Comment

Representation ID: 16742

Received: 11/10/2021

Respondent: Mr John Christophers

Dear Black Country consultation
My main comment on the plan is that all new homes should be built to net zero carbon standards
now.
The policy should include operational carbon emissions but also embodied carbon emissions. For a
new home, the embodied carbon emissions from construction can be as much as half the carbon
footprint measured over its 60-year design life (RICS, 2017).
There is a considerable evidence base for much stronger local standards, a there is no agreed national
standard, “Future Homes standard” still be some years away and subject to consultation.
The statutory Climate Change Committee have repeatedly made clear that national policies for new
homes are not yet driving change at the required pace (CCC, 2019).
The United Nations, IPCC, and other commentators consider 2050 targets will be too late to prevent
irreversible climate change, missing the Paris target to limit global warming to 1.5degC (UNCC, 2021),
(IPCC, 2021).
The Good Homes Alliance (GHA) Vanguard Network unites many local authorities who want to “Build
Net Zero Now”, rather than waiting for 2025 or 2030 (GHA, 2020).
There is clear evidence that new homes built merely to minimum Building Regulations standards - ie
not built to zero carbon standards - would be five times more expensive to retrofit a decade later
(Currie & Brown, 2019).
Construction is clearly the best point at which to make a home both energy efficient and low carbon.
I am happy to amplify/discuss any of these points further if you wish.
References
RICS (2017) Royal Instute of Chartered Surveyors. Whole life carbon assessment for the built
environment. Available at: hps://www.rics.org/globalassets/rics-website/media/news/whole-lifecarbon-assessment-for-the--built-environment-november-2017.pdf [Accessed 16 July 2021]
CCC (2019) Climate Change Commiee. UK Housing: fit for the future? Available at:
hps://www.theccc.org.uk/publicaon/uk-housing-fit-for-the-future/ [Accessed 16 July 2021]
UNCC (2021) United Naons Climate Change. NDS Synthesis report. Available at:
hps://unfccc.int/news/climate-commitments-not-on-track-to-meet-paris-agreement-goals-as-ndcsynthesis-report-is-published [Accessed 16 July 2021]
IPCC (2021) Climate Change 2021: The Physical Science Basis. Contribuon of Working Group I to the
Sixth Assessment Report of the Intergovernmental Panel on Climate Change. Available at:
hps://www.ipcc.ch/report/ar6/wg1/downloads/report/IPCC_AR6_WGI_SPM.pdf [Accessed 10 Aug
2021]
GHA (2020) Good Homes Alliance. Build Net Zero Now. Campaign iniave Available at:
hps://goodhomes.org.uk/campaign/build-net-zero-now [Accessed 12 Jan 2021]
Currie & Brown (2019) The costs and benefits of ghter standards for new buildings: A Report for the
Commiee on Climate Change. Available at: hps://www.theccc.org.uk/publicaon/the-costs-andbenefits-of-ghter-standards-for-new-buildings-currie-brown-and-aecom/ [Accessed 12 February
2021]