Edge Responses
Edge Responses
The Edge regularly responses to governmental, parliamentary consultations and policy reviews that concern the built and natural environments. Below are the most recent consultation responses and thought pieces written by Edge members.
National Planning Policy Framework (NPPF) consultation:
September 2024
the Edge applauds the new MHCLG ministerial team’s determination to deal with the nation’s pressing housing issues without delay and the pragmatic approach to approaching practical problems within the planning system, but believes that the proposals lack ambition towards a number of fundamental, but equally urgent issues, including the unavoidable responsibility to tackle the crises in the climate, nature, and national health and wellbeing .
In particular the Edge asks that the Framework should include provisions for:
a focus on combatting climate change, nature recovery and ensuring the best use of natural capital
a comprehensive Land Use Framework, making wide use of available data sets covering all types of land, as a National Service to underpin the changes necessary.
A social approach to development to ensure new towns and developments are environmentally and socially, not just economically sustainable
An independent national built environment research organization with Public Sector Research Establishment (PSRE) status to advise on the design and delivery of safe, economic and environmentally and socially successful developments
Mandatory design review for masterplans and design codes above a set size with teeth to require changes to improve placemaking.
The Future Homes and Buildings Standards: 2023 consultation
March 2024
the Edge has responded to the consultation by both completing the, unsatisfactory, questionnaire and by sending a letter with key points to the Secretaries of State for Levelling Up, Housing, and Communities and Energy Security and Net Zero expressing the following concerns:
1. That the incremental tightening of fabric improvement measures has been brought an end far too soon
2. The need to tackle embodied carbon in construction and buildings has been intentionally and worryingly omitted and should have been included
3. The Future Homes proposals barely mentions the challenge of retrofitting existing homes
4. Selecting Primary Energy over Delivered Energy as the main metric for assessing compliance makes it impossible for building users to easily monitor
The Whole Life Carbon Assessment for the Built Environment, RICS Professional Standard, 2nd Edition EDGE response to Consultation
April 2023
the Edge has responded the the RICS’s consultion on its Whole Life Carbon Assessment tool with 5 points:
It is vitally important to agree and maintain a coherent and consistent cross-industry method for assessing, recording and sharing the whole life carbon emissions from built and natural environment projects.
The studious neutrality of the WLCA is misplaced and measurement of WLC should have definition and purpose
The section on biogenic materials needs both greater clarity and encouragement for the intelligent use of this valuable resource.
Beta-testing the WLCA tool before it is finalised is an essential step to getting it right
The complexity of making WLC assessments using this method will be excessively daunting for the majority of built and natural environment practitioners and everything should be done to help with making it as easy to use as possible.
Levelling Up and Regeneration Bill: Reforms to National Planning Policy - Edge response to consultation
March 2023
the Edge has responded to the Planning Policy Consultation run by the Departmetn for Levelling Up, Housing and Communities
Net zero provides a clear long-term policy environment that will generate beneficial economic activity and growth through a much needed decarbonisation programme that reduces both demand and cost. This will, in turn, produce much sought after exportable skills and trade opportunities for UK service providers.
The UK has huge potential for renewable power generation as a result of its geography. If exploited and combined with increased development in energy storage capacity this could lead to the extraordinary triple win of economic growth, energy security and net zero electricity production.
BEIS Net Zero review EDGE response to Call for Evidence
October 2022
in response to the Call for Evidence on Land use planning in England the Edge has stated that Planning is an essential mediator between the market and those who live, work and rely on the land and in its built and natural environments. Planning is capable of taking the longer and wider-term view that markets do not necessarily need to worry about. We have been dangerously operating with a half-functioning system of land use planning for too long and reform is now overdue. Land use policy should be a means of building bridges between departments, disciplines and interests, fostering collaboration and cooperation in order to achieve the Public Goods it is well capable of delivering.
Recommendations include:
That an effective and easily accessible (for all) land use strategy is put in place as a matter of urgency as an essential tool for good governance. It should be backed up by an effectively public information campaign and the introduction of a digital, data-rich mapping resource .
The Treasury Green Book Annex A1, Non-market Valuation and Unmonetisable Values section on Environmental and Natural Capital, and its associated DEFRA guidance Enabling a Natural Capital Approach, or the principles they embody, should be used as part of the appraisal of all land use proposals.
Reform needs to be handled jointly by local and national government, but requires a reinvigorated/reinvented/re-resourced local government system in order to thrive.
Land use planning needs to be agile and responsive and able to continuously to adapt to changing circumstances. Departmental silos must be discouraged from developing that might stymie the necessary adaptability.
Submission to the House of Lords Inquiry into Land Use in England
April 2022
Submission to the National Infrastructure Commission in response to the Second National Infrastructure Baseline Report
February 2022
in response to the strategy the Edge has recommended:
The Commission MUST consider and drive actions to reduce the embodied carbon in the materials of manufacture and construction
Investment in fundamental research must be supported through government directed grants to industry-based R&D in construction materials and new manufacturing processes
Support fo the proposed ‘Part Z’ regulations (https://part-z.uk/)
A move away from private personal transport in cities, relieving congestion and enabling improved use of space, especially road space, for other vital uses
the Edge welcomes the strategy and states that:
There needs to be more certainty of funding and an agreed, deliverable programme for the retrofitting of the education estate
It is vital to have a carbon performance verification of the school estate
Climate and ecological literacy must be included throughout the curriculum at primary, secondary, FE and HE
There are more jobs and careers than ‘green skills’ which will benefit from climate and ecological literacy
There can be no place for ‘business as usual’ unless it means normalising better behaviour .
Submission to the Department for Education on Sustainability and Climate Change Education - Strategy for education and children’s services systems
December 2021
the Edge has recommended that:
there should be a size limit on buildigns that could benefit from permitted development rights
the permited development right should not apply to areas of outstanding natural beauty, World Heritage Sites and conservation areas
issues including climate, local infrastructure, basic housing standards, protecting high streets, planning obligations and consultations should be considered
Submission to the Ministry of Housing Communities and Local Government on: Supporting housing delivery and public service infrastructure
January 2021
the Edge believes that:
The climate and biodiversity emergency needs to be the overriding focus of any proposals for changing the planning system.
Any changes must be closely co-ordinated with more ambitious and well-enforced building regulations and infrastructure delivery.
Actions to deliver both mitigation of and adaptation to global heating are essential
Submission to the Ministry of Housing Communities and Local Government on: Planning for the Future White Paper
- October 2020
Submission to the Business, Energy and Industrial Strategy Committee on: Post-pandemic economic growth
- July 2020
the Edge believes that while it is important that the construction industry returns to maximum health it is important to use the opportunity of the recovery to achieve two important and long-standing goals:
· Becoming an efficient, safer and more productive industry and, in particular, embracing the potential of the digital revolution to order to achieve this.
· Meeting the target of net-zero carbon emissions from the UK’s built environment by 2050 as an essential component of the UK’s commitment under the Climate Change Act.
the Edge has a particular interest in hydrogen (H2) as a potential future energy carrier for buildings because it fundamentally changes the current market direction of travel for what is naturally a very fragmented sector.
Summary points
The proposals:
- lack joined-up, systems-level thinking.
- have the appearance of being driven by vested interests
- ignore who pays for the duplicate zero carbon energy supply networks required
Submission to the Environmental Audit Committee on: Technological Innovations and Climate Change: Hydrogen
- June 2020
MHCLG Consultation on The Future Homes Standard and changes to Part L (conservation of fuel and power) and Part F (ventilation) of the Building Regulations for new dwellings
February 2020
The Edge is, above all, a collaborative organisation and this response has been developed in discussion with other expert groups, notably CIBSE and LETI.
Our greatest concern with the proposals is the mismatch between the stated objectives and level of ambition, including the need to meet the UK’s legal requirement to achieve net zero carbon emissions by 2050, and the progress towards them evidenced by the proposals. The new Part L should be taking us at least half way towards the envisaged and necessary 2025 standards and ideally 60% of the way there.
Please find our full consultation response in the links below.
We very much support the intent of the Social Value Act but are aware that its application is still relatively limited due to lack of awareness and guidance. We therefore welcome this consultation and the proposal to specifically include social value in contract awards criteria. This should make it clearer to procurement teams that social value should be considered alongside cost when awarding contracts, and it should prompt bidders to examine opportunities.
Submission in response to: Social Value in Government Procurement consultation
June 2019
DEFRA Consultation on Environmental Principles and Governance post-Brexit
August 2018
We welcome this consultation and the opportunity to contribute to shaping the UK’s future environmental framework. Our response has been informed by expertise in a range of disciplines, as appropriate for such a wide-ranging consultation document.
It is our view that the proposals in the consultation fall short of replacing the current arrangements, especially in terms of governance, and we have summarised our concerns and recommendations below.
National Planning Policy Framework (NPPF) Consultation
May 2018
The Edge acknowledges that the government’s primary objective in revising the NPPF is to encourage a rapid increase in the provision of dwellings in response to a well-recognised and urgent housing need. However the Edge cautions that this must be done in a way that supports place-making – with health and wellbeing, integrated sustainable transport systems and high environmental building performance levels to serve the present and the longer term future.
Construction Industry Council (CIC) Strategic Review
March 2016
The Edge recognises the valuable role that the Construction Industry Council (CIC) plays in the industry in representing a wide range of professional institutions and membership organisations. The Edge believes that both co-ordination and collaboration amongst the wide range of bodies that form the CIC is essential to the health and forward development of the industry and the main mission of the CIC should be to support this.
Simon Foxell of the Edge gave evidence to the National Policy for the Built Environment Committee of the House of Lords on 10th December 2015.
Links:
Lords Select Committee on National Policy for the Built Environment
See the Video recording here.
Read:
Building Better Places - Report of the Committee 2015-16
Edge submission to Select Committee on the National Policy for the Built Environment, October 2015
Notes prepared for the Selected Committee session - December 2015
A supplementary note about the workings of the Cambridgeshire Quality Panel, December 2015