Tuesday, October 20, 2009

Salvo calls for architectural salvage trade to lobby their MPs by 30 Oct 09 about a proposed new undemocratic law/rule

Above: Not the right way to save old materials. Reusable bricks, roof slates, wood floorboards, and more, are destroyed by thoughtless and rapid demolition. Careful dismantling saves materials for reuse. [Photo taken from Vale of White Horse District Council demolition page *** - see more about this below

FROM 1987 to 1994 the UK government required local authorities to consider placing a 'salvage clause' on all planning applications and listed building consents where reusable material was likely to arise, requiring that it was reused on site, or sold to a local salvage contractor. This clause in PPG15 (Planning Policy Guidance Note 15) came about partly as a result of my relationship with Chris Patten, the then Tory cabinet minister, who was also my constituency MP.

In 1994 policymakers in the higher echelons of English Heritage rewrote PPG15, which is the bible used by UK local authorities, their listed buildings officers and planning officers, when making decisions about historic buildings. The salvage clause was dropped in the rewrite despite objections from Salvo on behalf of the trade.

The government is now set to produce a new version of PPG15, now called PPS15 (Planning Policy Statement 15) which is out for consultation until 30 October 2009. It can be seen here
PPS15 Consultation

I have drafted my comments (see below) which now need trade support. I would like every salvage dealer to put these points to their local MP so that they can have a voice in the decision. An important issue is that PPS15 is not a law debated in parliament.


Response from the UK reclaimed building materials industry on the consultation for PPS15
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A. Reusable materials arising from demolition and refurbishment need to be saved.

The most valuable material reclaimed from demolished buildings is removed from historic buildings dating from before 1920, and most of these are listed buildings or are in a conservation area, both of which are governed by the Planning Act but in reality controlled by guidance notes for local authorities written by English Heritage.

The old PPG15 prior to 1994 included a recommendation to place salvage conditions on planning consent to alter or demolish historic buildings which would result in the disposal of reusable building material. The salvage condition recommended either reuse of such material on site, or its sale to a specialist reclaimed building materials salvage business.

This clause was deleted when the revised PPG 15 was produced in 1994. Salvo's objection at the time was met with a verbal response by telephone from an employee of English Heritage that there was 'not room' for the clause about salvage conditions in the new PPG 15.

This change in government policy has led to hundreds of millions of tons of old but historic and reusable bricks, stone, ironwork and timber being sent to landfill, or recycled by being melted down, crushed and burned from 1994 to 2009.

The EU 2008 Waste Framework Directive has now been passed in the European Parliament, and must become law in the UK by 2013. It requires member states to reuse as a 'priority order' over recycling, waste to energy and landfill.

The new PPS 15 must reflect the requirements of the EU 2008 Waste Framework Directive by containing positive guidance to planning authorities requiring them to ensure the reclaiming of reusable material for reuse when demolition, alterations, refurbishment or restoration occurs.

B. Confusion of listed building and planning officers is increasing global warming.

Most reclaimed building material is used in the historic environment by private consumers working outside mainstream construction. Much reclaimed material is reused without planning consent being sought or given. When applications for consent are made which include reuse of reclaimed material, planning officers refuse on the basis of their informal opinion, outside any legal or formal structure. We estimate that in half UK applications, or sometimes in every instance in certain authorities, planning officers reject reuse of reclaimed material in historic buildings.

These refused applications, to our knowledge, have never been legally challenged because in order to achieve an overall scheme for a building on a site, applicants have in every case acquiesced and dropped the reuse of reclaimed materials as part of the application.

So government policy to reduce global warming by reuse has not been implemented at a local level, and this has resulted in increased carbon emissions due to new materials having to be manufactured to substitute for reusable old ones. For example, the major brick manufacturers now produce new bricks that look like reclaimed bricks, which can be used in those areas and for those applications where reuse is not allowed by planning officers and listed building officers.

The new PPS 15 must give clear guidance to planning departments which encourages the reuse of reclaimed building material.

The scale of the problem can be seen with bricks. Every year the UK demolishes brick buildings which contain a total of around three billion bricks. Every year the UK currently (2008 BigREc Survey comissioned by Defra) reuses around 300 million old bricks. Every year around 2,700 million bricks are landfilled or crushed.

Significant fossil energy is used to crush the old bricks. Every 12 bricks embodies the energy of a gallon of petrol which is destroyed when bricks are crushed.

The failure to reuse results in additional carbon emissions from new brick manufacture, added to which are increased carbon emissions from the crushing of old bricks.

Similar examples of energy and resource inefficiency exist across the reclaimed building material sector covering a large range of material, for example, from dressed walling stone, to tropical hardwood woodblock flooring, to fine Victorian joinery and staircases.

From Thornton Kay of Salvo Llp
and on behalf of 129 reclamation businesses of the UK salvage trade to whom this has been circulated and approved

PPS15 Consultation


Please contact your MP about this as soon as possible. The end of the consultation period is 30 October 2009.

Thanks for your attention

*** The following statement is taken from the Vale of White Horse District Council website:
In March 2007 the Vale of White Horse District Council signed up to the Nottingham Declaration on Climate Change. By doing this it pledged to reduce its own carbon emissions and to encourage others to do the same. The declaration sets out that the Council 'acknowledges the increasing impact that climate change will have on our community during the 21st century and commits to tackling the causes and effects of a changing climate on our district'. The document also commits the Council to reducing its own greenhouse gases and to encouraging other businesses and individuals in the Vale to do the same.
The Vale of White Horse District Council is typical of every local authority in the UK. All have signed up to policies which pledge to encourage reuse, but none of them actually do. This is why the government must act.

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