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Letter to the Welsh Assembly

As a member of Fforwm BREEAM, Eco-futures have recently contributed to a letter to the Welsh Assembly Government expressing our concern over the current policy direction with regard to sustainability:-

Dear Sirs

After attending the presentation by a Welsh Government Official at the ‘Nearer to Zero’ conference in Cardiff we felt that it was important to write this letter to the Assembly and its Members to highlight the short sightedness of current policy direction and the hugely damaging impact it could have on a whole range of innovative leading-edge professions in Wales.

Whilst we fully recognise the need to reduce the regulatory barriers to construction and house building in Wales and the socio-economic imperative to get Wales building again; the new Part L and the removal of TAN22 can only be seen as a retrograde step for a Sustainable Wales. As a direct result of the TAN22 requirements imposed back in 2009, Wales has grown a substantial industry of SME’s, contractors and Architects that understand and can deliver the highest levels of BREEAM and CODE. At the 2013 Awards 3 of 8 UK and 3 of 17 worldwide award winning buildings were located in Wales.

It makes absolutely no sense, from a sustainability perspective, to throw all of that progress aside for industry or developer short-term gains.  With The Welsh Government’s and the National Assembly’s Statutory Duty to govern with Sustainable Development at the fore, makes this policy shift hard to justify.  Especially, when as a direct consequence of this change, over 100 SME companies will be put at risk alongside many hundreds of employees; as a result of one simple appeasement to industry lobbyists. Wales needs houses but, it cannot afford to lose these high quality environmental and sustainable professional services.

The Main issues we see with the route outlined in the current proposals:

  • The requirement for us to continually progress towards Carbon Zero has been assisted by teams trying to attain CODE and BREEAM. With this aspirational level we have learnt a great deal on how to achieve these levels efficiently, with minimal cost. With TAN22 rolled up into the Building Regulations there is no vehicle to mandate, or provide guidance on, higher levels of sustainability and therefore prove the future knowledge and understanding required by the industry.WHERE WILL WE FIND THE KNOWLEDGE TO DELIVER FOR THE 2016 REGULATIONS

            “If you take away the first step, the next one just becomes bigger”. 

  • Timing and Enforcement by Building Control. We know from experience that the highest possible levels of sustainability and quality come from developments having had input at the earliest stages. Building Control is only brought into play as construction starts and therefore we lose any ability to correct any errors or omissions without substantial cost and conflict. Their findings will be too late to be implemented. With regards to enforcement, we believe this is simply not possible in the current climate. Building Control cannot, with all due respect, have the time, manpower and knowledge to enforce these higher levels of attainment.HOW CAN BUILDING CONTROL IMPACT ON PLANNING AND EARLY DESIGN DECISSIONS? 
  • TAN22’s use of the Code allows for a holistic approach to sustainability and covers a multiple aspects (Water use, Ecology, Drainage and flooding issues, Transport, Materials, and Construction Site Impacts); this will not be addressed by Part L alone. There is a serious risk that the sustainability and overall quality of housing will decline in the short term. Our members have provided data that shows the total cost of the assessment process equates to approximately £175 per dwelling, far less than the price on a front door.HOW CAN ALL THE RELEVANT ISSUES RAISED IN CODE/ BREEAM BE INCLUDED WITHIN REGULATION? 
  • It is also our understanding that Scotland has proceeded down this route with their Section 7 of the Building Standards and it has not worked particularly well. To such a degree that there is now a lobby to bring back some form of formal certification process by third party assessors.

There is an existing SME driven industry in Wales that is expert in studying, reviewing, training and policing these higher levels of sustainability in the form of our Members within Fforwm BREEAM and others. These organisations will have no further role as the proposed legislation stands.

We have our own, counter proposal, that we’d like you to consider, engage in and support:

The extra-over cost per house built, of pursuing TAN22 environmental standards, is less than £200 per house. Wales aspires to build an additional 8,000 new affordable homes over the next 3-5 years. We propose that the Welsh Government should ring-fence and redirect some of the efficiencies that will flow from inevitable public sector reform towards offsetting this perceived burden to the Industry. Not only would this £2m intervention protect and promote the vital Environmental Professional Services sector in Wales and the hundreds of high quality jobs it creates, it would also: 

i.         Protect Wales’ Unique Differentiator to the World, that we set ‘Environmental Excellence’ as our standard.

ii.       Shield the families who will occupy these new affordable homes from Fuel Poverty

 We’d also urge you to test whether the work done so far, particularly around the impact assessment and cost benefit analysis has taken adequate account of the adverse impact upon:  this vital professional services sector; Wales’ reputation and environmental credentials; and the long-term impact upon families occupying homes that aren’t as environmentally efficient as they should be.


For and on behalf of Fforwm BREEAM.