National Federation of Roofing Contractors (NFRC) SBE0045
Written evidence from the National Federation of Roofing Contractors (NFRC)
The National Federation of Roofing Contractors (NFRC) is the largest
trade association for the roofing and cladding industry in the UK. We
represent the entire roofing supply chain from manufacturers to merchants to
contractors, and are members of both Build UK and the Construction Products
Association (CPA). We are licensed by the Ministry for Housing, Communities and
Local Government (MHCLG) to manage the NFRC Competent Person Scheme,
which allows roofing contractors to self-certify work under Part L of the building
Roofs are an integral part of the built environment, and as such, our rooftops are a crucial part to the sustainability of the entire built environment. To provide just a few examples; a quarter of all heat loss is through the roof, so is integral to retrofit, the roof is the first place where rain hits and has an important role in reducing and slowing stormwater run-off. Each roof has huge potential to galvanise the energy of the sun both for electricity and heating water, and finally a roof can often be more than just a roof and can be used for green space, flowerbeds, and even whole ecosystems.
It is for this reason that we have commissioned the University of Southampton to
undertake a comprehensive research project ahead of COP26 as to how we can
best make our roofs future proof, both through preparing them for the inevitable
changes to the climate this country will see but also how to best utilise the roof
space in a sustainable way. We would be happy to share the research proposal
and initial findings with this Committee.
1.1. With regards to new homes, the government has stated that the Future Homes Standard should mean that by 2025, new homes will produce 75 – 80 per cent lower carbon compared to current levels and that no further retrofit work will be necessary for these homes to become net-zero. Whilst this does seem to meet the Committee for Climate Change (CCC) 's recommendation for 'new build homes to deliver ultra-high levels of energy efficiency', particularly now the Fabric Energy Efficiency Standard (FEES) has been retained, it does not meet the requirement for this to be as 'soon as possible' – 2025 was recommended as the latest date. We note that in its letter of February 2020, the CCC recommended the date of the Future Homes Standard to be brought forward, and the full definition of the Future Homes Standard should be set now and legislated ahead of 2024 to give certainty to industry.
1.2. We also have seen no evidence of the government implementing the CCC's recommendation to 'develop a targeted package to incentivise and support those developers and individuals who wish to take early action in building low-carbon and resilient homes'. If the government does not bring the Future Homes Standard to an earlier date than 2025, incentivisation may be a good alternative.
1.3. Other CCC recommendations in which the government does not seem to have yet fully met on new homes include:
1.3.1. Addressing issues around compliance and performance – the CCC recommended a shift towards monitoring actual energy performance, broadening the current focus on the current building safety work to include other areas of building regulations, and enhancing funding for Building Control Bodies. We are yet to see significant progress in these areas
1.3.2. Issues around flooding and water stress – the CCC also raised concerns that 'there are a range of wider issues outside of energy and thermal comfort that a good, sustainable home ought to have: water efficiency measures, green space, and Sustainable Urban Drainage'. These concerns are yet to be addressed by the government.
1.3.3. Tackling skills gaps – The CITB recently estimated that an additional 350,000 Full-Time Equivalent (FTE) construction workers will be needed by 2028 in order to meet net-zero by 2050 – this is a 13% increase on the current size of the workforce. For roofing, there will be an extra 10,000 workers required, which is a 22 per cent increase. On top of this, there will be a need to upskill a large number of workers – for instance, training roofers to instal solar PV. Whilst there have been some welcome interventions in this area, such as the Green Jobs Taskforce, to address the scale of the challenge, extra funding is required.
1.4. Whilst we believe the Future Homes Standard could be introduced sooner, and there are some gaps, overall, the government seem to have met the CCC's recommendations in this area, particularly on structural fabric.
1.5. Where the government certainly have not met the recommendations of the CCC is on our existing housing stock. The CCC made clear in its 'Homes fit for the Future' report that 'the 29 million existing homes in the UK must be made low carbon, low-energy, and resilient to a changing climate'. In 2019 85MtCo2 was emitted from buildings, with 77 per cent of this just from homes alone. The vast majority of energy used by homes is to heat them, and therefore upgrading energy efficiency is critical. However, most of the initiatives announced by the government have such as the Local Authority Delivery Scheme (LADS), the Social Housing Decarbonisation Scheme (SHDS), and the Home Upgrade Grant (HUG), have been focused on social housing. This still leaves 15.5m owner-occupied properties, 65 per cent of which are below EPC C, with no government scheme to help retrofit them, following the ending of the Green Homes Grant Voucher Scheme (GHGVS). The government must urgently set out a long-term approach to retrofit in its Heat and Buildings Strategy.
1.6. Furthermore, the focus on retrofit so far has been on energy efficiency, and whilst this is important, the CCC has emphasised the importance of the 'twin challenges of climate change – ending the use of fossil fuels and preparing our homes for the changing climate. Retrofit, therefore, needs to be broader and include measures such as passive cooling, water efficiency, and sustainable drainage. Roofing is critical here, and that is why we have commissioned the University of Southampton to undertake research on how we can make our roofs future proof to prepare for the changes to our climate that are likely to place over the years to come.
2.1. There are a number of roofing systems and materials that can be used to reduce the impact of new buildings. We list some of these below:
2.2. Roof insulation – As a quarter of all heat loss from a building is through the roof, insulation is a critical way that materials can be used to reduce the carbon impact of a building. For roofing, this takes the form of cold, warm, and inverted roof insulation. This not only keeps a building warm in winter but cools it in the summer. It is critical, here, however, that the installer understands the building fabric, thermal bridging the impact of one measure on the rest of the house, so they don't introduce condensation risk.
2.3. Cool roofs - these are roofs that can stay cool in the sun by minimising solar absorption and maximising thermal emittance, and are therefore an important passive cooling measure. As temperatures start to rise, particularly in the South East of England, cool roofs can benefit a building and its occupations by reducing energy bills by decreasing air conditioning needs and improve the comfort of the spaces that are not air-conditioned.
2.4. Green roofs – Green roofs have good heat preservation and insulation performance, which plays an important role in reducing heat loss and reducing the buildings carbon dioxide emissions. Green roofs can significantly reduce the temperature fluctuation of roofs, providing passive warming to indoor spaces
2.5. Intelligent polymers - The use of 'intelligent polymers' further increases the scope through light reacting surfaces and finishes which absorb pollutants that reverses air pollution and purifies harmful NOx particles, providing a cleaner and healthier environment.
2.6. Solar PV and solar thermal – Installing solar panels and solar thermal systems to a rooftop is also a good way to lower your carbon footprint. Solar energy is a natural, renewable source because it can be replenished, unlike fossil fuels which are finite. Solar produces little or no emissions when it's converted to electricity. However, there is embodied carbon within solar panels that need to be considered.
3.1. It is unclear what is meant by 'nature-based materials' here. There are a number of roofing materials that could be classified as 'nature-based including:
3.1.1. Each of these materials have their own benefits and disadvantages. Whilst some may involve low amounts of carbon for an extraction they may have to be imported or may not have a long durability or be easily recyclable. When deciding which material to use, each of these factors should be weighed up. Limited definitions of 'nature-based materials' should therefore be avoided.
3.2. Broader nature-based solutions, however, such as green roofs and walls, have a critical role to play to help the government achieve its net-zero ambitions.
4.1. The planning system and building regulations have a critical role to play in delivering a sustainable built environment. This can clearly be seen by the London Plan, which has led to a significant uptake in green roofs on new developments. We also anticipate Biodiversity Net Gain to lead to an uptake in green roofs and other green infrastructure. Other city regions and Local Authorities should look to imitate this approach.
4.2. Building regulations are clearly important in creating a sustainable built environment, as can be seen by the gradual enhancement of energy efficiency standards over the last few decades. This can also be seen in Scotland where their building regulations have meant that almost all new-build homes now have solar PV installed.
4.3. However, currently, building regulations are too often seen as the highest level of compliance rather than the baseline. To change this will require a behavioural change by all those in the supply change to support the huge drive that will be required to deliver sustainable design and building practices. Government should be encouraging developers to aim high, not to meet the basic standards.
4.4. Construction generally has suffered from a lowest cost tender approach which has been identified as one of the major issues behind the Grenfell tragedy. This approach is readily acknowledged as driving poor behaviour and a lack of investment in training and professional development with real change coming from either legislation that insist on proof of professional competence of companies and individuals. This is starting to change with the introduction of the Building Safety Regulation and Competency Steering Group as well as PAS2035 for the domestic market, but there is still a need for a culture change in the industry. We are driving this in the roofing industry through our 'RoofCERT' Accreditation Scheme.
4.5. In terms of retrofit, many installation measures will not be impacted by the planning and building regulation system. For examples, building regulation sign-off is only required for a roof, where a homeowner is replacing 50 per cent or more of the roof. This is where other incentives are needed to encourage homeowners to make upgrades, such as linking council tax to EPC ratings, cutting VAT, or subsiding sustainable materials.
5.1. There are a number of established methods for accounting for embodied carbon in buildings. This includes an Environmental Product Declaration (EPD) which is a document that independently verifies the environmental performance of a product based on Lifecycle Assessment Data. The EPD can feed into BREEAM or other assessment schemes, or into a BIM model
5.2. However, anecdotally the take up of these types of assessments has been relatively low. For this to change, end-clients and main contractors will need to drive this, and create a demand for this type of information.
5.3. The Committee should be aware of the draft Code for Construction Product Information (CCPI) which has been developed by the Construction Product Association's Marketing Integrity group. This aims to ensure that all construction product information is clear, accurate, up-to-date, accessible and unambiguous. We hope this will lead to greater transparency with regards to construction product information, including environmental factors.
6.1. Yes – building materials should be treated holistically, not just in terms of the carbon cost of manufacturing them. Durability and the ability for a material/system to be maintained are also important considerations, as well as the amount of carbon offset.
6.2. Clay tiles are highly recyclable, durable and if salvaged from existing buildings, have low embodied energy – however, there is a carbon impact in their production through firing and flue gas emissions.
6.3. Slates are also highly durable, but accessible reserves in the UK are relatively low and, therefore it is often imported, increasing the carbon cost.
6.4. Steel, zinc and lead and other metals are used through the roofing industry, and whilst higher in embodied energy are fully recyclable, and in the case of steel recycling can actually enhance its quality and strength.
6.5. Ultra-Low CO2 Steelmaking (ULCOS) is a partnership of 48 European organisations, including steelmakers, which have committed to reducing CO2 emissions of steel products by 50 per cent by 2050.
7.1. Green roofs are an important part of green infrastructure. Green roofs perform a vital role in helping cities adapt to the effects of climate change by reducing the need for artificial cooling in hot weather and reducing rainwater run-off, as well as providing a range of habitats for wildlife to thrive.
7.2. Traditionally there have been three broad classifications for green roofs - extensive, semi-intensive and intensive. However, whilst biodiverse roofs share many of the characteristics of an extensive roof, their increased specification merits a distinctly separate category, because although they are similar in composition to an extensive roof, it is designed specifically to create a habitat that will attract a particular plant species, insects and birds, by replicating or creating a habitat
7.3. Biodiverse roofs includes a brown roof, which is a low-vegetated version of a green roof where the growing medium is purposely-selected to allow plant species to inhabit the roof over time.
7.4. Whilst London has seen a large growth in the number of all forms of green roofs, this has not been replicated at scale in the rest of the country. This is starting to change in Cities such as Manchester, but this could be encouraged far more by central and local government.
7.5. Unfortunately, a side effect of renovating or insulating roofs is that nest sites for swifts and other roof nesting birds can be unintentionally destroyed. The loss of nesting sites is thought to be one of the main threats to swift populations in the UK. There are various ways to protect swift nests without impacting roofing work and vice versa, which is why the NFRC is working in partnership with RSPB to ensure the renovation of roofs doesn't impact on nesting sites.
7.6. City Councils & Local Authorities around the UK, such as Edinburgh City Council have policies and supplementary guidance for developers to promote the installation of swift nesting sites in the design of developments and renovations. Both the UK and Ireland are working towards the concept of 'Biodiversity Net Gain' for developments that leaves biodiversity in a better state than before, this needs to be built into legislation for refurbishment and renovations of existing building stock.
7.7. We will be working with the University of Southampton to look at how our roofs can become more climate resilient and would be happy to discuss the initial findings of this research with the Committee.
8.1. The development and expansion of towns and cities has seen an increased use of impermeable surfaces causing high rates of rainwater runoff. A Blue Roof is a flat roof, designed to allow controlled attenuation of rainfall during heavy and storm events as part of a sustainable drainage system, replicating the natural environment or improving the as built environment. A Blue Roof will treat and release the water at a managed and controlled rate directly into the sewers waterways and river systems or harvested as greywater for the building.
8.2. The development of energy-generating roof systems incorporating solar PV in the roof finish broadens the scope for adoption alongside conventional solar panel retrofit. Poor aesthetics coupled with improper installation and expensive maintenance costs are some of the criticisms levelled at mounted solar panels. PV can be integrated into both building facades and cladding using semi-transparent thin-film or crystalline solar panels; and on rooftops, using solar slates and tiles. A lot of the calculations regarding the value solar PV adds to a property are outdated, and NFRC is working with the Solar Trade Association to create a model that truly reflects the value solar provides. We hope this will encourage the take-up on domestic solar.
8.3. The commercial and industrial roofing sectors are particularly important to improving energy efficiency and for the widespread use of rooftop solar. However, building owners are often deterred from installing solar PV due to how they are treated by the business rates system. The supermarket chain Lidl recently installed solar PV on seven of their stores, and this resulted in their business rates bill increase by 528 per cent. The government should exempt all renewable energy from business rates to encourage its take-up.
9.1. Cut VAT on repair and maintenance - The government should urgently address the imbalance that exists in the VAT system. Currently, if you demolish an old building and rebuild it, you do not have to pay any VAT. However, if you refurbish a building you attract a bill of 20 per cent. This offers developers a perverse incentive and does not encourage reuse and refurbishment
9.2. Formulate a long-term National Retrofit Strategy – a long term-strategy of how the government intends to retrofit the 29 million homes in the UK between now and 2050 is needed. NFRC supports the Construction Leadership Council's National Retrofit Strategy, which sets out a framework the government could use as a long term plan. The upcoming Heat and Building Strategy is the perfect opportunity for the government to announce this.
9.3. Introduce a Green Annual Investment Allowance – much of the government focus has been on the residential sector, but the poor energy efficiency of the UK's non-domestic buildings should not be ignored. Non-domestic buildings account for 23 per cent of the total amount of emissions from buildings. Whilst the recent Super Deduction announced in the Budget was welcome, it did not cover buildings and was not linked to any green incentive. To encourage commercial property owners to upgrade their premises, the government should amend the definition of 'integral features' under plant and machinery to include roofs and insulation to allow thermal roof insulation to benefit from the Super Deduction. Alternatively, the government could extend the favourable Structures and Building Allowance (SBA) currently proposed within Freeports of 10 per cent relief over 10 years to be nationwide.
9.4. Ensure work is installed by competent installers
9.4.1. The appetite for culture change in the roofing industry is widespread although meaningful adoption by clients has been slow. Previous initiatives in energy conservation measures of the fabric of the existing building stock have had well documented problems with the condensation risk associated with poor design and workmanship.
9.4.2. The real change comes from clients, who either through legislation or initial incentives insist on proof of professional competence of companies and individuals. The investment of specialist contractors in professionalising their workforces, such as by obtaining PAS2035 certification, must be accepted by their clients as costing more, but the payback is in greater productivity, higher quality and future proof of buildings. Government should support companies to achieve accreditation such as PAS2035. A failure to do this was one of the main failings of the Green Homes Grant Scheme.
9.5. We will be looking at many of these issues in much more details in our research with the University of Southampton and would welcome a discussion with the Committee regarding this research, and how it can align with the objectives of this enquiry.
We would be happy to follow up on any of the points raised above, and provide oral evidence if needed.
 See here: https://livingroofs.org/new-report-reveals-londons-green-roof-success-2019/