select committee inquiry:
existing housing
stock and climate change
Memorandum by J K Preston MA DipTP MRTPI IHBC FRSA.
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 4 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 (e.g. 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
4 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 (e.g.
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 (e.g. 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 5 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
7 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).