Mayor criticises Government’s proposals to water down green policies

The Mayor of London, Sadiq Khan, has accused ministers of embracing the policies of ‘climate delayers’ by proposing national standards for carbon reduction in new homes that are lower and slower than those already being implemented in London. 

The Government’s proposed ‘2025 Future Homes Standard’ sets carbon reduction targets for new homes that are 25 per cent lower than London’s ‘Zero-Carbon Home’ standard introduced in the Mayor’s 2016 London Plan. 

This shortfall will be made worse by proposed Government amendments to the Planning Act 2008, which would withdraw local authorities’ powers to set tougher carbon reduction building standards than those set by ministers. This would effectively force London to adopt lower standards and slow its progress towards net-zero carbon emissions. Sadiq has recently said he wants London to be carbon-neutral by 2030.

Housebuilders have been embracing London’s higher standards for several years without this affecting their ability to build the homes London desperately needs. As a result of London’s higher standards, in 2018 alone, the capital achieved a carbon reduction of 39,000 tonnes of CO2 from new strategic development. London’s standards have also led to a boost in solar panel installations, with 5.5 MW of new electricity capacity created in London in 2018 as a result of the Mayor’s policies.

The Mayor has written to the Secretary of State for Housing, Communities and Local Government, Robert Jenrick, asking him to rethink the proposed new targets.

The Mayor of London, Sadiq Khan, said: “These shortsighted proposals are another example of how the Government is delaying urgent action on the climate emergency we are facing. 

“Hundreds of local authorities across England have declared climate emergencies – yet these proposals would hold back both the councils and developers who want to go further and faster to decarbonise new homes. London has shown how higher carbon reduction targets can be met while still delivering much-needed new homes.

“In a year in which the UK Government is supposed to be showing global leadership on climate change by hosting COP26, the government must show willingness to act and drop these damaging proposals – we cannot go forward by going back.”

The Government is proposing a 75 per cent target to come into force in 2025 – nine years after London successfully implemented a zero-carbon standard. 

The Government’s proposals are out of step with widespread public support for going further and faster on climate action. Recent opinion polling found 70 per cent of people questioned said they supported bringing forward the national net zero target from 2050 to 2030, whilst at least 265 local authorities have now declared a climate emergency ¹. The Government are also yet to set out a plan to meet the net-zero target adopted in June 2019.

Doug Parr, Policy Director at Greenpeace UK said: “In the midst of a climate emergency the government should be aiming for the highest standard for new homes, not lower them. Instead of showing leadership, the government is actually dragging some local authorities including London backwards just as carbon emissions from homes remain stubbornly high. Ministers should push for new homes that, instead of lining the builders' pockets and heating up the planet, keep people warm and save on their fuel bills as well. Boris Johnson cannot keep saying Britain is leading the world on climate when his government’s proposals don’t keep up with city mayors."

Kate Gordon, senior planner at Friends of the Earth, said: "At a time of climate crisis the government needs to be making all buildings energy efficient. Instead it's stifling ambition and innovation that places such as London are bringing about. If the government is serious about the climate emergency it should allow local authorities to set their own planning policies to deliver zero carbon, energy efficient development - as the London Plan rightly seeks to do. Building and development standards everywhere need to be made much tighter, otherwise we're left with homes that will need costly retrofits in the future. It is completely right that we plan and build homes to the highest climate standards.”

Camden Council Cabinet Member for a Sustainability, Cllr Adam Harrison said: “Camden, like many other local authorities nationally, has declared a climate emergency. We need national policies that support our zero carbon ambitions, yet the Future Homes Standard promises to remove our ability to retain our existing and more ambitious zero carbon homes standards even when it has proven to be deliverable across London since 2016. Government must not tie our hands – we will strongly oppose the proposals.”

Tor Burrows, Director of Sustainability and Innovation for Grosvenor Britain & Ireland, said: “The Future Homes Standard should be introduced before 2025 and include embodied carbon requirements as well as high fabric efficiency. We have to fix the bar high and all level up to the standards being set in London.”

NOTES TO EDITORS

·         London Plan 2016 (page 180) -  https://www.london.gov.uk/sites/default/files/the_london_plan_2016_jan_2017_fix.pdf

·         ¹ Local authorities who have declared a climate emergency - https://www.climateemergency.uk/blog/list-of-councils/  

Polling found 70 per cent of people questioned said they supported bringing forward the national net zero target from 2050 to 2030 -https://www.independent.co.uk/news/uk/politics/boris-johnson-climate-change-emergency-carbon-emission-cuts-a9280726.html

TEXT OF THE MAYOR’S LETTER TO THE SECRETARY OF STATE FOR HOUSING, COMMUNITIES AND LOCAL GOVERNMENT 

I am deeply concerned at MHCLG’s proposal to introduce national standards for carbon reduction in new homes which would be lower and slower than those that are already being implemented in London.

All the evidence shows that we must use every available measure to seriously tackle the climate emergency we face, and to meet the Government’s own net zero target. Some 250 local authorities across England have now declared a climate emergency. And polling this month showed that 70 per cent of those questioned said they supported bringing forward the net zero target. There is clearly wide public support for going further and faster, and I have pledged to make London carbon-neutral by 2030.

Decarbonising housing in London is a critical part of achieving net zero nationally, due to its population size and density and the nature of its building stock. To tackle this, in 2016 London established a zero carbon homes standard. Housebuilders have been building to London’s higher standards for several years – showing that it can be done. 

If MHCLG’s Part L proposals were to be adopted, the opportunity for other local leaders to set ambitious standards like those we have achieved in London would be lost. The proposals would deprive local leaders of a crucial way to accelerate achieving net zero nationally. This is not acceptable, and surely not in your interest. It is for these reasons that I urge you not to prevent local authorities which, like London, want to go further on decarbonisation from setting higher standards than Building Regulations. Government must set out a roadmap towards zero carbon homes as soon as possible, and tackle existing building stock as a matter of urgency.

Both carbon reduction options proposed in the Part L consultation would lead to an unacceptable lowering of standards in London. Our analysis shows that London currently requires a carbon improvement 25% higher than the preferred option set out in the consultation. As a result of our higher standards, in 2018 alone, London achieved a carbon reduction of 39,000 tonnes of CO2 from new strategic development – 39% more than required by current Building Regulations.

Introducing MHCLG’s proposals would also create uncertainty and confusion amongst house builders in London. There was previously a long-standing national trajectory towards zero-carbon homes, which gave the industry policy certainty and a timeline over which to invest in innovations and deliver improvements. The scrapping of this created a huge amount of uncertainty, and nationally, momentum in this area was lost. However, the consistent, strategic approach and clear timeline adopted in London, alongside the introduction of a net zero-carbon standard for homes in 2016, meant London could maintain a clear pathway towards zero carbon and has secured significant carbon reductions. London has demonstrated that this approach is both technically feasible and financially viable, while not impacting negatively on the delivery of much-needed new homes. 

London needs to be able to continue implementing our own established and more ambitious carbon targets, and I urge you to set out a national standard and roadmap towards zero carbon homes in such a way that other local leaders can set more ambitious targets as well. We will not move forward by going backwards.

I have outlined additional concerns below and enclose a technical response from my officers, who have already held a meeting with MHCLG officials on this issue and stand ready to work with your Department to find a solution to the issues identified. I await your urgent response.

Yours sincerely,

Sadiq Khan 

Mayor of London                    

Cc:       Rt Hon Andrea Leadsom MP, Secretary of State for Business, Energy and Industrial Strategy

Chris Philp MP, Minister for London 

            Sir Edward Lister, 10 Downing Street                               

Future Homes Standard: changes to Part L and Part F of the Building Regulations for new dwellings

Additional concerns

·         It is particularly disappointing that the proposed 2025 Future Homes Standard is not a net zero-carbon standard. This risks putting Building Regulations at serious odds with the Climate Change Act. Target setting is not enough; we need the supporting regulation and policy to make net zero-carbon buildings a reality. 

·         The removal of the Fabric Energy Efficiency Standard (FEES) alongside the updated carbon emission factors will mean that housebuilders will be able to meet Building Regulations by installing heat pumps in inefficient new homes – leading to poorly performing systems and higher energy bills for occupants.  

·         The proposed specification will not lead to the carbon savings envisaged. Based on our modelling of a typical London development, the preferred option of a 31 per cent carbon improvement on current Building Regulations (Option 2) actually translates to only a 14 per cent improvement; a further reason why we need to continue to apply our own carbon standards. 

·         The proposed specification under Option 2 will only result in a 22 per cent carbon improvement in flats. It is therefore misleading to state that the preferred option represents a 31 per cent carbon improvement. In London, apartments are comfortably meeting and surpassing our 35 per cent carbon improvement target, and therefore apartments should be made to meet higher standards. 

·         The proposed Performance Metrics and Carbon Factors in SAP 10.1 will also create a process that skews heating solutions towards building-level solutions. All decarbonisation scenarios for 2050, at a national and London level, require a contribution from heat networks (which your consultation recognises); but the current approach is actively discouraging developments from connecting to existing or planned heat networks.  

·         There are no proposals to capture the actual energy performance of new homes, to ensure they perform as intended and that occupant bills are acceptable. Officers understand that the Government is intending to consult on introducing mandatory in-use energy performance ratings for non-domestic buildings in the private sector in 2020. The same aspiration should be followed for domestic buildings. In the new draft London Plan, we are addressing this issue by requiring all major developments to report on energy performance post-construction to address the performance gap. My officers would welcome the opportunity to share our progress on this with Government. 

·         Currently, Building Regulations only consider the regulated emissions associated with heating and hot water use of new homes. The regulations need to tackle whole life-cycle carbon emissions, including unregulated emissions and those associated with materials, construction, repair, refurbishment, and end of life. As a minimum, Part L 2020 should account more accurately for unregulated emissions; however ideally it would also account for whole life-cycle carbon emissions through the calculation methodology. The new draft London Plan requires all developments referable to the Mayor to submit a whole life-cycle carbon assessment, and my officers would also welcome the opportunity to share our progress on this with Government.