Written evidence submitted by the Architects' Climate Action Network


  1. Introduction

Written evidence submitted by:


Fiona Macdonald is a conservation accredited architect at LDN architects based in Edinburgh, with experience in public sector cultural projects across Scotland and the north of England.


Anna Lisa McSweeney is an architect at White Arkitekter, with a long-standing interest in good design to create healthy cities and resilient communities. With over 6 years of experience of practicing in London, Anna Lisa is implementing the company’s Scandinavian experience and design ethos within the UK’s regulatory and planning context.  


Both Fiona and Anna Lisa are individual members of the independent and voluntary Architects Climate Action Network (ACAN) and coordinators of the Existing Buildings thematic working group, on whose behalf this response is submitted. ACAN is a network of individuals within architecture and related built environment professions taking action to address the twin crises of climate and ecological breakdown. The Existing Buildings group’s remit includes raising awareness within and beyond the industry of the importance of retaining, retrofitting and improving the performance of our existing buildings and their percentage contribution to net zero targets

  1. Key areas of concern for ACAN’s Existing Buildings Working Group

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


The refurbishment; otherwise referred to as the retrofit of our existing buildings, in particular homes, must be prioritised urgently if we are to meet our net zero targets. The EU Commission's new data shows that existing housing fabric in the UK is among the poorest in north-west Europe (UKACE). Existing private housing stock contributes to 13% of UK carbon emissions (CCC Report Feb 2019). Two-thirds of UK homes fail on energy efficiency targets by falling below the C grade on Energy Performance Certificates (EPCs).


In order to achieve a net zero operation balance in the UK, and so meet our legal 2050 targets, the energy demand of all our buildings must not exceed our capacity for renewable energy production.


80% of the homes we will live in by 2050 already exist[1], and therefore the carbon emissions of these homes must be reduced, in parallel with ensuring that the Energy Use Intensity (EUI) of newly constructed homes is brought to a minimum. As such, the introduction of a regulatory performance framework with EUI requirements will be necessary to ensure the building industry delivers necessary ultra low energy buildings.


In addition to operational energy, we must consider the embodied energy of our buildings, in order to achieve net zero whole life carbon. Leading industry organisations, such as the London Energy Transformation Initiative, have written a road map to achieving net zero whole life carbon, LETI’s Climate Emergency Design Guide (2019) defines key performance indicators for meeting whole life carbon in new buildings. 


Echoing the Architect Journal’s Retrofirst campaign, It is essential that we think reuse first, new build second. Where there is an existing building available, default action must be to keep it and upgrade, rather than demolition and building from scratch. Creative solutions to use of buildings must be sought to ensure their retention alongside high quality new buildings only where required and planned efficiently to limit impact.


Without regulation and fiscal policy that incentivises the retention and improvement of existing buildings, experience shows that clients and contractors will choose demolition as default; resorting to tried and tested construction methods and supply chains, and supported by the current system of VAT that means we pay 20% on refurbishment projects, but nothing to demolish and build anew.


Whatsmore, the extension of permitted development rights has  allowed for the demolition of certain types of vacant buildings to be replaced by new homes. A holistic planning process is essential to ensure high quality, affordable safe and healthy homes, and walkable, inclusive neighbourhoods that support sustainable communities and a variety of uses. Permitted development rights present a risk to achieving these aims.


Measures must be taken to disrupt ‘business as usual’, for example the introduction of a whole life carbon budget would limit the total carbon emitted over the lifetime of the building, and incentivise decisions that make the biggest savings on carbon emissions. In the report ‘UK housing: Fit for the future?’ the CCC has recommended whole-life carbon intensity targets in Building Regulations, and mandatory disclosure of carbon emissions for buildings.



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


It must become easier and cheaper for building owners to look after, upgrade and retain existing buildings than to build new; currently this is not the case. Ways we suggest this might be simply achieved are:


-          VAT reform including reduction of VAT on existing buildings and sustainable improvements.


The UK construction industry produces 40% of our total emissions; the initial embodied carbon in the construction phase of a building can account for 75% of lifetime emissions. Retrofitting is carbon-efficient but the current VAT regime privileges new build over refurbishment.

Refurbishment projects could be charged 0% rate VAT on total costs, if they substantially reduce CO2e emission of the building; 20% VAT imposed for new build schemes, reduced to 5% if the build meets minimum passive house standard; to 0% rate VAT for all items on a regularly updated list of energy-saving products[2]

The government could incentivise retrofit by removing the liability for VAT on approved energy-efficiency products and simplify the processing for claiming back.


  1. Our recommendations:


-          Additional charges on demolition

-          Higher tax on new builds with possible subsidies for Passivhaus or similar standards.

-          Introduce structured ways of organising and paying for communal repairs and upgrades for shared buildings.

-          Mandate whole life carbon assessment and budgeting on construction projects

-          Fund and mandate upskilling of trades and professionals

-          Re-balance how value is placed on buildings by reviewing Home Report valuations for mortgage lending.

-          Provide long term investment funding for domestic retrofit.


May 2021


[1]The report, ‘UK Housing: Fit for the Future? Climate Change Committee 2019.

[2]Scott Cato, Molly. Petition to UK parliament  ‘To create a tax incentive to favour retrofit instead of demolition and new build’. August 2021.