Regulations on emissions reduction are confusing and expensive. We should simplify the planning process by dispensing with emissions targets
On 26 October 2012, The Guardian announced that a wide-ranging government review of building regulations and standards would be taking place in an effort to cut costs for the construction industry and promote growth.
While it is highly debatable that the blame for the housing crisis and stagnant growth can be laid at the door of regulations and standards, there are some areas of overlap and duplication within the industry that add to the complexity of performance metrics, thereby causing confusion and costing time and money. Nowhere is this more apparent than in the emotive area of energy consumption and carbon emissions.
Part L is doing a good job of cutting emissions from new buildings, so why is it necessary for planning policies to add to this, requiring expensive contributions from renewable technologies?
Over the years, the demands on the industry have grown exponentially. Today, developers are required to compile complex energy strategies for submission to planning departments, which demonstrate how proposed buildings will meet the requirements of, occasionally overlapping, policy from both the Greater London Authority and the relevant local authority.
As an example, for a large housing development in London, the developer is likely to be required to demonstrate a percentage emissions reduction against the local authority policy, a percentage emissions reduction against GLA policy, adherence to Part L of the Building Regulations and compliance with level 3 or 4 of the Code for Sustainable Homes, all submitted to a mixture of planning and Building Control. That’s four different ways of showing that the houses will contribute to national emissions targets. Is it all really necessary?
With the Building Regulations review under way and against the backdrop of the 2013 Part L consultation targets, which set CO2 emission targets for new build at 45% for homes and 57% for non-domestic buildings compared with 2002, there is an opportunity to simplify the process.
Why not remove targets from planning policy altogether to give greater clarity and simplify the planning process?
It seems, from the evidence, that Part L is doing a pretty good job of cutting emissions from new buildings anyway, so why is it necessary for planning policies to add to this, requiring expensive contributions from renewable technologies, where it may be more cost-effective to achieve emissions reduction from other measures?
The emissions reduction targets set by local authorities are generally arbitrary too; 10% here, 20% there, and seemingly not based on any financial or technical modelling to establish suitability or viability. To add to the confusion, the 2011 update to the London Plan contains ambitious reduction targets of 40% better than the 2010 baseline for any relevant new development built in the 2013-16 period. Modelling conducted as part of the development of zero-carbon buildings policy and our own project experience at Hilson Moran have shown that it is extremely difficult (and expensive) to get anywhere near this using practical on-site solutions.
Let’s remove CO2 reduction targets and renewables contribution targets from planning policy, and have simple performance metrics for the industry
The planning process is intended to establish the suitability of a proposed development. Many decisions relate to the quality of design and are therefore subjective, which is why planning committees rather than individuals make decisions. Meeting emissions targets should be a yes/no answer, not a matter requiring the planning officer to be a technical expert, with the ability to objectively review complex energy strategies.
We also need to bear in mind that the current UK planning system does not encourage large amounts of services design to be completed prior to planning permission and nor should it, as to do so would increase financial risk for developers. This means that it is very difficult for consultants to accurately predict building energy usage (and hence emissions), when the system specification is likely to change during the latter stages of the design process.
So let’s remove CO2 reduction targets and renewables contribution targets from planning policy, and have simple performance metrics for the industry that can be better enforced through Part L by the Building Control bodies set up to do so. This won’t solve the housing crisis or lead the construction industry out of recession, but it will allow developers to meet targets in the most appropriate way and local authorities to promote regional low and zero-carbon infrastructure through community infrastructure levy contributions and allowable solutions from 2016.
Dan Jestico is head of research at Hilson Moran and one of Building’s 50 rising stars of sustainability