BUILDINGS AND INFRASTRUCTURE GROUP:
Zero Carbon Buildings : February 2020
1.1 – About 40% of all energy related emissions come from buildings and the construction process so in helping to achieve CCC’s stated aim of becoming zero carbon by 2030, tackling buildings and the construction process will play a big part.
1.2 – Our greatest task will be to tackle the poor quality of the existing building stock within the District but going forward, it is vital that all new buildings are constructed to be as low carbon as possible in order not to add to the carbon load.
1.3 – All new buildings in the district should therefore be required to show a level of energy efficiency and sustainability well beyond the minimum standards required by the current Building Regulations, with year on year improvements, until actual zero carbon in use (AZC) standards are achieved by 2025.
1.4 – This paper will make recommendations on how to frame policy in order to reduce carbon emissions and construct truly sustainable developments, both within the CCC estate and in the wider District.
1.5 – The recommendations in this paper cover new buildings only and will be followed shortly by recommendations for refurbished and retrofitted buildings together with an information pack for householders and businesses on how to aim for zero carbon emissions in their existing buildings.
2.1 – The Planning and Energy Act 2008 (as amended) allows local planning authorities to set and apply policies in their local plans which require compliance with energy efficiency standards for new homes that exceed the requirements of the Building Regulations. This Act also committed the government to making all new homes carbon neutral by 2016.
2.2 – In 2015 however, the then government (under pressure from the big housing developers) axed the plan to make all new homes carbon neutral by 2016 and set out, in a Written Ministerial Statement its “expectation” that local planning authorities would set energy efficiency standards for new homes to Level 4 of the Code for Sustainable Homes (this being equivalent to about a 20% improvement on the Building Regulations : Part L : 2013 standard). Furthermore, the current consultations on the Future Homes Standard (FHS) and Part L of the Building Regulations add to the state of flux, but it is fairly certain that a minimum improvement of 20% on the Building Regulations will soon be mandatory for all LPA’s.
2.3 – There thus remains much confusion amongst local authorities as to how far they can exceed the requirements of the current Building Regulations but having declared a Climate Emergency in July of 2019, with the aim of becoming zero carbon by 2030, CCC should follow or exceed radical new policies being set by many local authorities around the UK; these radical new policies being the basis of our recommendations.
3.0 THE THREE R’S AND THE PRINCIPLES OF SUSTAINABLE DESIGN
3.1 – Before looking at specific carbon reduction policies in detail, CCC should promote the “three R’s” of sustainable development, namely, Reduce, Reuse and Recycle.
3.1.1 – Reduce: Building nothing, challenge the need to build. Before any new building is constructed we should ask the question “why is it needed”? Can we manage without it? Where needed, buildings should be kept as small and efficient as possible.
3.1.2 – Reuse: Encourage refurbishment of buildings rather than replacement, especially property under the control of CCC. CCC should consider their current offices as an exemplar test case for reuse/retrofit. Also, encourage use of “brown field” sites.
3.1.3 – Recycle: New buildings should be constructed from recycled materials wherever possible and should be designed with the potential to be recycled and reused at the end of their lives. Also ensure that new developments have sufficient space for recycling facilities in the design.
3.2 – Whilst setting standards for the reduction in carbon emissions, it is also important to simultaneously promote the principles of sustainable building design, many of which are already included in the National Planning Policy Framework (NPPF) revised July 2018 and listed in Chapter 7 of the Canterbury District Local Plan adopted in July 2017 (Ref A3.1). These principles (Ref Appendix 2) can be incorporated into building developments at no, or very little, additional capital cost.
4.0 THE ZERO CARBON WAY AHEAD FOR NEW BUILDINGS
4.1 – The methods of measuring carbon and energy vary widely. The carbon assessment method included within the current Building Regulations creates a “performance gap” that results in buildings being far less efficient in reality than in their designs.
4.2 – There are however far more robust methods that should be considered, and one such method is the “Passivhaus Standard”. (Ref A3.2). There are also others including the Association of Environmentally Conscious Builders (AECB) Building Standard (based on Passivhaus but adapted to the demands of the milder UK) but Passivhaus remains by far the most widely used international standard.
4.3 – The Passivhaus standard puts the need for a high levels of fabric specification (insulation, air tightness and triple glazing etc) ahead of the provision of renewable energy solutions and offsetting and measures energy consumption rather than carbon emissions. It also includes assessment of currently ‘non regulated’ energy under the Building Regulations such as domestic appliances and cooking.
4.4 – Passivhaus has several standards, including:-
- PH Classic- the main standard of which over 60,000 buildings have been completed worldwide and will achieve a “near zero carbon” standard in use
- PH Plus, which matches energy consumption with energy generation on site and thus is an actual “zero carbon in use” (AZC) standard and
- PH Premium which exceeds energy consumption with generation and thus is “better than zero carbon in use”
4.5 – In setting policy, it is important to separately consider CCC development and private development, as in the former case CCC has control of its own estate and can thus more readily “call the shots” and become an exemplar authority.
4.5.1 – CCC Development
18.104.22.168 – In its Climate Emergency in July 2019, CCC declared that it will reach zero carbon by 2030. Thus, where CCC is developing its own estate, including East Kent Housing, or where it is selling land for development it can, and must, immediately set actual zero carbon (AZC) standards, in use, for all new buildings passing through the Planning and Building Regulation process.
22.214.171.124 – The most effective way to achieve zero carbon in use is to build using the Passivhaus Plus (or equivalent) standard which can and is being done right now. Reference should be made to the award winning Local Authority Passivhaus housing scheme in Norwich. (Ref A3.3).
126.96.36.199 – In addition, all efforts should be made to reduce “embodied energy” in construction.
4.5.2 – Private development
188.8.131.52 – Where CCC is setting policy for private developers and builders, the Council should stress the aim of achieving actual zero carbon (AZC) in use for all new buildings passing through the Planning and Building Regulation process by the end of 2020 and that the Passivhaus Plus (or equivalent) standard is its preferred way of achieving this aim.
184.108.40.206 – Furthermore, CCC should also aim to persuade private developers and builders of the merits of zero carbon buildings as these buildings will be highly efficient, very cheap to run and very desirable.
220.127.116.11 – However, it is recognised that not all developers or builders will be geared up to deliver Passivhaus (or equivalent) standards in the short term so we recommend that CCC should set an interim target; a target that is significantly better than the current Building Regulations requirements, In doing so, CCC should refer to, and follow the lead of other like minded councils around the UK who are adopting radical policies to combat the climate emergency. Bristol is one such council and we urge CCC to adopt policy that equals or betters Bristol’s lead (Ref A3.4).
18.104.22.168 – As such, it is recommended that all private development, which cannot meet the Passivhaus Plus standard, should be required to achieve, BY THE END OF 2020:
- a minimum of 20% reduction in regulated (Building Regulation requirements) CO2 emissions though energy efficiency measures to the fabric of the building.
- a further minimum 40% reduction in regulated (Building Regulation requirements) CO2 emissions through a combination of energy efficiency measures to the fabric of the building and on-site renewable energy generation (solar panels, heat pumps, hydrogen boilers etc). Emphasis should be placed here on encouraging fabric improvement over renewable energy provision.
- after applying the above measures, all development should be required to reach a 100% reduction in regulated and unregulated emissions (ie achieve zero carbon emissions) through the use of carbon offsetting. Acceptable offsetting measures should be via an agreed payment to the Council (via a 106 agreement or other legal/planning mechanism currently in place) of £100 per tonne of CO2 emitted by the development over a 30 year period.
- In addition to the above, commercial developments must achieve a BREEAM “excellent” standard and residential/mixed use developments must achieve a BREEAM for communities “excellent” standard. In this way, issues such as embodied energy and sustainable design principles can begin to be addressed.
22.214.171.124 – In addition, all efforts should be made to reduce “embodied energy” in the construction process. The Green Building Council have published a definition of zero carbon buildings in their ‘Net Zero Carbon Buildings: A Framework Definition’ which also takes into account operational energy and construction carbon used up to practical completion (Ref A3.5).
126.96.36.199 – It is also anticipated that there should be year on year improvement to the above policy such that by the end of 2030, all developments passing the Planning and Building Regulation process should be required to be truly zero carbon, including embodied energy, without the need for offsetting.
188.8.131.52 – Finally, all new developments should demonstrate, through an Energy Statement as part of the Sustainability Statement, how these requirements will be met.
5.1 – Having declared a Climate Emergency in July of 2019, with the aim of becoming zero carbon by 2030, CCC should be brave and resolute in following or exceeding radical new building policies being set by many local authorities around the UK.
5.2 – All new buildings in the district should be required to show a level of energy efficiency and sustainability well beyond the minimum standards required by the current Building Regulations, with year on year improvements, until actual zero carbon (AZC), in use, standards are achieved by 2025.
5.3 – CCC should also promote the Principles of Sustainable Design, including the “three R’s”; Reduce, Reuse and Recycle.
5.4 – Where CCC is developing its own estate, including East Kent Housing, or where it is selling land for development it can, and must, immediately set actual zero carbon (AZC) standards, in use, for all new buildings passing through the Planning and Building Regulation process. The most effective way to achieve this is to build using the Passivhaus Plus standard.
5.5 – Where CCC is setting policy for private developers and builders, the Council should stress the aim of achieving actual zero carbon (AZC) for all new buildings passing through the Planning and Building Regulation process by the end of 2020 and that the Passivhaus Plus (or equivalent) standard is its preferred way of achieving this aim. However, if actual zero carbon (AZC), in use, cannot be achieved using the Passivhaus Plus standard, CCC must set minimum, interim targets that are significantly better than the current building Regulation standards as outlined in section 184.108.40.206 above.
5.6 – CCC should, together with like minded council’s around the UK enter into dialogue with HMG to ensure that national regulations and guidance are revised and significantly improved, in line with the recommendations outlined in this paper
APPENDIX 1: CCAP AND THE BUILDINGS SUB-GROUP
A1.1 – CCAP was formed in June of 2019 to bring together civic society, our universities and local business to support the Council in the implementation of their Climate Emergency, to reduce our carbon footprint/emissions throughout the District and to work towards a zero carbon Canterbury
A1.2 – CCAP has formed a number of sub-groups to develop detailed strategies as part of it’s 10 point action plan and this sub-group covers Action 6: Buildings and Infrastructure.
A1.3 – Sub-group members and authors of this paper:
Keith Bothwell – BSc, MSc, Dip Arch, RIBA, honorary senior lecturer and former Deputy Head of School at the Kent School of Architecture, University of Kent, specialising in sustainable design.
Tim Carlyle – B.A Philosophy, BArch, Dip Arch, Code for Sustainable Homes Assessor, part time teacher at UoK, an architect with 40 years experience.
Paul Mallion – BSc (Hons), MSc (Arch), FRICS, Certified European Passivhaus Designer and director of Conker Conservation Ltd, Chartered Building Surveyors.
John Yard – BSc (Hons) Arch, Dip Arch, March, retired architect who specialised in sustainable development and low energy design.
APPENDIX 2: BUILDING CLEVER
A2.1 – Whilst setting standards for the reduction in carbon emissions, it is important to promote the principles of sustainable building design, many of which are already listed in Chapter 7 of the current Local Plan and can be incorporated into building developments at no, or very little, additional capital cost. These principles include:
- Design on a “fabric first” basis; highly insulated and air-tight structures
- South facing orientations for passive solar gain where appropriate in conjunction with solar shading
- Design to higher densities and preferably on “brownfield” sites
- Design buildings and structures to support solar panels and other renewable energy systems and flat roofs to be able to support natural “green roofs”
- Construct using materials with low embodied energy and preferably those that have sequestered carbon such as timber, hemp and straw. (See ref A3.6)
- Construct using less high carbon materials such as concrete, steel, aluminium, plastics and petrochemical foams
- Construct efficiently as to avoid waste; such as constructing “modular” buildings or other off-site construction techniques
- Design for adaptability and longevity from durable good quality materials and on the principle of “Long Life, Loose Fit, Low Energy”
- Consider light pollution
- Reduce water consumption by adopting good design standards such as the AECB Water Standard
- Construct permeable paving or storm water storage for new hard surfaces
- Design with nature, as well as people, in mind; to enhance biodiversity
- Design to capture waste heat by incorporating a ventilation system with heat recovery
- Design for ease of waste management and require a management action plan
- Establish a checklist for developers to follow to assist in proving compliance with the above
- Establish a register of local specialist skills, sustainable suppliers, and other resources to encourage use of local materials and assets
APPENDIX 3: REFERENCES
APPENDIX 4 : FREQUENTLY ASKED QUESTIONS
4.1 – The difference between the Passivhaus and BREEAM standards.
4.1.1 – Passivhaus is an energy and comfort standard wheras BREEAM (Building Research Establishment Energy Assessment Method) endeavours to focus on all environmental impacts. This is why we are recommending Passivhaus for energy and comfort and BREEAM for all other sustainable design issues.
4.1.2 – Passivhaus is an international standard that concentrates on the fabric of the building, ensuring that it is extremely well insulated, airtight and well ventilated. This high level of fabric specification, together with mechanical ventilation with heat recovery (MVHR) systems ensures high levels of comfort while using very little energy for heating. This standard also uses a rigorous and well proven quality assurance process. The Passivhaus Plus version recommended matches any remaining energy consumption with on site renewable energy generation, resulting in zero carbon construction in use.
4.1.3 – BREEAM (Building Research Establishment Energy Assessment Method) is also an international scheme but unlike Passivhaus, it is a “catch all” assessment of the sustainable design performance of building, community and infrastructure projects based on value judgements. BREEAM covers a wide range of categories including energy, health and wellbeing, the embodied energy of materials, pollution, transport, waste and water. BREEAM does improve the energy performance of buildings but an excellent rating can be achieved without achieving the desired higher performance or monitoring levels of the Passivhaus standard. BREEAM lacks the rigorous post occupancy evaluation of Passivhaus so has not been proven to work well in practice in terms of energy consumption and indoor air quality.
4.2 – What is the additional cost, over and above the current building regulations, of building to a Passivhaus standard.
4.2.1 – There is no straightforward answer to this question as there are many factors influencing buildings costs including form, type, size, orientation, and builder experience but research by the Passivhaus Trust, the Green Building Store, the Zero Carbon project and many others puts the added cost for a 3 bed housing unit at between 5% and 10%. This addition cost will decrease once developers and builders learn from their experience and become more efficient and buyers will experience greatly reduced energy bills (it is estimated that a 3 bed household will save approx 80% on an average annual energy bill of £1250), greater comfort and better interior air quality.