making the case for a code for sustainable buildings · 7 code for sustainable buildings...

March 2009 Making the case for a Code for Sustainable Buildings

2 www.ukgbc.org Code for Sustainable Buildings

About this report

The UK Green Building Council (UK-GBC) is an independent, membership-based, not-for-profit organisation committed to dramatically improving the sustainability of the built environment by radically transforming the way it is planned, designed, constructed, maintained and operated. A crucial feature of our work is the time limited ‘task groups’ we convene. These working groups bring together experts from within the membership with diverse perspectives - and often competitors - to work collaboratively to address a given challenge. Sharing expertise means that projects have access to a greater knowledge-base than any one organisation could possess alone. The following UK-GBC members were represented on the Core Task Group, and this report was written thanks to their generous support:

This report was written thanks to the contributions of the following Task Group members: Claudine Blamey, SEGRO Paul Edwards, Hammerson Bulen Hourshid, Davis

Langdon

Paul Phillips, Aggregate

Industries

Bill Bolsover, Aggregate

Industries

Bethan Ellis-Jones,

Linklaters

Bill Hughes, Legal & General

Property

Sunand Prasad, RIBA

Thomas Briault, Arup Stuart Farmer, Carbon

Trust

Martin Hunt, Forum for the

Future

Simon Rawlinson, Davis

Langdon LLP

Meabh Browne, Davis

Langdon

Peter Ferguson, Johnson

Controls

Tim Jones, SEGRO David Richards, Arup

Pippa Burchett, Legal &

General

John Frankiewicz, Willmott

Dixon

Janet Kidner, Lend Lease Suzanne Roberts, CBRE

Sarah Cary, British Land Andrew Frost, Willmott

Dixon

Judit Kimpian, Aedas Elaine Trimble, Arup

David Cheshire, Faber

Maunsell

Guy Grantham, Colliers CRE Ted King, consultant

Charles Walker, Legal &

General

John Connaughton, Davis

Langdon LLP

Kevin Greaves, Aggregate

Industries

Daniel Labbad, Lend Lease Miles Watkins, Aggregate

Industries

Ian Coull, Segro Ltd Alistair Guthrie, Arup Marco Marijewycz, E.ON Ant Wilson, Faber

Maunsell

Daniel Dowling, WSP

Ken Hall, Prologis George Martin, Willmott

Dixon

Charlotte Eddington, CBRE Vanessa Havard-Williams,

Linklaters LLP

Clare Neely, Colliers CRE

© Copyright 2009

UK Green Building Council


Contents

About this report 2

Executive Summary 4

Introduction 7

Methodology 7 The Task Group 7 The consultation 8

Core Themes 9

Policy Context 13 UK Policy and Regulatory Context 13 Main Conflicts & Barriers within the UK Policy and Regulatory Context 15

Value & Business Case 23 Introduction 23 What is the value proposition for sustainable buildings? 23 Barriers to demonstrating value 24 Proving the value proposition 27 Valuation process 28 How can the Code help? 29

Technical Issues 33 Introduction 33 Introduction to tools and standards 33 How should the Code interact with other sustainability tools, standards and aspirations? 34 What issues does the Code need to cover? 37 How should these issues be measured? 41 Conclusion 42

Operational issues 44 Who should own, operate, manage and pay for the Code? 44 How do we ensure quality control and technical rigour in a Code? 45 Education 47 What would ensure wide take-up of a Code for Sustainable Buildings? 47

Conclusion 49 Purpose of the Code for Sustainable Buildings 49 ‘GUIDING PRINCIPLES’ of the proposed Code 49

Recommendations and Next Steps 50 Recommendations 50 Next steps 50

Appendix 1 – Glossary 52

Appendix 2 – Value Literature Review 55

Appendix 3 – Regulatory and Policy Map 56

Appendix 4 – Workshop summary 58

Appendix 5 – Consultation document 59

Appendix 6 – Task group structure 60

Appendix 7 – Task group members 61


Executive Summary

BACKGROUND

Do we want or need a Code for Sustainable Buildings, and if so, what form should it take?

In 2004 the government-commissioned Sustainable Buildings Task Group recommended the development of a national Code for Sustainable Buildings. This led to the launch of the Code for Sustainable Homes, and the target for all new homes to be zero carbon from 2016 in December 2006. In mid 2007, the government revisited the question of whether we needed a Code for Sustainable (non-domestic) Buildings, and in March 2008, set out the ambition that all new non-domestic buildings should be zero carbon from 2019, based largely on the findings of the UK-GBC task group report, ‘Carbon Reductions in New Non-Domestic Buildings’. Given the rapid development of government policy and industry activity around sustainability, and carbon reductions in particular, in the UK, Europe and internationally over the last 3 years, the UK-GBC established a task group, to consider whether or not we want or need a Code for Sustainable Buildings, and if so, what form should it take?

CORE TASK GROUP MEMBERS

Paul King, Chief Executive, UK Green Building Council, Task Group Chair

Bill Bolsover, Chief Executive, Aggregate Industries UK

Dr John Connaughton, Partner, Davis Langdon

Ian Coull, Chief Executive, Segro John Frankiewicz, Chief Executive Officer,

Willmott Dixon Alistair Guthrie, Director, Arup & Partners Ken Hall, Managing Director, Prologis Bill Hughes, Managing Director, Legal &

General Property Daniel Labbad, Chief Executive Officer UK,

Lend Lease Sunand Prasad, President, RIBA Ant Wilson, Business Unit Director, Faber

Maunsell Department for Communities and Local

Government (CLG) officials and BRE sat as observers on the group.

To inform the core group, around 20 organisations took part in additional working groups focusing on technical, policy and value issues. A further 84 organisations (both UK-GBC members and non-members) responded to an industry-wide online consultation, and a workshop was held with attendees from over 80 organisations. KEY RECOMMENDATIONS 1. There should be a Code for

Sustainable Buildings that covers all new and existing non-domestic buildings in the UK.

2. The Code should be an overarching framework, which makes it easier for industry to understand policy and regulatory requirements and implement them effectively, throughout all stages of a building’s lifecycle.

3. The Code should set out the trajectory and stretching targets for a zero carbon, sustainable built environment – including carbon, energy, waste and water performance. All buildings must meet progressively more ambitious standards over time. Requirement for regular performance checks (a “building MOT”) would enable appropriate data collection and facilitate benchmarking. There should be mandatory disclosure of certain metrics in the public domain.

4. The Code should be owned by government, but represent a shared vision with the industry. This will require collaborative working, both across the industry and in partnership with government.

5. The Code should ensure consistency of approach between all policies, tools, guidance and initiatives. It should set the standards, metrics and targets that all sustainability tools should be aligned to and compliant with.


WHAT IS A SUSTAINABLE BUILDING?

Probably the best known and most widely accepted definition of sustainable development is that produced by the Brundtland Commission, of development that "meets the needs of the present without compromising the ability of future generations to meet their own needs." In this context, a sustainable building should be one which meets peoples’ needs – as a home, or a workplace for example – in ways which enhance its positive impacts and minimize its negative impacts, environmentally and socially, both locally and globally over time. The main challenge in translating such a definition into a meaningful goal, is that it is difficult to translate many of the potential facets of sustainability into quantifiable targets and milestones.

How would the Code define a sustainable building?

While the Task Group fully recognised the holistic nature of sustainability, often summarised as the ‘triple bottom line’ of social, economic and environmental considerations, they were also inclined to be pragmatic, and concluded that the Code should start by focusing on priority elements (or impacts) that are relatively easily measured, and around which there is a strong consensus for inclusion, ie energy and carbon, water and waste/resource efficiency. However, this is conditional on the recognition that it is important to broaden this set of elements as soon as possible, and to collect appropriate qualitative and quantitative data now, which could be used to establish new targets over time. To make sense in business case terms, the definition of a sustainable building must be based on standard quantitative measures supported by empirical evidence. Although evidence is emerging from the US and Australia of the link between sustainability and higher value, there is currently insufficient UK data to clearly demonstrate the business case for sustainable building, which is a key

barrier. It is important to provide a set of indicators and metrics based around easily adoptable standards that, where possible, would enable “like for like” comparison. The definition must be easily understood and communicated. There must be a clear presentation of how a building performs on key metrics. This will help decisions to be made which should deliver the most cost-effective improvements to buildings. A spider diagram1 could indicate what the regulatory minima will be over time for each of the key elements and demonstrate how the building performs in relation to each of these. It could expand indefinitely as new targets are added. Guidance and process tools designed to optimize the social, economic and wider environmental benefits associated with sustainable buildings could also be aligned to the Code, to ensure the best outcomes can be pursued, at key decision points throughout a building’s lifecycle.

NEXT STEPS

1. Establish a Code Working Group to include government, industry and other key stakeholders.

2. Code Working Group to further develop the policy and regulatory map for zero carbon and sustainable buildings.

3. Code Working Group to carry out a detailed mapping of existing tools and standards and establish a set of agreed “common metrics”.

4. UK-GBC to work with industry partners to drive data collection for the performance of buildings and develop the evidence base needed to demonstrate the business case for sustainable buildings

5. UK-GBC to scope out the current supply and demand for sustainability education and training and identify gaps.

1 For visual representation see Technical Issues chapter


PURPOSE OF THE CODE FOR SUSTAINABLE BUILDINGS

To set a trajectory for a zero carbon, sustainable built environment by 2050 ‘GUIDING PRINCIPLES’ OF THE PROPOSED CODE

The Code for Sustainable Buildings should: Be a shared vision between industry, government and other stakeholders to transform the sustainability of our built environment Ensure all key policy, regulatory and other requirements relating to the sustainability of buildings, throughout all stages of their lifecycle, are complementary and applied in a consistent manner to provide the clarity and certainty required to enable investment, innovation and effective delivery

Set out the zero carbon and sustainability trajectory for buildings that all relevant policy and regulation, tools and guidance should support and be aligned to Focus first on priority and measurable issues including energy, carbon, water and waste, and set ‘absolute’ performance targets for all buildings to meet over time Set outcome-based targets and milestones to stimulate innovation,

expressed using clear and universally applicable metrics Seek to harmonise existing standards or methodologies for use at different stages in the building lifecycle, and create a “common language” of metrics and measures between tools and standards which are approved as ‘Code compliant’ Be capable of evolution and development to include a broader range of sustainability needs over time Drive the consistent and systematic collection of data and information relating to the performance of buildings in relation to the priority issues over time, in order to measure progress and enable learning Provide the basis for the valuation of sustainable/green buildings by driving consistent data collection and enable benchmarking on key performance criteria

Increase ambition, market certainty and innovation, and reduce risks and costs associated with sustainable buildings Be owned by government and developed, managed and operated in a transparent and accountable way, by government working in partnership with industry and other key stakeholders


Introduction

In 2004 the government-commissioned Sustainable Buildings Task Group recommended the development of a national Code for Sustainable Buildings. This led to the launch of the Code for Sustainable Homes, and the target for all new homes to be zero carbon from 2016 in December 2006. In mid 2007, the government revisited the question of whether we needed a Code for Sustainable (non-domestic) Buildings, and in March 2008, set out the ambition that all new non-domestic buildings should be zero carbon from 2019, based largely on the findings of the UK-GBC task group report, ‘Carbon Reductions in New Non-Domestic Buildings’. At the same time, a number of other related questions have arisen, including: should we be aiming for harmonisation of international green building rating tools, so that we can achieve consistency of measurement and comparison of green buildings around the world2? What will be the effects of forthcoming European legislation and standards in the areas of the environmental assessment of products and buildings? How much impact will government policy designed to mitigate climate change have on the way we set targets and standards for energy efficiency and renewable energy, and how we measure the performance of buildings against them? In the last few years, sustainability has become a mainstream concern. Sustainability is now seen by many as a core business driver that relates directly to assessments of risk, reputation, value and profit. Most people in the industry recognise that this trend is only going to accelerate in the future. For all of the above reasons the UK-GBC decided to convene the Code for Sustainable Buildings Task Group.

Methodology

The UK-GBC sought to address the issues outlined in the introduction through a 6 month programme of work, which was undertaken by the Code for Sustainable Buildings Task Group consisting of a Core Task Group and three additional Working Groups, with a complementary process of wider consultation. THE TASK GROUP

The CSB Core Task Group (“Core Group”) consisted of 10 representatives from across the built environment value chain. A list of the Core Group and Working Group representatives can be found in Appendix 6 – Task Group members. The remit of the Core Group was to discuss and debate the core issues around the purpose, form and content of the ‘Code’ at a strategic level, which was then supported by further in-depth work across the following three Working Groups: (1) Policy Context; (2) Technical; and (3) Value and Business Case. The Core Group and Working Groups held regular meetings to which they invited a wide range of professionals in the construction and property industry. The Working Groups also gathered first-hand opinion in the form of presentations, interviews and case studies from a

2 It is noted that in furtherance of this issue, on 3 March 2009 a Memorandum of Understanding was signed between UK-GBC, BRE, USGBC and GBCA , for further information see www.ukgbc.org.


number of architects, consultants (including engineering and sustainability consultants), property developers, occupiers and valuers. Their work was further supported by their review of current UK policy and regulation, literature on the value of sustainable buildings and existing building environmental assessment methodologies, tools and standards. The supporting documents can be found in the appendices to this report. THE CONSULTATION

In addition to the programme of work undertaken by these groups, there was also consultation on the key issues outlined in this report. These consultation events took the form of: (a) a public online consultation held from 24 November to 12 December 2008 (a copy of the consultation document is attached at Appendix 5. Further details of responses can be made available on request); and (b) a consultation workshop event held 21 January 2009 (a summary of the workshop findings is attached at Appendix 5). These consultation events ensured that a wide cross-section of individuals from across the property value chain were given the opportunity to feed in their opinions and experience and explore the key themes in more detail. We are grateful to the individuals and their companies who took the time to respond to our consultation3, attend the workshop event4 and those who gave up their time to attend Task Group and Working Group meetings or be interviewed. The following report outlines the key recommendations and findings of the Task Group and covers issues relating to the current policy and regulatory context, technical aspects and business case for developing and delivering a Code. Each of the Working Groups has compiled their chapters using the Consultation responses, workshop findings and independent research. We acknowledge with thanks the assistance we have been given. Apart where otherwise stated, the views expressed are our own. A glossary of key terms used in this report is attached at Appendix 1.

3 Referred to in this document as “Consultees” 4 Referred to in this document as “Workshop Attendees”


Core Themes

Over the course of the Task Group’s work, a number of key themes were raised repeatedly in Task Group and Working Group discussions and through the Consultation. A brief summary of these is below. The themes are expanded upon in the subsequent chapters of the report.

Is there a need for a Code and if so, what is its purpose?

There is strong demand for the creation of a Code for Sustainable Buildings. The Consultation responses were almost unanimous on this issue. The Code should provide clarity for the industry and should help to provide a focus for the Government’s vision for the built environment as it relates to sustainability. The Task Group recognised that the introduction of the Code for Sustainable Homes has provided clear benefits to the house-building sector, however following the same model for the non-domestic sector is not appropriate. The non-domestic Code needs to take account of the considerable recent advances in knowledge and understanding about sustainability and resulting burgeoning of regulations, tools and standards. The Code should provide a framework to bring together targets; regulation and the tools and standards which the industry can use to deliver and understand sustainable buildings. The Code increase ambition, market certainty and innovation, and reduce risks and costs associated with sustainable buildings. The Code must provide all stakeholders in the non-domestic sector with an applicable and universally understood definition of a “sustainable building” in order to get cross-sector “buy-in” needed to support the momentum needed to create real, industry-shifting, change in management of the built environment. What should the Code be?

The Code should be a framework that has key targets to be achieved. The Code should specify minimum performance criteria to achieve base compliance, (i.e. the Building Regulations and other legal requirements) which would be mandatory, and also set out a stretching set of milestones and targets that would constitute improved performance. In this way it should enable Government to set out a regulatory trajectory into the future establishing progressive, bold policy and regulation that stimulates business innovation. The targets should be appropriate to building type and stage of the building’s lifecycle. There must be a clear link between the targets and basic building performance data so that stakeholders can understand and demonstrate the relationship between their decisions (be they in relation to materials extraction, product procurement, design, occupation of a building etc) and the overall targets. The Code should not be a new tool, it should enable people to utilise existing tools that are aligned to it. The value in not creating more confusion and the business case for the Code is based on this key point. The market needs the direction that would be provided by a framework, which makes sense of the legislative environment and clarifies which tools to use and how to interpret their results. The market would however benefit if the Code were to establish a common standard (“Code Approved”) which could be awarded to appropriate


existing or new tools and standards to reduce confusion in the market about which tools and methodologies to apply and how they relate to one another. How would the Code define a sustainable building?

While the Task Group fully recognised the holistic nature of sustainability, often summarised as the ‘triple bottom line’ of social, economic and environmental considerations, they were also inclined to be pragmatic, and concluded that the Code should start by focusing on priority elements (or impacts) that are relatively easily measured, and around which there is a strong consensus for inclusion, ie energy and carbon, water and waste/resource

efficiency. However, this is conditional on the recognition that it is important to broaden this set of elements as soon as possible, and to collect appropriate qualitative and quantitative data now, which could be used to establish new targets over time. To make sense in business case terms, the definition of a sustainable building must be based on standard quantitative measures supported by empirical evidence. Although evidence is emerging from the US and Australia of the link between sustainability and higher value, there is currently

insufficient UK data to clearly demonstrate the business case for sustainable building, which is a key barrier. It is important to provide a set of indicators and metrics based around easily adoptable standards that, where possible, would enable “like for like” comparison. The definition must be easily understood and communicated. There must be a clear presentation of how a building performs on key metrics. This will help decisions to be made which should deliver the most cost-effective improvements to buildings. A spider diagram5 could indicate what the regulatory minima will be over time for each of the key elements and demonstrate how the building performs in relation to each of these. It could expand indefinitely as new targets are added. Guidance and process tools designed to optimise the social, economic and wider environmental benefits associated with sustainable buildings could also be aligned to the Code, to ensure the best outcomes can be pursued, at key decision points throughout a building’s lifecycle. What buildings should the Code address?

The Code should cover both new and existing buildings and should cover the whole non-domestic building lifecycle, from planning, through construction to operation and finally demolition. The targets will need to be different according to the point that is being addressed in the value chain e.g. new build, lettings, sales, refurbishments, etc. Community-wide issues may be difficult to address within the Code, but it is essential that it interacts with planning. The Code should enhance rather than remove the relationship between communities and the buildings, especially when relating to district heat and

5 For a visual representation of this, see the Technical Issues chapter.


cooling networks, which is particularly important with regard to the business case and value of both new and existing developments. Should the Code be voluntary or mandatory?

The Code should be mandatory, in order to drive change. Many feel that the majority of stakeholders will not respond without a robust governmental requirement to comply. However, it is equally important that the Code sets out a regulatory escalator which would reliably indicate the future mandatory standards which will be adopted through other legislation such as the Building Regulations. This not only provides clear direction for the industry (enabling appropriate and future focused innovation) but also allows building owners and occupiers to demonstrate that their building is prepared for future regulatory requirements. There is value perceived in being able to say that a particular building is, for example, ten years “ahead of its time”. It should also have the ability to recognise and reward performance which is “beyond compliance”. Who should own and manage the Code?

Government should own the Code. It should be operated and managed by an independent third party stakeholder group. Robust and transparent governance structures must be put in place to ensure appropriate levels of engagement, technical rigour, non-partisan development, and constant evolution. It was agreed that the Code’s development and use needs to be clearly informed and reviewed regularly by a progressive industry group and other stakeholders that can provide practical feedback to Government6. In this respect there are lessons that can be learnt from the fora established to review implementation of the Code for Sustainable Homes, and from the Zero Carbon Hub, which is tasked with monitoring and addressing barriers to delivery against the zero carbon homes target. Government ownership is also important as it is felt that government can require the national collection of performance data (as recommended in UK-GBC task group report “Carbon Reductions in New Non-Domestic Buildings”) and that the data collected should be owned by a public body rather than be in the hands of a private entity. A few Consultees highlighted the need for the Government to lead by example – not just in terms of regulation, but in terms of procurement. We endorse the view expressed by the Sustainable Development Commission that it would be very desirable to build upon the public sector lead shown by English Partnerships and Housing Corporation (now the Homes and Communities Agency) on the Code for Sustainable Homes. We feel that the Office of Government Commerce’s efforts through its Public Sector Construction Clients’ Forum should be given added impetus. Education skills and training

Education, learning, development and training are all integral to the success of the Code. Many Consultees felt that there should be education and training across the industry to raise awareness of sustainability and that this was a key element to ensuring increased sustainability of buildings. We believe this should be extended to regulators, particularly

6 “The CSB should be industry-driven BUT endorsed by Government and referenced / required as part of the Planning or Building Control system. A CSB with multiple levels provides a valuable mechanism for signalling future policy changes.” Consultation Response


planning and building control officers. However, training is not an alternative to the roll out of binding sustainability obligations and many felt that there the industry will learn best by doing. It may also be worth having regional delivery mechanisms and partnerships as well as national ones, to ensure the successful implementation of the Code.


Policy Context

To determine the potential role of a Code, it is necessary to understand the existing policy and regulatory framework within which we plan, design, deliver and operate buildings, as well as consider likely future policy developments. This chapter presents a review of the current and future policy and regulatory context from a UK perspective and identifies some of the current conflicts between different regulations, policies and standards that can present barriers to those trying to achieve sustainable building. Finally, this chapter presents opinion on whether a Code for Sustainable Buildings, informed by progressive industry representatives, should influence future Government policy and targets or whether Government should lead and industry follow. UK POLICY AND REGULATORY CONTEXT

The Policy Context Working Group has developed a “Regulator and Policy Map” (Appendix 3 – Regulatory and Policy Map) which describes the key sustainability policies and legislation, tools and standards and government programmes currently applicable to the built environment in England and Wales. The Regulator and Policy Map differentiates between three types of instrument: regulation; voluntary tools or standards7 which can be required as a condition of development and have contractual force; and other Government programmes & initiatives. It concentrates on five principal environmental elements of sustainability particularly relevant to the built environment, namely carbon, energy, waste, water and biodiversity8 , is presented in accordance to the property value-chain and is split into six stages:

1. Planning and design 2. Project Procurement & Product Procurement 3. Construction 4. Operation 5. Refurbishment/Change of Use & Real Estate Transactions 6. End of life (demolition)

These are further broken down in the Technical Issues section. This chapter should be read in conjunction with the Regulatory and Policy Map (Appendix 3) International Context

The legislation, regulations, policy and guidance specific to non domestic property is developed against a broader global and European backdrop, particularly with regard to climate change. Globally, our diplomacy within the Kyoto Protocol negotiations and the G8 has influenced much of the recent climate related legislation in the UK, and we are only at the beginning of this process.

7 It is noted that the notion of ‘standards’ is very complex. These may be regulatory or voluntary and can be easily confused (for example regulations often include standards). This issue is further discussed in the Technical Issues chapter 8We have excluded from the Policy Map from scope social issues, transport, disabled access, amenity, health and safety and regulations focused on industrial emissions, discharges or waste management.


European Influence

The EU has already adopted a reasonable amount of regulation and policy on sustainability that is of relevance to the built environment. In December 2008, the EU Council of Ministers finalised the EU climate change package, including adoption of the target to reduce energy consumption by 20% by 2020 and to generate 20% of its energy from renewable sources by the same year. These targets will drive further legislative action across the EU and, in relation to energy efficiency in particular, there is recognition that progress to date has been insufficient. Some measures had already been developed by the EU before the 2008 Climate Change proposals. The Energy Performance of Buildings Directive (“the EPBD”) promotes the improvement of the energy performance of buildings within the EU and there are general environmental regulations which apply to the built environment as well as industrial operations, such as waste and trade effluent regulation. In addition, the EU is also updating its directive on energy using products (which is already applicable to large scale equipment such as boilers, but will be broadened to encompass many other energy using or energy saving products) and the related eco-design directives. This will affect fit out requirements for new buildings and refurbishments.

UK Regime

The Regulatory and Policy Map highlights that the key regulations which currently have most influence over the sector are: (a) the Town and Country Planning regime; and (b) the Building Regulations. In each case, their focus is primarily on new build, with relatively little policy as yet applicable to or explicitly aimed at improvements in the existing stock. There are also a great many voluntary or quasi voluntary standards, policies, codes and programmes (sometimes referred to as “soft law”), which may be legally binding in specific cases if they form conditions of a planning consent, or are wrapped into construction contracts or loan agreements. The Sustainable and Secure Buildings Act 2004 modified the Building Act 2000 to give Government wider powers to make regulations about reducing greenhouse gas emissions and these are likely to be exercised in coming amendments to the Building Regulations in England and Wales. There are also a number of UK statutes, passed at the end of 2008, which will have a significant impact on the sector over the next few years. These include the Energy Act (which includes provision for the Government to introduce a feed-in tariff for micro-generation); the Planning Act (which streamlines the planning approval process for infrastructure projects); and the Climate Change Act (which introduces climate budgets, public reports by a Climate Change Committee; a UK carbon trading scheme for non-energy intensive businesses; and an ambitious UK emissions reduction target of 26% by 2020 and 80% by 2050). Furthermore the “Strategy for Sustainable Construction”, a joint industry and Government initiative, is intended to provide clarity to business on the Government's position by bringing together diverse regulations and initiatives relating to sustainability. It also sets out specific commitments by industry and Government to take the sustainable construction agenda forward and provides a useful signpost for future regulation in some areas. It is important to note that until recently, all Building Regulations and even voluntary environmental or sustainability standards have been based on incremental improvements to standard practices. The introduction of the Government’s target for all new homes to be zero carbon from 2016 and the Government-owned Code for Sustainable Homes which sets


out the regulatory steps over time towards this target, have marked a departure from this – showing for the first time a destination (zero carbon) and the direction of travel to reach it (through step changes in Part L in 2010, 2013 and 2016).

Many have observed that there are elements of the Code for Sustainable Homes model should be replicated for the Code for Sustainable Buildings, as it established a level of certainty about the future

direction of regulation, resulting in a higher level of confidence in investing in research and development. This approach of setting a clear and ambitious trajectory for future regulation would encourage innovation but would also establish mandatory levels for compliance in relation to a range of sustainability elements over time. It was also thought that there is an important role for fiscal incentives to be introduced to encourage people to “go further, faster” beyond legal compliance, and to take on construction works and the innovation and investment into the required research and development for higher levels of the Code to be attained, before legally required to do so. MAIN CONFLICTS & BARRIERS WITHIN THE UK POLICY AND REGULATORY CONTEXT

Scattergun Approach

There are currently too many un-coordinated regulations, policies and demands impacting upon the development process, creating a disjointed, often confusing, and probably inefficient approach to achieving sustainable buildings. Over half of the Consultees regarded the proliferation of standards, diffuse legislation and the lack of consistency of approach in the way they are applied at a local and regional level, as the key “policy context” barrier to the development of sustainable buildings. Specifically it was felt that the lack of integration and alignment of requirements for achieving sustainable buildings within Planning, Building Regulations, Energy Performance Certification and the Code is critical9 10. Differing approaches taken by the planning departments of local authorities across the country also results in a lack of clarity and predictability that is problematic for the industry. However, it was recognised that differing priorities towards sustainability and the built environment are a necessary part of the planning system, since different parts of the country have different social, economic and environmental conditions.

9“At the local and regional level, the apparent fuzzy boundary between planning and building regulations does not serve the purpose of sustainability and so we think that the systems (planning and Building Regulations) should be streamlined and rationalised.” Consultation response (professional body) 10“There is a lack of consistency across Government, and the lengthy time lag in making regulation can result in an uneven playing field. There is also a lack of understanding generally of what zero carbon actually means. There is also an apparent disconnect between the planning system and building-level requirements.” Consultation response (trade association)


Consultees indicated that a Code should seek to overcome the above problems by providing a clear joined-up process at national level, and a cascade of regulatory and policy requirements applied in a consistent manner at local / regional levels reflecting and responding to best practice European standards and EU Directives (e.g. EPBD). Compliance with the Code would thereby demonstrate performance that is aligned to national building and planning legislation and regulation and European best practice. To achieve this, rather than introducing another new and additional standard, the Code must instead be a framework of regulatory, contractual and best practice elements, supported by the necessary tools and technical guidance (see Technical Issues chapter). It is essential that a Code should enable a seamless flow from legislation to delivery. To achieve this it should not be over-intellectualised but rather focused on ‘delivery and learning’ in order to achieve desired outcomes.

Lack of Uniform Approach to the Core Elements of Sustainability

Carbon and Energy Our regulatory mapping exercise identified, perhaps unsurprisingly, that the focus of sustainability related policy and regulation is currently almost exclusively focused on environmental impacts, and specifically on energy use and carbon emissions (both at national and international levels). This was also the conclusion of our Consultees.11 12 Biodiversity Historically there has also been much regulatory attention to biodiversity issues as a result of NGO action and a raft of EU directives and European Court decisions. This means that biodiversity is addressed at the planning stage, though subsequent enforcement of many obligations remains a weakness. The UK-GBC Biodiversity Task Group is reviewing available information, guidance and assessment methodologies and making recommendations for how the industry can come to better understand its impact on biodiversity through development. Water A clear area for future attention is water use. If the predictions of regional water scarcity and rising sea levels are correct, the need to manage the water footprint throughout a building’s life and to address flood risk at the development stage will become increasingly important. There is very little currently in place on this topic and it has been an area of weakness within the Building Regulations, although work to address this is underway13. In addition, the Consultation responses noted that there is no uniform approach to environmental sustainability issues across sectors such as housing, education and health or between regions, and that this “causes further confusion in the industry”14. Lack of clarity

11“In our opinion most of the UK’s recent standards, policies and legislation governing sustainable buildings appear to be concerned with short-term targets and, in particular, reducing the operational energy of buildings. … Whilst this narrow focused approach to improve operational energy may have been acceptable as a first attempt at developing more sustainable buildings we consider there is now a need to develop more sophisticated models.” Consultation response (University) 12“… However, most of these policies focus on carbon, energy and climate change. More holistic sustainability policy is required at national, European and international levels. Without these, there are fewer drivers for other environmental and socio-economic improvements.” Consultation response (architect) 13 Amendment of Part G is expected soon, also Strategic Forum for Construction is undertaking work in this area 14 Consultation response (Trade association)


as to what “zero carbon” means15 16, and even what a sustainable building actually is17 was considered by many Consultees to be a barrier to the development of sustainable buildings. Through the work of the Policy Context Working Group, it was noted there are elements of sustainability around which we do have relatively strong consensus about their incorporation into the Code from the outset. These include: energy use, carbon emissions, water management, and waste minimisation/resource efficiency. Clearly there are many other key considerations of sustainable development that would need to be considered over time (see Technical Issues chapter). Regulatory responsibilities

The regulatory responsibilities in respect of the built environment are unusually fragmented, each arguably continuing to reinvent the same wheel. A range of different Government departments are responsible for developing and implementing different elements of sustainability law and policy, many quangos are working on soft law proposals, and local authorities may then develop their own approach. This disparity is creating stakeholder confusion and hindering progress in the delivery of sustainable buildings. Conflicting Standards & Calculation Methods

As highlighted above, numerous concerns were raised regarding the proliferation of regulations, tools, calculations methods and software which can result in conflicting calculators, measures and claims. In particular, some commentators believe that BREEAM is overly subjective – certainly the lack of clarity about what constitutes “reasonable” can be an issue with this standard, as indeed it can with the Building Regulations. There is also a concern about having different calculating engines (e.g. SBEM, IES etc). However our view is that such issues are inevitable at this point in the evolution of the policy area, and they will get addressed by the relevant bodies over time. The role of the Code should not be to focus on micro management of these tools, but rather to try to create a structure that permits the core regulations and standards to be applied consistently and improved in a predictable and ordered way. As such there would be calculation methods that would be “Code approved”. Lack of Regulation of Existing Stock & Incentive for Refurbishment

It was apparent from our review of the current regulatory regime that most regulation concentrates only, or primarily, on the planning and construction phases of buildings with relatively little directly applicable to existing stock/refurbishment. Building Regulations are applicable whenever building works are proposed, including alteration and extension works on existing buildings, however there is very little regulation that is currently applicable to encourage a sustainable approach beyond consideration of energy performance upon refurbishment. For example, the Building Regulations do not encourage refurbishment (they only apply once people elect to carry out building works).

15 “A single, pragmatic definition of zero carbon is urgently required in order to enable value chain participants to mobilise themselves in a clear direction and provide certainty within the supply chain.” Consultation response (Energy Supplier) 16 It is noted that the Government published a consultation on 17 December 2008 on the definition of zero carbon homes and non-domestic buildings that proposes a definition of zero carbon new homes, based on high energy efficiency, on- or near-site carbon reduction, and allowable solutions for dealing with the remaining emissions. The paper also sets out current Government thinking on zero carbon new non-domestic buildings. The consultation runs until 18 March 2009. 17 “The profusion of sustainability metrics is a clear barrier to the take up of sustainable design.” Consultation response (Professional body)


As a result, it was suggested that the introduction of fiscal measures to encourage sustainable retrofitting and support a move to focus on the whole life of the building rather than simply the design and construction stages would be beneficial. We share our Consultees’ view that it is “very important that the whole lifecycle of the building is considered in terms of sustainability when the Code for Sustainable Buildings is being formulated.”18 They recommended that there should be increased focus on the energy performance of the building in use as “although a building in itself can be sustainable and receive a good Energy Performance Certificate on construction, sale or let, the energy use within it can be influenced massively by poor user control.”19 20 There were various recommendations for managing energy use such as smart-metering and legal agreements between landlords and tenants that might, for example, remove energy costs from the service charge. It is likely that, for larger scale energy consumers at least, the introduction of the Carbon Reduction Commitment will create a policy and economic driver for such changes and the impact that this will have on landlord: tenant relationships will almost certainly change the way that leases are structured as they relate to energy use and payment. Unintended Consequences

There are sometimes tensions between policies and guidance aimed at improving energy efficiency and the installation of renewable energy systems, as there is a common perception that a project budget often cannot support both. The outcome is usually in favour of the installation of renewable energy systems a requirement to secure planning. However, the result of this may be a reduction in the overall energy efficiency of the building. One respondent even felt that the “focus on zero carbon is acting as a barrier to sustainable development.”21 A number of developers and occupiers have commented in particular that the application of the Merton Rule, under which new developments are typically required to include a minimum amount of on-site renewable energy, arguably does not allow sufficient flexibility to optimise carbon emissions reductions or enable sustainable development within the limits of practicality. The Planning and Climate Change Supplement to Planning Policy Statement 122 introduces a “Merton Plus”23 approach that should help alleviate these problems by calling for an evidence-based understanding of the local feasibility and potential for renewable and low-carbon technologies, including microgeneration, to supply new development in their area (and encourages local authorities to promote an approach that is consistent with the energy elements of the Code for Sustainable homes where applicable). As suggested by the UK-GBC task group report “Carbon Reductions in New Non-Domestic Buildings”24, there is a need for all local authorities to collate renewable energy potential in the area and offer these as potential solutions enabling developers to link between sites and develop low carbon energy networks.

18 Consultation response (Property consultant) 19 Consultation response (Energy supplier) 20 “The code for sustainable homes fails to recognise that reducing building carbon emissions is not all about building regulations. As well as building-specific legislation (i.e. bricks and mortar), there is a need to legislate to reduce electrical demand (through appliance and equipment legislation) and also to decarbonise the electrical supply (which should involve a network-wide approach not just building-integrated issues).” Consultation response (University) 21 Consultation response (Engineering Consultancy) 22 http://www.communities.gov.uk/documents/planningandbuilding/pdf/ppsclimatechange.pdf 23 See Appendix 3 for further detail 24 December 2007


Some Consultees felt that the trend in pump-priming the market for renewable energy systems should be balanced against more appropriate cost effective improvements to buildings (façade/ fabric/ systems performance). The Code should seek to address this. In addition, Consultees noted that many policies do not reward off-site renewable energy generation, which will be an important way to achieve the target for new buildings to become zero carbon by 2019. On-site renewables, in many cases, may not be the most practical or the most efficient solution, and therefore the Code should allow the flexibility to invest in renewable technologies in the most advantageous manner in line with the spirit of the Planning Policy Statement on Climate Change. It may be necessary to provide for the ability to offset the renewables commitment outside of the boundaries of the relevant authority and possibly outside of the applicant’s own estate (for example, down its supply chain). This may be sensible provided that there are mechanisms which ensure auditing of performance, enable enforcement and measures in place to prevent double-counting. These are all matters which are likely to be reviewed in the context of the current CLG consultation on the Definition of Zero Carbon. Finally, a matter which requires further consideration is the concern expressed by many that a Code-based approach itself can sometimes be associated with a ‘box-ticking’ exercise which may potentially lead to ‘unintended’ and ‘perverse outcomes’. Careful thought needs to be given to how the development and implementation of a Code could avoid falling into this trap.

Carrots and sticks

There is scope for far greater use of incentives and penalties. A materials manufacturer suggested that “we [should] incentivise all stakeholders via fiscal measures, grant schemes and legislation (carrot and stick) to move as fast as possible in the right direction.”25 This was a commonly held view, with a sense that there could be a greater role for fiscal measures, for example, by extending Enhanced Capital Allowances for low carbon technologies used in the procurement, construction and refurbishment of buildings26. Another way of providing significant incentives for sustainable buildings is for Government to use its considerable leverage as a client, and to require higher standards for the procurement of all public sector buildings. While self-imposed Government policies exist (in theory all new government buildings should achieve a BREEAM Excellent rating), implementation and enforcement of these rules are poor. Wider and more systematic application would demonstrate a clear lead, and importantly provide incentives for industry to invest in higher standards, and bring about reductions in cost through economies of scale. Enforcement

Many respondents to the Consultation considered that lack of enforcement of regulations hindered progress towards sustainability in the built environment. It was highlighted that the Code would need, to be mandatory and strongly enforced by well trained Government officials in order to be truly successful in meetings its purpose.

25 Consultation response (Materials Manufacturer) 26 Consultation response (Property Consultant)


Skills Gap

Consultees identified that the “skills gap”27 that is currently a barrier to delivering sustainable buildings and would also be a barrier to the successful implementation of the Code unless education is initiated for both the private and public sector. Some Consultees commented that local authorities sometimes lack the skills and capacity required to set appropriate technical targets and critically evaluate individual submissions, and lack the resources to commission expert help when and where they need it. Given the speed of change in relation to this area, this is hardly surprising. Roles and responsibilities need to be more streamlined at national, regional and local level and much better training and support is required for those required to implement policy and regulation if they are to develop a more consistent approach to these issues. Evolving Requirements

There is a clear need to “future proof” any building constructed from now onwards. Whatever one’s view of the regulatory requirements now in place, given the changes in climate forecast over the next decades and emissions reductions that will be required during this period, further ratcheting of sustainability requirements is inevitable. Additionally, there are likely to be increasing expectations and challenges from the public on corporate social responsibility.

Overall, the regulatory regime applicable to the sustainability of buildings is currently a confusing space. “Soft law” is often ambitious, but can suffer from being worded ambiguously or permissively, rather than setting clear requirements. Many Consultees reported confusion about the “soft law” initiatives, in terms of the multiplicity of schemes, what they required and lack of consistency in how they are applied contractually. Accordingly, the current regulatory system will have to change. Indeed, our untidy regulatory landscape, the Government’s White paper on a Strategy for Sustainable Construction and recent Opposition Party policy statements illustrate that change has already started and there is a political consensus for it to continue well into the future. What is needed now is a framework to bring more order to the mix of existing regulation and soft law, to reduce overlaps, conflicts and unintended consequences and to address any gaps. It is proposed that a Code for Sustainable Buildings is essential, and a core part of that framework. Formal regulation is sometimes couched in general, potentially ambiguous terms, and there appear to be significant variations in interpretation and enforcement between different agencies and geographies. To date, the Government’s focus has been on dwellings rather than commercial or industrial buildings and it should be noted that Government’s record of implementing its own, self-imposed, sustainability standards for public procurement has been, at best, patchy. Overall, the area is difficult to navigate, and this is made worse by the speed of change in external policy drivers. There appears to be ambivalence and lack of clarity on the part of both legislators and the industry about clear sustainability requirements. Despite the stretching 2020 targets for energy reduction and carbon abatement, and the UK Government’s declared zero carbon trajectory and existing regulatory requirements are both relatively modest and often poorly enforced, and the industry driven standards are typically also conservatively expressed. This

27 “Mind the Skills Gap: The skills we need for sustainable communities”, Academy for Sustainable Communities Report


current approach will not deliver the requisite reductions in emissions and wider sustainability impacts and a clearer framework is urgently needed, which is something that the Code could provide. Recommendations from Policy Group

A Unifying Mechanism There is a need for a Code to act as a “unifying mechanism”28 to bring together the various legislation and policy requirements that currently apply to buildings. Many of our Consultees commented that the relationship between the Code and current and future the Building Regulations will be critical. At any point in time the Regulations need to reflect the Code’s minimum performance requirements, with amendments to the Building Regulations helping to reduce duplication and policy disconnects over time. The Code should set out the future trajectory of regulations and government policy, to provide a guide for projects that seek to achieve standards beyond the minimum requirement. The trajectories for improving carbon emissions performance represent one of the most important elements in such a Code. However, similar trajectories need to be set out for a range of other sustainability parameters, and phases in the building lifecycle, with as much emphasis on in-use performance of buildings as the design and construction phases. Approach to Sustainability The Code should focus not only on carbon and energy use, but on a broader set of environmental issues (this is expanded further in subsequent chapters) including on waste and water use. We see a current policy gap as regards water use29. New Build & Existing Stock The Code should include provisions addressing all stages of the construction and property lifecycle and in particular address the current barriers in dealing with the operational life of a building, and should encourage and drive the appropriate refurbishment of existing buildings. This is further discussed in subsequent chapters. Policy Escalator The Code should specify minimum performance criteria to achieve base compliance, (i.e. the Building Regulations and other legal requirements) which would be mandatory, and also set out a stretching set of milestones and targets that would constitute improved performance30. In this way it should enable Government to set out a regulatory trajectory into the future as it has done with the Code for Sustainable Homes which establishes progressive, bold policy and regulation that stimulates business innovation. It was agreed that the Code should incorporate current targets, with amendments to the Building Regulations helping to reduce duplication and disconnection in policy over time. It should also have the ability to recognise and reward performance beyond compliance. It would be necessary to ensure that the Code was kept under review to take account of the fast changing sustainability landscape and to help “prepare the industry for increasingly stringent requirements”.31 Accordingly the performance levels would be fixed for a limited period of years, with the expectation that additional levels would be introduced at regular

28 Consultation response (Design and Consultancy) 29 Although as noted above, work to address this is underway 30 “The [Code] must strive to reconcile and, where necessary, change these [i.e. the separate standards and codes of the various different disciplines in the building industry] to make a collaborative cross-disciplinary approach possible.” Consultation response (Architect) 31 Consultation response (Sustainability/Building Services Consultants)


intervals, reflecting developments in technology, climate and sustainability policy and sector knowhow. Portal to Share Information Feedback loops, in terms of dissemination of knowledge are fundamental and mandatory disclosure of certain metrics in the public domain would facilitate this process. The Code itself, its development principles/detail, any assessment criteria, guidance and anonymous data should be a public good. Enforcement The Code would need, not only to be mandatory in terms of implementation, but also strongly enforced by Government and trained officials in order to be truly successful in meetings its purpose.


Value & Business Case

INTRODUCTION

This chapter examines the issues around demonstrating value in sustainable building, and how a Code could assist in proving the business case. Valuers, investors and occupiers need to be able to attribute a value to sustainability in order to choose to occupy/develop/invest in sustainable buildings. In particular, many require a clear “financial value” to be demonstrated. There is a perception that there is a strong value proposition for sustainable buildings, however, a review of the research carried out to date shows that there is currently a lack of hard evidence to back this up, especially in the UK. Describing and providing proof for the business case for sustainable buildings is a gap that the Code must fill in order to drive change within the industry. Clear indicators showing the differences between one building and another will help to provide the clarity required for people to begin to identify the worth of different metrics and hence begin to place a value on sustainability features. There are a number of other barriers which must also be overcome, including confusion about the definition of sustainability as it relates to value and the lack of available data for benchmarking and comparability. The way in which the proposed Code can help to overcome these barriers is discussed below. A literature review of relevant research reports, conference papers and official publications was undertaken to help members of the Working Group better understand the key issues surrounding sustainable property development/occupation and the benefits that such a strategy may have from a business case stand point. A summary of the documents reviewed is attached at Appendix 2 – Value Literature Review.

WHAT IS THE VALUE PROPOSITION FOR SUSTAINABLE BUILDINGS?

Cost Savings

The literature review suggested that there are cost savings accessible to those that employ sustainable strategies. Sustainable buildings are designed to be more resource efficient. Reduced use of resources should have a positive impact on a company’s cost base over time. In the case of energy, the introduction of EPCs and DECs should help to provide further evidence to demonstrate the link between energy performance and value. There remains, however, a lack of firm consensus on the exact ratio between capital cost outlays and potential cost savings and often the full range of benefits from a sustainable solution are not fully explored or explained. This is not surprising given the breadth of sustainability issues and the huge variety of structures in our built environment. Cost as a Barrier

Even at the height of the boom market, the price of sustainability was an issue, as the cost savings arising out of energy efficiencies were typically ignored as too small, or requiring too long a payback period. One respondent argued that “current asset values [are] not enhanced by lower running costs of buildings and enhanced environmental and social benefits”.32 However, the EPC Regulations and the current economic difficulties may change this. A number of major businesses are mapping carbon reduction projects using an

32Consultation response (Construction, Housing, Property Care and Investment business)


approach broadly consistent with the Vattenfall:McKinsey Cost Curve33 in order to identify and implement projects (such as energy efficiency retrofits) which are accretive or can be done at least cost. This is consistent with comments from our Consultees that information on the “sustainability payback” should be clarified and made available for each sector. Other value drivers

Other value drivers are increasingly discussed in the industry. These include: increased asset values; higher rents; lower void rates; reduced risk of obsolescence/future proofing; improved workplace productivity; improved staff retention; improved user health/wellbeing; improved corporate image. Some of these are currently difficult to express in financial terms. To do so, we need to monitor and measure existing buildings within a common framework (and then relate them to new buildings). Some areas will be easier to measure than others. However, techniques for measuring the more complex issues are becoming more advanced. For example, measuring the productivity of individuals as well as organisations is starting to be linked directly to sustainability strategies within the working environment. These in turn can have a quantifiable impact upon employee recruitment and retention, an increasing concern in the modern business world. Several studies refer to this issue as being key to unlocking additional capital. Brand improvement related directly to sustainable occupational policies can add further business value. As a result, these are issues that would build the business case for taking a sustainable building, in turn leading to recognition of the value associated. Other drivers

Financial drivers both short and long term are clearly powerful, but they are not the only drivers that support the creation of sustainable buildings. For example, the government may choose to push the development of sustainable buildings in order to meet international reductions for greenhouse gasses. Government would see value in the reduction of carbon emissions, or reduced strain on municipal or local services. Additionally, the sustainability agenda helps to grow the economy and with this comes job creation. The Working Group has concluded that making the advantages of sustainable buildings clear will help to drive decision making and hence have an impact on the values attributed to sustainability features. When it is clear what the advantages are, this will be reflected in financial analyses and the way that buildings are appraised – in turn moving forward the sustainability agenda. As the market better understands sustainability there will be a strong push coming from clients and the public to improve energy performance and make buildings more sustainable. BARRIERS TO DEMONSTRATING VALUE

The importance of a definition

The lack of clear definition of a sustainable building is highlighted as a key barrier to demonstrating value. This chapter does not deal with the technical issues inherent in defining a sustainable building (see Technical Issues chapter) but examines how one can define a sustainable building in a way that makes sense financially.

33 A cost curve for greenhouse gas reduction, The McKinsey Quarterly 2007, Number 1.


In response to this challenge of setting a definition of a “sustainable building” which permits people to attribute a financial value to it, a series of principles were derived from the Consultation and are recommended by the Working Group:-

1. The definition should be clear and simple with measurable quantitative factors, underpinned by empirical evidence;

2. The definition needs to address a scope that is wider than carbon reduction; 3. The definition of sustainable buildings must cover new build and existing buildings 4. The Code should be able to focus on Outputs and Outcomes 5. The Code must recognise that sustainability performance standards will improve,

and therefore, any agreed definition of what makes a “sustainable building” will change over time.

Clear and simple definition Sustainability is a word that is often over-used and misunderstood, which is a barrier to the industry making sense of it financially. To make sense financially, the definition of a sustainable building should primarily be based on standard quantitative measures supported by empirical evidence. The host of interested parties currently all have varying perceptions of what a sustainable building is. The definition should be clear and simple and based on readily available data. It is important to provide a universal model, a set of indicators and metrics based around easily adoptable standards, that where possible would enable like for like comparison across sectors and markets. The structure of the development industry calls for a simple final form. There are very simple buildings (e.g. industrial applications), and there are non-professional end users of buildings, and for these a straightforward form of a Code is needed. When decision makers are presented with clear and reliable information, they can begin to make choices (which may differ depending on their priorities) based on this which in turn affects the worth that they attribute to the property. While we are unable to measure the investment performance of more sustainable property against less sustainable property it remains difficult to develop a clear business case for sustainable (or socially responsible) property investment34. For sake of a clear definition, should we make “carbon” a “proxy” for all other sustainability impacts? Carbon has become the proxy for many forms of environmental externalities. The market has an understanding of what carbon means even though it represents only one part of the much wider dialogue on climate change, environmental impacts and of course sustainable development. Having clear, understandable, targets is important if the property industry is to grasp the framework. However, the Working Group concluded that it would be too narrow to limit the Code to carbon or carbon proxies because: (a) the issue of sustainability is far larger than just carbon emissions; and (b) when considering “value” related issues, potential benefits related to user comfort and productivity could be ignored. Should the same definition of a sustainable building apply to both existing & new stock? In order for the market to work effectively and in order to drive the changes that are required in the construction and property industry, the Code must apply to both new build

34 IPF has commissioned IPD to complete the first stage of a programme of work aiming to develop an index which would fill this significant gap in the investment management tool-kit.


and existing buildings. Building on this, not only should the framework deal with the asset itself, but also the way that it is operated in order for value to be recognised by the tenants and the owners of the buildings. Furthermore, if the Code covers only new buildings, this could potentially create a market in which, for example, large corporate occupiers with strong sustainability commitments will only occupy new stock that falls within the “system”; or in which occupiers in older buildings are more disadvantaged than those in new buildings. Comparability between all buildings, on an even playing field, is important. Outputs and outcomes Both outputs and the related outcomes should be recognised by the definition of a sustainable building. The output is a building performance e.g. Air Tightness. The outcome of Air Tightness can be a reduction in running costs and lower UK carbon emissions. If the all those within the value chain (landlord, tenant, investor, etc) can see the link between the outputs and the outcomes i.e. operational performance versus how a building is supposed to perform, this will educate and instigate change. In turn, this will assist in attributing financial benefits to sustainability aspects. An evolving definition As noted above, statutory and voluntary standards relating to sustainability performance will alter over time. The definitions in the Code and the associated incentives used to motivate change will both need to be capable of evolving over time in order to drive progressive improvement but will also need to show a clear trajectory of where legislation is going. This is important to ensure commitment to change and to show the value of innovating “ahead of the curve”. This is further discussed in Operational Issues chapter. Communicating the definition It is not sufficient to simply “define” a sustainable building, that definition must be easily understood and communicated. Based on the above, a breakdown showing key information is thought to be valuable to help stakeholders recognise where “risks” lie and where improvements can be made. As opposed to a property just being labelled (eg, a “B” or “C” rating), a clear presentation needs to be given on how it performs relating to a range of key metrics e.g. energy, carbon, waste, water. For a visiual representation of this, see the Technical Issues chapter. This will then help decisions to be made which should, in turn deliver the most cost-effective improvements to buildings which will in turn, drive value. Availability of data

The overriding observation from the research carried out is that there is a lack of empirical data available on the UK property market. Studies focused on overseas markets, such North America and Australasia, are considerably more detailed. There is very little data on the UK market and it is inevitably problematic to use data from overseas markets to formulate conclusions which directly apply to the UK model. The shortage of UK research means that drawing on hard evidence to demonstrate a “value added” element from sustainable construction in the UK is inconclusive. While some of the conclusions from the overseas markets are portable in principle other factors such as legislation and traditional leasing practices vary considerably from one region to another. Hard data applicable to the UK is not available: While organisations such as the OPD (Occupiers Property Databank) are using their existing datasets to enable better assessment of occupier’s energy consumption and the overall efficiency of the buildings they inhabit, these databases are far from comprehensive and due to the relatively recent barrage of legislation, lack a true historical context. A number of reports found that utilities savings alone can often balance the extra cost of construction, however it is noted that based on


research undertaken in the UK to date, this statement cannot necessarily be applied in the UK. The key issue in this regard is that there is no link at the minute between the costs saved by a future occupier and the price received by a developer for the building. The market is complex in this regard and it is very difficult to incentivise a developer who is selling on buildings immediately, who sees no value in building in a more sustainable manner. The same applies to many landlords regarding operational improvements where there are no benefits perceived by them. Data in the market would help to change peoples decision making and hence there would likely be a modal shift in requirements, in the way that buildings are operated, built, and in landlord / tenant relationships. In turn, this will filter through to the value attributed to sustainability features. Building energy performance data is not consistent or readily available: As noted in the UK-GBC Carbon Reductions in Non Domestic Buildings Report, data on building energy performance needs to be universally tracked and data made publicly available in order to fully understand sustainable performance/ costs and thus accurate life cycle costing in order to calculate payback periods35. Measurement needs to be able to distinguish between the energy related to the operation of the building and the activities of the occupier(s). PROVING THE VALUE PROPOSITION

Valuations and transacted values The clearest way to demonstrate value in sustainable buildings is to show that the market will place a premium on sustainable buildings and/or will place a lower value on less sustainable buildings. The much talked about “Vicious Circle of Blame”36 has meant that very few of the key property stakeholders want to accept full financial responsibility for the perceived short term and long term risks associated with developing sustainable buildings, in particular in relation to innovative (untested) products, materials and processes. However, if sustainable building is ever to become mainstream (other than when mandated by regulation) then the market needs to recognise that there is additional value in it. When value is demonstrated and widely accepted, the financial value of less sustainable properties will be discounted thus further differentiating the market. Valuers reflect the decisions made in the market and the activity that is occurring at the time. If they are to reflect sustainability elements in their valuations, it requires property stakeholders to attribute a worth to sustainability elements. This will only happen when clear information on sustainability attributes is available so that people can begin to make decisions based on clear facts that are understood and when compliance becomes an issue. Whole Life Costing /Life Cycle Costing (WLC/LCC) The importance of WLC/LCC in supporting the value proposition was highlighted both in the literature review and in the Consultation. Work in this area was cited as important to align objectives of developers, owners and tenants and the future adaptability of buildings. To promote the uptake of sustainable techniques or upgrades it is critical for developers, landlords, investors, tenants and facilities managers to be able to: (a) attribute costs and financial benefits; (b) understand how those costs and benefits apply over time, and be able to evaluate alternatives on a comparable basis across the project life cycle; and (c) understand the basis of those comparisons.

35 Also freely available data would enable people to see what works and what does not work so informing future designers. 36 eg“Breaking the Vicious Circle of Blame – Making the Business Case for Sustainable Buildings” RICS, 2008


Life Cycle Costing (sometimes referred to as Whole Life Costing) provides a basis for comparing different approaches in terms of their likely costs and benefits over the project life cycle. There is now an international standard for Life Cycle Costing37 and, in the UK, an agreed method that supports this standard38. In addition, there is a common European methodology for Life Cycle Costing with a particular emphasis on sustainable construction39. Life Cycle Costing is increasingly becoming widely used in construction and property investment decision making. There is also a growing body of data on the life expectancies and performance characteristics of buildings and their constituent components. This data, and the analysis methods available, will support clients and decision makers in considering all costs and benefits associated with the design, construction, operation and disposal of their buildings. A further issue is that in the UK, it is very rare that all costs associated with the lifecycle of a building are channelled through the same profit centre. VALUATION PROCESS

In order to develop and refurbish buildings, a source of finance must be secured. Finance is gained based on valuations of properties. Valuers rely on proven value, which looks back at what is already known. Sustainability is a relatively new (but much overused and misunderstood) term. Its lack of proven track record and a lack of clarity over what it means is a barrier to it being considered and included in valuations. It is clear to the Working Group that at present sustainability is not being adequately considered in the valuation process and it was felt that “The Code will be able to achieve industry recognition if it impacts on the valuation of a building” Accurately and comprehensively informing valuers and the valuation community is paramount to the success of any sustainable building strategy in the UK. It was clear from the Working Group’s research that:

1. The valuation community still does not have the tools at its disposal to fully engage in the sustainability debate and thus enable them to attribute value to any elements of sustainability within their valuations.

2. Accounting practices address the requirements of many stakeholders and rely on widely used standards with regards to rates of depreciation or cycles of replacement for clarity and consistency of reporting. However, the assumptions behind standard rates of depreciation for built assets do not not reflect the potential longevity of sustainable buildings, and as a result, not only will a owner take a bigger charge on their profit and loss account to account for depreciation, but the asset will also sit on the balance sheet for a shorter period. Similar issues are faced with replacement cost accounting policies where a higher than necessary charge may result from an inability to recognise reduced replacement costs.

3. Valuers need to be informed on some of the key advantages of a sustainable construction strategy. These include longer lifespan of fabric, plant machinery etc., reduced replacement costs and lower operating costs with the potential advantages to all interested parties. Sustainable elements of a building’s fabric need to be included in the valuation process but that is highly dependent upon legislation and availability of hard data.

4. There is difficulty in the valuation of “less tangible, softer elements”.

37 ISO 15686-5: 2008. Buildings and constructed assets -- Service-life planning -- Part 5: Life-cycle costing 38 BSI and BCIS: Standardized Method of Life Cycle Costing for Construction Procurement, 2008 39 Life Cycle Costing (LCC) as a contribution to sustainable construction: a common methodology, 2007


As the RICS “Consultation Draft Valuation Information Paper”40 points out, “Whilst the role of the valuer is to reflect the behaviour of markets…. what is required is to consider the factors that will or will not ‘future-proof’ the property in terms of its ongoing demand and reflect these through the valuation.” Central to the operation of the definition of a sustainable building is the need for an explicit link via the Red Book (RICS Valuation Standards book which contains mandatory rules, best practice guidance and related commentary for all RICS members undertaking asset valuations). The Working Group felt that there was a central role for the RICS in this respect. The quality of information and its availability were seen as important to establishing value and market pricing of sustainability. Clear indicators on performance are important, for example, it was suggested that DECs should be rolled out immediately and the information kept on a publicly accessible online platform, but the use of the building must be made clear (a LESTER type solution) as it is well understood that similar buildings can perform differently dependant on the tenant. HOW CAN THE CODE HELP?

Regulatory escalator

The Code should set future standards, road map and a timeline to help industry respond, drive innovation, and plan ahead. For industry to have confidence in the future value of investment in sustainable buildings, there must be confidence not only in the robustness of the Code, but also in enforcement of compliance. Government is identified as the most appropriate promoter, enabler and enforcer of transition towards sustainability in the built environment. Consultees indicated that alignment with fiscal incentives and ensuring the definition formed part of building control were both fundamental to the value proposition. As such, metrics should be suitable for linking with statutory standards and fiscal incentives/disincentives to change. In setting standards, etc, it was agreed that they would need to be developed with detailed industry involvement and endorsement to ensure industry were engaged and would, in turn, facilitate the development of new products and supply chains, and also to make sure that the outcomes were aligned with the market drivers. Mandated Targets

The general consensus was that voluntary codes could help to raise the benchmark for sustainable buildings, but widespread take-up across key sectors would require a mandated Code. However, in doing this, any goals or targets mandated need to be timetabled and introduced on a stepped basis to enable:

Industry to prepare for change Industry to innovate (which also means that the targets should be outcomes focused

rather than prescribing how you would achieve these targets) Lessons learned from initial interventions can be utilised to shape the Code over

time Scope of sustainability metrics to expand over time

The Working Group concluded that there could be additional, innovative value, derived from a mandated Code as industry may try to achieve the Code in different ways and discover better solutions that could yield significantly improved results. A Code should have the ability to be both ‘standard’ for the mass market and flexible enough to enable competition

40 RICS 2009


and flexibility for the market leaders. A particular Consultation response highlighted that “the innovators must be allowed to innovate freely in order to achieve the rapid advances required of the industry; mechanisms must then be in place to capture the lessons learned and feed the most successful approaches back to the mass market”. The market leaders could strive to achieve future targets before they are mandated. Besides the innovation angle, this feature in a Code would also continue to support the marketing / competition angle currently driving the sustainability agenda in commercial property. The “I’m greener than you…” angle would keep the Code from becoming just another regulation, maintaining the cutting-edge, ‘glossy’ feel that sustainable development currently has and supporting the momentum needed to create real, industry-shifting, change in management of the built environment. There is a danger that a mandated Code could commoditise what a green building is, but the overall conclusion has been that the potential benefits outweigh this negative possibility with targets as opposed to strict guidance also helping to counter this. Associated incentives

Incentivisation was deemed to be an appropriate method by which to deliver industry change. If the Code had different achievement levels, e.g. future targets which will become mandated, it was suggested that incentivisation could be carried out through the tax system, with those achieving better results paying less tax, in some form. Some Consultation responses advocated the use of data within EPCs as an evidence base. A label

In discussing the need for a simple structure and user-friendly ‘label’ to support the practical roll-out of the Code across both the complex building industry and as a sales tool for the end user, the analogy of a new car tag was particularly apt. Every new car carries the same set list of indicators, which are more complex than a simple A or B, but as a car buyer they enable comparison on a standard range of choices. To take this analogy a stage further, it is noted that there are a number of financial incentives (Car Tax, Company Car Tax) which are designed to encourage the take up of lower emissions cars as well as innovation amongst manufacturers. Political lead

An issue that is evidently of some importance is the need for the provision of a government lead, particularly with respect to using public procurement as a lever to stimulate the adoption of sustainable practices,. However, if this does not go hand in hand with increased availability of information then political will alone may not be enough to convince the majority of property concerns to embrace sustainable practices above and beyond the bare minimum in order to comply with said legislation. Building regulations in different countries vary widely and are likely to impact upon sustainable benchmarks. Comparability and Benchmarking

In order to ensure that value can be demonstrated in sustainable buildings, stakeholders must be able to compare buildings (within the different building types & uses) to allow all parties (valuers, investors, occupiers, corporate decisions makers, etc) to have an understanding of comparative building performance and therefore gain an understanding around where value can be derived. Benchmarking and creating metrics for measuring sustainability are therefore critical to the development and implementation of the Code. Furthermore, benchmarking enables an understanding of how building performance may be


enhanced and also identifying where any particular property sits within the spectrum of sustainable buildings. The key point is that it should not just be sustainability or technical experts that understand the outputs and vision but also the layman. If this does not occur, compliance will become the key driver, which is acceptable to a point but does not help the market to derive value. In order for there to be this understanding, the system must be transparent, simple and clear to ensure that it is trusted by all and as a result helps to engender change. Having clear measures, targets and education around the purpose of the Code is also important in relation to transparency. Making it clear to all what the goals are is important to ensure that the Code is fully embraced by the industry. Having accessible data on buildings is important if valuable comparisons are to be drawn. One key point in this regard is that this data needs to be provided on a consistent basis if it is to be trusted. This is another reason why specifying core areas that can easily be measured would be a good starting point for the Code. If there is clear, accessible data, it is easier for stakeholders to take sustainability performance into account. Included within this could be financial comparisons, although it is recognised that this is unlikely to be easy to mandate and in reality, if the metrics are shown, stakeholders can then deduce their own financial conclusions. The Code should help to drive the collection and collation of data regarding the performance of buildings. ‘Unintended Consequences’

The Value Working Group also considered the need to avoid “unintended consequences” and how that applies when considering the value proposition. To avoid the unintended consequences, a logical assessment of the impact of the Code for Sustainable Buildings is required. The consequences fall in to two categories: 1. Those that pertain to the existence of the Code – immediate consequences 2. Those that pertain to the implementation of it – side effects Immediate Consequences In order to successfully unpack this category we need to consider some simple questions with complicated answers:

What is a building? Who owns it? What are its owner’s primary objectives?

The answers to these questions vary enormously and, direct impacts of the Code aside, the Business Case can be effected – fundamentally because ‘business’ can be quite diverse in its own right. The table below explores examples. Examples of buildings, owners and their primary objective Building Type Owner Objective Office Property company Return on investment Synagogue Faith organisation Gathering of people School Local Authority Develop children Art gallery Trust Exhibit works Campsite Toilet Block Campsite operator Ablutions Newsprint factory Newspaper Printing Power station Utility company Generation of electricity


Barn Farmer Keep straw dry In order to avoid unintended consequences, the definition of a building needs to be thought out properly. Subsequent to that, the details of the Code need to be ‘tested’ on the building types scoped in to avoid problems with implementation. It can easily be seen as well from these examples that the value drivers will vary considerably between the different uses and building types. This must not be forgotten and is another very good reason for breaking down the individual sustainability indicators and showing each impact separately. Side Effects Side effects are much more difficult to predict and are often born out of a testing phase. There are two categories of side effects: Technical: likely to include things whereby certain performance criteria are expensive, irrelevant or impossible in the context of certain types of building. For example, if the thermal performance of walls or perhaps the air-tightness of existing buildings is a feature of the Code with nominated performance standards, the effects this would have on the buildings listed in Table 1 would vary widely in their drama and applicability. Behavioural: would involve human reaction to the implementation of the Code. All areas of the Code would be subject to this but probably the best illustration would be around the definition of ‘a building’. For example, if the Code was triggered by a floor area of 100m2, we might find that buildings planned to be about this size suddenly become 99m2. Implication We need to carefully consider the target group of buildings. Where are the biggest offenders? Where is most to be gained? What are the quick wins? This will help define what a building is. The likely owners or responsible bodies involved need to be explored once the target buildings are defined. This will indicate what the specific business case is. Then, the performance areas of importance need to be established in the context of the building definition and business case(s) – designed to dramatically improve the sustainability of that discrete part of the built environment. Once the criteria are developed, a sense check or bench test needs to be performed by examining the implications on a wide number of buildings (essentially a “clinical trial” in all but name). The above further highlights the need to look at different types of buildings separately and the implications on different sectors needs careful consideration. Funding for schools for example, is different to the private sector. All of the stakeholders and drivers in each of the sectors must be carefully considered when setting the targets and trajectories.


Technical Issues

INTRODUCTION

It was the role of the Technical Working Group to provide technical advice on the form and content of a Code. To do this a review of existing tools and standards was undertaken, building on work undertaken by Upstream as part of the work of the UK-GBC Measurement and Reporting Task Group41. This review allowed the Working Group to understand what measurement methodologies, tools and standards already existed, where they were beneficial to the assessment of a sustainable built environment and where improvements were required. The Technical Working Group proposed that the Code would need to be an overarching framework that references relevant and appropriate tools and standards applicable across the building lifecycle from land acquisition to demolition/end of life. The Code should not replace existing codes and standards, but should clarify which tools and standards are appropriate to use, and how they should evolve, to inform decisions and enable the most sustainable development and use of buildings. The proposed framework would also help to harmonise existing codes and standards by using common language, units and targets to describe performance. INTRODUCTION TO TOOLS AND STANDARDS

In order to progress the development of a framework for tools and standards it is first necessary to identify what we mean by these terms. There are many different types of tools, standards and assessment methodologies currently used to establish the sustainability performance of a building. It is important to establish the differences between each of these types when discussing a proposal for a new Code for Sustainable Buildings. A code can be defined as: ‘a set of rules or principles or laws (especially written ones)’. As the word ‘code’ is applied to many different types of tools and standards, the first step is to examine the difference between these. The main different types of tools, standards and assessment methods are listed below. It is noted that there are a number of systems or tools in place which are hybrid of the below: Performance standards Performance standards could consist of the following:

1. Indicators (e.g. Carbon emissions measured in kgCO2/m2 per year) 2. Numerical targets (e.g. less than 35kgCO2/m2 per year) 3. Benchmarks (e.g. typical general office: 75.1kgCO2/m2) 4. Best practice measures, which can be process-related and specification-related (e.g.

undertake a Combined Heat and Power feasibility study and, if technically feasible, then incorporate into the building).

41“ Organisational Measurement and Reporting”, UK-GBC Task Group Report, July 2008


These performance standards could be stand-alone standards set for a project or could be integrated into environmental assessment methods. Some businesses may use them as Key Performance Indicators. Environmental assessment methodologies and tools (for third parties / for comparison) This includes environmental assessment methods such as BREEAM, LEED, Green Star and CASBEE; EPCs and DECs etc. They have measurable performance standards and a final score or rating that is achieved. Reporting frameworks Reporting frameworks set out the principles for measurement and reporting that need to be adhered to when reporting environmental and/or social performance data. For example, the Global Reporting Initiative (GRI) framework sets out how to record carbon emissions and other environmrental impacts, but does not set performance standards that have to be achieved. Management systems Environmental management systems (e.g. ISO14001) set out principles and processes to follow without setting performance standards or targets that have to be achieved. Standards of legislative compliance These standards are set to demonstrate that minimum standards have been met. For example, Building Regulations Part L has a “Target Emissions Rate” that has to be met to demonstrate compliance, there is only a “Pass” and “Fail”. Guidance & Codes of practice (e.g. CIBSE; BSIRIA) There is a considerable amount of guidance available and documents prepared by professional institutes can have the status of codes of practice that are expected to be followed by its members. These may have performance standards that have to be met or they can just provide guidance on what should be done in a given situation. Analysis and Calculation methods

It is important to note that many of these standards and tools (and indeed some legislation use different bases for their analysis and calculation methods. When calculating energy use for example, you can get very different results currently depending on which calculation method and even which software you use. LEED is based on Ashrae and BREEAM on Part L so forecast figures will be different for each. Depending on whether you use full IES or ISBEM or TAS or Hevacomp you can get a different result. All these add to the confusion and complexity which Code is trying to clarify.

HOW SHOULD THE CODE INTERACT WITH OTHER SUSTAINABILITY TOOLS, STANDARDS AND ASPIRATIONS?

Having established the need for a Code, one needs to understand how such a Code would interact with existing tools, standards and methodologies. The Code for Sustainable Homes is a new form of “code”, and in fact is a hybrid of a tool, standards and guidance. As discussed in previous chapters, it is proposed that the Code should follow a different model. The vast majority of Consultees suggested that the Code should cover both new and existing buildings and cover the whole non-domestic building lifecycle, from planning, through


construction to operation and finally demolition. To create one tool that covers all this would be extremely onerous if not impossible, and would reinvent some well conceived and well understood existing work. It has therefore been suggested that a framework could bring all these elements together and minimise the need to reinvent work. This proposal would also have the benefit of harmonising the various tools and hopefully add clarity. A framework that covers the lifecycle

The Technical Working Group agreed that it would be useful to provide an overarching framework for improving the sustainability performance of buildings. The Code should reference other standards and tools, as appropriate, and help to harmonise them. It should serve to identify the most applicable tool(s) and standard (s) to use at all stages in the building lifecycle, and create a “common language” of metrics and measures between tools and standards. This conclusion was borne out by the Consultation, with Consultees using expressions like ‘a map of the terrain’ and a

‘landscape for the industry’ and expressing a high demand for greater consistency and comparability (and reduced confusion). The Working Group initially noted that in the current climate, specific references to any particular tools, standards and codes could be difficult to keep current as new tools are frequently released, which could impose a weighty burden on the operators of the Code. However, the requirement for tools to be aligned with the Code, could also reduce proliferation of new tools, standards and guidance where existing ones could be seen to be meeting industry’s needs. (See Operational Issues chapter for further discussion) How would the Code interact with building measurement and assessment tools

It was agreed that it was unnecessary to try and reproduce existing tools and standards. In creating the Code a further assessment of existing tools and standards is required to identify the most successful elements of existing systems and areas where these could be further improved in the context of the Code (see “Next Steps”). The Working Group carried out a preliminary review of existing codes and standards and discussed the potential interactions with a new Code. It was agreed that there were existing tools/standards which apply across the building lifecycle and that there were several that overlapped (e.g. EPC and BREEAM). The building operation phase42 had little in the way of appropriate tools with numerical targets and ratings43. DECs were seen as a valuable development in providing a measurable rating for the operation of an existing building although it is noted that these only currently apply to public buildings.

42 although covered by standards (such as ISO14001) and benchmarks (e.g. CIBSE Benchmarks) 43 This might to some extent be addressed by the anticipated release of BREEAM In Use


Code as a matrix

There are a number of intervention points within the building value chain at which sustainability can be influenced:

Acquisition Masterplanning Building design Procurement/Construct Commissioning/building handover Operations Refurbishment Transaction/change of use Disposal

Each of these stages may need to assess different elements of sustainability and set different targets, however they should all use the same reporting framework. At these points, one could measure some or all of the sustainability elements set out below:

Energy and Carbon Water Waste Materials Pollution Biodiversity Health and well-being Management Climate change adaptation Communities

It is likely that some of these elements, or parts of them, would not be applicable at some of the intervention points. A matrix of these elements against the intervention points could be set out, detailing what requirements would be needed to meet different standards of the Code set for different target years. These standards could be produced relatively easy for the first four of these elements, while the others could be developed by the collection of data through the Code as set out in the section below, “Interface”. The Technical Working Group agreed that the Code needed to be consistent with standards and metrics that are mandated by Europe, for example CEN/TC35044 and ISO/DIS 21931-1. The Workshop also showed that the majority of respondents wanted the Code to adopt Life Cycle Assessment. This is further discussed below. How will the Code interact with corporate level measurement frameworks?

The Working Group acknowledged that it can be difficult to directly connect the sustainability performance of buildings with that of a company, however the inclusion of corporate level reporting is important for investors who increasingly need clarity on the value of sustainable buildings as signaled by corporate level rankings. The Code should help businesses to understand how the sustainability of the buildings they own or occupy relates to their overall corporate reporting requirements, and this should also help to create the financial incentives required to produce more sustainable buildings for businesses.

44 This was reflected in the Consultation results with (47/49) Consultees agreeing that that external drivers such as CEN/TC350 should be taken into account


Interaction with Planning Regime

National planning policy and guidance should be consistent with the aims of the Code. While we recognise that national policy is necessarily interpreted and applied at regional and local level, it should be possible to do this in a way that is consistent with the metrics and measures specified by the Code. An example of this is the way in which the PPS on Climate Change encourages local authorities and developers to describe carbon emissions reductions targets in a way that is consistent with the energy credits contained in the Code for Sustainable Homes. Learning from the Code for Sustainable Homes

It was agreed that the Code should not be built on the same model as the Code for Sustainable Homes but that there were elements of the Code for Sustainable Homes that were useful45. The Technical Working Group agreed that the Code should be made a mandatory standard and that it should be used to set out a path to improved performance and signal future changes to building regulations and other legislation. The Code for Sustainable Homes sets a model for this with levels 4, 5 and 6 corresponding to future revisions to the Part L2A. Six Consultees suggested that the Code should be an ‘intrinsic part of Building Regulations’ and two Consultees specifically suggested that the Code would have to join up ‘upstream and downstream tools, standards and methods’ by linking planning to Building Regulations, for example. Criteria for selecting relevant parts of existing tools/standards

The following section sets out possible selection criteria that could be used to develop a framework of tools that would make up the Code:

Apply ISO / TC350 standards wherever they are available; Use quantitative targets, wherever they are available Quantitative targets should be based on collectable data; Use parts of tools/standards that reference existing local legislative standards and

set escalators for future targets; Use tools/standards that include whole life cycle assessment wherever available; Use tools/standards that are third party verified wherever possible; Use UK specific standards in preference to imported standards; Use tools/standards that are recognised by industry; Use tools/standards that avoid duplication of effort to demonstrate compliance

wherever possible. This is not intended to be an exhaustive or exclusive list, but it sets out a number was ways in which the tools evaluated above could be assessed for suitability within the Code.

WHAT ISSUES DOES THE CODE NEED TO COVER?

What actual elements of sustainability should the framework measure and at which points in the building lifecycle46? The consensus of the Consultation and Workshop was that a Code

45 In the consultation workshop the majority of people (35/50) responded to the questionnaire to say that the Code should not be built on the same model as the Code for Sustainable Homes. 46 The source of responses indicate that the greatest numbers of replies were individuals or organisations involved in design, construction or refurbishment activities which may have influenced the way in which they answered the question. 25% of respondents were from government, academic or association sources. It appeared that only 8% of respondents represented building users. There was not a predominant view from the responses to question 3 with the highest single percentage view being less than 45%.


should provide a regulatory escalator towards goals set within its framework. These would be different for different stages in the building lifecycle. Measurement of some elements of sustainability might not even be relevant to certain stages of the building lifecycle. Others might not have targets set against them initially but would be particularly important to incorporate a requirement to measure these in order to facilitate appropriate target setting in future. Breadth of sustainability elements to incorporate

The question of what should be measured under the Code (and what areas were appropriate ones for which to set targets) was a controversial subject which divided many who responded to the Consultation. Whether or not to focus solely or primarily on carbon lay at the heart of this divide. Some felt that the Code should primarily measure CO2 to secure action against climate change, and support the Governments agenda. However the Working Group felt that this would not be helpful in delivering a sustainable built environment and that in order to enhance the future development of building assessment methodologies a broader range of metrics are required to ensure a balanced sustainability assessment, covering social, environmental and economic facets. Supporting this, a very high number of Consultees suggested that carbon should not be the sole measure of the framework47 but that it should cover qualitative as well as commonly identified quantitative measures such as carbon, energy use water, waste etc. It was felt by the Working Group that at the very least, the Code should set targets and facilitate measurement for all sustainability impacts for which the Government had already set targets or minimum requirements. “…targets should be annual and aspirational but not reinvent the wheel, i.e. follow what is already in place…” The Working Group discussed the reasoning behind the decision not to limit the Code to carbon impacts alone. It was felt that to purely focus on Carbon as a normalised metric was incorrect. The current use of a normalised metric, the ecopoint, by the BRE Green Guide methodology was discussed as an example of how a single reference score led to frustration when wishing to look at different impact categories. It was felt by some in the Working Group that it was too blunt to be meaningful.

Elements for which it is currently not possible to set targets

The Code must include aspects of sustainability that we are currently unable to set meaningful targets for due to a lack of relevant information. The Code should require these elements to be measured. The purpose of this is to ensure the collection of relevant data in respect of these elements, enabling the publication of benchmarks and the development of

47 In addition, the majority of stakeholders who attended the Workshop concurred with this view, with 72% believing that the Code should be measuring more than just carbon.


appropriate targets to be set out in the Code and the trajectory for their achievement. Future fixed targets could therefore be developed through the collection of data relating to elements of sustainability for which the Code initially did not set specific targets. This would signal the future direction of policy and best practice. Building types?

The Consultation responses validated the thinking of the Technical Working Group, that one Code should be used to assess all non-domestic building types at all phases of the building lifecycle. To do this, modules would be required for these different stages and possibly for different building types (although simply setting differing targets may be sufficient).

A combined percentage of 45% of Consultees called for either modules or building types to be recognised suggesting that different types of building or building use need to be addressed and that ‘one size fits all’ would not be effective. The need for a Code that reflected use, flexibility and adaptability is important and has to address sites that have mixed use. Examples of this might be hospital sites, manufacturing sites with distribution and administration or retail/hotel/apartment buildings. However it should be noted that it may be more appropriate to describe

buildings by typologies used in the UK-GBC Carbon Reductions in New Non-Domestic Buildings Report48. In the Workshop, the vast majority of responses agreed that the Code should have a series of bespoke elements referring to different building types. This is likely to reflect the issue that the non-domestic stock is vastly different, ranging from data centres to churches. Lifecycle stages

New vs Existing Stock The Technical Working Group felt strongly that the Code should cover all the phases of the non-domestic building lifecycle i.e. cover existing and new build, from the planning stage, through construction into operation and end of life. This was supported by responses to the Consultation and the Workshop questionnaire. It is recognised that implementation for existing buildings will be challenging, but this all the more of a reason to address the issue “head on” in the Code. Inevitably (as mentioned above), the elements measured would depend on the stage in the lifecycle of the building. Current tools do not cover post-occupancy evaluation or embodied energy issues well. Some of the Consultees argued that it would not be possible to mandate “in-use” standards for existing buildings as these would be impossible to impose and, perhaps more importantly, to retrospectively apply to buildings which are already occupied. However, we do not believe that this should be a barrier to implementation. There are several relevant examples in the sector which demonstrate that where a clear need is identified (and a base line is mandated), it is

48 shallow plan, deep plan, shed


possible to require certain levels of “in use” behaviour, and indeed for these requirements to be applicable (and understood) across the supply chain49. Retrospective imposition may create untenable situations for landlord/owners/occupiers so a set of criteria as to how it might apply would need to be developed. These might include:

Size (for example spaces greater than 1000 square meters)

Use/Change of use Refurbishment

In Use Performance Occupant behaviour was a identified by the Consultation as being an issue that many were concerned with. Respondents believed this to be important but also recognised that it is a difficult to address. Whilst building design can direct and facilitate occupant behaviour the impact of behaviour can to some extent be designed out or mitigated by design, it does fall heavily into the building use phase where there is little quantitative information or performance measurement mechanisms available. Is it appropriate to design for the worst case? Should we design building systems to be entirely intuitive to assume the worst case that building occupants will be completely unengaged? The better functioning buildings are those where the facilities managers understand their systems and how to manage them properly50. The Technical Working Group support the inclusion of “in operation” aspects but suggest that further work be undertaken to bring together existing initiatives and to develop these into tangible criteria or benchmarks that enable some ability to demonstrate performance in this area. The impact of behaviour is currently measured through the use of proxies. Training for occupants and encouraging innovation in engaging building users through the Code were suggested. Life Cycle Assessment (LCA) The assessment boundaries of the sustainability of buildings are currently being developed through ISO/TC59/SC17 and Draft International Standard ISO/DIS 21931- Sustainability in building construction. This is also shaping the work of the European Standards Group CEN/TC350, which is developing Lifecycle Assessment (LCA) standards to support EU Commission Mandate M/350, Directive 98/34. During the stakeholder workshop on the Code, 74% of respondents to the Workshop questionnaire felt the Code should be based on LCA. Arguably, ‘life cycle’ and LCA support the need for buildings to be considered from cradle to grave. The total response combined was 38%. The application of LCA to buildings is arguably very academic but already exists in some forms (eg The BRE Green Guide to

49See for example, the implementation of the Construction (Design and Management) Regulations 2007, applying health & safety requirements at all points in the construction life cycle. 50 Group discussed an analogy with the car industry. Previously cars were clunky, less reliable and could be fixed by the owner is many cases. As cars become more complex, requiring computer systems to understand and fix, driver become disengaged with how their works and cars are more reliable.


Specification and ENVEST2). The principle is therefore established and should be used more widely for building life. Many of the building assessment tools (eg BREEAM and LEED) require some degree of LCA. Performance/measurement

The Technical Working Group support the requirement for performance criteria (and measurement) to enable quantitative evaluation of building design and operation. It is also recognised that an element of qualitative measures will still be required. The benefit of quantitative measures is that

performance can be scaled and it enables benchmarking to be used to assist in the identification of best practice and prioritisation of improvements.

HOW SHOULD THESE ISSUES BE MEASURED?

As described above the Code needs to set specific targets and identify the tools which are able to quantitatively demonstrate that the targets are met. The question of precisely what the Code should measure (and how), drew out a diverse range of perspectives from the Technical Working Group and Consultees. Therefore identifying what needs to be measured and how, is both a highly sensitive and significant question in the context of what the Code itself, and what it is seeking to achieve. An enduring theme observable from both Working Group discussions and a high number of Consultees was that the Code should set targets and Key Performance Indicators that are meaningful for society and drive quantitative measurement. It was also noted by the Working Group that there were many areas of sustainability that cannot currently be easily quantitatively measured nor can meaningful benchmarks be set. For these areas there is a need for qualitative measures to be used in the interim, whilst new measurement methodologies are developed, refined and accepted. Consultee acknowledged that “…not all criteria will initially be measurable or quantifiable but nonetheless recognised that in time new methodologies could be integrated…”. There was a desire for outcome/performance based targets to be accompanied by relevance guidance where applicable: “…where possible the code should set out required performance rather than specific technologies…” This technology agnostic principle was shared by the broad majority with further qualification of the need to ensure that the Code was not prescriptive in the solutions applied. Outcome based criteria were preferred as it was felt that otherwise “…innovation would be stifled…”. The majority of Workshop Attendees agreed that the Code should prescribe processes for dealing with certain issues which are difficult to quantify, without setting absolute targets. For example, community consultation process; establishing appropriate green travel plans etc. The Workshop revealed some disagreement about whether weightings should be applied to the various issues to be covered by the Code. This is a complex issue with there being a perceived need for a single score or result from existing tools and assessment methods. This


is an issue that will need further consideration. It is noted that currently ISO standards do not recommend weightings51whereas weightings are applied in the BRE Green Guide LCA methodology. The BRE document “Creating environmental weightings for construction products” highlights some of the issues.

CONCLUSION

Key assessment methodologies were all referred to during the Consultation and reviewed by the Technical Group. A common theme of these methodologies is their reliance on building regulations and other third party standards. This suggests the concept of a framework or matrix approach for the Code. Creating one tool/measurement in the Code would be extremely onerous and would duplicate existing assessment methodologies, tools and standards, some of which are well embedded in their particular role. Therefore assessing the existing tools and standards with a cross-industry expert group should be a key part of creating the Code. The way forward proposed by the Technical Working Group and endorsed by the Consultation, is therefore believed to be a framework that brings all these tools together in pursuit of a common target of a sustainable building. This target should have a defined regulatory escalator to create steps and dates towards meeting that target that the whole industry can follow, but where possible use the existing methodologies, tools and standards. A matrix of tools and assessment methodologies at each stage of the building lifecycle would enable ratings for each phase to be obtained. This would mean that certain measures which could not be affected at certain stages (e.g. embodied impacts of building structure during operation) could be excluded. To do this, a clear measurement methodology must be used: one as simple as the EPC/DEC A-G building rating system; one that contains the various regulated mandatory minima and unregulated targets; and one that allows the collection and benchmarking of data and performance levels in relation to these targets to better inform the industry and possible solutions. The concept of a spider diagram has therefore been put forward by a number of independent sources as the way to demonstrate this. This could indicate what the regulatory minima will be over time for each of the key elements, demonstrate how the building performs in relation to each of these, and collate a total that could translate into an overall rating. This could expand indefinitely as new targets and directions are added.

51 though ISO/DIS 21931-1 would allow weightings


It could also enable continual improvement to be targeted at the operational phase through a requirement for regular performance checks – a kind of building “MOT” process. This would build on existing in use requirements such as EPCs, DECs and ventilation system checks, but much of the criteria would need to be developed and measurement methodologies adapted or created.


Operational issues

WHO SHOULD OWN, OPERATE, MANAGE AND PAY FOR THE CODE?

The Task Group concluded that Government should own the Code. This is because it was felt that the framework needs to be mandatory to drive change and therefore Government

would need to have overall ownership, but bring together an expert stakeholder group to develop, manage and implement the Code. This expert stakeholder group should comprise industry, academic, NGO and other not for profit organisations52. Suggestions on the actual make up of the organisation were diverse although its need for independence was regularly stated. A common theme was that a new body should be formed comprising of representatives across the industry. “The Code needs to be based on close engagement with all key stakeholders, including: investors, occupiers, developers, builders,

government, investors, planning authorities and so on.” 53 In addition to this, it was felt that the members of the stakeholder group, particularly those representing industry, should be elected onto the Group and that the elections should take place regularly. This would ensure that stagnation did not take place. Those who put themselves forward for the group should also meet key criteria to ensure that the right individuals were in place. This would be similar to the Green Star model that was implemented in Australia. The actual operation of the Code would need to be independent in order to ensure that the ethos of the framework was not unduly influenced by one lobby group/set of interests In addition, it is believed that while a fully independent NGO or other not for profit organisation should operate and manage the Code, assessment against Code standards should be carried out by multiple “accrediting organisations” (competition in this area was identified as very important by a number of Consultees). A mechanism for dispute resolution and the potential for financial penalty for non-compliance should be considered. Operation and management

The Consultation found that industry expertise is crucial, but Consultees were clear that they did not want industry involvement to have the effect of “watering down” the Code and making it less aspirational in the targets it set. It is noted that, given the commitment to sustainability of the Consultees, it was unsurprising that many wanted the Code to be strongly enforced through, for instance, building control. It is suggested that the Code would need to be “policed” by local authorities via the current building control

52 “It is essential that the Code is owned by a “custodian” not-for-profit organisation (e.g. the UK-GBC) on behalf of the whole industry.” Consultation response (consultant) 53 Consultation response (University)


arrangements, with a system in place for appeal/reference to a “third party” public body if local authorities fail to police the system adequately. Third party validation of data is believed to be very important. Assessment and third party validation

Many of the Consultees suggested measurement of performance against the Code using independent accreditation assessors. Code assessors should be members of a Competent Person Scheme (CPS) licensed by the expert stakeholder group. A number of CPS management companies could operate competitively to common scheme standards. This system would need to be in place prior to the roll-out of the Code. To achieve the Code level would require detailed involvement from all design and delivery team members, and perhaps require them all to upload information for a reviewer rather than just an assessor uploading information as under current assessment regimes. It is also noted that for assessment to impact on the value of buildings, third party verification of data and assessment results would be required.

Payment for Code

In relation to payment, it is thought that Government needs to invest in the development, implementation and enforcement of the Code (the capital phase). However, industry would need to pay for compliance with the Code (the revenue phase). Cost of assessing

Many have commented that if applying the Code were to add significant extra cost to a scheme, it would be unpopular with the industry. Respondents stated that in their experience the cost and time taken to complete sustainability assessment are deterrents. It is noted that a significant time and financial cost can be directly attributed to the current confusion about which “assessments” and “reporting frameworks” etc to use, and when (and to the inconsistencies between the data and information these currently require). By providing significantly improved clarity on these issues, creating greater predictability and thereby reducing risks for industry, the Code should reduce the costs associated with these issues. Cost of compliance – existing buildings

It is noted that the transformation of existing buildings will inevitably cost money and will not happen overnight. In setting performance targets and mandatory standards, consideration should be given to a phased introduction for existing buildings to enable planned maintenance and capital expenditure to work. The SME sector of occupants in particular could be heavily impacted by sudden high retrofitting costs for buildings that no longer comply. In developing the Code we should therefore consider a phased introduction according to size of building, similar to that employed for EPCs. Online interface

Ease of use via a simple well-designed online interface with a graduated response structure can cater for all development sizes and levels of engagement and will maximise the uptake of the Code.

HOW DO WE ENSURE QUALITY CONTROL AND TECHNICAL RIGOUR IN A CODE?


The overwhelming desire from respondents to both the Consultation and the Working Groups was to ensure the following:

The correct ownership and management of the Code (see above) A method of ensuring transparency Assessor competence (see above) Cost (see above)

Some current tools and standards are perceived in a negative way in terms of both ownership and transparency, however the benefits of the schemes themselves are thought of in a much more positive way. The way in which the the Code for Sustainable Homes and BREEAM deal with the issues of transparency and technical rigour are cited as models on which the Code could build on. Whilst the Code needs to be wider reaching, this does not mean reinventing the wheel. The Code should create a framework under which existing systems could still operate. “Start with method used for QA for BREEAM, but streamline the process to reduce QA costs.”54 It was proposed that the Code be “future proofed” by creating a framework that allows adaptation to the continually evolving understanding of best practice of sustainable design.

Suggestions included highlighting the date of accreditation, regular monitoring of buildings against updated versions of the Code as well as live monitoring of building performance through anonymous data collection. “The Code needs to be continually evolving with new legislation and progress, therefore the DATE for accreditation will be relevant as the Code may have been updated.”55 Key to any Code would be transparency of calculation methodology and this was the question with the highest level of agreement through the various consultation processes.

Many Consultees have also endorsed the UK-GBCs findings contained within their first task group report “Carbon Reductions in New Non-Domestic Buildings” which was for national collection of performance data that could be used to benchmark buildings and assess industry trends. CarbonBuzz, a CIBSE RIBA platform was also mentioned as a useful template for highlighting the discrepancy between forecast and actual energy use of buildings and for the continuous gathering and publishing of building energy use data online. Method of Ensuring Transparency

It is recognised that full transparency is not always possible due to the commercially sensitive nature of some of the information. Whenever possible information should be published to allow for benchmarking and identify future best practice. Anonymous publication of data has been mentioned as a possible mechanism to share information in the public domain and provide data for benchmarking. Many people commented on the need for a clear framework and benchmarks to cover not just energy use but water, embodied impact, waste, etc. “Benchmarking and (standardised) feed back should be a key part of

54 Consultation response (multi-disciplinary consultancy) 55 Consultation response (financial services)


the code, to allow comparisons to be drawn and encourage companies to innovate with their existing premises” 56 There remains debate about whether or not results should be published anonymously. Display

As noted in the Value chapter, a clear (and publicly displayed) presentation needs to be given on how a building performs relating to the elements of the Code. The “spider diagram” proposed in the Technical Issues chapter, could provide this display, and indicate what the regulatory minima will be over time for each of the key elements, demonstrate how the building performs in relation to each of these, and collate a total that could translate into an overall rating.

EDUCATION

Education has been identified as key. It is important to ensure that all stakeholders in the industry have appropriate level of knowledge and understanding. The industry as a whole needs to know what we are trying to achieve, why, and by when. This is potentially a precondition to the success of the roll out of the Code. The industry also needs the skills to deliver it. It is noted that the need for increased knowledge and education have been highlighted by many of the Consultees as a means of overcoming some of the barriers in relation to the practical issues of delivery and use of sustainable buildings. Education/promotion about the Code across the full spectrum of industry stakeholders will be crucial to a successful take up. Most successful labelling systems – such as for appliances – have been in industries with small product development teams, whose designs are repeated thousands of times over. The non-domestic building market is almost always the opposite: complex product development and financing, involving a very wide range of professionals, and fairly bespoke end products. This calls for a significant learning programme, and a very transparent Code development and administration. This education needs to be supported by best practice case studies and guidance in order to increase understanding of benefits and also issues that might be encountered.

WHAT WOULD ENSURE WIDE TAKE-UP OF A CODE FOR SUSTAINABLE BUILDINGS?

Factors leading to higher take up: Effective marketing Mandatory elements incorporated in regulations over time Recognition by investment community (facilitates benchmarking) Industry driven Recognition across the supply chain therefore easy to require compliance as part of

contractual requirements Potential to submit anonymous data for benchmarking Well recognized and endorsed standards (marketing potential)

Barriers to wide take up:

Private ownership

56 David Woodhead, Engineer, Expedition Engineering


Lack of training courses High cost of assessment Non-applicability to SMEs Audience that a tool is designed for (e.g. not designed for occupiers therefore low take-

up) Unclear overlap with other existing tools standards Methodological inconsistencies between different tools makes them incompatible with

each other (e.g. methodologies used to calculate LCA).

Finally, it is critical to identify “trigger points” at which it would be mandatory to assess a building’s performance against the Code. In addition to design stage, and post construction stage, other opportunities for intervention points for existing buildings might include letting (such as with EPCs), refinance and refurbishment.


Conclusion

The conclusion of the Task Group there is a strong case for the development of a Code for Sustainable Buildings that should be based on the following guiding principles:

PURPOSE OF THE CODE FOR SUSTAINABLE BUILDINGS

To set a trajectory for a zero carbon, sustainable built environment by 2050

‘GUIDING PRINCIPLES’ OF THE PROPOSED CODE

The Code for Sustainable Buildings should: Be a shared vision between industry, government and other stakeholders to transform

the sustainability of our built environment Ensure all key policy, regulatory and other requirements relating to the sustainability of

buildings, throughout all stages of their lifecycle, are complementary and applied in a consistent manner to provide the clarity and certainty required to enable investment, innovation and effective delivery

Set out the zero carbon and sustainability trajectory for buildings that all relevant policy and regulation, tools and guidance should support and be aligned to

Focus first on priority and measurable issues including energy, carbon, water and waste, and set ‘absolute’ performance targets for all buildings to meet over time

Set outcome-based targets and milestones to stimulate innovation, expressed using clear and universally applicable metrics

Seek to harmonise existing standards or methodologies for use at different stages in the building lifecycle, and create a “common language” of metrics and measures between tools and standards which are approved as ‘Code compliant’

Be capable of evolution and development to include a broader range of sustainability needs over time

Drive the consistent and systematic collection of data and information relating to the performance of buildings in relation to the priority issues over time, in order to measure progress and enable learning

Provide the basis for the valuation of sustainable/green buildings by driving consistent data collection and enable benchmarking on key performance criteria

Increase ambition, market certainty and innovation, and reduce risks and costs associated with sustainable buildings

Be owned by government and developed, managed and operated in a transparent and accountable way, by government working in partnership with industry and other key stakeholders


Recommendations and Next Steps

RECOMMENDATIONS

1. There should be a Code for Sustainable Buildings that covers all new and existing

non-domestic buildings in the UK.

2. The Code should be an overarching framework, which makes it easier for industry to understand policy and regulatory requirements and implement them effectively, throughout all stages of a building’s lifecycle.

3. The Code should set out the trajectory and stretching targets for a zero carbon, sustainable built environment – including carbon, energy, waste and water performance. All buildings must meet progressively more ambitious standards over time. Requirement for regular performance checks (a “building MOT”) would enable appropriate data collection and facilitate benchmarking. There should be mandatory disclosure of certain metrics in the public domain.

4. The Code should be owned by government, but represent a shared vision with the industry. This will require collaborative working, both across the industry and in partnership with government.

5. The Code should ensure consistency of approach between all policies, tools, guidance and initiatives. It should set the standards, metrics and targets that all sustainability tools should be aligned to and compliant with.

NEXT STEPS

1. Establish a Code Working Group to include government, industry and other key

stakeholders.

2. Code Working Group to further develop the policy and regulatory map for zero carbon and sustainable buildings.

3. Code Working Group to carry out a detailed mapping of existing tools and standards and establish a set of agreed “common metrics”.

4. UK-GBC to work with industry partners to drive data collection for the performance of buildings and develop the evidence base needed to demonstrate the business case for sustainable buildings

5. UK-GBC to scope out the current supply and demand for sustainability education and training and identify gaps.


Appendix 1 – Glossary

Ashrae American Society of Heating, Refrigerating and Air-Conditioning Engineers http://www.ashrae.org/

BRE Building Research Establishment. http://www.bre.co.uk/

BREEAM Building Research Establishment Environmental Assessment Methodology. UK based environmental assessment methodology owned and operated by the BRE, used to assess the environmental performance of buildings. http://www.breeam.org/

BSRIA Building Services Research & Information Association. http://www.bsria.co.uk/ CASBEE Comprehensive Assessment System for Building Environmental Efficiency. Building

environmental assessment method managed by the Japan Sustainable Buildings Consortium. http://www.ibec.or.jp/CASBEE/english/overviewE.htm

CDM Construction (Design & Management) Regulations. CDM Regulations 2007 SI No 320 (CMD 2007) aim to reduce the number of construction related accidents and injuries in the UK. http://www.hse.gov.uk/construction/cdm.htm

CEN/TC 350 The standards of CEN/TC 350 ‘Sustainability of Construction Works’ are standards being developed by a Technical Working Group of the European Committee for Standardization, that will describe a voluntary harmonized methodology for the assessment of environmental performance of buildings and life cycle cost performance of buildings as well as the quantifiable performance aspects of health and comfort of buildings. http://www.cen.eu/

CIBSE Chartered Institution of Building Services Engineers. http://www.cibse.org/ CLG Department for Communities and Local Government. http://www.communities.gov.uk/ CPS Competent Person Scheme. Introduced by Government to allow individuals and enterprises

to self-certify that their work complies with the Building Regulations. CRC Carbon Reduction Commitment. Proposed mandatory emissions trading scheme from April

2010. http://www.carbonreductioncommitment.info/ CSB Code for Sustainable Buildings CSH Code for Sustainable Homes. National standard for sustainable design and construction of new

homes launched December 2006. http://www.communities.gov.uk/thecode DEC Display Energy Certificate. Shows actual energy usage of a building, the Operational Rating. Based

on energy consumption of a building as recorded by gas, electricity and other meters. Required for buildings with a total useful floor area over 1,000m 2 that are occupied by a public authority and institution providing a public service.

ENVEST2 Building Research Establishment Life Cycle Assessment Software. Software tool for estimating the lifecycle environmental impacts of a building from the early design stage http://envestv2.bre.co.uk/

EPBD Energy Performance of Buildings Directive. Directive of the European Parliament and Council to promote the improvement of energy performance of buildings in Member States. http://www.buildingsplatform.org/cms/

EPC Energy Performance Certificate

G8 A forum for governments of eight nations of the northern hemisphere: Canada, France, Germany, Italy, Japan, Russia, the United Kingdom, and the United States; annual summit meeting of the G8 heads of government.

GreenStar Australian building environmental rating system owned and operated by the Green Building Council of Australia. http://www.gbca.org.au/green-star/

GRI Global Reporting Initiative. Develops and disseminates globally applicable ‘Sustainability Reporting


Guidelines’. http://www.globalreporting.org/Home

Hevacomp Building Services Design and CAD software http://www.hevacomp.com/default.htm

IES Integrated Environmental Solutions. Provide Integrated Building Analysis Software system http://www.iesve.com/

IPD Investment Property Databank. Provides independent market indices, benchmarks and performance analysis for property sector http://www.ipd.com/

IPF Investment Property Forum. Membership organisation aimed at improving awareness, understanding and efficiency of property as an investment. http://www.ipf.org.uk

iSBEM Basic user interface which accompanies Simplified Building Energy Model

ISO International Organisation for Standardisation. Develops and published International Standards http://www.iso.org/

ISO 14001 International standards for implementing environmental management systems (EMS) http://www.iso.org/

ISO/DIS 21931-1

Draft Framework for methods of assessment for environmental performance of construction works (Part 1: Buildings) http://www.iso.org/iso/iso_catalogue/catalogue_tc/catalogue_detail.htm?csnumber=45559

ISO/TC 350 See CEN/TC 350 ISO/TC 59/SC17

International Standards Organisation Technical Committee for Sustainability in building construction http://www.iso.org/iso/iso_technical_committee?commid=322621

KPI Key Performance Indicator Kyoto Protocol International agreement for reducing global greenhouse gas (GHG) emissions linked to the

United Nations Framework Convention on Climate Change. http://unfccc.int/kyoto_protocol/items/2830.php

LCA Life Cycle Assessment LCC Life Cycle Costing

LEED Leadership in Energy & Environmental Design. Building environmental assessment methodology owned and operated by the US Green Building Council. http://www.usgbc.org/DisplayPage.aspx?CategoryID=19

LES-TER Landlord’s Energy Statement and Tenant’s Energy Review. Set of tools and a process designed to enable landlords and tenants to measure, understand and reduce their emissions from their ownership and occupancy of commercial buildings. http://www.les-ter.org/page/home

Merton Rule London Borough of Merton planning policy that requires new developments to generate at least 10% of their energy needs from on-site renewable energy equipment. The most commonly accepted threshold is 10 homes or 1,000m2 of non-residential development. http://www.merton.gov.uk/living/planning/planningpolicy/mertonrule.htm

MOT Ministry of Transport – Roadworthy Test for Vehicles

NGO Non Governmental Organisation OGC Office of Government Commerce http://www.ogc.gov.uk/ OPD Occupiers Property Databank Part L Part L of the Building Regulations (in England and Wales) was introduced by government on 6

April 2006, and it concerns the implementation of energy efficiency measures. http://www.planningportal.gov.uk/england/professionals/en/4000000000562.html

Quango Quasi Non Governmental Organisation Red Book RICS Valuation Standards (The Red Book) contains mandatory rules, best practice guidance and

related commentary for all RICS members undertaking asset valuations. http://www.ricsbooks.com/RedBook


RIBA Royal Institute of British Architects http://www.architecture.com/ RICS Royal Institution of Chartered Surveyors http://www.rics.org/ SAP Standard Assessment Procedure (for the Energy Rating of Dwellings). Government approved

calculation tool for the calculation of the energy performance of swellings. Used to fulfil the requirements of Building Regulations.

SBEM Simplified Building Energy Model. Government approved calculation tool for the calculation of the energy performance of buildings that are not dwellings. Used to fulfil the requirements of Building Regulations.

SDC Sustainable Development Commission http://www.sd-commission.org.uk/

TAS Thermal Assessment Software

UK-GBC UK Green Building Council http://www.ukgbc.org WLC Whole life Costing Zero Carbon Hub (ZCH)

A public/private partnership established to take day-to-day operational responsibility for co-ordinating delivery of low and zero carbon new homes. http://www.zerocarbonhub.org/


Appendix 2 – Value Literature Review

Appendix is available for download on the UK-GBC website: www.ukgbc.org/site/taskgroups


Appendix 3 – Regulatory and Policy Map


Appendix 4 – Workshop summary


Appendix 5 – Consultation document


Appendix 6 – Task group structure


Appendix 7 – Task group members


UK Green Building Council The Building Centre 26 Store Street London WC1E 7BT T: +44 (0)20 7580 0623 E: [email protected] W: www.ukgbc.org

making the case for a code for sustainable buildings · 7 code for sustainable buildings...

Documents