Mr Daniel Scharf                            SBE0009


Written evidence from Mr Daniel Scharf


I am a Chartered Planner with over 40 years working in the public, private and voluntary sectors.  I run workshops on planning, consult with NGOs and campaign groups and blog at


1.       To what extent have the Climate Change Committee’s recommendations on decarbonising the structural fabric of new homes been met?

The most recent opportunity for the Government to show that the recommendations of the CCC are being accepted/met was the Future Building Standards published in January 2021.  This states document demonstrates a high degree of carbon illiteracy and the issue of embodied carbon is deliberately not being addressed, and will be dealt with in the longer term.  The reasons given (including extensive personal correspondence over the last 5 years) is a lack of agreed methodology.  Whist there might be slight disagreements about how this could be calculated, there is very substantial agreement between NHBC, CCC, UK and World Green Building Councils, LETI and RICS about how this could be calculated.  Delaying the necessary regulation for the longer term and relying on zero carbon ready building is a flagrant breach of the CCC position and imperils the statutory carbon budgets (and targets).

2.       How can materials be employed to reduce the carbon impact of new buildings, including efficient heating and cooling, and which materials are most effective at reducing embodied carbon?

One of the ways in which embodied carbon in construction might be reduced is through Modern Methods of Construction (MMC).  Whilst MMC could reduce the use of some of the most carbon intensive materials, the manufacturing processes will increase the demand for electricity.  Not only must the carbon intensity of this electricity be factored in, but this demand will compete with growing demand from the roll-out of heat pumps and the manufacturing and use of Electric Vehicles /batteries.  This requires a holistic/systemic over view of decarbonisation of building and buildings within the overall economy.

Homes England is carrying out research into many aspects of MMC, but seem to be very confused about whether this includes the level of embodied carbon.  It is seems clear from HE publications, terms of reference and correspondence that the current research is not into how embodied carbon could be reduced (currently at about 50 tonnes per dwelling) but concerned about increasing and accelerating supply.

The Government’s policy to meet housing needs through extensive new building implies the additional building of new services and infrastructure that can be very carbon intensive and that would be reduced or eliminated by concentrating on the re-use and retrofitting/sub-divisions within existing built-up areas.

3.       What role can nature-based materials can play in achieving the Government’s net zero ambition?

The CCC rely on the increased use of timber.   Even where this has happened in the past, the facing materials (and associated servicing and infrastructure) have relied on cement/masonry. The new advice on ‘beauty’ and community involvement is likely to increase or maintain the pressure to use brick and tile. Carefully explained regulation is required to ensure that beauty implies that ‘form follows function’, the latter of which is to build at real net zero (in construction and performance).

The substitution of timber (ie timber framing) would result in only a modest decrease in construction emissions due to the extent to which timer is already being used in housebuilding. More substantial saving could be achieved through timber cladding (and cedar shingles/tiles) and lime based rendering were this aesthetically acceptable.

The recent rise in timber costs (about 80% in 6 months) shows that this material is not dependable or resilient and should be used sparingly in retrofitting and subdivisions.

There are very significant uncertainties regarding the extant to which construction timber can reduce carbon emissions (and contribute to negative carbon) in the global circular economy.

4.       What role can the planning system, permitted development and building regulations play in delivering a sustainable built environment? How can these policies incentivise developers to use low carbon materials and sustainable design?


The planning system could contribute to reducing construction carbon by introducing a re-use/retrofitting first policy. This is most effective if included in the NPPF and/or NPG. It can be referred to in Development Plans and in Supplementary Planning Documents but only if supported by the Secretary of State on appeal.


Permitted Development Rights are subject to conditions/limitations that could and should require carbon neutrality or negativity and refer to an approved methodology. In the absence of such limitations PDR will continue to be a significant carbon loophole.


5.       What methods account for embodied carbon in buildings and how can this be consistently applied across the sector?

There are a number of existing methods of calculating whole life carbon from buildings and the excuse from MHCLG that none are ‘agreed’ seems to be a delaying tactic.

6.       Should the embodied carbon impact of alternative building materials take into account the carbon cost of manufacture and delivery to site, enabling customers to assess the relative impact of imported versus domestically sourced materials?


Carbon accounting is very susceptible to ‘leakage’ and it is absolutely necessary to include transport carbon if the result is to be even close to real zero.


7.       How well is green infrastructure being incorporated into building design and developments to achieve climate resilience and other benefits?


One of the lessons being learned from Covid induced restrictions has been the multiple values attached to local\accessible green space.  Unfortunately the landscaping of new developments does not currently embrace all the benefits that could be secured were a holistic approach taken to the provision of green space.  Forest gardening is one process through which the community and health benefits would be increased (see and


8.       How should re-use and refurbishment of buildings be balanced with new developments?


The Government has become hostage to the claim that 300,000 new dwellings are required to meet housing needs.  One myth, among many, associated with this policy, is that new building at that scale will increase affordability.  The only evidence on that issue shows an impact/reduction of about 2%, that is ‘trivial’ or ‘insignificant’ and within all the many margins for error.  The most substantial component of the cost of new building is the inflated price of land (the shortage of labour/skills and materials are becoming very significant) that the Government has declined to address (see 2018 NPPF review).  The question being posed, is how new build, with its very significant carbon costs in construction and operation compares with re-use.


With about a million more dwellings than households (ie 28m against 27m) and about half of the space and fabric of the existing stock not meeting genuine housing needs, the case for substantial new building at scale needs to be put under proper scrutiny even before applying the environmental impacts of new build.


Re-use and refitting are the only ways of meeting housing needs within carbon budgets. Most of the existing urban areas are already equipped with infrastructure and services (benefitting from more custom from increased density of occupation).


9.       What can the Government do to incentivise more repair, maintenance and retrofit of existing buildings?


Most of the Government funding and policy for housing stimulates demand (universal credit/housing benefit, Help to Buy, Stamp Duty relief, intermediate housing/equity sharing), doing more to inflate prices than to increase supply of housing of the right type/size and needed levels of energy efficiency and fuel poverty reduction.  Only a small fraction of that funding would be required to spark into life a nationwide programme of custom splitting harnessing the energy of those wanting to create their own home (many thousands having languished on the statutory self build registers for the last 4 years), and those wanting to downsize without the means to do so ‘in situ’.  These energy efficient sub-divisions would result in the necessary insulation and heating of space and fabric that would be meeting genuine housing needs. Incidentally the increase in housing occupation densities would make it easier to achieve the 15 minute neighbourhoods based on active travel. Also see


Mobility standards would be increased to meet the needs of the ageing population.


The grants/loans for custom-splitting should cover the feasibility and design stages as well as advice on the legal and financial aspects.  Variations would include rental, purchase and rent-to-buy.  Loans could be repaid on completion of the sub-division and by instalments or deferred to future sale.


The green custom-splitting of existing stock within existing built-up areas would involve very limited construction or operational carbon compared with new build.  There is no current national programme for upgrading the existing 27m dwellings to an adequate (ie 1.5 degree global warming) standard.


May 2021