Source · Select Committees · Environmental Audit Committee
First report - Building to net zero: costing carbon in construction
Environmental Audit Committee
HC 103
Published 26 May 2022
Recommendations
5
Acknowledged
Local authorities are mandating WLC assessments of their own accord.
Recommendation
Local authorities are mandating WLC assessments of their own accord. Evidence so far shows that the policy is achievable and is working, with few barriers to its introduction. Introducing mandatory WLC assessments for buildings could be an easy way for …
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Government Response Summary
The government acknowledges calls for a clearer timeline for mainstreaming assessment, management, and reduction of embodied carbon, stating they are engaging with stakeholders, watching the GLA's requirements, and looking at international policy examples to build a robust evidence base.
6
Accepted
Para 74
We recommend that Ministers immediately assign responsibility to the relevant member of the BEIS Departmental...
Recommendation
We recommend that Ministers immediately assign responsibility to the relevant member of the BEIS Departmental Board to monitor international policy developments in embodied carbon, with a remit to feed observations into the development of UK policy on embodied and whole-life …
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Government Response Summary
BEIS is already leading the UK involvement in the Industrial Deep Decarbonisation Initiative (IDDI), an international alliance that aims to create markets for low carbon industrial materials, and is planning a roadmap on guidance for harmonisation of product level embodied carbon disclosure and on carbon limits.
7
Deferred
Para 75
We recommend that the Government introduce, not later than December 2023, regulations to mandate whole-life...
Recommendation
We recommend that the Government introduce, not later than December 2023, regulations to mandate whole-life carbon assessments for buildings above a gross internal area of 1000m2, or which create more than 10 dwellings. This requirement should be established in Building …
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Government Response Summary
The government intends to consult in 2023 on mainstreaming the measurement and reduction of embodied carbon, considering various levers including building regulations, and will carry out research and analysis to understand the impacts of potential interventions, with a focus on SMEs.
8
Rejected
Para 76
The timeline for the Future Homes Standard should be brought forward to December 2023 to...
Recommendation
The timeline for the Future Homes Standard should be brought forward to December 2023 to align the timeframes for addressing operational and embodied carbon. This will help provide the industry with the confidence it requires to construct low- carbon, energy …
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Government Response Summary
The government will not alter the timeframe for the Future Homes Standard (2025), stating it delivers on net zero commitments while ensuring new homes are delivered. However, they are accelerating work on a full technical specification for the Future Homes Standard, to be consulted on in 2023 and legislated in 2024.
9
Accepted in Part
Para 77
We recommend that following the introduction of whole-life carbon assessments, the Government should develop progressively...
Recommendation
We recommend that following the introduction of whole-life carbon assessments, the Government should develop progressively ratcheted carbon targets for the built environment, to match the pathway to net zero set out in periodic carbon budgets. These ratcheting targets should be …
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Government Response Summary
The government will explore the potential of a maximum embodied carbon level for new buildings in the future, but emphasizes the need for a robust evidence base of building-level whole life carbon data, while also citing the importance of territorial emissions reporting and urging other countries to raise ambition on tackling climate change.
10
Deferred
Para 78
We recommend that a clear timeframe for the introduction of mandatory whole-life carbon assessments and...
Recommendation
We recommend that a clear timeframe for the introduction of mandatory whole-life carbon assessments and ratcheting targets should be set by Government by the end of this year.
Government Response Summary
The government plans to consult on their approach to embodied carbon in 2023, and further information about this will be provided in due course.
11
Acknowledged
In our view, the RICS Professional Statement on whole-life carbon assessments is fit for use...
Recommendation
In our view, the RICS Professional Statement on whole-life carbon assessments is fit for use and already familiar to UK industry. We recommend that, as soon as possible following promulgation of the planned update of the Statement, the Government should …
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Government Response Summary
The government recognizes the importance of a standardised method of calculation for assessing embodied carbon and commends industry for developing standards like BS EN 15978, PAS2080 and the RICS Professional Statement. The government will look at whether endorsement of specific standards, methodologies or tools for assessing whole life carbon is appropriate.
13
Accepted in Part
Para 91
We recommend that the Government should change the term embodied energy to embodied carbon in...
Recommendation
We recommend that the Government should change the term embodied energy to embodied carbon in the National Model Design Code and provide a clear definition of embodied carbon and whole-life carbon in the NMDC based on the WLCN, Building to …
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Government Response Summary
The government is reviewing comments on the National Model Design Code and will assess these in light of reforms to the planning system, and are offering support on themes related to the coding process. However, they state that detailed guidance on how to assess embodied carbon should be defined separately to the NMDC.
15
Accepted
Para 107
The Department for Business, Energy, and Industrial Strategy should invest in raising awareness within the...
Recommendation
The Department for Business, Energy, and Industrial Strategy should invest in raising awareness within the industry and amongst the public on the existence and benefits of low-carbon cement and continue to encourage research and development into new low-carbon products.
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Government Response Summary
BEIS is working with the Green Construction Board, the wider membership of the Construction Leadership Council and the ICE to promote the Low Carbon Concrete Routemap to industry, and outlines the recommendations for clients, designers, contractors and suppliers.
16
Acknowledged
Para 108
We recommend that the Government investigate possible ways, beyond public procurement, to incentivise the use...
Recommendation
We recommend that the Government investigate possible ways, beyond public procurement, to incentivise the use of low-carbon cement to ensure that these cement alternatives become the product type of choice by 2030. This should include an assessment of the feasibility …
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Government Response Summary
The Government will work with manufacturers through the GCB to understand the opportunities and barriers to decarbonise cement manufacture, as well as individual manufacturer plans, for policy development.
18
Acknowledged
Para 126
Mandating whole-life carbon assessments for buildings, as we have already recommended, would be a simple,...
Recommendation
Mandating whole-life carbon assessments for buildings, as we have already recommended, would be a simple, material neutral way of encouraging the greater reuse and recycling of steel components.
Government Response Summary
The government acknowledges that WLCAs may increase awareness of recycling and reuse rates, and states they would like to increase their understanding of the potential impact through further evidence gathering.
19
Accepted
Para 127
The Government should work with local authorities to investigate effective and appropriate ways to store...
Recommendation
The Government should work with local authorities to investigate effective and appropriate ways to store and catalogue steel components for reuse and to communicate the availability of components across local area networks of constructors prepared to reuse steel.
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Government Response Summary
The Government has worked with steel producers and major customers to encourage the development and use of digital information about steel products, to support the use of ‘Object Libraries’ and other digital design tools that accelerate the design of projects, and continues to support the use of BIM technologies.
23
Accepted in Part
Para 153
The Government must develop a coherent policy, joined up across Departments, to address the need...
Recommendation
The Government must develop a coherent policy, joined up across Departments, to address the need for increased tree planting to address biodiversity and climate change concerns and the need for sustainable commercial plantations using appropriate tree species to meet the …
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Government Response Summary
The government highlights the England Tree Action Plan, the Nature for Climate Fund, and the Timber in Construction Working Group to design a policy roadmap, which will report before the end of this Parliament, but notes that further research is needed regarding safety implications and the realistic supply of domestic timber.
24
Accepted
Para 154
In response to this report, Government should set out how its strategies to develop green...
Recommendation
In response to this report, Government should set out how its strategies to develop green jobs will address the need for skills in timber use in construction.
Government Response Summary
The cross-government and industry timber in construction working group will design a policy roadmap, with education and skills within the timber in construction sector being a key element. The Government will work with industry to co-ordinate and increase sharing of best practice for skills in timber in construction.
25
Accepted
Para 155
The Government must invest now in further research and safety testing on the use of...
Recommendation
The Government must invest now in further research and safety testing on the use of structural timber. The outcome of such research must inform a review of all relevant building regulations so as to render them properly applicable to modern …
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Government Response Summary
The government has committed to encouraging research into barriers to uptake of timber in construction, including looking at timber strength grades and the fire resistance of engineered timber structures. The government also published its response to the combustibles ban consultation in June.
27
Acknowledged
Para 163
The Government should encourage development of a centralised national database of EPDs and, through its...
Recommendation
The Government should encourage development of a centralised national database of EPDs and, through its own procurement practices require the collection and publication of EPDs. The EPD database should be digital, freely available to end users, and user-friendly.
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Government Response Summary
The government is considering evidence from a Call for Evidence on how an emissions reporting system should be designed and implemented, and is participating in the Industrial Deep Decarbonisation Initiative (IDDI), which encourages the use of consistent reporting standards. The IDDI launched an emissions disclosure pledge at COP26.
28
Acknowledged
To limit ‘greenwashing’, the Government should introduce measures requiring suppliers who wish to make an...
Recommendation
To limit ‘greenwashing’, the Government should introduce measures requiring suppliers who wish to make an environmental claim about a construction product to produce an EPD to substantiate it. (Paragraph 164) Building to net zero: costing carbon in construction 69
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Government Response Summary
The government is aware of measures in other jurisdictions that put an obligation on manufacturers to substantiate environmental claims and is considering this as it prepares to consult on a range of domestic measures, including emissions reporting and disclosure, by the end of 2022.
29
Deferred
Para 165
The Government should conduct a cost-benefit analysis of whether to provide advice or financial support...
Recommendation
The Government should conduct a cost-benefit analysis of whether to provide advice or financial support to smaller manufacturers to enable them to produce EPDs for their materials.
Government Response Summary
The government is exploring options to reduce the burden of emissions reporting, especially for SMEs, and preparing to consult on domestic measures by the end of 2022.
32
Acknowledged
The Government should also issue its response to the consultation on the draft Waste Prevention...
Recommendation
The Government should also issue its response to the consultation on the draft Waste Prevention Programme for England: Towards a Resource-Efficient Economy not later than the date the House rises for the 2022 summer recess. This will be over a …
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Government Response Summary
The new Waste Prevention Programme is being revised following consultation in 2021, and publication is expected later in 2022. There will be further engagement on individual policies set out in the Programme.
35
Not Addressed
We recommend that, in its response to this report, the Government should set out the...
Recommendation
We recommend that, in its response to this report, the Government should set out the number and proportion of public works construction projects for which whole- life carbon assessments have been undertaken pursuant to the provision in the 2020 Construction …
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Government Response Summary
The government states that the Construction Playbook sets out best practice guidance, including the use of whole life carbon assessments, but there are no plans to collect and publish information on the number of projects where an assessment has not been undertaken. However, they are exploring a set of industry recognised standards and guidance for WLC assessment.
36
Deferred
Para 183
We recommend that the Infrastructure and Projects Authority establish clear guidance on the criteria for...
Recommendation
We recommend that the Infrastructure and Projects Authority establish clear guidance on the criteria for exemption from conducting whole-life carbon assessments for public works projects. We further recommend that, not later than the spring of 2023, the Government undertake a …
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Government Response Summary
The government is working internationally through the IDDI to establish a common roadmap and principles for whole life carbon and reporting of public construction, and the IPA is running a cross-Whitehall working group to propose a consistent Whole Life Carbon Assessment for public projects by 2023. A consultative process on policies to combat carbon leakage and grow the market for low emissions industrial materials will begin later this year.
37
Accepted
We recommend that the Government bring forward legislative proposals, by amending the Procurement Bill if...
Recommendation
We recommend that the Government bring forward legislative proposals, by amending the Procurement Bill if necessary, so as to require a whole-life carbon assessment to be produced as a condition of participation in any tender for publicly financed building projects. …
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Government Response Summary
Contracting Authorities are already able to request a whole-life carbon assessment during the procurement process where relevant and proportionate, and this will remain the case after rules reform.
39
Deferred
Para 214
We recommend that Ministers urgently commission a comprehensive evaluation of the impact which recent amendments...
Recommendation
We recommend that Ministers urgently commission a comprehensive evaluation of the impact which recent amendments to permitted development rights have had on incentives to retrofit existing properties. The outcome of that evaluation should inform further amendments to the permitted development …
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Government Response Summary
The government will review the National Planning Policy Framework to make sure it contributes to climate change mitigation and adaptation as fully as possible, and believe that consideration of retrofit vs demolition is best addressed through this review. They have no plans to carry out specific research of the impact of permitted development rights on incentives to retrofit existing properties, but continue to keep the application of the right under review.
41
Acknowledged
Para 216
We recommend that Ministers evaluate the impact of the time-limited zero- rate of VAT for...
Recommendation
We recommend that Ministers evaluate the impact of the time-limited zero- rate of VAT for the installation of certain Energy Saving Materials well before its expiry date of 2027, with a view to extending the provision beyond 2027 if it …
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Government Response Summary
The government acknowledges the importance of ESMs, but states that further changes to VAT would require careful consideration and consultation to ensure value for money and prevent unintended behavioral effects, in the context of over £50 Billion of requests for relief from VAT received since the EU referendum.
42
Deferred
Para 217
A mandatory requirement to undertake whole-life carbon assessments when undertaking building projects will further incentivise...
Recommendation
A mandatory requirement to undertake whole-life carbon assessments when undertaking building projects will further incentivise retrofitting. This provides another justification for our whole-life carbon recommendation in chapter 2.
Government Response Summary
The government intends to consult in 2023 on measuring and reducing embodied carbon in the built environment.
43
Deferred
Para 218
We recommend that circular economy statements including pre-demolition audits should be a requirement of planning...
Recommendation
We recommend that circular economy statements including pre-demolition audits should be a requirement of planning applications which entail demolition of properties, as is already the case for certain applications which London boroughs are required to refer to the Mayor of …
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Government Response Summary
The government will consider the role of circular economy principles in national planning policy as part of a review of the National Planning Policy Framework.
45
Accepted
We recommend that the Government work with industry to increase consumer awareness of the environmental...
Recommendation
We recommend that the Government work with industry to increase consumer awareness of the environmental and monetary benefits of high-quality retrofit solutions with a view to increasing the uptake of retrofit work in line with the net zero trajectory and …
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Government Response Summary
The government states they are working to review and improve communications to ensure that consumers have access to the information and advice they need to make retrofit decisions. They mention the Simple Energy Advice Service (SEA) and a new heat pump online calculator.
47
Accepted
Para 234
We reiterate our recommendation to develop a retrofit strategy and up-skilling programme for construction to...
Recommendation
We reiterate our recommendation to develop a retrofit strategy and up-skilling programme for construction to meet the needs of net zero. This should be published before the 2022 summer recess.
Government Response Summary
The government asserts that they agree with the committee and highlights the Green Jobs Delivery Group, the Department for Education's Sustainability and Climate Change Strategy, free Level 3 qualifications for adults, and the Green Apprenticeships Advisory Panel (GAAP) to work with employers to align apprenticeships to net zero objectives as already covering this.
48
Acknowledged
Alongside a mandatory requirement to undertake whole-life carbon assessments and a national methodology for assessments,...
Recommendation
Alongside a mandatory requirement to undertake whole-life carbon assessments and a national methodology for assessments, the Government should make training 72 Building to net zero: costing carbon in construction in undertaking whole-life carbon assessments accessible across all levels of education …
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Government Response Summary
The government is reforming the skills system to create more routes into skilled employment and employers are at the heart of these reforms. They are using existing programmes to support construction skills and working alongside industry to ensure that their existing skills programmes can be directed to support the net zero agenda.
Conclusions (19)
1
Conclusion
Acknowledged
Para 69
There is no Government policy requiring the assessment or control of embodied carbon emissions from buildings. As a result, no progress has been made in reducing these emissions within the built environment. This inaction remains despite the built environment making up 25 per cent of the UK’s total greenhouse gas …
Government Response Summary
The government acknowledges the lack of policy and highlights existing decarbonisation strategies and the intention to explore a maximum embodied carbon level for new buildings.
2
Conclusion
Acknowledged
Para 70
A broad cross-section of the construction industry is willing and able to undertake whole-life carbon assessments. In the absence of an approved UK national methodology, the RICS Professional Statement on WLC is used as the accepted industry methodology for WLC assessments. Alongside this, various further guidance and software tools have …
Government Response Summary
The government agrees that a standardized method of calculation is required to consistently assess embodied carbon, and will look at whether Government endorsement of specific standards, methodologies or tools for assessing whole life carbon is appropriate.
3
Conclusion
Acknowledged
Para 71
The Department for Business, Energy, and Industrial Strategy is currently considering the possibility of funding an update of the RICS methodology. This update is intended to make the methodology more accessible and more transparent thus addressing the concerns raised by Ministers to us about the RICS methodology. Once the national …
Government Response Summary
The government understands the importance of a consistent methodology for reporting whole-life carbon and welcomes plans to update and expand the RICS Professional Statement, with government officials continuing to contribute to this activity.
4
Conclusion
Acknowledged
Para 72
The UK is slipping behind comparator countries in Europe in monitoring and controlling the embodied carbon in construction. If the UK continues to drag its feet on embodied carbon, it will not meet net zero or its carbon budgets. There is significant opportunity for the UK to learn from emerging …
Government Response Summary
The government acknowledges that some countries in Europe have started legislating whole life carbon assessments and will review the different methodologies employed by these countries, and monitor the impact of their implementation, to help inform future policy-making.
12
Conclusion
Accepted
Para 90
The National Model Design Code represents a good start to the task of improving efficiency and reducing the environmental impact of materials used in construction. Regrettably, in its current form it does not provide the ambition or detailed guidance necessary if it is to make a meaningful contribution to addressing …
Government Response Summary
The government states that the National Model Design Code encourages local councils to set design standards, develop policies that consider the assessment whole life costs and implement sustainable construction, focusing on reducing embodied energy and embedding circular economy principles, and should be read as part of the National Design Guide.
14
Conclusion
Accepted
Para 106
We welcome the Government’s investment in the development of low-carbon cements as set out in the Industrial Decarbonisation Strategy. Alongside research and development, more needs to be done to raise awareness of low-carbon cements within the industry and amongst the public, to generate demand and increased investment in these products.
Government Response Summary
The government highlights the publication of the Low Carbon Concrete Routemap, a comprehensive guide to reducing carbon emissions associated with the construction industry developed through collaboration by a wide range of independent experts.
17
Conclusion
Accepted
Para 125
The reuse of steel components is not yet common practice in the UK. One of the main barriers to steel reuse is the collection, storage, testing and certification of used steel components. The Department for Business, Energy and Industrial Strategy and the Infrastructure and Projects Authority are already investing in …
Government Response Summary
BEIS is continuing progress on providing the sector with support to decarbonise, which includes support provided through the increase of the EII compensation scheme, funding steel projects through programmes such as the Industrial Fuel Switching competition, and the Industrial Energy Transformation Fund.
20
Conclusion
Acknowledged
Para 150
Significant obstacles to the uptake of timber products in construction remain. These include issues regarding fire risk and insurance, price volatility, securing sustainable and local supply chains, and addressing skills gaps in the use of timber. The Government has made little progress in addressing these barriers since the Climate Change …
Government Response Summary
The government acknowledges the obstacles to timber uptake and highlights the establishment of a Timber in Construction Working Group to design a policy roadmap, expected by the end of 2023.
21
Conclusion
Accepted
Para 151
The post-Grenfell prohibition on the use of combustible materials in external walls has had a disproportionate impact on the use, innovation and testing of structural timber. Material safety perceptions have also affected the availability and cost of insurance, making it near impossible for developers to use timber in high rise …
Government Response Summary
The Government has kept the outright ban on the use of combustible materials in and on the external walls of new blocks of flats, hospitals, and student accommodation over 18 metres, and introduced statutory guidance for residential buildings between 11 metres and 18 metres (to commence on 1 December 2022).
22
Conclusion
Acknowledged
Para 152
Whilst timber is often the most appropriate material to use to lower the embodied carbon of a building project, it cannot be assumed that this will always be the case. Timber use, from appropriate sources, should be verified as the best whole-life carbon answer to a given construction project, in …
Government Response Summary
The government recognizes the importance of a whole life carbon approach when using timber in construction and encourages the industry to use the most appropriate low carbon materials and to produce efficient low-carbon designs. They also state that the Timber in Construction Working Group will consider how to sustainably increase timber supply to meet increased demand.
26
Conclusion
Acknowledged
Para 162
There is a lack of Environmental Product Declaration (EPD) data for a wide range of materials, limiting the ability of developers to choose low-carbon materials. The UK is falling behind European counterparts where EPD data is far more widely available, resulting in developers choosing European materials over locally sourced UK …
Government Response Summary
The government acknowledges the lack of EPD data and highlights the Industrial Decarbonisation Strategy and the Call for Evidence to develop policy proposals for low emissions industrial products, with a consultation planned by the end of 2022.
30
Conclusion
Deferred
Para 166
There is availability of low-carbon and recycled building products to meet current demand, however there are insufficient incentives for product manufacturers to develop new low-carbon materials and for developers and designers to use these products. The Government has invested in initiatives and programmes, set out in the Industrial Decarbonisation Strategy, …
Government Response Summary
The government intends to consult on interventions to mainstream the measurement of embodied carbon in the built environment in 2023, noting that WLCAs can only be successfully implemented as part of a broader effort to decarbonise industrial supply chains. They are also developing policies in this area, including product standards, product labelling, and public and private procurement initiatives.
31
Conclusion
Acknowledged
Para 167
In our view, the most effective way overall to encourage resource efficiency and the development and use of low-carbon materials, whether low-carbon concrete, steel, timber, or any other material, is to establish a mandatory requirement to measure whole-life carbon and introduce progressively more stringent carbon targets on buildings.
Government Response Summary
The government acknowledges the important role that measuring whole-life carbon can play. They state that they will consult on their approach and proposals to mainstream the measurement and management of embodied carbon in 2023.
33
Conclusion
Acknowledged
Para 180
The Government has committed to using public procurement to drive demand for low-carbon industrial products and expects whole-life carbon assessments to be undertaken in respect of all public works projects. The extent to which this expectation is met, and the impact it has had on procurement practice, is unclear. Guidance …
Government Response Summary
The government acknowledges the lack of clarity and highlights the UK's work with the Industrial Deep Decarbonisation Initiative (IDDI) to establish common principles for whole life carbon and reporting of public construction.
34
Conclusion
Rejected
Para 181
Public procurement policy which mandates the completion of whole-life carbon assessments could kick-start the market for low-carbon construction. In time, a low- carbon standard for public works projects would help to remove the data barriers to establishing this market. The introduction of a Procurement Bill in the 2022– 23 Session …
Government Response Summary
The government states that while the Procurement Bill offers an opportunity to reform procurement rules, it does not include specific provisions on the target to achieve net zero carbon emissions by 2050, and it would not be appropriate to include such policy priorities on the face of the Bill to include in individual procurements.
38
Conclusion
Acknowledged
Para 213
Retrofit and reuse of existing buildings, where practicable, should be prioritised over new build to conserve resources, minimise embodied carbon emissions, reduce demolition waste and deliver cost-effective solutions to delivering on housing demand. Local authorities and housing developers are expected to balance multiple objectives when meeting housing needs, and therefore …
Government Response Summary
The government reiterates its commitment to upgrading homes to EPC Band C by 2035 where practical and has committed £6.6 billion to support upgrading the energy efficiency of existing homes, while also mentioning permitted development rights and their review.
40
Conclusion
Acknowledged
Para 215
We welcome the steps taken by the Chancellor of the Exchequer to address the inequity in the VAT regime between new build and retrofit. We nevertheless note that this differential treatment will expire in 2027 and is limited in scope, covering only Energy Saving Materials rather than broader aspects of …
Government Response Summary
The government acknowledges the VAT inequity and highlights existing reduced VAT rates for certain residential renovations. Extending this to all property renovations would cost £3.75 billion per year.
44
Conclusion
Accepted
Para 219
A lack of consumer awareness regarding retrofitting solutions, the perception that retrofit work is costly and/or disruptive, and consumer mistrust in the retrofit sector’s ability to deliver quality housing solutions, is creating further barriers to investment in retrofit. In our view there is a clear role for Government to support …
Government Response Summary
The Government acknowledges the cost of living pressures and highlights existing support packages. They claim to be stimulating demand for retrofit through direct investment, VAT reduction, strengthening minimum energy performance standards, supporting green finance, and improving consumer understanding, and outline existing quality assurance mechanisms.
46
Conclusion
Accepted
Para 233
The present shortage of workers in the energy efficiency and retrofit sector is chronic, given the overall timetable for decarbonisation of properties. This is a point we have repeatedly emphasised in our recent reports. Significant skills gaps also exist in the measurement of embodied and whole-life carbon and the use …
Government Response Summary
The Department of Business, Energy and Industrial Strategy has spent almost £6 million on a skills training competition which delivered around 7000 training opportunities for the energy efficiency and low carbon heating supply chains and are developing options for further funding. The Government also previously provided £4.7 million of funding to six local supply chain demonstration pilots.