Memorandum submitted by The Steel Construction
Institute
REVISION TO
BUILDING REGULATIONS
1. We believe that the energy reduction
targets for 2010 (25% improvement over 2006 Regulations) are readily
achievable through fabric insulation and airtightness improvements.
The 2013 targets (44% improvement over 2006 Regulations) are also
achievable largely from fabric improvements although better insulation
materials/technologies would reduce the wall thickness requirements.
In this regard, we note that light steel frame construction does
not suffer the same restrictions that traditional masonry construction
does with respect to cavity width.
2. We welcome the suggestion to reward construction
quality in the new regulations. As standards rise, the need to
reduce the gap between design and reality becomes increasingly
important. Accredited systems and factory based offsite construction
have a fundamental role to play in improving the energy efficiency
of new homes.
3. Following on from the previous point,
we consider that compliance is more easily achieved and enforced
with factory based offsite construction where repeatability is
guaranteed by the manufacturing process and factory quality control
measures. Subject to factory quality assurance, there is scope
to limit the need for on-site testing.
4. We have profound concerns over the suggestion
to introduce procedures for including the effects of thermal mass
in performance calculations. This might encourage heavier construction
which generally goes against the principles of sustainability.
Furthermore, whilst thermal mass may in certain circumstances
reduce overheating, were overheating to occur, thermal mass can
prevent rapid cooling resulting in night-time discomfort. Increasing
thermal mass can also lead to higher heating requirements. We
believe that, given the need for homes to be adaptable to changing
lifestyles, regulations should encourage the construction of homes
that are more responsive to the user in terms of both heating
and cooling. The emphasis should therefore be on thermal comfort
as a performance requirement rather than thermal mass as a prescriptive
requirement.
THE CODE
FOR SUSTAINABLE
HOMES (THE
CODE)
5. We welcome the aims of the Code but consider
that it has a number of shortcomings in its detail. In most respects,
it is over-prescriptive; a performance driven code would be more
conducive to innovative delivery, greater competition and greater
empathy with market requirements.
6. We do not believe that the mandatory
rating announced last February will have any noticeable impact
on the construction and purchase of new homes. Such impact, we
believe, is only possible if either the benefits of higher ratings
were rewarded through fiscal measures or at the very least quantified
and widely understood by the public. Neither is the case at present.
7. We find it curious that the criterion
(which existed in EcoHomes) relating to proximity to a public
transport network has been dropped in the Code given the impact
of transport on the environment.
HOUSING SUPPLY
ISSUES
8. There are often tensions between a Council's
Planning Department, Housing Department and the requirements of
RSL's. For example, the Housing Department might insist on three
bedroom or larger properties which RSL's feel will not be marketable.
Planners, on the other hand, insist on a particular level in the
Code without appreciating the impact that this may have on the
marketability of a project (eg insisting on Code level 4 may have
no other impact than the elimination of baths from a property
which in turn makes that property less marketable without achieving
any significant benefit). There is a feeling that planners do
not fully understand the Code and the impact which some of their
requirements have on the viability of a scheme. We therefore consider
that there is scope for more joined-up thinking on these issues.
9. The general impacts of traditional construction
are well publicised (half a tonne of waste per person per year,
10% of all traffic, etc.). There are also location specific impacts
by way of disruption and pollutions. The construction of three
million new homes by 2020 must be planned so as to minimise the
impact of construction. Offsite construction has been shown to
reduce waste from construction sites by over 70% and to significantly
reduce transport to site of both personnel and materials. It is
also the only way to meet these targets given the site-based skills
shortage.
ZERO-CARBON
10. Zero carbon as referred to in the Code
is understood to mean that any energy taken from the grid to facilitate
the running of the home, has to be less than or equal to the amount
put back through renewable technologies.
11. The technologies available are such
that this is currently only economic and practical on very large
sites.
12. For small sites, we believe that zero
carbon is only economically achievable with current technologies
by permitting carbon offsets.
13. We do not believe that blanket rules
relating to on or near-site renewables and low/zero carbon technology
can practically be set in isolation from the site characteristics
(eg location, size, etc.).
ECO-TOWNS
14. We support the Eco-town concept in principle
but await the detail of the sustainability standards that will
apply. In particular, the scale of such projects is an opportunity
to establish benchmarks with respect to what can be achieved with
on and near-site renewable energy, transport infrastructure, recycling,
volume manufacture of homes to a consistent standard, etc. all
with a view to minimising environmental impact.
15. Whilst it is still very early days,
the Chinese experiment at Dongtan has promoted large numbers of
innovative town planning and design ideas. The Government should
carefully examine relevant lessons from that experiment in developing
detailed ideas for English eco-towns.
24 April 2008
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