Zurich Insurance                            SBE0139

Written evidence from Zurich Insurance


About Zurich Insurance


Zurich UK provides a suite of general insurance and life insurance products to retail and corporate customers. We supply personal, commercial, and local authority insurance through a number of distribution channels, and offer a range of protection, retirement, and savings policies available online and through financial intermediaries for the retail market and via employee benefit consultants for the corporate market. Based in a number of locations across the UK - with large sites in Birmingham, Farnborough, Glasgow, London, Swindon and Whiteley - Zurich employs approximately 4,500 people in the UK.


Executive Summary


Zero carbon targets and energy efficiency measures are driving changes to the way we plan, design, build and occupy homes. With a national net zero carbon target of 2050, and a requirement for all new homes to be zero carbon ready by 2025, progress is imperative.  However, the UK’s building stock remains one of the most inefficient in Europe and the UK must be more proactive in addressing this challenge.


In particular, creating low or zero carbon homes, achieving ultimate energy efficiency, and tackling fuel poverty are important and essential ambitions in this transition phase. However, these boxes tick targeted requirements only; it is imperative that the Government is also developing sustainable built environments and communities comprising of homes that are fit for purpose and fit for the future. 


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


1.1  We do not believe that the Climate Change Committee’s recommendations on decarbonising the structural fabric of new homes has been met.  Indeed, we are concerned that new homes are being built and existing homes are being refurbished to comply with current building regulations with little regard for the future and future functionality.


  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?


2.1  It is important that a holistic approach is adopted when materials incorporated to reduce the carbon impact of new buildings are considered.  Whilst the reduction of carbon is important the overall resilience of these materials to flood, fire, escape of water and other peril events should also be considered as part of a whole lifecycle consideration. It is also important that any proposed benefits are monitored throughout the lifecycle of the development to ensure that the proposed benefits continue to deliver for local communities.


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

3.1  The need for the housebuilding sector to modernise its methods of construction has been increasingly identified as a key concern, with it commonly suggested that traditional brick and block methods are unable to achieve the output required to meet the demand for new homes which adhere to sustainability targets.  Modern Methods of Construction (MMC), particularly the use of light-weight timber frame, are, therefore, a growing trend in the UK and increasingly viewed as the key building methods to meet the demand for affordable and sustainable housing.  However, as MMC becomes more prevalent, trends are emerging around serious problems that can be experienced when implementing MMC, particularly issues relating to the durability of the development, and the increased risk of larger scale water and fire damage which need to be considered. 


3.2  Indeed, Zurich is seeing large scale losses on properties built using less traditional methods and materials.  Poor material choices (particularly external finishes) and poor installation are the main causes. However, the challenges of new materials and systems go beyond that.  Timber is frequently used structurally and for facades and cladding, which presents additional risk considerations. In our experience these buildings are more likely to suffer catastrophic damage in a fire. 


3.3  It is also important to consider that nature-based materials go beyond the building themselves.  In the wider built environment, the inclusion of natural drainage solutions, green spaces and trees also contribute to net zero and wider biodiversity ambitions.  We, therefore, remain concerned by the Government’s decision to put on hold the enactment of Schedule 3 of the Flood and Water Management Act 2010 and the requirement for all new developments to include Sustainable Drainage Systems (SuDS) due to fears that compulsory SuDS could discourage house building by increasing development time, construction and land-opportunity costs.


  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?


4.1  Legislative, regulatory and governance requirements can sometimes be unclear or contradictory, and so it is understandable that public and voluntary sector organisations often find it difficult to build a clear, joined-up picture when it comes to sustainable construction.


4.2  The extension of permitted development rights is complicating this situation further, as it is reducing the level of control local authorities can exert over development taking place in their area, and thereby diminishing the effectiveness of the local authority planning function as a lever to driver up standards. 


4.3  Creating homes built to current minimum standards and climate requirements could also be short-sighted planning. Sustainable homes need to go beyond today’s climate change impacts and modifications, they must also reflect evolving use and lifestyles, reflecting how the climate and society are changing and will continue to change.  Wider conversations around built environments, taking in local landscapes, infrastructure, and amenities, factoring in whole areas around buildings, as well as those within them must be at the centre of sustainable construction.


4.4  However, we must not think of buildings in their abstract – they are peoples’ homes; livelihoods; and memories.  The loss of residential housing renders people homeless, disrupts children’s education, results in the loss of sentimental possessions, increases stress, and adversely affects the mental health of residents.


4.5  Zurich is clear that it is not enough that new buildings only offer enough resilience to simply ensure that people can escape safely but mean that they often don’t have a home to return to.  The Government’s Building Safety Bill is a once-in-a-generation opportunity to update building regulations with a prescriptive resilience baseline which establishes both lifespan and performance characteristics for new buildings in the event of a flood or fire.  With the unknown impact of climate change on the built environment, minimum resilience standards will ensure greater levels of protection are provided as a matter of course


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


5.1  Zurich does not have any insight on this topic.


  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?


6.1  Zurich does not have any insight on this topic.


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


7.1  Buildings should be designed and constructed with a long-term, holistic view that considers factors including:

        Any additional risks that could be introduced during the construction phase as a result of the materials and methods used

        The likelihood that the building would have to be completely reinstated in the event of a major fire/flood

        The impact this could have on the most vulnerable members of society

        How well the development meets local needs, and how well connected it is to other amenities and services

        How occupants will actually use the building and how this could affect its energy efficiency, fire compartmentation and so on. There also needs to be consideration of whether the occupants will even be aware of the impact of their actions

        How energy performance will be monitored (and if necessary, corrected) throughout the lifecycle of the building. Building telematics can be used to monitor not only energy performance, but also other environmental factors such as water efficiency. Such telematics systems could prove increasingly important as climate-related events such as heatwaves and water shortages become more common. 


  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?


8.1  The technology examples identified are all known for their benefits in respect of assisting in reducing the carbon footprint, but when considering these systems, approaches, and technologies, it is essential that detailed consideration is given to the risks associated with their use, and that they are not considered in isolation from a risk perspective. For example, the increased use of solar panel installations is well established, but the increased use must take into account issues such as their location from an access and maintenance perspective, potential storm damage, and the appropriate fire protections installed as part of the system, together with consideration of the building construction.


8.2  Life cycle considerations also need to be taken into account as part of any of these technologies to ensure that appropriate maintenance regimes are considered at the earliest stages of the design process, are well documented and understood, and can be rigorously achieved and maintained throughout the building’s lifetime. Simple examples include ensuring porous surfaces are maintained and do not become blocked due to a built up of silt and debris over time, that appropriate tests are undertaken to ensure capacity for storm surge type events, and that these can be retained throughout the lifecycle.


8.3  Similarly, with porous surfaces there is also the need to ensure building occupants understand that these materials form integral elements to the water management and surface water flooding prevention strategies, and by way of example, that porous hardstanding cannot be altered to hard surfaces without appropriate consideration of the impact and risks in doing so. Consideration must be given to how this is monitored and maintained, with continued relaxation of planning controls and legislation.


8.4  Grey water circulation and roof water harvesting are well recognised as positive approaches from an environmental perspective, but their interface with the fabric of a building present a range of risks. Given the significant impact that escape of water events can have in terms of costly and disruptive losses, the range of risks need early consideration relative to the type of building, the occupancy profile, the materials used within the fabric of the building and the protections from an escape of water perspective. Quality of workmanship, both in terms of initial design, physical detailing and installation, and ongoing maintenance, which should consider such issues as where pipes are routed, are concealed, and how their integrity can be maintained. 


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


9.1  Home design and build should be adaptable to changing use and demands to be sustainable. It also has to have the ability for upgrades to ongoing higher performance standards to negate the need for expensive and unnecessary retrofitting too soon after construction.


9.2  The Government must, therefore, consider changing goals, targets, approaches, needs and costs, in parallel with energy efficiency and zero carbon.  What is bound to change are the materials, methods and technologies used to construct and refurbish our homes. Most new build developments involve some aspects of modern methods of construction (MMC) be that full system methods using large-scale offsite construction, or individual building components and technologies.


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


10.1          Retrofitting the UK’s 29 million existing homes and converting non-domestic buildings in line with future low carbon and energy efficient standards is essential to provide the number and quality of homes needed, while meeting climate change mitigation and adaptation requirements.


10.2          However, the Government needs to demonstrate foresight and urgently update building regulations to encourage the proactive take up.  For example, from 2025 no new homes can be added to the gas grid. It is unsustainable, therefore, for homes being built in the years up to that date to have gas fired heating and cooking. Inevitably in the near future all homes will have to be retrofitted with non-carbon fuelled heating and cooking systems. The housing industry must start to plan and act now. Not adopting this approach in new build developments just adds unnecessary expense, disruption and waste in the future.


10.3          However, a focus on repair, maintenance and retrofit must be coordination with a consideration of the whole life value of a new building. At present new homes being built are unlikely to last generation.  This is building in waste without a true consideration of sustainability; we must collectively ensure we are not creating uninhabitable properties of the future.  It needs to be about more than energy efficient and warm and dry homes. They also need to be well ventilated and resistant to over-heating which is increasingly important given changing climate conditions.


May 2021