Mr Nicholas Owens                            SBE0091

Written evidence from Mr Nicholas Owens


My name is Nicholas Owens, I am a Parish Councillor for the village of Hassocks in West Sussex.  We have approximately 640 new homes to be built in our Parish over the next few years: these have already received outline consent from Mid Sussex District Council, and will shortly be coming forward with full planning applications.

In terms of relevant qualifications, I have an MSc in Architecture and the Sustainable Environment from the University of Kent, which I received in 2020.   I was part of the Parish’s neighbourhood plan Working Group which has introduced an energy efficiency requirement into our Neighbourhood Plan (more on this below); and I am in the process of retrofitting a 1978 chalet bungalow to ‘EnerPHit’ standards – i.e. close to Passivhaus.

Why I am submitting this evidence

I am passionate about improving houses to meet the threat of global warming.

Energy efficiency measures in our Neighbourhood Plan.

Policy 5 of our Neighbourhood Plan is about Enabling Zero Carbon.  It states that:

“Development proposals will be supported that maximise the opportunity to include sustainable design features, providing any adverse local impacts can be made acceptable.

“Residential development proposals that modify existing buildings (including extensions) should seek to maximise the inclusion of energy-saving measures and renewable energy generation.

“Proposals which make provision for charging electric vehicles at each dwelling (where feasible) and on-street; and making parking areas charging ready will be supported.”

This is a watered down version, as the Planning Inspector was not willing to accept what we originally proposed, which was:

“Support will be offered for development proposals that maximise the opportunity to include sustainable design features, providing any adverse local impacts can be made acceptable.

“All residential development proposals that modify existing buildings (including extensions) should seek to maximise the inclusion of energy-saving measures and renewable energy generation.

“Planning applications for developments of new dwellings must be accompanied by an Energy Assessment using the standard assessment procedure* (SAP) to demonstrate how carbon dioxide emissions are to be minimised onsite.

“All new residential development will be required to demonstrate that the net maximum heat energy requirement of the dwelling calculated using the SAP is 15 kWh/m2/year or less**/***.

“Proposals which make provision for charging electric vehicles at each dwelling (where feasible) and on-street; and making parking areas charging ready will be supported.

* For a definition of this process see Part L1 of the Building Regulation.

**/*** A negative value would mean the development is expected to be a net exporter of energy to the grid or to a district heating system. 15 kWh/m2/year is the German Passivhaus standard. However this Policy is not saying that Passivhaus standard should be adopted, as the UK climate is better suited to automated domestic heating and ventilation controls that were not available when the Passivhaus standard was developed; but it does take the Passivhaus level of heating energy efficiency as the objective standard to be achieved.

Thus the current planning system has forced upon us an inability to define precisely the energy efficiency of new homes (and extended / altered homes), with the effect that the most efficient way of heading towards a zero carbon housing sector is prevented.


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

The recommendations have not been met, for two reasons:  Firstly, the New Homes Standard has not yet been defined, it only exists in consultation draft; second, it does not come into effect until around 2026 on the assumption that 2024 building regulations approvals take a year to build. Thus, a further 4 ½ years’ worth of lower quality housing will be built before then.  This is in spite of the fact that MHCLG in its circular to local authorities dated 10.02.2021 has required that all new builds are ‘nearly zero energy buildings’ from 31.12.2020.


To assess whether the Future Homes Standard (as written in 2021) will bring new homes to Passivhaus standard, consider Table 1 below.

Table 1: Comparison of a planned retrofit in Hassocks with the Future Homes Standard

This shows that the Future Homes Standard (FSH) is close to Passivhaus.  The roofs u-value in the FSH seems to rely on Cellotex of equivalent as it would require over 300mm of wood fibre to achieve that result. Cellotex adds to global warming in its construction.


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?


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

Wood fibre and cork insulation are efficient, however cork is regrettably not available in sufficient quantities to base a standard on. The impact of wood fibre is seen in Table 1 above.

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 require builders and developers to achieve a certain low level of heat demand in terms of operational carbon emissions.  The Passivhaus standard of 15 kWh/m2/year is a possible measure to use and is backed up by Excel tools like the Passivhaus Planning Package (“PHPP”) to demonstrate its achievement. Published research shows it is a good match with minimal “performance gap” in the built results. This has to be backed up by a rigorous system of certification and the Passsivhaus Designer qualification does exactly this job of setting a standard and professionalism so should be adopted as it is without tinkering or amendment.


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


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. There are add-ins to the PHPP software, e.g. that designed by Tim Martell of the Association of Environmentally Conscious Building, that do exactly this job. 


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


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?

RIBA has set a 2030 Challenge for improvements in some of these aspects of sustainability, and this seems to be a practical way to go that is also supported by the Architectural profession.


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

Around 80% of the buildings existing today will be still in use in 2050, therefore the 2050 zero carbon commitment cannot be met without making existing buildings more sustainable.  What I have found from doing my own retrofit (and indeed my MSc dissertation was on this topic) is that a cost effective zero carbon retrofit of 1970s buildings does not exist, i.e. there is no break even. The way to go I suggest is therefore:

a)      to insist that all alterations to buildings are done to a zero carbon standard – i.e. for the fabric elements to match the FSH or for the outturn energy efficiency of the building to meet the EnerPHit standard of 25 kWh/(m2.annum) – it is harder and more expensive to retrofit to Passivhaus levels;

b)      to require all homes to reach a minimum level e.g. EPC ‘B’ or possibly ‘C’ energy efficiency by a certain date;

c)       to better align the EPC assessment with Passivhaus, as the current EPC methodology is prone to wild errors;

d)      to require all houses to move to heat pumps – this reduces their carbon footprint by around two thirds in one move;

e)      to rebalance gas and electricity prices so that electricity is not penalised and gas carries added ‘nudge’ taxes to get people off it: this will mean that overall energy bills for householders do not rise when they put in a heat pump.


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

The green homes grant has failed, because the process of getting tradesmen accredited was too onerous; the process for paying out the money was too slow; it was foolish to have this managed by a non-British company and worse, based 7,000 miles away in California; and the process for actually getting a grant was incomprehensible to most people (myself included). The grants were also way too small for householders to bother - £5,000 goes nowhere in externally insulating a detached house, and internal insulation is fraught with dangers of causing humidity, mould, and unhealthy living conditions.  (The AECB Carbon Lite Retrofit course spells out these dangers in detail).

In contrast the renewable heat incentive grant application process works.

This is a complex area but I would suggest that any builder or tradesman offering home insulation must have the AECB Carbon Lite Retrofit qualification or an equivalent qualification.  The grant payment mechanism could be an extension of that for RHI, however the money should be up front not paid over 7 years, as overwise most householders will do nothing and the scheme will fail again. Rigorous build standards must be enforced and the directors of builder firms / traders not meeting these standards should personally be barred from providing these services in future.  It’s not good enough just to bar non-performing companies.  New ones with rogue directors can spring up like an infestation of weeds.  Bar the directors.   


May 2021