The Council for British Archaeology                            SBE0018

Written evidence submitted by The Council for British Archaeology

Executive Summary

• Greater understanding and knowledge sharing amongst LPAs regarding the whole carbon life of buildings should inform decision making about sustainability in the built environment.
• Environmental viability assessments should calculate the relative carbon impact of schemes to demolish standing structures and build new, against the adaptive re-use and retrofit of existing buildings. Such assessments should consider the embodied carbon of standing structures, new materials and emissions from construction work as well as daily carbon emissions.
• Making VAT reclaimable for low carbon building materials and schemes to maintain, repair and retrofit existing buildings (especially historic and Listed buildings), rather than being charged at the standard 20%, would make these more sustainable options more economically viable for developers. This would create a level playing field with the effectively zero-rated VAT levied on new home construction. The parity in VAT costs would incentivise developers to pursue these more environmentally sustainable options.

Who are The Council for British Archaeology

The Council for British Archaeology (CBA) is a charity committed to making archaeology accessible to anyone interested in exploring the stories of people and place. As the voice of archaeology in the UK we bring together community groups, commercial units, academics and heritage organisations to create and share opportunities to participate, discover and be inspired by archaeology.

As a national amenity society, the CBA are statutory consultees within the planning system. We review over 4000 planning applications each year, 85% of which are for Listed Building Consent (LBC). Through our Listed Buildings Casework team and advocacy work we speak up for the historic environment. Our primary focus is around the archaeological and historic interest in the built environment, its appropriate conservation and changes within the historic environment being informed by an understanding of where significance lies in evidencing how places have evolved in relation to past people. We champion the important contribution that the historic environment makes to the place based identity and well being of current and future generations.

We welcome the opportunity to respond to the Sustainability of the Built Environment consultation. Our specific interest in this consultation relates to the importance of understanding the total carbon emissions associated with traditional buildings and how their refurbishment could contribute to meeting  the  UK’ s target to be carbon neutral by 2050.

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

Don’t know / prefer not to say.

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?

Don’t know / prefer not to say.

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

Don’t know / prefer not to say.

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?

• There is a standing precedent for incentivising building projects through VAT rating. The ability to reclaim VAT on new build homes could be assimilated for use in a scheme to incentivise the use of low carbon building materials.
• Viability assessments are often required to justify planning proposals in comparison to alternative schemes or uses for a site. We especially see this around listed and locally listed structures. Viability assessments are almost always reduced to economic viability, with little consideration given to environmental viability. Where environmental viability / sustainability within the built environment is factored in, this is often superficial and disregards the whole life embodied carbon of existing buildings. An example of such an approach can be found in this planning application in Worthing here – Colonnade House, 1-7 High Street, Worthing
• An improvement, which could be delivered within the planning system is the introduction of a requirement for environmental viability assessments for applications involving substantial demolition, especially of listed and historic buildings. These should consider the environmental impact of proposed schemes, with a weighting in favour of those that best contribute to the UK’s commitment to be carbon neutral by 2050. This could be through the choice of building materials or the adaptation of standing structures.
• When a viability assessment is comparing the retrofit of existing buildings with their demolition and rebuild, it is crucial that a full picture of embodied carbon, as well as daily emissions, is considered. The way in which the omission of embodied carbon can skew the findings of a sustainability assessment is set out in response to question 9.

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

Don’t know / prefer not to say.

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?

Yes.

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

Don’t know / prefer not to say.

8. How should we take into account the use of materials to minimise carbon footprint, such as use of water harvesting from the roof, grey water circulation, porous surfaces for hardstanding, energy generation systems such as solar panels?

Don’t know / prefer not to say.

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

• Approximately 230 local authorities have declared a climate emergency, making a commitment to reduce carbon emissions and tackle the impact of climate change in their areas. This requires multiple strategies across all departments. As “emergency” implies fast action, tough decisions, new ideas and radically different solutions to living and transport from those developed in the 20th century are necessary. Research into carbon in the built environment needs promoting and using to inform the implementation of sustainability-led policies across UK local authorities.

• Compelling research into the embodied carbon in pre-1919 building stock[1], commissioned by Historic England, demonstrates the imperative of not wasting the embodied carbon in standing buildings if the UK is to reach its legally binding commitment to be carbon neutral by 2050.

• In terms of sustainable development, the adaptive reuse of standing buildings far outweighs their demolition and rebuilding. The mindset that old buildings are inefficient in terms of energy usage focuses on the daily emissions created by heating and powering a building, overlooking the carbon embodied within the building and the carbon lost through demolition. By considering operational emissions only (which the building regulations currently do), a comparison between retrofitting a Victorian terraced house and a new build dwelling of a comparable size under-estimate the New-build emissions by approximately 30% over 60 years, giving this option a false advantage and making refurbishment appear to be a less attractive option for emissions savings[2]. Where there is an opportunity to adapt, reuse and retrofit existing structures the embodied carbon of a building and the carbon released through demolition should be considered alongside the comparative daily emissions of old and new buildings.

• Where there is an opportunity to either demolish a standing structure, especially historic buildings, and construct a new building or reuse the existing structure, retrofitting it to improve its environmental efficiency, viability appraisals could be used to assess the comparative carbon usage of both schemes. Such appraisals must consider the embodied carbon in the standing building and those of the new building materials and construction emissions in calculating the relative merits of both schemes.

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

The government incentivise new build house construction by making it zero rated for VAT purposes, as VAT can be reclaimed. By comparison, the retrofit of existing buildings is more costly with work to existing buildings being VAT rated at the full 20%. There is no economic incentive to repair or retrofit standing structures, which often makes demolition and new build more economically viable for developers. To level the playing field there should be parity in the VAT rating between new build homes and works to repair, retrofit and adaptively reuse existing buildings as low carbon emitting homes.

May 2021