The below is BEFS Draft response – for comment, by Monday 16th November.
Built Environment Forum Scotland (BEFS) is an umbrella body for organisations working in the built environment in Scotland. Drawing on extensive expertise in a membership-led forum, BEFS informs, debates and advocates on the strategic issues, opportunities and challenges facing Scotland’s historic and contemporary built environment. BEFS is a member of the Climate Heritage Network steering group.
BEFS is supportive of the Draft Infrastructure Investment Plan for Scotland, particularly the inclusion of existing homes within the definition of infrastructure; the support for resilient and sustainable places, and the acceptance of the recommendations previously made by the Infrastructure Commission for Scotland.
Many mentions are made to the ‘doubling [of] investment in maintenance over the next 5 years’. This investment appears to be focused on transport infrastructure – all aspects which may well require maintenance – but which do not perhaps benefit the breadth of society in the way a programme of incentivised, nationwide, home maintenance would be able to. A programme which would support skilled, local jobs, improve spend in local economies, and support local supply chains. With outcomes benefitting public health, carbon savings, and the very real potential for personal reduction in outgoings; all in addition to improving homes across Scotland at a time when we are using them most. A programme defining and supporting a wellbeing economy.
Maintenance of this kind would also be essential to the best outcomes being sought by the Infrastructure Investment Hierarchy – a hierarchy which BEFS strongly supports. Prioritising enhancing and maintaining our existing assets is at the core of much work within the built environment and heritage. The work with public sector bodies to develop asset management plans is also strongly supported.
However, it is paramount that phrasing such as that on page 8 – “something new might only be built if there is still a demonstrable service need for a facility, and an existing asset can’t be repurposed” – remains true to its ideal. “Can’t be repurposed” is very different from, is seen as – too awkward, time consuming, expensive, or fragile – to repurpose. This repurposing also needs to take into account the embodied energy within existing structures and factor that accordingly into carbon calculations.
Consulting on carbon impact of future investment plans is mentioned. This could usefully include embodied carbon.
Work towards emissions reduction is also positive and noted, but needs to run alongside behaviour-change education and incentivisation. Buildings also need to be well maintained and wind/water-tight to best assess what interventions will produce the best carbon savings.
Place : within a place based approach housing delivery is duly mentioned, in line with reusing our assets the 1000s of empty homes in each area could be taken into account. Enabling reuse of existing assets, often within connected places with amenities.
BEFS strongly supports the addition of ‘natural’ to the definitions and descriptions of infrastructure.
BEFS queries the readiness of the pipeline through education into employment which will enable the take-up of the jobs intended to be supported through the capital investment programme.
The proposed amendments are consistent with the implementation of the Place Principle as adopted by Scottish Government.
CONSULTATION QUESTIONS: p32
2b) Additional measures to ensure embodied energy and whole-life carbon costs need to be included.
Also, it needs to be clear that an existing asset can only be replaced/demolished when it CANNOT be repurposed, not when it is merely too fragile/difficult/time-consuming or seemingly expensive – to replace.
3a) A dashboard of indicators appears sensible. Especially if whole lifecycle costs, maintenance and associated jobs related to that; as well as the expected life of the asset are taken into account.
3b) – no answer
3c) BEFS on behalf of the Built Heritage Group OPiT has worked on the draft development of a Strategic Investment Toolkit which is relevant in this discussion: https://www.befs.org.uk/wp-content/uploads/2020/05/Draft-SIT-Complete-Pack.pdf
4b) Add in whole life costs and embodied carbon calculations
5a/b/c – no answer
BEFS responses to a number of Consultations in relation to the Built Environment can be found at: https://www.befs.org.uk/resources/consultations/