A widespread shift from demolishing buildings to reusing them requires urgent changes to both planning and building regulations, reports Adam Branson
Back in September, the AJ launched its RetroFirst campaign, to promote the retrofitting of existing buildings over demolition and rebuild. The problem it addresses is simple enough. While architects and engineers have become adept at designing and delivering buildings that are highly energy efficient operationally, the industry still has an unfortunate tendency to look at an existing building and decide that the best thing to do is to knock it down and build something new.
What is typically ignored is that the building’s embodied carbon will go to waste and that the new structure comes with an extensive carbon footprint of its own. Recent research by the Royal Institution of Chartered Surveyors found that just over half of the lifetime carbon emissions from a typical residential building can be attributed to activities and materials used prior to handover. The equivalent statistics for warehouses and offices are 47 per cent and 35 per cent respectively.
A large number of buildings have been needlessly torn down and replaced over several decades. Independent planning expert Peter Studdert, for instance, refers to the ‘over-enthusiastic demolition of perfectly sound Victorian terraced houses’ in some of the Housing Market Renewal Pathfinder Areas in the late 2000s, while Julia Park, head of housing research at Levitt Bernstein, cites the earlier demolition of Euston Station, and the Mappin & Webb building in the City.
The National Planning Policy Framework should be amended to include a ‘presumption in favour of refurbishment’
Housing estates are all too often bulldozed, says Joe Giddings, co-ordinator at the Architects Climate Action Network (ACAN) ‘There are a lot … Robin Hood Gardens, the Aylesbury Estate and the Heygate Estate were all unnecessarily demolished, or are in the process of demolition, when they could have been retained and refurbished.’
The RetroFirst campaign argues that it is overwhelmingly preferable to retain and upgrade buildings wherever possible, as well as maximising the use of reclaimed construction materials.
The campaign is multifaceted and includes specific proposals on changes to tax and public sector procurement. But it is also abundantly clear that reforms to both the planning and building regulations regimes are required. So, what might those reforms look like?
Local planning authorities (LPAs) already have the ability to include specific policies in their local plans and could take action to promote reusing buildings. But producing a local plan takes time and, quite simply, the planet can’t wait. We need national planning policies to promote retrofit.
‘England’s National Planning Policy Framework [NPPF] could be updated,’ suggests Giddings, ‘to include, for instance, new obligations that require any application proposing demolition of an existing building to demonstrate that reuse of the existing structure was first explored.’
Heygate dsc 0509©lottesheedy
Source: Lotte Sheedy
Studdert agrees that the NPPF should be amended and argues that a ‘presumption in favour of refurbishment’ should be inserted as a subset of the ‘presumption in favour of sustainable development’.
His suggested wording reads: ‘In determining planning applications, there should be a presumption in favour of developments that reuse and refurbish existing buildings.’
As Alex Ely, principal at Mæ, points out, such a policy is already in operation in the Netherlands. ‘In the Dutch system, you have to make the case that it is better value to replace rather than refurbish,’ he says. ‘There is a presumption in favour of refurbishment and you have to make the case if you want to rebuild.’
A requirement for developers to justify the need to demolish all but the smallest of buildings is also something that should be considered as part of the planning application process, argues Park.
‘It could require a “justification statement” outlining why demolition is necessary, including evidence of redundancy and an outline of future plans for the site,’ she says. ‘The level of detail should be proportionate to the scale of the building and in some cases a full, possibly costed, set of options may be required.’
The permitted development rights (PDR) regime also needs tackling. Worryingly, housing secretary Robert Jenrick used last year’s Tory conference to resurrect the party’s earlier suggestion to allow developers the right to demolish commercial buildings and replace them with homes without the need for full planning permission. Jenrick said that the ‘revolutionary’ idea would give ‘the freedom for a developer to demolish’. Park and other experts were aghast.
But even the PDR system in its current state is sorely in need of reform. At present, developers need planning permission in order to demolish any building within a conservation area. To save as many buildings as possible from the wrecking ball, the same principle could be applied across the board.
It is a glaring omission that embodied carbon is not included in the Building Regulations
‘Permitted development rights could be removed for any demolition,’ says Giddings. ‘It is still possible in a lot of cases to just demolish a building without applying first. This has to change.’
Any such move, however, would place further burdens on the development industry – obtaining planning permission for anything can be both time-consuming and costly – and central government may fear being seen to introduce more planning red tape. But, even if central government is unwilling to act, there are still steps that enlightened LPAs can take.
Most importantly, they have it within their power to issue an article 4 direction under a General Permitted Development Order (GPDO). This removes all or some of the permitted development rights on a site, depending on the outcome the LPA is seeking to achieve. Not all authorities will be willing to take such action, but as Giddings puts it, ‘the 65 per cent of councils that have declared a climate emergency would be a good place to start’.
Using the Building Regulations to prevent demolition is a trickier tactic as by that point in the process, any proposal to demolish a building will have planning permission. However, Building Regulations certainly could be reformed in order to promote the use of reclaimed building materials and embrace the concept of the circular economy.
‘It is a glaring omission that embodied carbon is not included in the Building Regulations,’ says Giddings.
Changing this could be done either by creating an entirely new part of the regulations or by amending ‘Part L’, which relates to the conservation of fuel and power. In addition, Building Regulation 7, which deals with materials and workmanship, could also be updated to take account of embodied carbon. ‘It is easy to imagine a few lines being added into that to encourage reuse of existing materials,’ Giddings concludes.
According to Geoff Wilkinson, a building inspector and AJ columnist, one of the biggest challenges is that the Building Regulations are only worded to recognise the use of new materials, which have to be certified.
‘When you are using recycled or upcycled materials, it is highly unlikely that they will be tested to the current standards, so you have this immediate barrier,’ he says. ‘What needs to happen is that the regulations are reworded and ensure that upcycled and recycled materials can be used.
‘We really need to ensure that we keep much better records of products and materials that are going into buildings to ensure that the paper trail is there. BIM [building information modelling] records can help us to determine that these materials are suitable for reuse.’
In addition, Wilkinson proposes that the regs should be updated to include both an Energy Performance Certificate and a new materials performance certificate. This could ensure a whole-life carbon approach so that the embodied carbon in the materials used forms as much of a part of a building’s sustainability profile as its potential in-use energy efficiency.
‘We need to move away from it being a simple measure of energy performance and into the issue of recyclability – the materials that have gone into the building and what the carbon journey has been,’ he says. ‘[A building] may well not produce much carbon, but the fact that we’ve flown the materials in from China has created a massive carbon footprint.
‘We could also say that a building needs to have a designed-life of 100 years, rather than 15 or 20 years. If it doesn’t meet that, it needs to have a higher level of recyclability.’
In this context, proponents of reform including architects should view Brexit as an opportunity, says Wilkinson. ‘With Brexit, we are potentially in the very helpful position of being able to start rewriting whatever rules we want,’ he argues. ‘Up until now we have been tied into European standards, but now we can actually be the world leaders on this. We could start to write codes of practice and regulations that aren’t tied to anyone else’s rules.’
With Brexit, we are potentially in the very helpful position of being able to start rewriting whatever rules we want
Policies to encourage material reuse are already included in the design section of the draft London Plan, which could be used as a template for other metro mayors who have control over strategic planning or for individual LPAs.
The principles could also be extended to cover other sectors. ‘Local authorities could follow the lead of the London mayor by introducing policies that support the circular economy,’ says Park.
Ely adds: ‘We’ve been working with the [London] mayor and one of the things we are looking to promote is the circular economy. It’s steering applicants to retain and refurbish where practical. If it isn’t, then new buildings need to be designed for the circular economy, so for disassembly and reuse.’
Other changes to the draft London Plan made at the behest of campaigners have also strengthened the case for reuse and could be replicated elsewhere.
Clare Richards, founder of not-for-profit practice ft’work, says that during an evaluation hearing, she and others argued passionately for the removal from the draft policy of ‘a clear default position of demolition and redevelopment’ of housing estates.
The new clause reads: ‘Before considering the demolition and replacement of affordable homes, boroughs, housing associations and their partners should always consider alternative options first. They should balance the potential benefits of demolition and rebuilding of homes against the wider social and environmental impacts.’
Then there is the potential to make changes to the developer contributions regime. As things stand, developers are required to make contributions to everything from affordable housing to new schools and doctors’ surgeries through section 106 agreements and the community infrastructure levy (CIL). Furthermore, the Environment Bill, which was laid before Parliament before last month’s general election and is expected to return imminently, will require developers to ensure that projects make a 10 per cent net gain to biodiversity and that the gain is maintained for 30 years.
‘New obligations could be created by introducing new sections to the Town & Country Planning Act that require legally binding agreements to be in place for the disposal or recycling of demolition waste,’ says Giddings. ‘The developer would pay a levy depending on what percentage is not recycled.’
Source: ‘Walworth 039’ by Surprise Truck. Licence: cc by 2.0
So there are plenty of ways in which the planning and building regulations systems could be reformed in order to support the aims of RetroFirst, but what are the prospects for them being taken forward?
On the face of it, the government should be responsive – after all, Parliament voted to declare a climate emergency just last year and a majority of local authorities have done the same. Perhaps even more significant is the UK’s new legally binding commitment to a net-zero economy by 2050 – a world first.
According to Richards, developers should be increasingly willing to get with the agenda. ‘People see development as something that is done to them and, for many people, the reality of demolition is in fact displacement and the loss of their community,’ she says.
‘Investors and developers are finally realising that building trust is essential. They are beginning to understand that environmental and social sustainability go hand-in-hand.’
Giddings also points to the response to the Grenfell Tower tragedy as a precedent for how action can be taken relatively quickly when a dire need for change has been identified.
‘Following this appalling tragedy, new sections were introduced into the building regs within two years and they continue to be revised,’ he says.
‘Whether the changes have gone far enough or been done in the right way is another matter, but the point is that following a very public disaster, changes were implemented relatively quickly. The case has to be made that given the scale and urgency of the climate emergency, everything should be under review.’
RetroFirst Logos 2019 3
RetroFirst: Can policy change encourage more retrofitting?