UK Green Building Council                            HRSC0062

The UK Green Building Council is an industry network with a mission to radically improve the sustainability of the built environment by transforming the way it is planned, designed, constructed, maintained and operated. As a charity with over 700 member organisations, we span the entire sector from some of the largest property owners, managers and developers, manufacturers, multidisciplinary advisory and engineering firms, energy providers and distributers and banks through to public sector bodies including the NHS, MOD and many local authorities as well as many SMEs.

Background

The Environmental Audit Committee (EAC) has launched a short inquiry examining heat resilience and sustainable cooling, including the relationship between heat and health.  As part of this it has issued a call for evidence - https://committees.parliament.uk/work/7811/heat-resilience-and-sustainable-cooling/

Summary

As extreme weather events, often heat related, feature in the news on a daily basis this inquiry is both welcome and timely.  UKGBC agrees that urgent action is required to ensure the UK can adapt in good time, and improve the resilience of every home and community before it is too late.  The window for successful action is narrowing all the time.

We note the related inquiries of the Energy Security and Net Zero Committee and the potential synergies between this area of policy and that of their inquires, looking at ‘Keeping the power on: our future energy technology mix’, ‘A flexible Grid for the future’ and ‘Heating our homes’ – each of these policy/ delivery domains could contribute to greater resilience and more urgent adaptation to future heat challenges.

Key to successful adaptation, and greater resilience is the nature and function of the home, and those other buildings we use for offices, to provide public services and for in-door leisure activities. 

With today’s understanding of the interaction between the fabric of a building and its environment, and of the ways in which homes and buildings place demands on utility infrastructures, it is possible to design and build for resilience in the face of expected climate impacts. 

It is therefore essential that we urgently adapt and update our planning, development and building policies to reflect the capabilities that we want new buildings to have in the future. It is simply untenable that new homes and buildings could still be built to designs and with technologies from the 20th century.

In updating these policies we can also release other benefits, including greater infrastructure resilience, local jobs, and improved quality of life; not least when recognising that no building is an island – each is part of a wider system of connected infrastructures that when well-planned can add value to each other. 

This will be particularly true for the energy system where buildings and homes will become increasingly energy capable, with home owners taking the prompt of higher fossil fuel costs to install solar PV, to fit EV charge points and to integrate these technologies with home storage to self-supply their car, and home.

As we have highlighted in our response to the sustainable electrification Inquiry such approaches in turn support electrification of both heat and mobility, and can help grid management too, reflecting the growing importance of flexibility in demand, to mirror the intermittency of renewable generation.  Smart Energy Capable Homes and Buildings can help enable adaptation, and increase resilience.

In UKGBC’s recent Heat and Building scorecard we highlight progress against the Heat and Building Strategy and identify key measures that could speed the arrival of a net zero built environment. A major opportunity this year is to set a modern Standard for new build that prompts design and build of smart energy capable homes and buildings. 

Such a standard would look to ensure thermal comfort (winter warmth, summer coolth), energy efficiency and capability, water efficiency, digital connectivity; with measurement, mitigation and minimum standards for embodied carbon. UKGBC’s five tests for a net zero and climate resilient future Homes Standard can be accessed here.

For developments of a large scale, we recommend they should be required to follow the dynamic thermal modelling approach (TM 59) which will help take into account overheating risk for a location.

While existing homes and buildings have been planned and built to different expectations of performance, reflecting expectations of stable weather patterns, evolving building technologies, designs, and planning policies, they will inherently underperform and be less resilient or adapted. 

All future programmes to retrofit or upgrade homes should take account of location, ideally look to take an area based approach where possible (enhancing affordability and allowing scale solutions that suit the location) and ensure overheating is considered as part of a rounded approach to thermal comfort.  This could form a part of local planning, be included in local area energy planning (LAEP). 

To take into account individual home and building owner action overheating /thermal comfort should be included in building regulations and planning permissions for extensions and significant renovations.

Terms of reference questions

1. What evidence exists on the relationship between heat and human health (mortality and morbidity), and which communities are worst affected?

Nothing to add here.

2. How can sustainable cooling solutions and adaptation strategies be implemented in such a way as to minimise overheating, reduce energy consumption and prevent overloading of the electricity grid during peak demand?

Our starting point is to consider homes and buildings as infrastructure when taken in aggregate.  We can see this play out in the nature of the urban heat island effect, where the aggregate mass of buildings (and roads) change the thermal nature of a locality.  Retrofit/upgrades to existing homes in urban areas will benefit from an area-based assessment to take into account such affects, to provide a locationally appropriate response to potential future overheating.  Subsequent area-based responses can help ensure measures are both affordable and at an appropriate scale for the location – in some cases this could offer the opportunity of networked solutions, in addition to building by building solutions.

Some cooling technologies are passive and should be prioritised, these include measures such as the addition of external shutters, the use of white paint and nature-based solutions such as green roofs and street trees. Secondary to this are dynamic measures, many of which are electrically powered e.g. mechanical ventilation systems, air conditioning.  Unmitigated additional electricity demand could cause grid issues at times of peak demand, as well as increase the electricity needing to be generated by the system.  That is why we recommend an approach to cooling solutions that seeks to manage the electricity demand that can be triggered by cooling devices. 

At the simplest level that could just mean ensuring any electrical cooling installation is accompanied by the installation of a suitably scaled solar PV installation; given the nature of overheating we could expect a reasonable relationship between the electrical demand from cooling to the generating ability of the PV.

A further development would be to encourage Smart Energy Capable Homes, as noted above, and in our submission to the Sustainable electrification Inquiry.  Such homes would be designed for thermal comfort and include technologies to supply and manage electricity, i.e. solar PV, building based battery storage, smart energy controls.  Taken together these would offer a high degree of self-supply, meaning the wider grid need not see a change in peak demand.

With suitable incentives to home owners such homes could go further and support the grid by reducing the demand they ‘show’ at what might otherwise be times of peak, they can also be managed to operate as sources of electricity, i.e. Building to Grid (B2G), a locationally specific and potentially energy system asset than EVs offering V2G.  Such homes would be powered by their own electricity and grid ‘top up’ which could be managed to minimize risk, be that of overheating to the householder, or overloaded distribution grid.

For new build the future Homes Standard should require modelling for such energy capability, and expect the design and deployment of fabric and technologies to ensure future thermal comfort at low net energy demand.  (Net energy demand being the gross use by the building less its own supply).

3. What actions can be taken to protect those most vulnerable to the impacts of extreme heat?

As part of UKGBC’s Upgrading Britain’s Homes campaign, we are developing a calculator tool to assess the national investment needed in retrofitting homes and help policy makers understand where best to prioritise government budgets. Adapting homes is an important part of the retrofit work needed nationwide. UKGBC urges the Government to prioritise sufficient investment to upgrade and adapt the homes of fuel poor and near fuel poor households.

Vulnerability is closely linked to a person’s agency to manage their environment. Particular focus should be given to people living in rented accommodation, care homes, hospitals and attending schools and places of study. Also people at work are increasingly vulnerable and should be afforded rights. The TUC has a useful guide on how to protect workers.

4. To what extent do the Government’s Climate Change Risk Assessment and National Adaptation Programme (as well as other related strategies such as the Net Zero Strategy and Heat and Buildings Strategy) identify and address the risks from extreme heat? (Note: The third NAP, covering the five-year period from 2023-2028, is expected to be published in the summer of 2023)

Risks to health, wellbeing and productivity from heat stress hazards are well identified within the third Climate Change Risk Assessment, particularly under risk H1. Whilst the third NAP addresses heat stress risk, the approaches recommended are inadequate for the level of risk the UK faces both today and in future timescales. Approved Document O is referred to for residential buildings, which should be updated to include assessment of future climate scenarios (where appropriate); and only dynamic measures are suggested for non-residential buildings (mechanical ventilation and air conditioning). Passive measures are not referred to in the NAP3.

5. Does the current planning framework do enough to encourage heat resilience measures such as cooling shelters, water bodies, green infrastructure and shading to be integrated into urban planning? Where such measures are incorporated, how accessible and successful are they?

The planning system is a vital tool in tackling the climate crisis. It is crucial to every decision we make on renewable energy deployment, ensuring building developments are sustainable and don’t further entrench our over-reliance on motorised transport, and to every measure we take to build resilience against flood risk and heat stress. The Government has failed to set the planning system to work on the greatest challenge facing our society.

Without an overarching legal requirement to mitigate and adapt to climate change at a national level, measures designed, approved and delivered across the country are inconsistent, inadequate and insufficiently strategic.

UKGBC is calling on the Government to introduce a formal legal purpose of the planning system to deliver on the Climate and Environment Acts. The Government should support amendments tabled to the Levelling up and Regeneration Bill in the House of Lords. 

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This will provide a clear framework for local decisions to prioritise action to mitigate and adapt to climate breakdown. Given the different starting points of rural, coastal, suburban and urban, as well as the weather variations across the UK we would expect good solutions to have to be considered, supported and deployed locally.  As an example, The London Plan does have a section - Policy 5.9 Overheating and cooling[1], and Bristol City Council’s Draft Policy NZC4[2] also addresses heat stress. But these are exceptions rather than the norm.

6. What can be done to protect the UK’s existing public and private sector housing stock from the impacts of extreme heat while ensuring that homes are sufficiently warm in the winter months?

Several retrofit options are suitable for the existing UK housing stock. Increased insultation, when combined with effective ventilation measures, can simultaneously warm homes in winter months and keep them cool in summer months. Passive strategies, such as fitting external shutters or planting deciduous trees, can be used to limit internal solar gains in summer months whilst letting gains through in winter months.

7. What role might reversible heat pumps (which can act as both heating and cooling systems) and other emerging technological solutions, such as the development of smart materials, play in meeting future cooling demands?

They will have a role, we would highlight the need for dynamic design, both at the building/home and development site scale, to ensure technology deployment make sense for the setting.  Performance based standards can help ensure appropriate technology deployment, while allowing design to take into account context and integrate technologies, both passive (i.e. smart materials) and active (mechanical ventilation).

8. How can cleaner refrigerants with low or zero global warming potentials support the UK’s cooling needs while contributing to the national emission reduction targets?

Nothing to add here.

9. Does the Government’s Future Homes Standard adequately consider overheating in homes? If not, what additional elements should it include?

As previously published the future Homes Standard only included limited, and we argue insufficient, measures to address ventilation and overheating.  If unaddressed these will only add to the retrofit burden, coupled with less than sufficient energy efficiency, water efficient and energy capability expectations. 

The future Homes Standard is a key moment in demonstrating the government gets what is needed, and that much of the sector can already provide to ensure modern new homes that are adapted and resilience in the face of changing climate impacts.

10. How effectively is the Government working across departments and with local authorities to ensure a coordinated approach is taken to heat resilience?

Heat resilience should be treated as a national priority. Coordination is currently weak and completely inadequate for the scale of the challenge. DEFRA’s efforts to coordinate ministries as diverse as Education, MoJ and Culture Media and Sport need to be given the authority and resources of the Cabinet Office with the Prime Minister as an active champion. The Department for Energy Security and Net Zero could also play an important role. Giving climate adaptation a strong legal authority through changes to the planning system would also form an engine behind much stronger coordination with local authorities and local planning bodies.

11. Does the UK need a dedicated Heat Resilience Strategy? What lessons can be learned from other nations when it comes to national strategies for heat resilience?

The UK does need a dedicated Heat Resilience Strategy but this should be interconnected with other strategies given the interdependencies of hazards such as heat stress, drought, water stress and flooding. The National Adaptation Plan (NAP) could in future fulfil such a role if were to take homes, workplaces, other in-door facilities into proper account.

For further information, please contact Louise Hutchins, Head of Policy and Public Affairs

August 2023