Memorandum submitted by UK Green Building
Council (UK-GBC)
BACKGROUND TO
THE UK-GBC
Our mission is to dramatically improve the sustainability
of the built environment, by radically transforming the way it
is planned, designed, constructed, maintained and operated.
In 2004, Government's Sustainable Building Task
Group reported that no one body or organisation concerned with
sustainability was providing clear direction for the sector as
a whole. The UK Green Building Council (UK-GBC) was created by
the industry and launched in February 2007 to fulfil this role,
and to bring cohesion to the UK green building movement.
Our members are in the main drawn from across
industry, including architects, engineers, house builders and
commercial developers, contractors, energy companies, product
manufacturers and financers. They are joined by NGOs, academic
institutions and government agencies. For a full list of our members
go to: http://www.ukgbc.org/site/ourmembers
We are a campaign for a sustainable built environment.
We are committed to campaigning for action—by government,
by the industry, by whoever has a role to play to deliver on our
mission. For more information on the UK-GBC go to: http://www.ukgbc.org/site/aboutus
INTRODUCTION TO
THIS SUBMISSION
AND SUMMARY
OF POINTS
1. UK-GBC is a member of the Government
2016 Task Force, co-chaired by the Housing Minister Caroline Flint
and the HBF's Stewart Baseley. We also sit on the CLG's Green
Commercial Buildings Steering Group. It is worth highlighting
three pieces of work in particular that we have been involved
with in the last year. These are dealt with in more detail through
the course of this submission.
(i) UK-GBC was asked by the previous Housing
Minister Yvette Cooper, at the launch of the Callcutt Review in
November 2007, to report on the feasibility of setting up a zero
carbon delivery hub to help the industry meet the 2016 goal. The
results of this study were presented to the 2016 Task Force in
January 2008 and led to the announcement in the Budget of pump-prime
funding for such a vehicle, to be launched later this year. See
Annex 1.[16]
(ii) UK-GBC is currently conducting a review
of the definition of zero carbon, the results of which are due
to be released on 12 May 2008. CLG, BERR and Treasury officials
sit as observers on the group that is writing the report, and
have committed Government to a full public consultation, using
the group's report as a guide, this summer.
(iii) Although outside the scope of this inquiry,
UK-GBC's report "Carbon Reductions in New Non-Domestic Buildings"
which was produced for CLG and published on the CLG website in
December 2007, does have implications for issues that span the
domestic/non-domestic divide. This led to the Chancellor's Budget
announcement that Government intended all new non-domestic buildings
to be zero carbon by 2019.
2. The following analysis can be summarised
as follows:
(i) The Code for Sustainable Homes and the 2016
target have been genuinely groundbreaking and are responsible
for galvanising the industry.
(ii) There are a series of challenges to overcome
if the industry is to be successful in meeting the goals, which
cannot be ignored. The definition of zero carbon and the successful
establishment and work of a delivery hub are key.
(iii) We are at a critical juncture for the zero
carbon concept and policy. Concerns should not be an excuse for
failure, but a spur to action—by both government and the
industry.
THE CODE
FOR SUSTAINABLE
HOMES AND
THE 2016 ZERO
CARBON TARGET
General comments and observations
3. The Code for Sustainable Homes and the
associated 2016 target for all new homes to be zero carbon is
perhaps the most progressive environmental policy this Government
has been responsible for and is not always given the credit it
deserves. The policy is an attempt to get to grips with the fact
that our homes are responsible for over a quarter of our carbon
emissions, are massive consumers of water, timber and other resources
and have a huge influence on how we live our day-to-day lives—not
least our travel choices. Of course the Code and the target deal
only with new build, and Government track record on the existing
stock is not impressive, but with ambitious targets on the numbers
of homes to be built between now and 2020, it was imperative to
stop the rot in the new build sector and stimulate the market
for technologies that can be transferred across to the existing
stock. Also, Government has more leverage over new build than
existing.
4. With the setting of the regulatory escalator
towards 2016, Government showed it recognised that small, incremental
changes to Building Regulations every couple of years are simply
not enough. We needed to focus on the ultimate goal—ie zero
environmental impact—and work back from there to find the
best and most cost-effective way of achieving it. The Code has
also encouraged house builders to think about water, waste, materials
and biodiversity in the ground.
5. This took some quite bold political leadership
by Government, who deserve credit for bringing with them both
an industry that had not been previously characterised by flexibility
and innovation and also the majority of the green NGOs.
6. Also to their respective credit, most
house builders recognised that the best way of bringing sustainability
into the mainstream was for Government to set out clearly what
the changes were going to be and when. This would allow industry
to use the Code to gear up in advance for the changes to Building
Regulations. It is hard to over-state just what a significant
impact the 2016 policy has had on the house building industry,
genuinely galvanising it into action and catalysing innovation.
7. Within weeks of the Code being announced
in December 2006, for example, Barratt's were making plans for
a prototype zero carbon "mainstream" home, which will
shortly be unveiled at the BRE innovation park. It is this change
in mindset that is fundamental to our success or failure in meeting
the climate change challenge in the broadest sense. The construction
industry has long been perceived as the guilty party in its responsibility
for negative environmental impacts, but the most progressive in
the industry are now in the process of rethinking and reengineering
their business, to become an enabler rather than a disabler of
sustainable, low-carbon living.
Public engagement
8. From 1 May 2008 Code for Sustainable
Home ratings will be mandatory for all new homes. It was particularly
important to ensure that all homes received a rating, so that
buyers of homes that are simply built to minimum Building Regulations
receive a "nil-rated" home, and are made aware that
their home is not a sustainable home built "to the Code".
This should be an important part of increasing awareness, because
if consumers remain by and large completely oblivious to the Code
and what it implies, then we're not going to drive up demand for
sustainable homes, which is so important for developers who need
to get a payback on building to higher standards.
9. Although the recent NHBC report cast
doubt on whether home buyers were ready for zero carbon homes,
there is encouraging evidence to the contrary. In January 2008
a Mori poll showed 92% of those surveyed were keen to have sustainability
features incorporated in their new homes. There are undoubtedly
challenges to overcome in terms of public acceptance of some aspects
of sustainable home design, eg water-saving devices, and at the
moment very few people even know what a zero carbon home is, so
inevitably there will be a level of scepticism about what it might
mean for consumers. But we have come a long way in a very short
space of time. The success of TV shows such as Grand Designs demonstrates
the appetite for better quality and increasingly more sustainable
homes—which should be delivered by the industry in higher
numbers as we move towards 2016. UK-GBC strongly believes the
NHBC report (and other with similar messages) should be a call
to action, not an excuse for failure.
Trajectory to zero carbon—various issues
10. Part L of the Building Regulations will
improve, on 2006 requirements, by 25% in 2010, 44% in 2013 and
100% in 2016. However, 2016 also includes a requirement that all
non-regulated energy be zero carbon. This is all residual energy
use in the home that is not contained within Part L, such as non-fixed
electrical appliance use. This means that the last regulatory
step, between 2013 and 2016 is disproportionately large.
11. Government needs to look carefully at
the calibration of the steps in the Code and Building Regulations
and the market signal they send. Despite setting out intentions
on future policy, the trajectory is not yet statutory, and therefore
is not "bankable" for industry in terms of investment.
This is particularly an issue for product manufacturers attempting
to secure funds in order to invest and innovate, whose markets
will depend on future regulations.
12. Related to this, the UK-GBC believes
there is a responsibility that must be taken by opposition parties,
to send a strong message to investors that the level of ambition
would not diminish with a change of government. A consistent and
predictable policy landscape is essential to instil confidence
in the market.
13. The trajectory of policy, and the resultant
steps in building regulations are very important as they will
result in different technologies being favoured to deliver the
carbon savings at different levels. This can lead to technological
"cul-de-sacs" eg at Code Level 4 there may be high demand
for solar thermal (solar hot water) products, which are then "designed-out"
at Code Level 5 when it makes more sense to supply hot water,
heating and power from combined heat and power (CHP) technology.
This creates an unhelpful "boom-and-bust" potential
in certain technology sectors and is something the zero carbon
delivery hub needs to investigate further.
14. There are currently some other loopholes
and perversities built into the Code and building regulations
which largely come from the workings of SAP and which may have
unintended consequences such as making it easier to meet target
carbon reductions by using electric heating in homes. Again, the
technology work stream of the delivery hub will need to ensure
an urgent revision of SAP and work is already taking place around
this by several stakeholders including Defra (who are responsible
for SAP) and the Construction Products Association.
Compliance
15. Compliance, measurement and enforcement
are serious issues for any building. There is no point designing
a "sustainable home" if no checks are made to ensure
this has goal has been met. Ironically, it is probably easier
to monitor standards in homes built to higher standards than simply
to minimum Building Regulations, because a private Code assessor,
in a process separate to Building Control, carries out checks
against homes built to the Code.
16. Undoubtedly compliance, even against
minimum building regulations, is currently problematic, with high
failure rates. There is no easy solution to this and inevitably
it will require institutional change in, and better resourcing
of building control departments in local authorities.
Definition of Zero Carbon
17. As recognised by Callcutt, the definition
of zero carbon is a source of endless confusion, even for those
relatively close to the issue. The Treasury defined zero carbon
for the purposes of providing stamp duty relief and in doing so
excluded the use of offsite renewables that weren't connected
by a private wire. We understand this was due to a desire to ensure
the policy was "fiscally watertight", which is understandable
to an extent. However, this sweetener might have been well-intentioned,
but it had a perverse effect, because the zero carbon definition
in CLG's Technical Guidance for the Code (ie at Code Level 6)
was belatedly amended to also exclude the use of off-site renewables
in order to be consistent with the Treasury's definition—despite
having previously allowed it.
18. Concerns were raised by house builders,
both large and small, that this definition was unworkable. A lack
of clarity over the definition in the Code, and therefore future
trajectory of building regulations, threatened not only future
ability to deliver the target number of homes en masse, but also
created confusion amongst engineers, architects, developers and
their clients in respect of those developments currently in the
pipeline.
19. To help Government respond to these
concerns, the UK-GBC established a task group under the leadership
of Mark Clare (CEO of Barratt Homes) to bring together building
and energy experts to recommend possible solutions. Government
welcomed this move and officials from CLG, BERR and HMT sit as
observers on that group. This report is expected to be released
on 12 May and UK-GBC.
20. It is worth highlighting that the principles
this task group are assessing are also broadly applicable to the
new non-domestic sector. A solution to the zero carbon definition
problem is just as relevant to incorporate into policy in the
non-domestic sector and the future trajectory to 2019. Furthermore,
a significant amount of new home building will come in the form
of mixed-use development, and so the zero carbon solutions in
these circumstances are directly related.
Zero Carbon Delivery Hub
21. Last year's Callcutt Review recognised
the problem of the definition of zero carbon and also highlighted
another fundamental challenge to meeting the 2016 target, which
is the lack of a body specifically charged with ensuring smooth
progress towards the goal. Yvette Cooper (when Housing Minister)
when responding to Callcutt asked the UK-GBC to report to the
2016 Zero Carbon Task Force on the feasibility and scope of such
a body (see Annex 1), and we continue to work closely with Government
and other stakeholders on the setting up of this organisation.
22. The UK-GBC reported that the delivery
hub needs to lead programme management of several key work streams
to maintain an overview of the critical path to 2016. Key areas
include technical issues, exemplar projects, skills and training,
energy supply and public engagement. There are problems to be
tackled in each one of these work streams, and such an organisation
must continually identify potential threats to delivery of the
2016 target and ensure action is taken to address them.
23. This body is likely to be a wholly independent,
dedicated not-for-profit company with an executive team, and a
small Board to oversee its operations (comprising representatives
from key stakeholder groups). Initial core funding is likely to
be split between the private sector and government and a reference
to the government funding was made in the Budget announcements.
DELIVERING VOLUME
AND SUSTAINABILITY—IMPLICATIONS
OF HOUSING
GREEN PAPER
24. Almost 18 months since the Code's initial
launch, if anything sustainability is even higher on the agenda
of industry and right now sits alongside the debate on volume,
affordability and quality generally. It's crucial that sustainability
is not seen as some sort of optional extra to these other goals.
In her first speech on green building at a UK-GBC event on 27
February 2008, Caroline Flint said "The need for better
homes is equally important (to volume and affordability). And
that has to mean greener homes". It is important that
this objective remains strong. The headline finding of the Callcutt
Review, which reported in November 2007 was that the industry
could deliver both volume and sustainability—as long as
recommendations were heeded.
Costs
25. One of the greatest barriers to increasing
the delivery of much higher quality, resource efficient new homes
has been the perception of prohibitively high costs. But many
of these costs have been misunderstood, and figures misused to
support partisan arguments. Of course, in simple terms, it is
more costly to build (for example) a zero carbon home than one
built to minimum standards of Building Regulations. The most frequently
quoted costs are from a Cyril Sweett report which showed a possible
additional £36,000 per dwelling. But this approach has to
be seen in context for a number of reasons:
(i) These costs tend to be calculated per single
unit, meaning savings, for example through community-scale renewables,
are not factored in. In other words, these reports are based on
models that have not been cost-engineered.
(ii) A commitment that all new homes must meet
the highest standards of sustainability will drive investor confidence
and accelerate the growth of new markets in new technologies for
energy efficiency and renewable energy, and quickly bring costs
down.
(iii) A more resource-efficient home is a better
quality home, and higher quality means higher value. In time,
the better performing energy-efficient and even self-sufficient
home with lower or even negligible energy bills (particularly
given the upward trend in the price of energy) will be valued
more highly by the home-buyer, which will be reflected in the
cost they are willing to pay.
(iv) Perhaps most importantly, there are huge
savings to be had from economies of scale. In this sense, the
Housing Green Paper's ambition for 3 million new homes by 2020
should be seen as an opportunity to mainstream sustainability,
rather than as part of the problem.
(v) Current evidence from Element Energy, which
is highlighted in UK-GBC's forthcoming zero carbon (definition)
report, suggests that costs are already significantly less than
the ones cited in the original Cyril Sweet report. This report
will also include a number of case studies of current efforts
to build to zero carbon, and associated costs.
26. However, it is often the volume itself
which proves controversial. July 2007's Housing Green Paper set
out ambitious plans for 3 million new homes by 2020 and has resulted
in reports from the Social Market Foundation and others which
have questioned whether this number can be delivered without recourse
to Greenfield building and environmental degradation.
Planning
27. The planning system is frequently a
battleground between house builders and environmentalists, but
the Greenfield "versus" brownfield is not always helpful.
Undoubtedly we need to build more new homes, and we need to provide
land for these new homes. We also need to be careful to protect
land with real ecological value and indeed build-in biodiversity
conservation if not enhancement into new developments. But some
of our greatest biodiversity oases are actually brownfield sites
in our towns and cities, and some of our green fields have become
ecological deserts through the overuse of pesticides. Assessment
of ecological value is therefore complex and needs to be considered
on a site-by-site basis.
28. Related to the debate over volume is
the debate over density. High density development usually conjures
up images of high rise blocks and hostile living environments.
But some of the most valuable areas of real estate in the UK—Kensington,
Notting Hill, the Royal Crescent in Bath—were built to far
higher densities than most new housing, have stood the test of
time and become increasingly desirable. One of the key advantages
of well-designed, higher density areas is their ability to support
the kind of infrastructure—public transport, local shops
and other businesses, parks and allotments—that help a community
thrive and create a sense of place. New homes need to be supported
by real and sustainable infrastructure provision. This is not
something that can be done cheaply, but is an essential investment
with long-term rewards.
29. This is all part of quality design,
which is the key to real sustainability. New developments have
to work for their residents and be able to last and adapt to changing
needs over time, in order to be sustainable in the true sense
of the word. We cannot afford to make the mistakes of the past
when a rush to meet urgent affordable housing need resulted in
compromises in quality, durability and urban design. The cost
of these mistakes was high: we created dysfunctional places that
fostered crime, poor health and fractured communities. These issues
are also related to the Eco-Towns policy.
Eco-Towns
30. The Eco-Towns policy has had a rough
ride, although this is almost entirely to do with general opposition
to development rather than public objections to the "eco"
part of the proposals. UK-GBC is very supportive of the development
of Eco-Towns, which provide a huge opportunity to show that sustainability
and quality go hand in hand.
31. Emphasis should be placed on creating
quality places, where people will want to live for generations.
It is important that these are not seen as "eco islands"
or "green ghettos", but a vision for the future where
attractive, zero carbon homes, plus sustainable transport, access
to green space, and a healthy local economy all add up to a better
quality of life for residents.
32. Part of the problem is that residents
of existing communities nearby do not perceive benefit. Eco-Towns
must become part of, and add value to, the existing landscape
of the UK. There are options for exploring links between new development
and existing communities, by using funds from Section 106 to directly
benefits local people by helping to fund the upgrading of existing
homes in terms of energy efficiency, thereby off-setting increased
energy use in new homes and providing on-going savings for existing
residents.
33. It is frequently said we should learn
from European or international counterparts, on green building.
This has tending to imply technical know-how. In fact it is the
process which we can learn most from rather than the technical
solutions. It is important we learn from best practice on developing
a vision, masterplanning and implementation, through the most
effective, integrated working.
1 May 2008
16 Not printed. See www.ukgbc.org Back
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