Examination of Witnesses (Questions 760-779)
Ms Gilli Hobbs and Mr Andrew Swain
6 MAY 2008
Q760 Lord Haskel: For measuring sustainability,
the BRE has developed a series of environmental assessment methods,
known as BREEAM. Do they work? How effective are they? What do
they do?
Ms Hobbs: BREEAM is basically a building level
assessment of lots of different sustainability aspects. I have
my crib sheet here because I am not that au fait with BREEAM.
It looks at the operational energy of the building, along with
things like the water use and the materials that are going into
the building. It does look at waste, land use and ecology. You
look at all these different sections and you basically can do
good things within them to reduce impacts. The more you do, the
more credits you get. Then, depending on the number of credits
you get, the BREEAM building design stage will get maybe a pass,
or good, or very good, or excellent. They have just introduced
an outstanding category. I think they work. 100,000 buildings
in the UK have been certified to BREEAM already. Half a million
buildings have been registered for certification. There is the
design stage, but there is also a post-construction review to
make sure that all the things they said they were going to do
have been done basically—so there is the pre assessment
and the post assessment. They do work in terms of trying to get
the overall environmental impact of that building improved. It
is a strong tool for that.
Mr Swain: Perhaps I could introduce another
acronym, CEEQUAL—which is very similar to BREEAM but covers
the civil engineering construction project. It stands for Civil
Engineering Environmental Quality Assessment Scheme and assesses
the sustainable performance of a civil engineering project. There
are two sections within the CEEQUAL scheme that cover waste: waste
management on site and minimising waste, but there is also material
selection and what proportion of materials are reused and recycled
and so on. That is a positive, proactive way for clients, designers
and contactors to demonstrate best practice, going that extra
step on a construction project, a civil engineering project. I
think both BREEAM and CEEQUAL have particular merit. Again, if
we could influence that, I would like to see greater focus on
the need for CEEQUAL on government-funded projects.[2]
Q761Lord Haskel: Are there pressures within
the industry for buildings to conform and for construction sites
to conform?
Mr Swain: Yes.
Q762 Lord Haskel: For instance, if the
Government said they wanted to build a school, would there be
any benefit in saying that they have to fulfil these particular
statements?
Mr Swain: Yes. BREEAM is already there. In terms
of specification of contract requirements, they will specify that
the building must meet a certain BREEAM rating.
Q763 Lord Haskel: This is already in
practice, is it?
Mr Swain: That is already in practice. I would
like to see the same for CEEQUAL. At the moment it is a voluntary
scheme, so the industry is stepping up to the plate and saying,
"We feel that this particular project is going beyond the
legal minimum. I would like to see that bring brought out in government
type funded projects.
Ms Hobbs: There is BREEAM Olympics, for example.
Lots of the high profile projects already have BREEAM but it is
a standard for certain publicly procured buildings to achieve
a certain level of BREEAM, like very good or excellent. It really
is a focal point to reach certain standards of sustainability.
Q764 Lord Haskel: Is there pressure in
the private sector to meet these standards?
Mr Swain: Obviously there is an award scheme
and a certificate at the end of it, so private companies like
to be able to promote themselves as a sustainable business, whether
it is within the construction building type area or civil engineering.
There is kudos from going through these assessment schemes.
Q765 Lord Haskel: As far as planning
permission and all that sort of thing is concerned, it is voluntary.
Mr Swain: It is voluntary, yes, but I think
it does help with the planning process because in order to get
a number of credits you have to have a number of systems in place
in terms of your environmental performance before you can go ahead
with that. Generally you would expect it to be quite a competent
contractor or client going forward with those sorts of schemes
anyway, but I would still like to see it pushed down through the
supply chain.
Q766 Lord Howie of Troon: We have been
told by the BRE that the present life-cycle impacts do not really
bring together such matters as waste reduction and carbon reduction.
How can the weightings of various environmental aspects affect
the output of a life-cycle assessment and how might that affect
the design and construction of a building or a civil engineering
project?
Ms Hobbs: Life-cycle assessment basically looks
at a number of issues, of which waste and recycling are just two
out of maybe 13 different impacts that will be quantified. To
take this table, for example, you might want to look at the energy
required for it along with the water use, pollution, waste, and
recycling impacts; so, in eco points, this table might have this
many eco points compared to that table. You need to weight everything,
in order to get it to a single figure. When I was putting the
submission in, it was really that, once everything is weighted
and put into a single number, it is quite difficult to extract
the waste information, to make decisions based upon waste reduction,
and also make sure you are making the wider decision based upon
environmental impacts. But the weighting is required in order
to get a single metric, which is the only way you can simplify
things, so really you need to go back a step and have greater
transparency in the individual impacts that make up that weighted
figure. Then you can start to make decisions on waste reduction.
Having made those decisions on reducing the energy consumption
of a building, looking for specifications that have a lower environmental
impact and looking for products that automatically have a lower
environmental impact, then trying to reduce it further through
reducing the waste and through increasing the opportunities for
resource use. That is the sort of hierarchy of decision-making
that we think we should undertake at the BRE and it is a question
of whether we have enough information at each of those stages
to help people make those decisions. Currently the answer is that
we do not have that information. Suppliers quite often do not
have that information, even if their customers ask for it. Until
you have that, how can you start to make those decisions really?
Q767 Lord Howie of Troon: Are these life-cycle
assessments reliable? My house in north-west London will be 100
years old—this month, I think, or sometime quite soon. I
cannot imagine someone sitting down and assessing a life cycle
of 100 years. The Forth Bridge is even older. How reliable are
these really?
Ms Hobbs: To take this table, when you are designing
it you say, "We expect this table to last for 20 years"
and you would then quantify the impacts over 20 years. If it lasts
100 years, then you have started off on the wrong premise. As
you say, that is exactly what is happening with buildings, they
are lasting and have to last a lot longer then their design life,
so, in the life-cycle assumption you used, you may have used the
wrong figure.
Q768 Lord Howie of Troon: We are back
to illusion again, are we not?
Ms Hobbs: Yes. There is a lot of that.
Q769 Chairman: Maybe we could move on
from the industry to legislation and government policies. We have
heard that once the "waste" label has been put on to
materials, this can hinder their re-use. Is this the case? Which
valuable materials in the construction industry do you think should
have the waste label taken away from them, so that people are
not inclined to go to landfill? Is this a problem?
Mr Swain: It is a real problem. It is a huge
problem. The waste label is probably the biggest problem we have,
actually. But we have these legislative controls in place, and
I think it is important that we keep those. The definition of
waste is based on case law. That also makes it difficult for people
to make a decision because it is a bit of a grey area, if you
like. It is never clear cut whether a material is or is not a
waste and it is sometimes very difficult to get that guidance
and to make a commitment on whether it is a waste or not. Once
it has that waste label, that dictates what you can and cannot
do with that material, in terms of where you place it and how
you process it and who you give it to. I think it is important
to maintain those legal controls. I think we need to be clearer
on guidance, certainly from the regulator, on what we can and
cannot do with certain waste materials. Defra and the EA are going
in the right direction with the number of waste Quality Protocols
that have been developed at the moment. Some of these have an
impact on the construction industry in terms of materials. If
we could move away from the term "waste" and call it
a resource, I think that would start educating people that waste
is not a waste, it is a resource that has a potential for use
or re-use elsewhere. Rather than the legal position, it is just
the terminology "waste" that gives it a label. Clients
and designers do not like the idea of using waste materials because
it conjures up an image of inferior product. It is far beyond
that. We have already said we have technical specifications for
site materials. We can demonstrate that they would perform like
a virgin product. It is the labelling that is the problem rather
than the legal bit.
Q770 Earl of Selborne: Clearly this is
a key area. I understand that you are saying we must keep the
legal controls, but you have found in the past that case law has
been unhelpful with the designation.
Mr Swain: It has. As soon as you have a waste
material, you have to jump through a number of hoops in order
to recycle it, reprocess it, or take it somewhere to do those
sorts of activities. The law has changed recently, in terms of
environmental permitting, to make it a lot easier to do some of
those activities, but it really does cut off a number of contractors
and clients, certainly at the smaller end of the market. With
the hassle of jumping through those hoops, it is a lot easier
for them just to dispose of it.
Q771 Earl of Selborne: I wonder, therefore,
whether secondary legislation is needed rather than relying on
case history. If you redefined what is meant by waste in certain
categories in law then there would not be any danger of a legal
case producing an unhelpful result.
Mr Swain: I mentioned the quality protocols
that have been developed with WRAP and Defra and other organisations.
They make it quite clear when that waste ceases to be a waste
and what is required in terms of process. They are very useful
but, again, I think they should be communicated more widely within
the industry. You have to remember that there is a handful of
large, major contractors who are aware of this stuff but below
that there is a huge amount of small- to medium-sized businesses
that generate huge amounts of waste materials which are not aware
of the protocols and need help and education.
Q772 Lord Methuen: We discussed landfill
briefly earlier and its incentive to reduce waste within the construction
industry. The Sustainable Development Commission argued that the
cost of landfill remains too low compared to other more sustainable
alternatives and represents a relatively small proportion of the
business operation expenses. Do you think that the landfill tax
is high enough to drive waste reduction?
Mr Swain: I do not think my colleagues will
be very happy with this, but I do not think it is high enough,
no. We need to make it a significant burden, for people to consider
other options in terms of the re-use or recycling of that material.
It still is cheaper, in certain areas, to dispose of to landfill
inert construction demolition waste than it is to re-use or recycle
it.
Ms Hobbs: I think you probably need a differential
landfill tax based upon the environmental impacts of landfilling
particular materials. There are lots of holes in the ground that
need to be filled up, so you do need to have a certain amount
of landfill going on anyway, but there are certain materials that
will produce more methane, for example, and they are easier to
recycle, and so it needs to be a bit more sophisticated in order
to actively prevent certain materials from going to landfill by
either banning them or making it prohibitively expensive for those
materials to go in.
Q773 Lord Howie of Troon: Appropriate
materials from building sites can be used for reclamation from
the sea. It has been done. The Channel Tunnel is a very good example
of that. Would that be described as landfill and subject to the
tax, or would it more sensibly be described as reclamation and
exempt from the tax?
Mr Swain: It would be exempt from the tax. Waste
only attracts tax when it goes to a licensed landfill facility.
If it was re-used elsewhere as an engineering fill, then it would
not attract the tax but it would be subject to waste management
legislation—and, again, that can prove difficult in some
circumstances.
Q774 Chairman: Can you explain to us
something about the aggregate levy. How does this work? Is it
effective?
Mr Swain: The aggregate levy is not a tax but
a levy that is added to primary aggregates that come straight
out of the ground. I think it is £1.90 per tonne increasing
to £2 per tonne from April 2009 and it is applied to virgin
materials. In essence, that cost is passed on to the customer,
whoever is buying that material, so the price of aggregates has
obviously gone up. The incentive behind that was for customers
to look elsewhere and to look at recycled materials. That has
happened, but ... . Perhaps that levy is not high enough—though
I would not like to say that. That is the idea behind it. The
Government has put a levy on virgin materials and a tax on materials
being disposed of to landfill to encourage this re-use and recycling.
I do not think we are quite there yet.
Q775 Lord Haskel: On the question of
landfill, we were in Flanders the other week and they have no
landfill in Flanders. Would that be a way of dealing with it here?
Would people be able to find alternative uses?
Mr Swain: You have mentioned looking in the
broader term to other areas. Obviously Holland does not have a
great deal of landfill space either and they are quite innovative
in terms of what they do with their recycling of their materials,
from domestic waste as well as construction waste. We are running
out of void space in the UK. I think we need to prepare as a construction
industry by looking at smarter ways of dealing with our waste
materials.
Q776 Lord Howie of Troon: I want to ask
you about Site Waste Management Plans. They have been voluntary
up to now, I believe. Have they been useful in reducing waste?
Do you think that making them mandatory is a good idea?
Ms Hobbs: Site Waste Management Plans are now
compulsory for any site over £300,000. They have a dual objective:
to reduce fly-tipping and to improve resource efficiency. They
will encourage resource efficiency, in terms of understanding
how much waste you have and what you are going to do with it in
advance of the construction site starting. It has yet to be proven
that they will reduce the amount of waste produced, because, as
we have said before, you have to move up the supply chain a lot
more to reduce waste, but, in terms of making it much more obvious
what is going to happen on the site in terms of managing materials,
the Site Waste Management Plan is going to be very effective.
Lord Howie of Troon: Thank you very much.
Ms Hobbs: They are compulsory for any site over
£300,000. One of the things that we did suggest at the time
of the consultation was that there was a central place to collect
these plans so that we start to get a much better idea in terms
of the amount of waste that is bring produced but, also, what
the different companies were doing to manage their waste—because
that would all have to be written down. Unfortunately, that has
not happened, so that is an opportunity missed really, because
now each company has its own Site Waste Management Plan without
there being a central place to log them.
Q777 Lord Howie of Troon: If they are
compulsory but they are not working terribly well, as you seem
to be saying, what should be done about it?
Ms Hobbs: We proposed that they should be logged
centrally; first of all, to help enforcement but, also, so that
we could start to collect information in terms of what sort of
actions are being undertaken. In order to comply with the legislation,
you do not have to reduce the amount of waste that you produce;
you have to make statements regarding waste minimisation. You
have to measure the amount of waste being produced and you have
to review your plan during the construction and also afterwards,
but there is no compulsion within that to do anything better really—which
is a shame.
Q778 Lord Howie of Troon: Is the saving
worth the cost of making the plan?
Ms Hobbs: Yes, it is. A cost impact assessment
was carried out and they did save money.
Mr Swain: They were only introduced as mandatory
from 1 April or 6 April this year, so I think it is early days
to say. The fact that they were first voluntary and are now mandatory
within the industry shows how slow the industry is to take up
these sorts of things. It could have done it on voluntary basis
but has not. I would concur with what Gilli said really: it is
very useful in terms of getting the client and the designers and
the contractors towards thinking about the waste that is being
produced. At least it is a step in the right direction. Most importantly,
it ensures compliance with the legal requirements in terms of
the duty of care, making sure that waste is disposed of properly
or handled properly—which is a big failing in the industry
at the moment. I would only say that it is on projects of £300,000
or more and there are a lot of construction projects out there
that are much less than that. But if it is so important, why do
we not just introduce it as mandatory, across the board through
the planning process? Again, the key is in communication and education
in the industry. The major contractors have got it, but the smaller
guys perhaps are not aware of the requirement in the first place.
But the plans are a good thing.
Q779 Lord Bhattacharyya: How do you measure
the Site Waste Management Plans? What criteria do you use? Do
you carry out a simulation, to see what will happen if you do
it this way or that way? Do you go through a very structured approach?
Ms Hobbs: The only requirement of the legislation
is to measure inert hazardous and non-hazardous. The BRE has its
own Site Waste Management Planning tool which separates it out
into much more detail. That is our way of having a consistent
way of measuring construction waste that is then automatically
fed into the benchmarking website and then relayed back to the
industry. We average out waste that would be produced for different
types of construction, so that they can then use that in order
to create their plan and hopefully improve against it. The BRE
has a consistent way of measuring waste. Constructing Excellence
have key performance indicators in terms of waste. Different contractors
have their own ways of collecting waste. Again a missed opportunity
is in not having a commonly agreed set of benchmarking data. At
the moment there is the BRE one and then it is up to the individual
companies as to whether they use our tool or not really.
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