carefully considered. For buildings which are
parts of a terrace, or other formal compositions, the impact of
cladding one part needs to be considered in terms of the whole—and
if possible a unified approach needs to be made.
There is no sign that as yet the Government
has as yet taken account of the potentially disastrous impacts
external insulation could have on the character of listed buildings
and conservation areas.
2.2.2(c) Micro generation
The visual impacts, noted in the previous paragraph,
of turbines, solar panels etc have been exacerbated because the
products on the market have generally been technical solutions
designed without consideration of appearance or potential context.
Individual units have been added to existing buildings as afterthoughts,
and without regard for the potential structural (forces arising
from wind turbines) and/or visual consequences. Solar panels in
particular are disruptive to the appearance and texture of traditional
roofs, and tend to stick out like "sore thumbs". It
is only very recently that products have become available (eg
photovoltaic "slates" and flat solar panels) which offer
potential for improved integration into the design and fabric
of new or existing buildings.
2.3 Regulation issues and opportunities
As noted in 2.2.1 and 2.2.2 above, too often
well-intentioned works have been ill-chosen in terms of effectiveness,
and unnecessarily adverse in their impacts. The urgent need to
address climate change issues means that we now have to catalyse,
with Government taking the lead, improved human behaviours and
building performance on a much larger scale. There are major issues
in terms of both the nature of the works, and of industry capacity
(manufacturing and implementing). These can only be resolved by
much stronger and better-considered Government intervention, in
terms of:
(a) influencing the behaviours of owners
etc (in terms of what they do and how),
(b) minimising wasteful and harmful interventions,
by making best practice widespread and encouraging appropriate
solutions,
(c) developing appropriate skills in the
industry,
(d) stimulating the market to make unit costs
come down, and
(e) encouraging the manufacturers to produce
better-designed and more aesthetically pleasing products.
To achieve these, a combination of fiscal and
regulatory incentives is needed.
3. ENERGY PERFORMANCE
CERTIFICATES
These should recognize the different performance
characteristics of pre-1919 traditional buildings, and the need
for special consideration of appropriate solutions for historic
and visually significant buildings and locations. Those drafting
the certificates need to be trained to recognise and understand
these characteristics and issues.
4. THE PROVISION
OF INFORMATION
FOR HOUSEHOLDS
AND PROSPECTIVE
HOUSE BUYERS,
INCLUDING ENERGY
PERFORMANCE CERTIFICATES
Better information is essential; this needs
to cover behaviours (both the way householders use their buildings
and the need for maintenance) and appropriate works. The problems
experienced with Home Information Packs in their present limited
form have been particularly disappointing, because what is really
needed (for both building owners and prospective purchasers) is
a Building Log Book. Log Books could provide ready-reference essential
information on the construction and history of houses, on the
works carried out to them, and on how best to use, maintain, and
improve their performance.
How I wish such a Building Log Book had been
supplied with the house my wife and I bought five years ago! We
have had a nightmare time because the previous owners kept no
records of electrical and other works, which have turned out to
be of very dubious quality. We are now having to seriously consider
removing wall finishes on an extension built only seven years
ago, simply to find out where the cabling goes and where it would
be safe to put brackets for new curtain poles!
5. GOVERNMENT
EFFORTS TO
REDUCE CARBON
EMISSIONS FROM
EXISTING HOUSING
STOCK WHETHER
IN PRIVATE
OR PUBLIC
OWNERSHIP AND
OTHER RELATED
PROGRAMMES INCLUDING
DECENT HOMES
Government should promote exemplar projects
for the appropriate refurbishment of traditional dwellings. Government
also needs to be mindful of the extent of building works being
carried out, which may meet modern constructional standards, but
in ways which could prevent adding energy conservation or microgeneration
measures.
The loft extension carried out to our house
by the previous owners reduced the scope for insulation and involved
removal of the hot water tank; the boiler (at ground floor) does
not have a tank. We have been exploring the use of solar panels
(our rear extension has good orientation), but installation would
be particularly difficult and disruptive because of the way the
extension was done. There must be many thousands of loft extensions
across the country with similar difficulties.
6. THE TECHNOLOGIES
AVAILABLE TO
REDUCE EMISSIONS
AND THE
GOVERNMENT'S
ROLE IN
FACILITATING RELEVANT
FURTHER TECHNOLOGICAL
DEVELOPMENT
The key technological issues may relate to behaviours
and energy use within the home, rather than building works, although
Government has a key role to play in promoting improved design
of energy saving and microgeneration technologies. As noted above,
technologies are only part of the issue, and there needs to be
a very strong focus also on appropriate construction practices
and skills.
7. THE COSTS
ASSOCIATED WITH
REDUCING CARBON
EMISSIONS FROM
EXISTING HOUSING,
WHO SHOULD
MEET THOSE
COSTS AND
PARTICULARLY, IN
RESPECT OF
LOW-INCOME
HOUSEHOLDS, INTERACTION
BETWEEN CARBON
EMISSION REDUCTIONS
AND THE
GOVERNMENT'S
AMBITIONS TO
REDUCE POVERTY
This is a very serious issue which needs to
be tackled in ways which recognise the need for appropriate solutions.
There may be scope for economies of scale.
8. THE SPECIFIC
CHALLENGES WHICH
MAY ARISE
IN RELATION
TO HOUSING
OF SPECIAL
ARCHITECTURAL OR
HISTORICAL INTEREST
8.1 I suggest that to achieve its aims,
the Committee needs to broaden the focus of this query from housing
of special interest to include all pre-1919 traditional buildings,
to address the issues noted in 2.2.1and 6 above. As noted, all
such buildings may need different approaches to the improvement
of more modern structures, and the means have to be provided for
ensuring this.
8.2 Turning to "housing of special
architectural or historic interest", I suggest that the appropriate
principles to follow have already been established within Part
L of the Building Regulations—special consideration, within
the general principle of seeking improvements where possible without
damaging special interest, for a wide range of "historic
buildings". In principle this regulatory approach allows
expert advice (through Conservation and Building Control teams
of the Local Planning Authority, working together) to be given
on improvements appropriate to the particular building:—in
fact, just the approach which is needed on a more widespread scale
to promote effective upgrading of the stock.
8.3 However this approach is compromised
in practice, for buildings which are not Statutory listed, because
there is no requirement to seek permission or consult, for works
to a dwelling, unless the works are not "permitted development"
(subject to an Article 4 direction or otherwise outwith the General
Permitted Development Order). It is further flawed because the
use of outsourced Building Control, and/or FENSA window installers,
can bypass the opportunity for a joined-up approach.
8.4 There is a mismatch between the lack
of regulation (GPDO) over householder works, and the special consideration
under Part L. This needs to be resolved by addressing the issue
of Permitted Development rights for buildings in Conservation
Areas and the other categories of "historic building"
given special consideration under Part L. Restriction of specific
Permitted Development rights on window replacement and external
insulation would help ensure that appropriate solutions are adopted
and energy conservation aims are achieved. While Government has
hesitated for 15 years (since the English Historic Towns Forum's
"Townscape in Trouble" highlighted the issues) over
restricting permitted development rights in Conservation Areas,
the introduction of Part L restrictions over householders' freedom
in 2002 was received with minimal opposition. Now is the time
to provide a joined-up approach, which I am sure would be accepted
by the public.
9. CONCLUSIONS
9.1 What is needed is a sound basis for
ensuring appropriate upgrading of the housing stock to meet climate
change challenges, while avoiding either wastage of resources
on misconceived works, or needless damage to the quality of our
built environment.
9.2 Informed choices and best practice (including
development of better technology at lower cost) need to be made
widespread through a combination of increased (but well-targeted)
regulation, and incentives.
9.3 Difficult choices, balancing different
values and environmental "goods" may be involved. British
Standard BS 7913:1998 A guide to the principles of the conservation
of historic buildings provides an excellent starting point
for such decisions—provided that it is made available far
more widely than its price of £68 for 28 pages allows. (I
have in the past suggested that English Heritage should seek the
republication of this document in far greater volumes, with a
cover price of say £5).
| 
