The Council for British Archaeology                            SBE0018


Written evidence submitted by The Council for British Archaeology

Executive Summary

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.


  1. 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.


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

Don’t know / prefer not to say.


  1. 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?


  1. 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.


  1. 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?



  1. 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.


  1. 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.


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






  1. 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