The NLA Net Zero Expert Panel sent a letter to the Ministry of Housing Communities and Local Government in response to the consultation
concerning the ban on the use of combustible materials in buildings.
The panel believes that the use of timber plays a critical role in decarbonising construction and deliver our Net Zero targets. As a result, the group has made the following remarks in response to the consultation:
- Extending the ban on combustible materials needs to be proportionate, evidence-based and balanced against other factors influencing the design and construction of the built environment. In particular, the use of timber in facades, in the construction of balconies, and in solar shading devices (such as timber shutters or external louvres) may form a controlled and limited fire risk but serve to reduce the embodied carbon in construction.
- The recently introduced regulations that inhibit the use of specific combustible materials in the facades of residential accommodation above 18m seems to provide a balanced and proportionate approach. Extending the scope of the buildings to include hotels and other sleeping accommodation (which tend to be better managed than homes) could be a disproportionate response that inhibits the uptake of low carbon materials and the use of timber. The use of timber on and in facades and external features should be assessed using a fire-engineered approach to limit risk and the spread of flames, as covered by existing regulations.
- Impeding the use of materials with lower embodied carbon (such as appropriately specified timber) could impact opportunities for reducing national carbon emissions.*
- Including solar panels within the scope of the combustible materials ban will restrict the application of a renewable energy source and doesn’t appear to have an evidence basis, especially given the negligible fire load of the components on a solar panel.
- As an alternative strategy to extending the scope of the ban on combustible materials, the government should consider a programme of improving competency and awareness in existing regulations that are in place to protect life, and undertake a review of regulation enforcement. Dame Judith Hackitt’s recommendations already recommend a more stringent regulatory approach, although this only applies to tall buildings within a certain scope. Nevertheless, the Hackitt review highlighted poor levels of enforcement of building regulations and low penalties for non-compliance across the construction sector which allow constructors to compromise standards with potentially dangerous outcomes.**
- More should be done by the government to improve compliance and enforcement of building regulations, including improving competency and capacity in the construction sector (together with the professional and trade institutions) before a disproportionate extension of the scope on banning combustible materials is considered.
- This legislation should be drafted alongside a comprehensive understanding of the impacts on meeting our long term national carbon reduction commitments. The superstructure of a residential building accounts for 46% of total embodied carbon emissions (LETI)***. We need to drive the total emissions down and removed carbon wherever possible. The superstructure is low hanging fruit - replacement technology exists. Building large numbers of homes over the next decades without access to low and zero embodied carbon materials like mass timber as main structural elements will hamper the UK's ability to meet zero carbon aspirations by 2050.
The consultation closes on 23.45 Monday 25 May 2020.
The panel is formed by industry leaders from across London’s built environment sector – spanning from architecture, design, construction and planning – and acts as an advisory board to identify the key challenges and solutions for the built environment sector to contribute to achieve the zero carbon targets for London.
NLA Net Zero Expert Panel members
Marion Baeli, Partner, PDP
Ashley Bateson, Partner, Hoare Lea (Chair)
Gary Clark, Principal, Science and Technology Regional Leader, HOK London Studio
Juliette Morgan, Head of Sustainable Development, British Land
Nils Rage, Sustainable Design and Innovation Manager, Landsec
Douglas Phillips, Senior Environmental Analyst, Historic England
Craig Robertson, Associate, Head of Sustainability, AHMM
Tom Steel, Director, Heyne Tillett Steel
Sonal Jain, Director – Net Zero Carbon, Workplace and Clients, JLL
Derek Wilson, Senior Sustainable Development supervisor, TfL