Clean Air in London SBE0100
Written evidence submitted by Clean Air in London
Introduction and Executive Summary
- Clean Air in London (CAL) submits this memorandum to the Environmental Audit Committee’s (EAC’s) inquiry into ‘Sustainability of the built environment’ which closes on 15 May 2021. Thank you for inviting submissions. EAC’s announcement of the inquiry can be seen here:
- CAL’s mission is to achieve, urgently and sustainably, full compliance with the World Health Organisation’s (WHO’s) air quality guidelines throughout London and elsewhere.
- CAL is a not for profit company limited by guarantee, registered in England and Wales, with number 7413769. Further details about CAL can be found at https://cleanair.london.
- CAL is independent of any government funding, has cross-party support and a large number of supporters, both individuals and organisations. CAL provides a channel for both public concern and expert opinion on air pollution.
- Please note that Simon Birkett, Founder and Director of CAL, is also the Chair of the Knightsbridge Neighbourhood Forum (KNF) which produced the first ‘made’ neighbourhood plan in central London. Further details about KNF can be found at https://www.knightsbridgeforum.org/.
- CAL’s submission addresses points 4, 7, 8, 9 and 10 of your ‘Call for evidence’.
- Point 4: What role can the planning system, permitted development and building regulations play in delivering a sustainable built environment? How can policies incentivise developers to use low carbon materials and sustainable design?
- The planning system is in a state of flux at the moment e.g. we do not know whether four tiers of planning policy in central London will be made more complex by the Government adding four tiers of design codes. It is also unclear whether the Government’s initial objective, which seemed to be intended to move us towards the United States system of such codes, has got accidentally misdirected to more traditional UK-style design codes.
- CAL points you to the success of the ‘made’ Knightsbridge Neighbourhood Plan 2018-2037 (KNP). Its 40 planning policies define clear end points for 2037 (e.g. zero aim emission buildings), encourage developers to get there now and will increase pressure as time passes. In contrast most other plans include policies which suggest incremental change at best in order to avoid the local authority or Mayor from having to prepare a Strategic Environmental Assessment and justify their requirements e.g. “at least air quality neutral”.
- In CAL’s experience, larger developers want to build all-electric buildings to reduce or avoid the need for maintenance, leaky pipes etc. There is no reason why this cannot be done. Modern, well insulated buildings may only need their heating turned on for two weeks a year. Unfortunately, developers can be heavily incentivised by poor planning policies to include gas boilers, CHP or other fossil fuel generation on-site e.g. to score BREEAM points to make it easier to achieve the BREEAM ‘excellent’ rating often required by planning policy. The KNP’s policies deliberately negate those perverse incentives e.g Policy KBR40(D)(b).
- The City of London Corporation’s Air Quality Supplementary Planning Document sets the gold standard for local authorities and others to move quickly towards ‘zero air emissions buildings’:
- One of the greatest needs is to consider construction, energy efficiency etc at the design stage of a project.
- Another of the greatest needs is to minimise energy use in buildings and maximise energy efficiency and the production and use of renewable energy to meet their needs. See KBR35(A). All new developments and refurbishments requiring planning permission need to deliver zero air emission buildings.
- High standards of construction are important. See:
- The KNF’s best practice guidance on construction standards and procedures:
- The Institution of Civil Engineer’s ‘Engineering Cleaner Air’ report and in particular the section titled ‘Industry practices’:
- London and other cities need to set more ambitious standards for the use of zero air emission construction equipment.
- See JCB’s excellent 100% electric ‘e-tech’ range of non-road mobile machinery i.e. “yellow plant”:
- Point 7: How well is green infrastructure being incorporated into building design and developments to achieve climate resilience and other benefits?
- In London, it is common for plastic or synthetic greenery to be used in developments. This is unacceptable. The KNP states in Policy KBR10(D): Urban greening: Use of synthetic materials to provide a visually equivalent finish will be resisted e.g. plastic greenery.
- Urban forests in cities and towns will not regenerate naturally. They need active management to ensure they are resilient to climate change, diseases and pests across a variety of species of different ages. Please see policies KBR9; KBR10; KBR37; KBR38 and the KNF’s best practice guidance for tree management plans:
- Point 8: How should we take into account the use of materials to minimise carbon footprint such as use of water harvesting form the roof, grey water circulation, porous surfaces for hardstanding, energy generation systems such as solar panels.
- See Point 4 above.
- Point 9: How should re-use and refurbishment of buildings be balanced with new developments?
- Grosvenor has some very early data that indicates that 30% of emissions over a building’s life cycle comes from the initial materials and construction process, about 30% comes from maintaining the plant and the remaining 40% is from its operation. With that in mind, reducing and eliminating the embodied carbon from the first two factors is of critical importance if the built environment is to help reduce overall global carbon emissions. The article below requires ‘free’ registration:
- These statistics emphasise the importance of refurbishing and/or reusing buildings wherever possible and to the maximum extent possible. We must also allow double or triple glazing in listed buildings without undue obstacles.
- Point 10: What can the Government do to incentivise more repair, maintenance and retrofit of existing buildings?
- See point 4 above and KNP40(D).
- Paragraph 10.11 of the KNP explains:
- It will be more cost effective in principle to meet these obligations by requiring new development and substantial refurbishment, when they occur, to make incremental investments than to require changes to entire buildings in a short period for the majority of the building stock in the Neighbourhood Area in the medium or longer-term. Ideally, three to five per cent of the building stock would be upgraded in this manner each year during the life of the Knightsbridge Neighbourhood Plan.
- CAL would be pleased to give oral evidence if invited to do so.