Response to Future Homes Standard 2019 consultation
1. We warmly welcome the Ministry for Housing, Communities and Local Government invitation to respond to changes in Part L (conservation of fuel and power) and Part F (ventilation) of the Building Regulations for new dwellings.
2. The Confederation of Timber Industries (CTI) is an umbrella organization which represents the £10bn timber supply chain, essential to the employment of around 200,000 people.
3. As an integral member of the construction industry, and advocates for sustainably sourced timber, we will help the Government reach its ambitious housing and climate targets.
4. We note the Committee on Climate Change (CCC) has highlighted the built environment contributes up to 40% of the UK’s total carbon emissions – a figure which includes both embodied and operational carbon.
5. The CTI believes that meeting the significant carbon reductions required to achieve net zero emissions by 2050, there must be a significant transformation of the construction industry, and current outputs, to both lift productivity, as well as the quality and efficiency of houses built.
6. This means we agree on principle that new build housing must be built to higher energy efficiency standards.
7. Ultimately failure to build houses to a higher standard now will result in higher end costs for future consumers, with the CCC showing in their report that retrofitting dwellings can cost up to five times the cost of designing in appropriate standards from the start.
8. It would be fiscally irresponsible to pass this burden forward, with a period of increases in regulatory requirements around energy efficiency already being planned in order to reach net zero by 2050 – and Government must not miss this opportunity.
9. We are concerned that the Government is poised to miss an opportunity to transform the industry by not extending its legislative focus to deal with embodied carbon - related to the emissions from the construction of buildings.
10. Many local authorities already include a whole life carbon assessment to account for the carbon embedded in the development, such as the Greater London Authority, and the Government should set a minimum baseline across the country - while allowing local authorities to push beyond those standards.
11. We wish to draw the attention of the Government to two key pieces of research into embodied carbon and the use of sustainable timber:
- Research from the Royal Institute of Chartered Surveyors estimates that embodied emissions sit at around 45% of a total building project.
- Research from the Biocomposite Centre estimates that using sustainably sourced timber can result in a 20% to 60% reduction in embodied carbon.
12. In our recent report with the APPG for the Timber Industries, How the timber industries can help solve the housing crisis, we include many case studies of homes built to high energy efficiency standards with reduced embodied carbon by using sustainably sourced timber.
13. There are methods for measuring the embodied carbon of projects, such as the ‘Whole life carbon assessment for the built environment’ developed by the Royal Institute for Chartered Surveyors.
14. Industry leaders are increasingly considering embodied carbon, for example RIBA’s Architects Declare seeks a reduction in embodied carbon of at least 50-70% before offsetting through renewable energy projects or certified woodland or reforestation projects.
15. We are concerned that the lack of inclusion of a plan to tackle embodied carbon, and absence from the Future Homes Standards and in resulting consultations will mean this legislation is not sufficient to tackle the climate crisis.
16. We would also like to express our agreement with the Cabinet Paper on Energy Efficiency: building towards net zero, p.123, which asserts the necessity of Government intervention to raise standards in the market and provide a level playing field.
“However, we are disappointed that we may have to wait until 2025 for homes to be built with “world-leading levels of efficiency” when the UK’s two largest housebuilders confirmed they do not require a long lead in time to deliver higher standards. Barratt and Persimmon said that higher standards could viably be delivered within 18 months. But with profit margins and shareholder returns the overriding priority for the majority of large housebuilders, they will not upgrade their standards without being required to do so by regulation. We recognise that there are some more progressive housebuilders who have indicated willingness to deliver higher standards at scale, but there is no commercial case to do so without a level playing field among all developers.”
17. Providing a level playing field with legislatively embedded performance-based targets for the construction industry would encourage market competition, innovation, speed up the pace of change, and reduce the overall carbon footprint of construction.
18. Currently more than 50,000 homes in the UK are built using timber frame, but there is significant variation in the use of timber in the UK (83% of new housing starts in Scotland using timber frame, compared to 30.7% in Wales, 22.8% in England, and 17.4% in Northern Ireland)
19. Increasing the use of sustainable timber in construction has been recognized as a key method of reducing carbon emissions by the CCC in the UK Housing: Fit for the future report, by the Royal Institute of Engineers and Royal Academy in the Greenhouse Gas Removal report, and internationally by the United Nations in the Emissions Gap – Report 2019.
20. The Structural Timber Association estimates there is existing capacity to double the number of homes built using timber frame to 100,000 homes.
21. This demonstrates there exists both the technology, means and capacity to solve both the housing and climate crises.
22. In the APPG report, How the timber industries can help solve the housing crisis, a series of recommendations for both national and local governments were introduced which would help create a business environment and better support the construction industry to shift to the use of sustainable material such as timber.
23. On a further note, we would like to express concern that the current regulatory system for building standards does not have the legislative tools (such as penalties or sanctions) or the independence from the private market to ensure building standards are upheld.
24. If the Government seeks to raise standards, as well as support for industry, there must be an accompanying uplift in regulatory activity to ensure that these standards are met.
- We recommend the Government expand the focus of Future Homes Standard legislation to include embodied carbon.
- We recommend the Government ensure that there is an appropriate regulatory regime in place to ensure that standards are upheld by the industry.
- We recommend the Government implement the recommendations of the APPG for the Timber Industries report on How the timber industries can help solve the housing crisis.