# / . 4 % 8 4 - ! 2 # ( )("# RESPONSE ON 0ART , 'ETTING THE BEST FROM ENERGY CONSERVATION !N EDITED VERSION OF THE )("# RESPONSE TO THE /$0- S @0OSSIBLE &UTURE 0ERFORMANCE 3TANDARDS FOR 0ART , 4HE )("# RECOGNISES THE IMPORTANCE OF THE ENERGY CONSERVATION AGENDA AND SUPPORTS THE GOVERNMENT S CONTINUING EFFORTS TO FULFIL ITS COMMITMENT TO THE +YOTO AGREEMENT 7HILE THE ABOVE DOCUMENT IS AT AN EARLY STAGE OF DELIVERING FUTURE IMPROVEMENTS IN ENERGY SAVING IN BUILDINGS THE INSTITUTE IS GRATEFUL FOR THE OPPORTUNITY TO PARTICIPATE IN THE PROCESS )T IS NOTED THAT THE GOVERNMENT INTENDS TO RETAIN THE GUIDANCE THAT RECOGNISES THAT NEW ENERGY SAVING STANDARDS MAY NOT BE APPROPRIATE FOR HISTORIC BUILDINGS 7E ASSUME THAT THE WORDING OF THE CLAUSE IN THE CURRENT !PPROVED $OCUMENT , !$, WILL BE SIMPLY BROUGHT FORWARD INTO THE NEW !$, (OWEVER THE INSTITUTE IS CONCERNED THAT THIS CLAUSE IS NOT MENTIONED UNDER THE SECTION @2EFURBISHMENT OF THE EXISTING STOCK AND TRUST THIS OVERSIGHT WILL BE CORRECTED FOR NON DWELLING HISTORIC BUILDINGS IN FUTURE DOCUMENTS AND !$, 4HE INSTITUTE WELCOMES THOSE MEASURES WHICH UNDERLINE THE CULTURAL IMPORTANCE OF HISTORIC BUILDINGS )("# MEMBERS ARE AWARE OF THEIR RESPONSIBILITY TO TAKE REASONABLE STEPS TO REDUCE ENERGY LOSS WHERE IT CAN BE ACHIEVED WITHOUT HARM TO THE CHARACTER AND IMPORTANCE OF THE HISTORIC BUILDING "UILDING CONTROL CHIEFS IN GENERAL FEEL CONFIDENT THAT 0ART , IS BEING IMPLEMENTED FLEXIBLY AND THEY SEEM TO BE TAKING A SENSIBLE APPROACH (OWEVER )("# MEMBERS IN SOME AREAS OF THE COUNTRY REPORT THAT THIS IMPORTANT CLAUSE IS NOT BEING IMPLEMENTED BY BUILDING CONTROL DEPARTMENTS AND OFFICERS 0ARTICULARLY WITH WINDOWS !$, IS BEING ENFORCED WITHOUT SUFFICIENT SENSITIVITY TO THE HISTORIC BUILDING IN QUESTION )T WOULD BE HELPFUL IF THE DEPARTMENT WOULD ISSUE FURTHER STRONGLY WORDED GUIDANCE TO BUILDING CONTROL DEPARTMENTS ENCOURAGING A MORE FLEXIBLE AND SENSITIVE APPROACH RECOGNISING THE REQUIREMENTS OF HERITAGE LEGISLATION AND THE IMPORTANCE OF INTER PROFESSIONAL DIALOGUE 4HE BIGGEST PROBLEM WITH WINDOWS STEMS FROM THE ACTIVITIES OF &ENSA REGISTERED COMPANIES &ENSA URGES GIVEN THE MASSIVE AMOUNTS OF EMBODIED ENERGY INVESTED IN THEIR CONSTRUCTION AND IN THE PROCESS OF DEMOLITION AND REDEVELOPMENT 4HE ENERGY USED TO MANUFACTURE MATERIALS AND CONSTRUCT A BUILDING IS OFTEN GREATER THAN THE ENERGY USED DURING THE BUILDING S LIFETIME 4HE THERMAL INSULATION VALUE AND CAPITAL REVENUE BENEFITS OF TRADITIONAL MATERIALS AND BUILDING TECHNIQUES ARE GREATLY UNDERVALUED 7E ARE SIMILARLY CONCERNED THAT NOW THAT SUSTAINABLE SOFTWOOD FORESTRY IS A REALITY PRICE AND ADVERTISING ARE STILL ENCOURAGING THE PUBLIC TO REPLACE TIMBER WINDOWS AND DOORS WITH 06#U AND OTHER UNSUSTAINABLE PRODUCTS #ONCERN CONTINUES TO BE EXPRESSED ABOUT THE DIOXIN CONTENT OF SOME PLASTIC BUILDING PRODUCTS 4IMBER WINDOWS CAN ACHIEVE THE SAME LEVELS OF ENERGY CONSERVATION OF @MODERN MATERIALS !S THE PURPOSE OF !$, IS TO HELP CONSERVE AND PRESERVE THE PLANET JOINED UP GOVERNMENT THINKING WOULD WE BELIEVE INCLUDE FISCAL CONTROLS TO LEVEL THIS PRICE DIFFERENCE IF NOT TILT THE CONSUMER TOWARDS SUSTAINABLE BUILDING PRODUCTS -ANY )("# MEMBERS ARE INVOLVED IN DESIGN WORK FOR EXTENSIONS AND NEW BUILDINGS IN HISTORIC AREAS 4HE INSTITUTE IS PLEASED TO SEE THAT THE DOCUMENT RECOGNISES THE NEED FOR THE !$ TO BE FLEXIBLE AND CAPABLE OF SUPPORTING @SUFFICIENT DESIGN FLEXIBILITY 4HE )("# IS CONCERNED THAT TO DATE ENERGY CONSERVATION MEASURES HAVE ENCOURAGED SET SOLUTIONS AND THUS HELPED DIMINISH THE ARCHITECTURE OF NEW DWELLINGS AND PRODUCED A POOR RANGE OF DESIGN SOLUTIONS 4HIS WAS PRECISELY THE CONCERN OF THE )("# %NGLISH (ERITAGE AND OTHER HERITAGE GROUPS WHO WERE ALARMED BY THE ORIGINAL PROPOSALS IN -EASURES TO DATE HAVE ACTED AS A STRAIGHTJACKET ON ARCHITECTURAL CREATIVITY INNOVATION VARIETY AND CHARACTER 7E BELIEVE THAT A FLEXIBLE APPROACH WRITTEN INTO THE !$ COUPLED WITH BETTER INTERPRETATION AND INTER PROFESSIONAL DIALOGUE COULD HELP SOLVE THE PROBLEM (OWEVER WE NOTE WITH CONCERN CLAUSES AND @4HE EFFECT OF SIZE AND SHAPE WHICH COULD IF IMPLEMENTED WITHOUT SENSITIVITY TO THE QUALITIES OF GOOD DESIGN AND CHARACTER LEAD TO BLAND SIMPLE BOX LIKE STRUCTURES WITH LITTLE INTEREST AND NO ARTICULATION 4HE INSTITUTE IS CONCERNED ABOUT AIR IMPORTANT MATTER IS NOT SPEEDIER 4HIS IS ESPECIALLY DISAPPOINTING AS THE /$0- COMMISSIONS CONSULTANTS TO PRODUCE DATA ON MANY SUBJECTS WHERE A TIGHTENING OF REGULATIONS IS SOUGHT 4HE CURRENT !$ APPROACH FOCUSES ON THE @REVENUE COSTS OF ENERGY IN BUILDING 4HE )("# BELIEVES THAT ONLY WHEN THE @CAPITAL ENERGY COSTS EMBODIED IN ITS BRICKS TILES MORTAR METALS GLASS TIMBER PLASTICS AND OTHER MATERIALS IS QUANTIFIED AND WEIGHED AGAINST THE CONSEQUENT @REVENUE COST THAT A TRUE PICTURE AND ASSESSMENT OF LIFE CYCLE ENERGY COSTINGS IN BUILDINGS WILL BE ACHIEVED 4HE CONSERVATION OF HISTORIC BUILDINGS IS AN INTRINSICALLY SUSTAINABLE PRACTICE REGISTERED INSTALLERS TO COMPLY WITH THE BUILDING REGULATIONS AND TO LEAVE CASES INVOLVING HISTORIC BUILDINGS TO THE NORMAL BUILDING CONTROL ROUTES &ROM LOCAL AUTHORITY RETURNS WE KNOW THAT THIS IS NOT HAPPENING INDEED &ENSA INSTALLERS ARE TOTALLY IGNORING THIS 4HIS UNDERMINES THE EFFORTS OF THE /$0- AND %NGLISH (ERITAGE TO MINIMISE DAMAGE RESULTING FROM THE NEW 0ART , #ONFIDENCE IS FURTHER ERODED BY THE FACT THAT OF THE PALTRY ONE PER CENT OF INSPECTIONS THAT WERE CARRIED OUT IN THE FIRST QUARTER THAT &ENSA WAS OPERATING PER CENT OF THEM FAILED 4HE INSTITUTE IS PLEASED TO SEE THE EVOLVING APPRECIATION OF EMBODIED ENERGY BUT IS CONCERNED THAT PROGRESS ON EMBRACING THIS SELF EVIDENTLY
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