Memorandum submitted by The Royal Institution
of Chartered Surveyors (RICS)
RICS believes that the move to sustainable homes
with a lower carbon footprint must:
— not be too prescriptive so that innovation
is stifled;
— allow for improvements in building
regulations, the building of district combined heating/cooling
systems and undertaking of quality research and development;
— assess the changes in production
methods, materials and skills required to produce low carbon homes;
— enable best practice to be developed.
To help meet supply issues and drive these changes
government must:
— introduce some interim milestones
to assist track progress;
— help overcome the cost barriers that
will be incurred to meet targets;
— produce a clear definition of zero
carbon;
— include the use of renewable energy
within any definition;
— inform the home buying public about
the lifestyle changes coming with sustainable zero carbon homes;
and
— develop a national infrastructure
strategy.
WHO IS
THE RICS?
By way of background, RICS is the largest organisation
for professionals in property, land, construction and related
environmental issues worldwide. We promote best practice, regulation
and consumer protection to business and the public. With 140,000
members, RICS is the leading source of property related knowledge,
providing independent, impartial advice to governments and global
institutions.
RICS is uniquely well placed to offer its perspective
as the leading property professional body, required by its Royal
Charter to place the public interest at the core of all its activities
and ahead of its members' own interests.
1. REDUCING CARBON
EMISSIONS FROM
NEW HOMES
1.1 Is the target for all new homes to be
zero-carbon by 2016 on track to be achieved? Does the Government
need to do any more to deliver this target?
No, there is a great deal more work required
by both Government and the industry before there is a clear understanding
of what the target actually means and whether we are on track
to achieve it. There is a clear need for Government and industry
to develop key interim milestones to assist meeting future targets.
A decision needs to taken by Government to include
off-site and near site renewables that can be included in the
definition. At a more hands-on level, there is a fundamental lack
of established definitions in this area which significantly inhibits
progress. The property industry is uncertain as to what is required
of it. Consequently, industry is finding it difficult to prepare
itself by acquiring the necessary skills, knowledge and technologies
to ensure it can achieve the set targets and consequently pledge
that standards are maintained throughout the life cycle of a building.
There is a significant lead time to develop such new skills and
processes and so these matters must be addressed as soon as possible.
Work is just starting on the revision of the
Building Regulation Guidance Approved Document L regarding the
next reduction in CO2 and there will be two further revisions
before the 2016 target is reached. A considerable number of changes
will be needed to meet the standards of these interim revisions.
For example, observations of European low energy building types
such as the "Passiv Haus" show that in order to achieve
very low to zero carbon standards much of the construction process
needs to be carried out off-site. The required quality standards
cannot be achieved using the current on site methods commonly
used in the UK. Specialist skills and understanding of the specific
system being used as well as very close supervision during the
the on site assembly and construction process if the design integrity
is to be preserved.
Addressing consumer behaviour and demand is
also yet to be tackled. Current best practice shows a different
mindset for the average homeowner is required. In order to achieve
maximum energy efficiency in their homes a Passiv Haus takes a
long time to warm up, but once the required temperature is reached
only low amounts of energy are required to maintain it; opening
the windows has little effect so ventilation is fairly simple.
For lightweight construction types the opposite is true.
The cost of achieving zero carbon is a barrier
as these significantly increase on approaching net zero carbon
emissions.
Cost implications also need to be considered
for developments of various sizes, particularly as the smaller
the development the greater costs.
Further concerns arise from how the target will
be achieved for the more complex small scale developments where
regulatory cost may be greatest.
The Government should consider the cost benefit
analysis of building to code level 6 versus building to a lower
level such as 4/5 and investing the difference in a significant
programme tackling carbon reduction in existing stock. This would
result in greater carbon reductions for the same amount of money.
RICS RECOMMENDATIONS
A clear definition of zero carbon homes is
needed as a top priority. A common agreed strategy between Government
and industry to ensure continued cost efficient progress towards
meeting interim and ultimate targets is essential.
Government should agree pragmatic interim
targets with all levels of the housebuilding industry towards
achievement of the zero-carbon target. It should also seek to
develop a shared understanding across the private and public sector
of the different challenges that will need to be addressed to
meet each of those interim targets.
Government and industry need to more accurately
assess the changes in production methods, materials and skills
required to produce low carbon homes. Significant upfront investment,
well ahead of 2016 is required if we are to come close to achieving
the target.
Government needs to consider relevant costs
to ensure the most cost effective carbon reductions programme
is implemented. The Government must find practical solutions to
overcoming expected cost barriers particularly with regard to
the current state of the property market.
The Government also needs to inform the home
buying public about the lifestyle changes coming if zero carbon
homes are to work effectively. A clear campaign—based on
accurate evidenced based practices will be required to help educate
the public about sustainable behaviour and new technologies. It
should be clarified that zero|
Government must provide incentives, including
tax breaks, to help meet the targets and to facilitate increased
research and development in sustainable development. It is essential
that best practice is evidence based.
1.2 How should "zero-carbon" be
defined? What role should carbon offsets play in meeting this
target?
RICS believes that it is essential that the
definition of zero carbon should outcomes focused and not be prescriptive
in order to facilitate and encourage industry to innovate in this
area.
New technologies and sustainable practices
are needed and are expected to change rapidly over the coming
years. Solutions to the challenges ahead must be encouraged through
an appropriate definition.
RICS believes that the current Treasury Definition
is not satisfactory and the following must be considered as part
of the development of the definition:
— Focus on the building itself being
zero-carbon.
— Exclusion of white goods.
— Consideration of energy supply to
the home.
— Inclusion of near site and off site
renewals.
— Evidence based decision on the appropriate
form, scale and location of the renewables.
— Consideration of how different development
types may achieve zero carbon such as individual bespoke homes
versus mass produced kit homes vs In-fill vs Greenfield vs inner
city developments.
— Credibility/safeguarding of carbon
offsetting.
1.3 What impact will the progressive tightening
of energy efficiency building regulations have up to 2016? Are
the targets for 2010 and 2013 achievable?
The impact will be higher building costs which
will then be passed on to the consumer. The current climate of
"credit crunch" means there is even lower incentive
for developers to invest in low carbon technology. Maintaining
the current business will be their priority for the next few years.
The targets for 2010 and 2013 might be achievable
but at high cost. Not every technology is suitable for every site.
The cheapest technologies may not be possible ie. in inner city
sites like much of London. There is insufficient wind speeds for
wind turbines, and bio-mass fuel should not be used because of
transport and smoke problems. This leaves photovoltaics, solar
heating and ground and air source heat pumps, all of which are
currently very expensive with long payback periods and don't generate
huge amounts of renewable energy, so there would still need to
be back up systems, eg for when it is cloudy. Heat pumps take
up a lot of room comparatively and with the high pressure on land
use, installing a ground source heat pump may not be economically
feasible.
RICS says a three pronged approach is needed:
— improvements in building regulations,
— increasing building of district
combined heating/cooling systems and
— the encouragement of research
and development for low carbon homes.
1.4 How should compliance with the targets
be measured and enforced?
It is impossible for Building Control to act
as site supervisors and check every detail of construction. There
is already significant pressure upon the building control resources
within local government. The RICS believes the Future for Building
Control consultation currently being undertaken by Government
represents the right approach to the development of this function.
Furthermore with production line methods of off-site construction
becoming more important new mechanisms of assurance will be required.
There needs to be a level of independence either
in the person or the accreditation of the person who is ensuring
compliance. This can be achieved via some sort of government approved
scheme similar to energy assessors. Enforcement can then be carried
out through trading standards.
RICS suggests an "appointed person"
who visits the site regularly and signs off the construction in
the same way a health and safety supervisor signs off compliance
with the CDM regulations.
1.5 What is the likely scale of environmental
impacts (especially carbon emissions) of the construction of three
million new homes (ie, irrespective of where they are sited)?
How should these impacts be reported? What should be the role
of central Government in minimising them?
Three million new homes means three million
homes worth of embodied energy (ie the carbon produced in materials
manufacturing and the construction process). The Environment Agency
has a crude CO2 embodied energy calculator but there is a need
for a better estimation of the amount of carbon involved.
The wider concern with large scale developments
is the lack of sufficient infrastructure to go with this level
of development eg reservoirs for the South East of England and
transport infrastructure.
RICS strongly support Sustainable Construction
Strategy developed by the BERR, with other departments and the
industry as an example of the right partnership approach to reducing
emissions from construction. RICS believes that a national infrastructure
strategy is needed to ensure that it is delivered by Government
Department and agencies and a high level coordination unit should
be established in the Cabinet Office.
2. ECO-TOWNS
As currently envisaged, how big a contribution
will they make to reducing the environmental impacts of housing
in England-both in their own right, and in the development of
design and techniques that could be rolled out in other developments?
The development of eco-towns will have very
little direct impact on reducing total carbon emissions from buildings
and will almost certainly have some negative environmental impact.
In terms of total numbers, eco-towns will only provide 100,000
homes of the three million the Government wants built by 2020.
The main concern of RICS is that eco-towns will
be isolated and not effectively linked to other communities. This
is a result of the requirement that they are separate from existing
towns and cities. There is also a real risk that eco-towns could
become isolated dormitory settlements supplying workers to existing
towns, rather than people living and working in the same town.
As a result there are likely to be high levels of private car
use associated with eco-towns as people will still want easy access
to work, shops and services in nearby towns.
Instead of creating brand new eco-towns the
Government should be encouraging development on sites adjoining
existing settlements to create eco-extensions. These new areas
could be more effectively integrated into existing public transport
networks and would be better linked to jobs and services. There
would also be a benefit to people living in existing towns who
could benefit from the additional services provided in the eco-extension.
It is not sustainable to have a town made up
of green buildings if economic and social issues are ignored and
there is an increase in private car use. Moving people away from
existing towns and cities into isolated communities seems to be
completely at odds with wider development of sustainable communities.
3. CODE FOR
SUSTAINABLE HOMES
What impact is the Code for Sustainable Homes
likely to have on the construction and purchase of new homes?
How well is the mandatory rating likely to be enforced? Should
the Code be changed in any way?
The Government admits that the mandatory rating
under the Code for Sustainable Homes will only have a minimal
impact on carbon emissions from new build private homes for sale.
The Impact Assessment published alongside the Housing and Regeneration
Bill suggests that:
"The baseline rate of assessments has been
assumed to follow current assessment rates under EcoHomes:
Public sector—24,000/yr; and
Private sector—3,000/yr (equivalent to
2% of private new build).[41]
"
Whilst the Code is valuable as a market based
tool to help inform consumers, this will only have a minor impact
on new build and an even smaller impact on the total building
stock. If we are to see a significant increase in environmental
standards for new privately built homes, there will need to be
a concerted effort from house builders to take up assessment and
build to high environmental standards. However, the lack of demand
from buyers for these high environmental standards suggests that
progress towards interim targets towards zero carbon homes will
be the only way to guarantee reduced carbon emissions from new
homes.
The Government has argued that the Code will
help boost innovation in the construction industry and lead the
market towards producing zero carbon homes. This is unlikely to
occur across the board, particularly as housebuilding levels will
fall due to cost constraints in a declining market. This must
be taken into account with any requirements on new housebuilding
as increased costs will have more of an impact on levels of development
in the current market compared to more favourable economic conditions.
Ensuring funding for improvements to existing
homes will avoid this problem and will have a greater impact on
total levels of carbon emissions.
4. GREENFIELD
AND GREEN
BELT DEVELOPMENTS
To what extent do, and should, planning controls
protect greenfield and green belt land from development of new
housing? How adequately are environmental considerations (for
instance, biodiversity and rural landscapes) being taken into
account in deciding the location of new developments?
Government must take a clear lead on the relative
impact of protecting the green belt versus freeing up land for
housing development. Green belt land is often around areas of
high housing demand and development in these areas would have
a serious impact on increasing levels of affordability and accessibility.
These sites also tend to have lower costs associated with them
than brownfield sites and could help reduce development costs
in a declining market and ensure supply levels are maintained.
More land than at present will need to be brought into development
in order to achieve Government targets for housebuilding and affordability.
However, we must not simply allow urban sprawl
over green belt land. In particular there must be high density
housing built to high energy efficiency standards with effective
non-car transport links. One way to ensure this type of development
takes place would be by using eco-town standards to, instead,
create eco-extensions to existing well serviced centres.
5. INFRASTRUCTURE
What progress has the Government made, in the
two years since EAC's last report on this issue, in ensuring that
new developments are being built with adequate infrastructure
in order to make them successful and sustainable?
The answers to the above questions have demonstrated
the critical need for investment in infrastructure for low-carbon
and renewable energy for both near site and off-site locations.
These will have an essential role to play in the achievement of
zero carbon homes for 2016 or beyond.
RICS is yet to see an appropriate appreciation
across the other relevant parts of Government of what this will
mean for UK energy and renewables policy. For example, the public
may sensibly believe that the reductions from having zero carbon
homes are additional to reductions from achieving the latest UK
renewables target. This would mean that BERR should actually increase
its target for the provision of renewable energy (or other low
carbon energy provision) beyond that required by currently published
UK commitments to the EU. Furthermore, simple mechanisms for house
builders to secure truly additional near-site and offsite renewables
off other providers will be required. Subsequent occupiers of
these new homes will also have to be locked-in to using these
renewable resources.
In tandem with the definition of zero carbon
homes, Government should produce a clear strategy for what additional
renewable/low carbon energy infrastructure will be required to
achieve zero carbon homes. Such a strategy should also make clear
who within Government and industry will be responsible.
RICS want to work with government to help tackle
some of the pressing environment issues that we are currently
facing. We would welcome the opportunity to give oral evidence
in order to expand upon the points raised above. Please contact
Daniel Cook, Public Affairs Manager (email; dcook@rics.org, phone
0207 695 1754) if you require us to give evidence.
25 April 2008
41 P74, Housing and Regeneration Bill-Impact Assessment
http://www.communities.gov.uk/documents/housing/pdf/HousingandRegBill Back
| 
