UK Green Building Council Consultation Code for Sustainable Buildings Task Group

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1 UK Green Building Council Consultation Code for Sustainable Buildings Task Group Supported by:

2 Submission to UK Green Building Council on Code for Sustainable Buildings from Oxford Institute for Sustainable Development (OISD) Oxford Brookes University Creating Sustainable Environments Overview of OISD The Oxford Institute for Sustainable Development (OISD), which is based within the School of the Built Environment at Oxford Brookes University, was established in July OISD, which has six main research groups, is the largest academic research institute in the UK dedicated to research on sustainable development in the built environment. The website is at: A recent HEFCE report into sustainable development in higher education in England suggests that the Oxford Institute for Sustainable Development (OISD) is one of the key players in sustainable development research. OISD is also a member of the UK Green Building Council. The mission of OISD, which has a multidisciplinary focus, is to help create a sustainable future by undertaking research on sustainability in the built and natural environments. OISD is currently carrying out a range of funded research for the research councils, industry and the public sector. Prof. Tim Dixon, Director of OISD (E: tdixon@brookes.ac.uk) and Dr Rajat Gupta (OISD: Architecture Unit) Oxford Institute for Sustainable Development Oxford Brookes University December

3 Section 1 - Core issues Question 1 Is there a need for a Code for Sustainable Buildings, and if so, what is its purpose? Issues to consider: Are there enough/too many standards already? Who should a Code be targeted at? Can one Code be applicable across the whole of the industry (irrespective of building form and type)? What does industry need to help it meet the challenge of building and operating more sustainable buildings? Should we leave this to government? Is it possible to develop a Code which provides enough guidance to be useful to industry without being so prescriptive that it stifles innovation? Can/should one code cover new and existing buildings? Yes: there is a need. Non-domestic buildings represent an important source of carbon emissions. The code should be unified and linked with the Code for Sustainable Homes, but both codes should be reviewed and renewed in the light of the importance of existing building stock. 3

4 Section 2 - Technical issues Question 2 How should the Code interact with other sustainability tools, standards and aspirations? Issues to consider: What current tools/standards are useful and where do we need further harmonisation of them? Where are the gaps in existing assessment methods/standards? Can/should there be a holistic Code, overarching all of the existing tools, standards and methods, placing each in context? Clearly the Code needs to link with and underpin BREEAM and the Building Regulations. A unified system is desirable. Previous research for RICS (Green Profession report) by the Oxford Brookes Oxford Institute for Sustainable Development (OISD) has shown that there are a whole range of metrics used by property professionals in assessing sustainability. This can sometimes be confusing and greater unification and standardisation is needed nationally and internationally. Question 3 What issues does the Code need to cover? Issues to consider: Should there be one code that addresses all building types or should it have a series of bespoke elements? Should it focus on carbon, environmental or a wide range of sustainability issues? Should a Code seek to cover new and/or existing buildings? Can a code include social and economic issues? Should the Code incorporate the behaviour of building occupants? The Code should focus on the full range of non-domestic building types. Although environmental issues are of paramount importance the Code should also focus on social and economic issues to link with BREEAM. Both new and existing buildings need to be incorporated. Given that a sustainable building is based not only on the building but also the people in that building then building occupants should also be key to the new code. Question 4 What should the Code be measuring and how? 4

5 Issues to consider: Does a Code need to measure specific issues? Should the Code confine itself to parameters that can be quantitatively measured (such as CO 2 /m 2 or per person)? Should the Code simply set measurable outcome-based targets without describing a method to achieve them? If the Code is to measure, how do we ensure a robust measurement methodology? The Code for Sustainable Buildings (CSB) should encourage evidence-based building performance using regular post-occupancy evaluation studies (POE), after 1, 3, 5 and 7 (and so on) years of occupancy of the building 1. The POE studies should include both hard and soft issues of building energy performance: a detailed audit of actual energy use and environmental impact; monitoring of temperature, humidity and lighting; as well as an assessment of occupant satisfaction through questionnaires. This will help in fine-tuning the performance of buildings to save energy, carbon and fuel costs, as well as learning important lessons for future projects. Over the years, research on post-occupancy evaluation of buildings by OISD and others have shown that a there is a wide credibility gap between designed energy use versus actual energy consumption, due to (Source: Bill Bordass, 2008): Little monitored information and feedback being available on building performance in use to those who procure and regulate buildings. Problems with design, specification, build quality, commissioning, handover, operation, controls, usability, management and communication. More equipment, using more electricity in particular and often requiring yet more equipment to cope with the consequences. Unmanageable complication as we throw more and more technologies into buildings, when what we really need is to keep it simple and do it well. Recent work by OISD for the FE sector and Association of Southeast Colleges has highlighted the urgent need to incorporate passive design in new FE buildings, and rapidly update energy and carbon emissions benchmarks. It is vital that CSB action plan encourages better building performance of new and refurbished buildings to best practice standards (such as 25kgCO 2 /m 2 /year) for energy, water, waste, material and transport 2. Question 5 How do we ensure quality control and technical rigour in a Code? Issues to consider: Which stakeholders need to have oversight of the Code? How can the Code s structure and process ensure rigour and quality assurance (e.g. external accreditation, oversight board, technical input)? How can transparency be ensured (proactive, transparent feedback loops, accessible database for benchmarking)? 1 Gupta, R. (2007). Leading by example: post-occupancy evaluation studies of city council-owned non-domestic buildings in Oxford to assess the potential for reducing CO 2 emissions. Peer-reviewed paper. Proceedings of the 24 th International Conference on Passive and Low Energy Architecture (PLEA) November 2007, SINGAPORE. 2 Gupta, R and Chandiwala, S. (2007). How to conserve energy in further education colleges. Seacourt Publishers, Oxford. ISBN

6 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. A UK-wide statistical study of typical and good practice benchmarks related to energy use, carbon emissions, water consumption, waste generation and transport should be encouraged, as either the current benchmarks are out of date (for example: Benchmarks for energy use in CIBSE guide F) or simply do not exist (water consumption in buildings other than offices). For CSB to be actively pursued, benchmarking building and premises performance against key indicators is vital. Eventually this will move the industry towards evidence-based sustainable design and performance. 6

7 Section 3: The policy context Question 6 What are the key elements of the policy and regulatory context in which the Code must operate? Issues to consider: In your sector, what do you see as the most important current and future policies (including regulation and standards) that act as enablers and/or barriers for sustainable new and existing buildings, at the following levels (1) Local/Regional; (2)National; (3) European; (4) International? In our view it is important to focus on all three levels. At a national level the triumvirate of the Climate Change Act, Energy Act, and Planning Act are all very important and the Climate Change Committee s targets for the non-domestic sector is a vital piece of the jigsaw. Clearly the EPBD is also playing a major role in the UK and across the EU. Question 7 What, if any, are the main areas of conflict between the different regulations, policies and standards that present barriers to those trying to achieve a sustainable building? 7

8 Two main issues are: (1) Fragmented and often opposing objectives in the different layers of policies (2) Lack of fiscal incentives to underpin legislative change. From our research and the findings of others we believe that the following instruments will need further analysis at a UK level: Mandatory code for existing buildings based on operational energy use. The current polarisation on VAT for refurbishment and newbuild continues to mitigate against sustainable retrofitting. There is now a large body of evidence to suggest there should be a reduced 5% rate for refurbishment and an increased rate to the same percentage for newbuild. Tax breaks, including enhanced capital allowances for energy-efficient capital expenditure and tax relief for retrofitting involving energy efficient measures. There needs to be greater consensus between occupiers and investor/landlords as to the type of information that is needed within nay new Code. The UK Green Building Council and the various property industry bodies (eg Property Industry Alliance) need to ensure a consensus view. Key to this will be further research which should identify the full range of tools which can be used to improve energy measurement. These include: Regular post-occupancy evaluation of buildings to look at both the hard and soft issues of building performance (Gupta 2007) 3 Landlord energy statements to provide operational energy use and related carbon emissions to both tenants and landlords. Carbon modelling of the non-domestic building stock by local authorities using principles of GIS-based neighbourhood level modelling developed by well-respected DECoRuM model ( In addition, further research is needed to examine the behavioural aspects of energy consumption and how key stakeholders in the commercial property sector are engaging with the sustainability agenda. 3 Gupta, R. (2007). Leading by example: post-occupancy evaluation studies of city council-owned non-domestic buildings in Oxford to assess the potential for reducing CO 2 emissions. Peer-reviewed paper. Proceedings of the 24 th International Conference on Passive and Low Energy Architecture (PLEA) November 2007, Singapore. 8

9 Question 8 Should a Code for Sustainable Buildings, informed by progressive industry representatives, help determine future Government policy and targets; or should Government lead and industry follow? Issues to consider: Do we want a voluntary, market based, industry-driven Code? Should it be voluntary, but signal the future policy trajectory? What can we learn from the Code for Sustainable Homes? How do we ensure that the Code provides a vehicle for feedback to inform and support policy development and industry action? There should be consultation but the Code should be government-led. Another voluntary code will simply not work, particularly was we enter and economic recession. The property industry will not self-regulate and we need a much tighter unified system which is mandatory and applies to existing stock and new build. If fiscal breaks and incentives underpinned this then the system would be strengthened still further. Section 4 - Value & business case Question 9 How can we demonstrate/create value in sustainable buildings and developments? Issues to consider: What do you need in order to demonstrate value? What are the key drivers of value for your sector/business? Is it necessary, or possible, to compare buildings like for like? Is it necessary or desirable, in order to generate greater clarity, to relate everything to carbon impact? Is the monetary value the only driver? Could there be a point at which sustainability performance no longer contributes to building value, and other incentives for investment are necessary? Will benchmarking need to be an integral part of the valuation process? 9

10 This requires more research. There is no clear evidence from the UK that sustainable buildings are worth more than conventional buildings (although US data suggests there is a strong case for this). There needs to be a market in such buildings before valuers price any premium into their market valuations. OISD has recently completed research for Investment Property Forum on occupier demand for sustainable offices in the UK and it is clear that sustainability is relatively less important than other factors, such as location, in the final choice of building and this is research which is based on actual moves made by occupiers. A key barrier for occupiers is seen as the additional costs of sustainability, followed by undersupply 4. Despite the Vancouver Accord (a commitment by valuation standards organizations globally to begin the process to embed sustainability into valuation and appraisals, which was launched on March 2nd 2007), progress in the sector is still struggling to escape the circle of blame culture. Question 10 How can we define a sustainable building in a way which enables valuers, investors and occupiers to attribute a financial value to sustainability? Issues to consider: How can the financial disconnect between sustainable building investment and lower building running costs be reconnected by a Code? For the purposes of assessing financial value, can the sustainable building only be defined by quantifiable, measurable elements or is there a way of defining qualitative benefits? Can social issues be taken into account? How can a sustainable building, its adaptability & flexibility be incorporated and given a financial value? What barriers currently exist in the implementation of sustainability in the valuation process? Our research for IPF suggested that there is a clear difference in the evolution of thinking on green and sustainable buildings partly created by cultural differences between North America / Australasia where the term green is commonplace, and the UK and Europe, where the term sustainable tends to be used. This is not an exclusive distinction, and the terms have frequently been used interchangeably. However, the main differences between the terms can partly be related to whether the focus is on new build ( green ) or new build plus existing ( sustainable ). In this respect, the term, green is taken by some to mean beyond compliance. If a sustainable building includes both new and existing buildings then it is clear that market evidence provides the key to linking valuation with the code. The RICS s new guidance on valuing property which includes a sustainability dimension will be helpful when it is published in It is also clear that organisational change is a key driver in the market for sustainable offices: occupiers want buildings which can help them achieve cultural change and encourage more sustainable practices, and the key benefits of such buildings include a better public image, improved client relations, and better employee relations. These dimensions should also be captured. 4 The research will be published by IPF in February

11 Question 11 Who should own, operate, manage and pay for the Code? Issues to consider: How should the Code be administered? Who would maintain it and can a code be financially self-sufficient? The UKGBC clearly has a major role to play. Government support is also needed and it could be that the property industry played a major role in helping craft the Code but occupiers and other groups would require representation. Question 12 In your sector, what would ensure wide take-up of a Code for Sustainable Buildings? Issues to Consider: Are there particular features of a Code which would be necessary or a priority if a Code is to transform the non-residential property market? Is government support necessary, or is industry endorsement and marketability sufficient? What practical aspects of existing sustainability tools and standards (such as training, auditing and transparency) are particularly useful or difficult for developers, builders, and owners and occupiers? Government endorsement of the Code is essential for its success. Raising stakeholders awareness of the Code would be vitally important. References Dixon, T., Colantonio, A., Shiers, D., Gallimore, P., Reed, R., and Wilkinson, S. (2007) A Green Profession? RICS Members and the Sustainability Agenda. London: Royal Institution of Chartered Surveyors (RICS). Dixon, T., Ennis-Reynolds, G., Roberts, C., and Sims, S (2009-forthcoming) Is there a demand for UK sustainable Offices? London: Investment Property Forum (IPF). 11

12 Gupta, R. and Chandiwala, S (2008). Building for the future: making the UK further education colleges sustainable. Keynote. The Oxford Conference 2008: 50 years on - Resetting the Agenda for Architectural Education July 2008, OXFORD. Gupta, R. (2007). Leading by example: post-occupancy evaluation studies of city council-owned nondomestic buildings in Oxford to assess the potential for reducing CO 2 emissions. Peer-reviewed paper. Proceedings of the 24 th International Conference on Passive and Low Energy Architecture (PLEA) November 2007, SINGAPORE. Gupta, R and Chandiwala, S. (2007). How to commission sustainable construction in further education colleges. Seacourt Publishers, Oxford. ISBN Gupta, R and Chandiwala, S. (2007). How to conserve energy in further education colleges. Seacourt Publishers, Oxford. ISBN Gupta, R, Sant ana, D and Chandiwala, S. (2007). How to conserve water in further education colleges. Seacourt Publishers, Oxford. ISBN Thank you for taking the time to contribute to this consultation. When responding to the consultation, please state whether you are responding as an individual or representing the views of an organisation. Please also include the following details about yourself and your organisation: Name: Prof. Tim Dixon and Dr Rajat Gupta Position: Professor (Dixon) and Reader (Gupta) Organisation: OISD, Oxford Brookes University Organisation type e.g. property developer, architect, NGO: Research and education address: tdixon@brookes.ac.uk Tel: Please note that, copies of the responses we receive may be made publicly available at the end of the consultation period. The information they contain including your name, organisation name and any other personal information may also be published in a summary of responses. Unless you state otherwise we will assume you are happy for us to publish your response. If you have any questions in this regard please contact 12