Royal Commission on Environmental Pollution

The Royal Commission on Environmental Pollution's 22^nd Report, Energy - The Changing Climate, published in June this year, concluded that the government should plan for very large reductions in UK carbon dioxide emissions over the next half century, and that improved efficiency of heating and lighting in homes and other types of buildings must play a leading role in achieving such reductions. Heating and lighting in buildings accounts for about half of UK carbon dioxide emissions; and at the moment total energy consumption in buildings is rising. The Commission therefore welcomes the review the Department of the Environment, Transport and the Regions has carried out to assess the maximum contribution the Building Regulations in England and Wales could make to meeting the carbon dioxide reduction targets.

Those sections of the 22^nd Report that are directly relevant to the Building Regulations are enclosed with this response, as is a summary of the entire document. The Commission supports the 'essence of the principal proposals' for the introduction of standards, or the setting of higher standards, as described on pages 2-5 of the consultation paper. Many of these proposals are in accord with the recommendations made in the 22^nd Report. In particular the Commissions strongly supports use of the Building Regulations to improve the energy efficiency of existing buildings, as proposed in part 2 of the consultation paper.

Much more stringent standards will be needed eventually. It is sensible that these should be approached on a phased (or technology-forcing) basis, as the paper proposes. However the Commission urges the government to press ahead with preparations for the further amendments set out in part 5 of the paper, including legislation to amend the Building Act. Among other possible initiatives mentioned (outside the scope of the Building Regulations) it strongly supports the introduction of a sellers' pack for homes that includes an energy rating, the development of planning policies that will improve the efficiency of energy use, and measures to encourage the voluntary adoption of higher, best practice standards.

An immediate concern is that the standards in the proposed new edition of Approved Document L (part 3 of the consultation paper) will not require sufficient improvements in energy efficiency. For dwellings the Commission's recommendation is that the Building Regulations should achieve a SAP 100 rating by 2005. The calculations used for the consultation paper show that under all the present proposals (first phase, second phase and combined phases) the benefits in lower energy costs, for both dwellings and other buildings, substantially outweigh the extra construction and equipment costs in terms of net present value before taking into account the external costs imposed on the environment or (in the case of non-domestic buildings) the climate change levy the government plans to introduce.

If the calculations are robust, there is a sound economic case for improvements in energy efficiency even with the relatively low (current) fuel costs assumed in the calculations. One reason why regulations exist is to push the level of energy efficiency in new buildings nearer to the optimum point where the sum of construction costs and lifetime energy costs are minimised in net present value terms. If the unusually high price of crude oil prevailing at the time of writing this response were to be sustained and had the effect of raising other fossil fuel prices then the case for energy efficiency improvements becomes even stronger. The Commission's view is that efficiency standards for building fabric and heating, lighting and cooling equipment can and should be raised more than is proposed, and closer to the point where the present value of total costs equals the present value of total benefits. If table 5 (page 25) is taken as an example, the Commission received evidence that, for an average increase in construction costs not very much greater than £1,400 per home, the average improvement in energy performance per dwelling could be pushed some way above 26% compared to a dwelling built to the current standards (equivalent to an annual saving in fuel bills of about £130 on current prices).

The Commission supports the move to a carbon-based index for demonstrating compliance with the Building Regulations. In the case of dwellings, however, there is a strong case for retaining, in parallel with that, a SAP-type index based on cost, with a simple explanation of its significance, as the basis for the information house builders and vendors should be required to provide to prospective sellers.

Steel House, Westminster

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