Zurich UK HRSC0026
Zurich Insurance Submission: Heat Resilience and Sustainable Cooling
About Zurich Insurance
Zurich UK provides a suite of general insurance and life insurance products to retail and corporate customers. We supply personal, commercial, and public sector insurance through a number of distribution channels, and offer a range of protection, retirement and savings policies available online and through financial intermediaries for the retail market and via employee benefit consultants for the corporate market. Based in a number of locations across the UK - with large sites in Birmingham, Farnborough, Glasgow, London, Swindon and Whiteley - Zurich employs approximately 5,000 people in the UK.
Executive Summary
Heat stress is a growing risk to both property and the health and wellbeing of people, particularly vulnerable or older residents of buildings. Adaptations to buildings design, construction and operation that could maintain thermal comfort during heatwave events, such as good ventilation (openable windows), planting, water features, reflective surfaces, shading, and passive (targeted insultation) and active cooling measures (electric fans, air conditioning), are often not present, particularly in older buildings. Zurich is concerned on behalf of our customers that buildings in the UK do not generally feature these adaptations and are at risk of overheating in summer months. As a result, we believe the Government should consider how it can increase the implementation of these adaptations by strengthening building regulations and planning frameworks and increasing public awareness of the risk of heat.
Specifically, to address overheating risk we recommend that Government:
Government should raise awareness to the public of heat risk with:
Zurich Response to Consultation Questions:
Heat stress is a risk to both property and health. It is likely to be a growing risk in the UK due to the impacts of climate change (hotter, drier summers in the present and future). According to the NAP3, published in July 2023, ‘Hot summers and heatwaves will become more intense and longer lasting, particularly in the South-East of England’.
Following the heatwaves of 2018 and 2022, there is a growing appreciation in the insurance sector that heatwaves and heat stress are a growing risk to human health and property in the UK. According to a 2019 report by the Climate Change Committee (CCC), ‘one in five homes in England already dangerously overheats during heatwaves’. Last summer, heatwaves in England caused 2,556 deaths, with the CCC predicting the toll could triple from an average of 2,000 to 7,000 each year by 2050.
This is evidenced by high temperatures and heatwaves being rated as a ‘moderate-catastrophic, somewhat likely (0.2-25%)’ risk in the recent National Risk Register update. The high degree of variance in the potential scenarios calculated in the Risk Register shows how the UK’s built environment needs to be resilient to a wide range of outcomes. Prolonged elevated external temperatures can lead to overheating in buildings, which can have detrimental health, wellbeing and productivity effects on building users.
Health and well-being can be harmed from high temperatures, particularly for vulnerable or older residents. The Resolution Foundation 2023 report, It’s Getting Hot in Here, highlights some of the health risks associated with high temperatures: ‘Heat exhaustion and heat stroke, cardiovascular and respiratory issues, and sleep disturbance and mental health problems are all linked to high temperatures in the home’. There is also a concern, recognised in Arup’s 2022 report, Addressing overheating in existing UK homes, that heatwaves can sap productivity, especially as so many people now work from home at least some of the time. The issue of workforce productivity and decent work being affected by heat is comprehensively covered in the ILO’s 2019 report ‘Working on a warmer planet’. This study focuses on the impact of high temperatures on four sectors: agriculture, construction, industry and services.
The European Agency for Safety & Health at Work notes in their ‘Heat at Work’ guidance that there is an increased risk to first responders and healthcare workers of working in high temperatures, in addition to construction and agriculture in Europe. There seems to be a lack of policy with respect to worker health in the UK, other than for health and social care, through the focus on making buildings more resilient. Prolonged extreme heat events can also cause behavioural change and be linked to antisocial behaviour. The Lancet’s 2021 study, Interpersonal violence associated with hot weather, details the negative impacts that hot weather can have on behaviour. This effect of high temperatures will impact public (blue light) service capacity, as well as the individuals or groups involved.
Schulte & Chan’s 2009 study, Updated assessment of occupational safety and health hazards of climate change, identified seven key impacts that policymakers should be aware of: (1) increased ambient temperature; (2) air pollution; (3) ultraviolet exposure; (4) extreme weather; (5) vector-borne diseases and expanded habitats; (6) industrial transitions and emerging industries; and (7) changes in the built environment. They also note links to mental health and industrial productivity. Hazards 1, 3 & 4 (heat waves) link to heat and human health.
Adaptations to design and build that could maintain thermal comfort during heatwave events, such as good ventilation (openable windows), planting, water features, external shading, and passive and active cooling measures (electric fans, air conditioning), are often not present, particularly in older buildings. Internal (greenwalls) or external (trees, bushes) planting, can be effective in providing shading and reducing air temperatures, but it needs to be ensured that proper maintenance regimes are in place to prevent root damage to the property from external planting, and reducing the risk of planting drying out and becoming a potential fire risk. Wildfires starting in external planted areas and spread to damage property are a growing concern of insurers, with some significant claims resulting from the ignition of dry planting.
The prevailing modern design aesthetic, especially for new builds, seems to favour large glass windows, especially South-facing, which could also increase heat trapped during the day leading to thermal discomfort. Where glass already predominates in a building, the Government should offer guidance on passive cooling measures that are not energy intensive that could be retrofitted. Passive cooling is preferable so to not increase associated building emissions, and the government should consider how these can be encouraged in new build and retrofits through stronger building regulations and retrofit support.
Vulnerable populations are those over 65s, infants under one year and those with health conditions that are made worse by increasing temperatures. The Lancet Countdown project has global data about the impact of heat on vulnerable populations. The 2022 UK Climate Change Risk Assessment identifies ‘Risks to human health, wellbeing and productivity from increased exposure to heat in homes and other buildings’ as a priority risk area requiring urgent action.
This has a particular impact on the UK health and social care system, summarised in UK Climate Risk Health and Social Care paper. This paper shows that heatwaves are likely to have a more significant, detrimental impact on lower socio-economic populations in poorer housing and with less access to cooler outdoor areas.
Government policies on extreme heat should also be cognisant of the climate justice element to overheating – that lower-income households are likely to be more exposed to the risk of overheating and heatwaves, particularly those in manual/outdoor jobs, as they are less able to take action to adapt their home, occupation and habits to accommodate high temperatures. The scale of the challenge is highlighted be the Resolution Foundation’s 2023 study, which found that, 'more than half (54 per cent) of the poorest fifth of English families, three-times as many as among the richest fifth (18 per cent), live in homes liable of getting too hot.’ For example, those from higher economic backgrounds may have larger and better adapted properties to the heat, with more green space. They also have the option of leaving urban areas and staying in a residence in a countryside (and perhaps cooler) location.
Government should raise awareness to the public of heat risk with:
A) Guidance about action they can take.
B) Alerts for heat risks.
C) Provisions to ensure local authorities are properly resourced, so that they can put effective policies in place for managing extreme heat stress.
D) Alerts and guidance should be designed with vulnerable communities in mind, so that they can be targeted for engagement to raise awareness of the risks.
The CCRA3, published in January 2022, highlights the urgency of the rate that climate change is occurring in the present, rather than just being a future challenge, and highlights the resultant risks to human health, wellbeing and productivity from increased exposure to heat in homes and other buildings. The following section from the document highlights many of the concerns about overheating that we have raised above:
The Advice Report for CCRA3 outlines the significant risks of overheating in buildings as UK temperatures increase and heatwaves become more common. As well as risk to life, high temperatures will lead to productivity losses for UK workers. The report highlights that exposure to heat in homes will increase if the tendency for people to work from home because of the Covid-19 pandemic is adopted by businesses and workers permanently. There will also be implications for the future delivery of health and social care if as trends indicate there is a continued move to more home-based care rather than hospitals.
Building designs and technology are available that can greatly reduce occupant exposure to heat while ensuring high levels of thermal efficiency. Beneficial adaptation actions include the updating of building regulations and other policy measures to address overheating through passive cooling measures like better shading, reflective surfaces and green cover. The report warns that with 300,000 homes due to be built each year across the UK there is a major risk of lock-in if they are not planned and built to address overheating alongside energy efficiency and low-carbon heating.
The NAP3, published in July 2023, contained some positive steps from the government, such as:
Further, the NAP3 states that to support the government’s effort to address overheating risks:
Whilst these steps are to be welcomed, there is a lack of clarity as to how the steps will be implemented. For instance, how will the net zero retrofit program and overheating inspections from the government work in practice to drive material buildings amendments lacks clarity. The scale of the issue of overheating in buildings is significant - a Loughborough University study found 4.6 million homes in England suffer from overheating, while Government survey data published earlier this month suggests it affects nearly one in 10 (8%) homes.
There are concerns, that the Programme doesn’t go far enough in driving retrofit of existing buildings to be more resilient and materially reduce the risks associated with the climate and high temperature. Tougher building regulations and a stronger planning framework need to be considered by the Government, alongside a clear steer from Government about which of the plethora of public bodies is taking the lead on mitigating building risk.
Prolonged summer highs can be exacerbated by the urban heat island effect in cities, where the proliferation of hard, concrete surface absorb and retain heat. Zurich has long advocated for the Government to increase the use of Sustainable Drainage Systems (SuDS) in developments, which can have a range of risk reduction benefits – including urban cooling. Whilst it is welcome that Defra have committed to implementing Schedule 3 of the Flood and Water Management Act 2010 which requires sustainable drainage in new developments, a consultation on this has yet to materialise.
One step that could help achieve this would be Government amending and strengthening building regulations (Part O, updated last year) to reflect the need for thermal comfort of inhabitants at 21oC, rather than the current threshold for liveable internal environments (set up 26 degrees centigrade). Changes to building regulations and guidance should encourage building design to employ passive cooling methods (targeted insultation, shade, white colouration and reflective surfaces, planting, water features) to achieve this, rather than energy-intensive solutions (such as Air Conditioning), to achieve comfortable summer internal temperatures in buildings, ensuring the continued thermal comfort of building users.
The Government should consider implementing a building certification scheme, such as ‘Property Resilience Certificates’, to raise standards and building quality. Public awareness and resilient design in the built environment should be encouraged by a transparent system of certification, allowing buyers and building users to see which physical risks of climate change the building is resilient to and which might be a future risk that needs further action (from them in the form of retrofit, and for the community from local government scheme). These would act like an augmented and expanded EPC to include other building features such as flood risk/resilience, overheating/ventilation, water usage and drought risk, wind speed and storm damage risk, energy performance and efficiency. PRCs would need collect complex building data and display it simply to residents, users and potential buyers in order to provide an economic signal and behavioural driver. This would help use market forces to promote building resilience in the planning and construction industry and increase the uptake of resilient retrofits by stoking buyer awareness and demand.
Zurich has raised concerns about government changes to relax planning regulations for building use changes using permitted development rights (PDR) rush to redevelop shops and offices could create a swathe of substandard homes that are vulnerable to climate change. These poor-quality conversions are at serious risk of overheating and can suffer from other issues, such as escape of water incidents which can seriously damage the building and contents.
Public and private stock in the UK is at significant risk of overheating risk over the coming decades. Government should amend building regulations (Part O, updated last year) to reflect the need for thermal comfort of inhabitants at 21oC, rather than the current threshold for liveable internal environments (set up 26 degrees centigrade).
As stated above, in addition, building design should employ passive cooling methods (shade, white colour, planting, water features) to achieve this, rather than energy-intensive solutions like Air Conditioning, to achieve a comfortable summer temperature. Effective ventilation of properties will be essential to months ensuring that homes can be insulated and warm in the winter, whilst remaining cool in summer months. The Government should investigate how this balance between seasonal highs/lows can be accommodated in building design.
Wider government programmes to increase energy and heating efficiency in buildings should recognise that targeted insulation in the right place, is a passive design measure that reduces the risk of overheating of properties in the summer and has the added benefit of reducing heating requirements in the winter.
As the Government’s Heat and Buildings Strategy 2021 states, ‘The Future Buildings Standard consultation also proposes mitigation against the risk of overheating in new residential buildings’. However, it remains to be seen how the Standard, combined with the changes to Building Regulations Part O (overheating) and Part F (ventilation), will be implemented to deliver better outcomes for building users on thermal comfort.
There is a concern that due to the prior climate and weather patterns, buildings in the UK are generally poorly adapted to overheating, as the intensity and frequency of these events occurred less often in the past. The 2019 report from the CCC, ‘UK Housing – Fit for the future?’, highlighted the need for a statutory requirement for reducing overheating risks in new builds, stating that policy ‘requirements to minimise overheating risk are inadequate’, whilst also recommending retrofit actions and behaviours that residents of older buildings can adopt.
There is a need for more coordinated guidance from government to increase heat resilience. A system of targeted alerts and more for local government for climate adaptation initiatives is needed. Zurich has made the case to Government for a ‘National Adaptation Fund’ for local government, which would remove the current need for councils to bid for funding. Instead, funding would be automatically allocated to councils, allowing them plan for the long term, and providing the capital needed to take action on adaptation. Funding should be combined with a new statutory duty for local authorities to deliver climate resilience for their local community through funding adaptation projects, such as increasing passive cooling measure uptake in public buildings.
Yes, the UK would benefit from a dedicated ‘Heat and Resilience Strategy’ from the Government, with clear targets and delineated roles and responsibilities on addressing overheating risk, both in new build properties and retrofits. The CCC’s Progress Report to Parliament 2023 stated that, ‘no policy to manage overheating risks in existing health and social care buildings’, which as stated above is a significant concern given the vulnerability of people in these settings. The Government’s Heat and Buildings Strategy 2021, describes taking action to reduce building overheating as ‘no regrets’ action, and states:
When developing policies to future-proof buildings, we will consider our current and possible future scenarios, including overheating risk, indoor air quality risk, flood risk and water scarcity. Energy efficiency measures, when installed incorrectly or without appropriate adaptation measures, can create airtight spaces, which can increase the risk of overheating and decrease indoor air quality.
The Government should help communities to understand their extreme weather risks. The government should improve the sharing of national and local risk assessments that would allow communities to better understand the risks that may affect them, improve their resilience and plan for emergencies.
More accurate risk data and modelling would also help inform policy makers on hazards, exposures and vulnerabilities within their countries, providing them with greater insight on adaptation issues such as prevention, risk reduction and preparedness. The Government needs to take a long-term time horizon, ensuring that building and communities are resilient to the risks that climate and weather patterns will present by the mid/late Century, rather than just looking at the challenges of the present.
As part of the London Climate Change Partnership, Zurich is engaged with the Greater London Authority, to contribute to the Mayor’s London Climate Resilience Review and highlight overheating risk to establish steps towards developing a dedicated ‘Heat Plan for London’. If successfully developed, this could potentially provide a blueprint for national government to adopt a similar strategy.
August 2023