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Joint Committee on Environment and Climate Action debate -
Tuesday, 2 Jul 2024

Circular Economy as it relates to Construction Sector: Discussion

The purpose of this morning's meeting is to have a discussion on the circular economy as it relates to the construction sector. On behalf of the committee, I welcome the following witnesses. From the Irish Green Building Council, Ms Marion Jammet, head of policy and advocacy, and Mr. Giovanni Impoco, circularity lead. From the Construction Industry Federation, Mr. Hubert Fitzpatrick, director general, Mr. P.J. Ryan, head of environmental, social and governance, ESG, and Mr. Raymond Stapleton, vice president and chairman of the federation's ESG policy committee.

Before we begin, I will read a note on privilege. I remind the witnesses of the long-standing parliamentary practice that they should not criticise or make charges against any person or entity either by name or in such a way as to make him, her or it identifiable or otherwise engage in speech that might be regarded as defamatory to the good name of the person or entity. If witnesses' statements are potentially defamatory in respect of an identifiable person or entity, I will direct them to discontinue their remarks. It is imperative that they comply with any such direction.

Members are reminded of the long-standing parliamentary practice to the effect that they should not comment on, criticise or make charges against a person outside the Houses or an official either by name or in such a way as to make him or her identifiable. I remind members that they are only allowed to participate in the meeting if they are physically located in the Leinster House complex. In this regard, I ask members joining us online to confirm prior to making their contributions that they are indeed on the grounds of Leinster House. I will go first to Ms Jammet for her opening statement.

Ms Marion Jammet

I thank the Chair and the committee for the invitation to present today.

The Irish Green Building Council is a registered charity, with over 400 members drawn from all parts of the construction value chain. Our role is to provide leadership for a more sustainable built environment. While there are inspiring examples of circularity in the Irish construction sector, Ireland has one of the lowest rates circular material use in Europe. Many construction materials are technically reusable, but less than 2% of building elements are currently reused. The circular economy can be described as an economic system in which the value of products and other resources is maintained for as long as possible.

Circularity is not just about recycling. It requires a fundamental shift from the current linear economic model of make, use and dispose. A circular approach to construction can reduce carbon emissions, while preserving natural resources and creating economic value. Embodied carbon emissions account for 14% of Ireland’s national emissions. There is no decarbonisation without a circular economy. Competition will intensify as demand grows for finite natural resources, leading to further increases in the price of construction materials. Circularity is key to improving resilience in the supply chain. Buildings and construction materials can be circular if they are designed to be easily shared, maintained, repaired, reused, remanufactured and, the least favourable option, recycled. For instance, it is better to reuse a steel column as it is, as opposed to melting it down and recycling it into a new column, particularly as this process requires a significant amount of energy. Renovations are almost always lower impact than new builds. Extending the use life of buildings and, more specifically, the elements with a high environmental cost, such as structures and facades, is critical. When we do build new, we must design out waste at all stages of the building life cycle.

Leaner designs are key in addressing carbon emissions and waste. For instance, off-site prefabrication can reduce waste during production and construction. Elements and spaces that may not be essential for the functioning or efficiency of a building must be reassessed. Buildings must be designed for optimum use by facilitating alternative uses at different times and over the lifespan, while retaining the value. It can be as simple as allowing enough leeway within the building design that when occupants need change, the building can be easily adapted.

We can re-imagine how our homes can be designed for life, by using a modular approach to easily transition from a one-bed property to a three-bed home and vice versa. Designing homes for adaptability would allow us to respond more quickly and efficiently to demographic changes, such as the trend toward smaller households. Just like structures fitting together like Lego, products, services, and entire buildings must be designed to be deconstructed and their components reused.

Reducing waste and supplying high value secondary materials suitable for reuse and recycling at a later stage, requires designs that support ease of deconstruction. For example, screws and fixings can be used rather than adhesives, to facilitate reuse. Digitalisation and material passports can further support this process. They provide a structure to collect information on a product, its safety, environmental impact and reusability.

To conclude, we cannot tackle the three environmental crises we are facing without transitioning to a more circular construction industry. By keeping assets at their highest value for longer, this transition can also improve the resilience of the supply chain and add value to our society and economy. Despite challenges, the construction sector holds immense potential to implement circularity. To support this transition, a full set of co-ordinated actions are needed. More specifically, circular approaches must be fully integrated into public procurement to drive changes in the market. We also need more financial incentives, including for pilot projects, to support innovation.

The certification and licensing system must continue to be streamlined to increase the credibility and widespread use of pre-used products and material. Improving quality assurance is key in increasing trust in the process and in supporting circularity. The circularity principle must also be integrated into planning, which could be through a requirement for larger projects to demonstrate adaptability and that deconstruction has been considered in the design and through pre-demolition audits as a condition for demolition.

Finally, upskilling in circularity must be further encouraged. We thank the committee once again for the invitation to inform its work.

I thank Ms Jammet for her opening statement and go now to Mr. Fitzpatrick for his statement.

Mr. Hubert Fitzpatrick

I thank the Chairman, Deputies and Senators on behalf of the Construction Industry Federation, CIF, for the opportunity to meet with the committee and address this important issue which could have major influence on construction in the future. I am here today with Mr. Eamonn Stapleton, managing director of Clonmel Enterprises and chairman of our environmental, social and governance, ESG, policy committee, and Mr. P.J. Ryan, head of ESG in the federation.

What is the circular economy? Ireland's Circular Economy and Miscellaneous Provisions Act 2022 defines a circular economy as a model where production and distribution processes of goods, products and materials are designed to minimise the consumption of raw materials; the delivery of services is designed to reduce the consumption of raw materials; goods, products and materials are kept in use for as long as possible; the maximum economic value is extracted from goods, products and materials; and goods, products and materials are recovered and regenerated at the end of their useful life. Circular economy concepts are nascent in construction compared to other sectors and to date, they have focused on waste prevention and management.

In relation to infrastructure development, Ireland's economy and population are expanding, but there is a shortfall in infrastructure that will impede future growth and potentially hinder our progress towards a net-zero economy. Ireland has not developed the same level of infrastructure as our European neighbours, which have established an impressive energy and transport system over the last century and are therefore better positioned to achieve their sustainability targets. The recent National Competitiveness and Productivity Council, NCPC, bulletin underscores this deficit - Ireland ranks 38th globally for basic infrastructure, including water infrastructure, the density of road and rail networks and particularly energy infrastructure, which results in higher electricity costs for industrial companies.

However, it is important to recognise that building infrastructure requires substantial quantities of virgin aggregates. The European Aggregates Association indicates that up to 20% of the current aggregate demand could eventually be met with recycled materials.

Additionally, much of Ireland's infrastructure is new, while some of our European neighbours have ageing infrastructure that can now be demolished, with the potential to recycle uncontaminated aggregates into new structures. The industry is concerned that drawing conclusions about Ireland's rate of construction circularity, the circularity gap, overlooks the underdeveloped state of our basic infrastructure and may penalise future development and growth. Any transition to net zero must be a just one.

On construction and demolition waste statistics, according to EPA data for 2021, construction and demolition waste forms the largest waste stream in Ireland, accounting for 51%, or 9 million tonnes, of the national total of 17.6 million tonnes. Notably, 85%, or 7.7 million tonnes, of construction and demolition waste is soil and stone. Thus, waste data is dominated by soil and stone. Most construction and demolition waste in Ireland was recovered by backfilling, at 85%, with 7% disposed of and 8% recycled. Regarding national decisions in Articles 27 and 28, the industry has worked with the EPA to develop national decisions on Article 27, dealing with by-products, and Article 28, relating to end-of-waste for recycled aggregates. These decisions aim to improve circularity by promoting recovery and reuse over disposal. The national greenfield soil and stone decision, which is anticipated soon, will delegate approval from the EPA to local authorities, streamlining the process and potentially allowing more brownfield material to be reused or recovered.

Regarding challenges in the new process, local authorities need time to adapt to their new roles and must be properly trained and resourced. Finding lawful receiving sites for greenfield soil and stone is challenging. Soil recovery facilities may need to adjust their licensing regimes, which could be time consuming. Timing is a major challenge, as materials can only be stockpiled on site for six months. An IT application to match donor and receiving sites and developing local depots for temporary storage could help mitigate these challenges.

On non-soil and stone construction and development waste, of the remaining 15% of construction and demolition waste, 45% comes from concrete, brick, tile and gypsum, with 27% being mixed construction and demolition waste. Introducing the waste recovery levy for mixed skips from 1 September is expected to increase the segregation of mixed-waste skips and reduce waste sent for recovery by incineration or use as solid recoverable fuel.

Regarding circularity in the concrete industry, the industry plans to collaborate with State agencies to allow crushed concrete to be reused as a secondary cementitious material, reducing the need for original Portland cement. This practice, which is common in most European countries, would enhance circularity and reduce greenhouse gas emissions in the concrete industry. The aggregate sector struggles with circularity due to the heavy weight of aggregates, making their transport over large distances cost-prohibitive. Additionally, the time mismatch between surface material availability and local construction project needs necessitates storage space, which is often lacking. To improve circularity, we urge local authorities to provide storage facilities and propose extending the permitted on-site storage time for soil and stone from six months to at least 24 months.

On measurement and reporting, the EU's corporate sustainability reporting directive, CSRD, will drive sustainability reporting, including reporting on environmental topics such as greenhouse gas emissions. The CIF has launched the CIF carbon calculator to help SME firms calculate their footprint and contribute to more robust data for tier 1 contractors' scope 3 emissions. The focus on measurement will increase awareness of embodied carbon emissions and uptake of products with environmental product declarations, EPD. As part of the CSRD, many CIF firms will need to report on resource use and circular economy under European sustainable reporting standard E5, driving greater awareness and behavioural change in procurement.

Regarding supply chain sustainability, understanding and being aware of evolving regulatory requirements throughout the supply chain will be essential for the industry to advance cohesively.

The CIF is proud to be a founding partner of the supply chain sustainability school, and we believe this free resource will assist firms of all sizes in embarking on their journey towards a more sustainable and circular future. Typically, 80% of contractors' greenhouse gas emissions are due to their subcontractors and suppliers.

Turning to key initiatives for the circular economy in construction, integrating circularity adds complexity and uncertainty to construction projects. Contractors must align their bids with detailed client specifications. Resource and waste management plans, material logistics, site layout, supply chain engagement and on-site training are essential. The industry supports developing a qualified resource manager qualification to champion resource efficiency.

Clients and design teams must make informed choices about construction methods, thereby encouraging contractor innovation. Processing materials on site is crucial for minimising the transportation of resources and waste. The permitting regime for mobile crushers on construction sites needs updating for flexibility to support circularity. A centralised online permitting system, standardised application procedure, clear guidance and a tiered permitting approach are recommended.

Regarding legislation and standards, primary legislation, regulations and construction standards must work together to support the reuse or recycling of all construction and demolition waste, effectively minimising landfill disposal. Clients must plan for this during the design and construction phases. This will foster a manufacturing ecosystem where all construction materials are reused or recycled. We caution against new legislative barriers, like the EU proposal to classify recycled aggregates as substances under the REACH regulation, which would impede reuse. Circularity is a priority, and such regulations should be carefully considered. The industry welcomes the revision of the construction product regulations to mandate the declaration of a product's environmental characteristics, contributing to the development of harmonised technical product specifications.

Moving to testing and certification, robust but balanced testing criteria for secondary construction products are needed and we recommend developing a suitably resourced national testing centre for new innovative products.

On grants and supports, grants from Enterprise Ireland and local enterprise offices should be accessible to the wider industry for sustainability initiatives and the development of sustainability action plans. Additionally, support should be available to provide extra training for local authority staff working on small-scale projects, thereby enhancing the skills of engineering staff who manage and design these projects.

In respect of the review of construction works management framework, this should be updated to embed circularity, with additional support for the Office of Government Procurement. This includes whole life-cycle costing, quality in contract awards, digitalisation and green public procurement. Government policies should be harmonised across all agencies to speed up the approval and certification of new recycling processes. The insurance industry must align with the construction sector to support using construction byproducts and innovative solutions, avoiding impacts on collateral warranties.

We urge the Government to support the construction circular economy by investing in a construction byproduct recycling industry and developing digital waste-tracking tools. Construction waste is a valuable resource and the industry is committed to becoming an integral part of the circular economy.

I thank the committee members for the opportunity to address them and we will answer whatever questions they may have.

I thank Mr. Fitzpatrick for his opening statement and call Deputy Kenny.

I thank the witnesses for their contributions and opening statements. We are in the midst of a housing crisis. In that context, one thing that strikes me is the fact that everyone says the solution is to build more houses. That is pretty obvious. The difficulty we have with labour restrictions and everything else in this regard is a major problem. The tendency seems to be, and it is a valid one, to move to the system used in other countries where houses are manufactured and constructed more so on site instead of being built in situ from the ground up. This approach has the advantages of speed, efficiency and effectiveness. It brings us back to the point made by Ms Jammet concerning the ability to deconstruct these houses and reconstruct them elsewhere. How much work is involved in coming up with systems like that in respect of what are often referred to as modular-type houses?

Will there be a situation in the future whereby these houses can be easily expanded or their structure and layout easily changed in order to do that?

On the materials being used, we are told we need to move away from concrete-based houses and towards more renewable or less carbon-intensive structures. How much research and development is going into that? In an Irish context, we have a difficulty with dampness. It is one of the main problems. What is the long-term sustainability of such products?

On recycling the products that are used, a new method in road construction is that the top layer is taken off, recycled and produced back out and there is no material, except additional bitumen or tar, going in. Can that type of method be used for concrete? Can it be recycled in a similar manner? Where are we with that and how widespread are the situations in which it can be used? I imagine it can only be used on a large scale. It would be difficult to do that kind of thing on smaller construction sites.

Ms Marion Jammet

With regard to modern methods of construction and modularity, there are two things we might like to highlight. There are a number of considerations. First, we need to support leaner designs that require less material. That is one thing. We have good examples from other countries such as the Netherlands and Denmark, where this type of modular home has been designed. It could be a two- or three-floor building that is designed in such a way that a one-bedroom apartment could become a three-bedroom apartment at some point and vice versa. Clearly we need innovation. It needs to be considered if we look at our demographic trends. We will have more and more smaller households so we cannot rely 100% on three-bedroom detached properties. We need to ensure they are built in the right way and modular construction is one of the solutions to ensure buildings can be more easily adapted. It is also potentially a solution to ensure that it would be easier for an elderly household to stay in the area they want to. It could be easier for them to downsize and for us make sure we keep specific places more lively. There is definitely potential there.

On bio-based material for construction, there are far more timber-frame buildings in Scotland so I would not necessarily rely on the climate. We need to do more testing, but we need to facilitate innovation in that field. Ireland has a large agricultural sector so potentially we also have a lot of opportunities for bio-based construction materials, especially if we consider that measurement of whole life carbon will become mandatory at a European level from 2028. It is already mandatory in other member states. In some countries, such as the Netherlands and France, that have already regulated that field with targets, we are seeing a transition more and more to this type of product. It is also about building capacity.

Mr. Hubert Fitzpatrick

There are three strands to Deputy Kenny's question. I will take some and then hand over to my colleagues. There is quite a lot of innovation taking place in the housing area at the moment. We have traditional build, build with light gauge steel, timber frame, pre-cast concrete and modular construction. Approximately 48% of all scheme houses being built now are timber frame and that percentage has been growing. That said, there are restrictions on the height of timber frame units and we need to ensure we can reconcile building regulations with fire safety requirements in the use of timber frames.

There is still a body of work to be done to further increase use of timber in higher-scale developments, but significant research is now under way. The priority is now speed and cost. We must also look at what happened with the whole modular piece in the UK, where there were many failures with regard to the manufacturers of particular modular units. We must ensure that we do not repeat those mistakes. Nevertheless, we have a growing industry here that has potential. That will have to be sorted out in the procurement process going forward.

Mr. Stapleton would be better able to answer the question on road construction. Then Mr. Ryan can take on the issue of recycled concrete.

Mr. Eamonn Stapleton

The Deputy is right to recognise that there are opportunities for the recycling of surfacing materials, which has been ongoing for quite a while. Recently, the amount of recycled materials that could be incorporated into new Macadams was increased, so there are improvements there. The problem with the climate impact of full new road construction is probably deeper than that. There is obviously the issue to which Ms Jammet referred, which is that waste materials are transported but other materials are re-imported to create a road. Both of these result in significant transport issues, which is when significant emissions arise. The materials themselves by their nature may not be the issue but it is a matter of their transport. The opportunity to improve emissions there probably lies with the design element of it. Yet, as the Deputy knows, when it comes to construction, there is very little time to influence that. Also, one is in a commercial situation, so it is not as easy. The opportunity is ultimately for the clients to look at their designs and come up with the most efficient solution with the least impact on the climate. The surfacing suppliers are working very hard on improving their own material designs so that they can incorporate recycled materials.

Mr. P.J. Ryan

On the question about the decisions the EPA is making, it has made one on site-won asphalt. It has taken a national decision on that, which will speed up the process of getting those decisions approved. It used to be on a case-by-case basis, which made the process of going through the EPA a lot slower, but it is much quicker now. That will hopefully drive more of that site-won asphalt to be reused.

Following on from that, Mr. Fitzpatrick mentioned the national greenfield soil and stone decision. Up to now, that was on a case-by-case basis. The volume of applications was such that it was taking too long to process them. Again, that national decision will hopefully speed up that whole process by delegating that decision-making piece to local authorities. That will hopefully take a huge chunk of soil and stone, which was being treated as waste. Now, it is an article 27 by-product.

On the issue of concrete, other countries in Europe allow one to take crushed concrete and bring it back into the cement industry and the concrete process. Our local standard here does not allow us to do that yet, but we are hoping to work with industry, the Irish Concrete Federation, ICF, and other standards agencies. We hope to get that through in the next year, so we will also be able to start taking concrete. It will have to meet particular standards, obviously. If there is heavy metal contamination in the concrete, you might not be able to do that. Yet, you will hopefully be able to start seeing more circularity and that will hopefully displace the ordinary portland cement, OPC, which is heavy on carbon. Hopefully, this will start to make it more sustainable.

Are there any issues around that? I am thinking of the problems we have with mica, pyrite, etc., in the context of adhering to regulations as we move forward to come up with better materials that may have unintended consequences in the future.

Mr. P.J. Ryan

This particular process would probably be controlled by the big cement producers, which already have very tight quality assurance, QA, processes. It is probably different from what happened with the mica issue, where there were many smaller concrete block producers. The controls just may not have been there. Regarding the entities that would be doing this at scale, not everybody would be permitted to do this. The controls there would be tighter than they were with concrete blocks.

I have just one final point. The cost of all this is the first thing people think of, and it has been the experience in the past that when you go to a greener type of building, the costs go much higher compared with the costs of traditional materials that have been used. We have an argument going on at the moment about the cost of affordable housing in Dublin. The cost of affordable housing everywhere is an issue, and if we are going to try to produce houses that are of a lower carbon footprint but whose cost will be higher for the consumer, it simply will not work. We need to acknowledge that and have solutions for it.

Mr. Hubert Fitzpatrick

On that point, it is quite true that the standard of house building today is far superior to where it was five, six or seven years ago. That does carry a cost and, with the cost of all the technology, it is significant. That said, one's running costs subsequently are a lot lower, but it does result in a greatly increased cost of construction, which ultimately impacts the supply of housing.

Ms Marion Jammet

It is also about starting early. It can be difficult if you think about sustainability at a later stage. If a building is designed to be more sustainable earlier, it does not necessarily have to be more expensive. A lot of this, as I said, comes back to having leaner design, perhaps using less material, which in itself can reduce cost. I am not saying it is exactly the same here as in France, but it does not always have to be more expensive. In Bordeaux, for example, Grand Parc was a social housing apartment block that was retrofitted. There are currently 530 accommodation units there. I think the cost of renovating that unit was about a third per unit what it would have been if the building had been demolished and rebuilt. There are things like that that we need to consider. It is the same in Ireland. I know it is not housing, but looking, for instance, at the Treasury Building, which is not too far from here, steel was reused, which was cheaper than sourcing new steel. It therefore depends also on the material and on the value of the material in the first place.

Thank you for that. Deputy Bruton, do you want to go next?

Yes. I absolutely agree with this statement from the building council that we cannot tackle the three environmental crises we are facing without transitioning to a more circular construction industry. What I am hearing from the CIF, however, is that, like the Kerryman, "I would not start from here." That seems to be the dilemma we are trying to reconcile here.

The first question I would be interested to hear an answer to is how far public procurement has embraced the principles the building council outlines: building for repurposing, choosing materials based on their lifetime impact, making sure that you can easily adapt and that you do not have mixed materials that are then very hard to recycle and so on. How far are we down the line? I hear the CIF say that if only the clients would specify this, it could do a lot more, but where is the public client in this? That is the first question that strikes me.

How far on are we in agreeing the sector targets? We understood that when the circular economy Act was passed, within six months of the activation of a certain section, we would have a strategy for the construction sector and food and so on. Two years on, we do not have those. I understand that consultation is under way, but what are the witnesses' views on what the reuse target should be, what the material usage reduction target should be and what the recycling target should be?

What should change on sites to make all of these things possible? From the discussion, it seems that this is very ad hoc. The CIF is going to the EPA for its consideration of things. There does not seem to be an overall strategy that says certain things need to happen in a defined period. That is my frustration.

We have 2 million homes already and they are underoccupied. There is more space per person in Ireland than in other countries. A lot of people like myself are rattling around in three, four or five-bedroom houses. Where are we with repurposing, renovating and switching from three-bedroom to one-bedroom units, as Ms Jammet has mentioned, as regards our existing stock? Is the council only talking about new modular homes than can be easily constructed like Lego or is there a pathway towards releasing some of that underoccupied stock and making it easier for people who want to rightsize? At the moment, it seems that it is way beyond people's capacity to anticipate such a change as a result of planning costs and so on. If repurposing that existing 2 million is the most circular thing we could do, where are we with innovation in that area?

Ms Marion Jammet

Obviously, it is easier to design for adaptability in a new build. That makes perfect sense. There are more challenges in renovations but it may be possible. In many of the suburbs of Dublin, an additional floor could be put on some of the properties or areas could be gentrified. There are definitely options as regards the existing stock. It might just be about looking at our needs and trying to better understand the stock we already have. It may not be possible to make some of these three-bed detached properties more adaptable but at least we know they are already in the stock and that we may not need more of them. It is about thinking in that way, trying to better understand what we already have and what we need and looking at innovation where these properties can be made more adaptable.

It is not only about housing. It is also about intensifying or maximising the use of buildings at different times of the day. That can be done in some existing buildings. The example in Amsterdam we mentioned in our statement was a new build but similar examples could be found. Many of our schools are empty for a few months during the year. How can we make better use of these buildings?

To go back to public procurement, we have seen positive developments in recent months, especially with regard to the requirement to measure whole-life carbon and using methods of construction that result in less embedded carbon.

Is there a number we could track to know-----

Ms Marion Jammet

I will ask Mr. Impoco to come in on that. It is always difficult to give an exact number but the Deputy is right; what is missing is targets for larger projects. Mr. Impoco can expand on this but in Italy there are targets for reuse and recycling. In France, a certain percentage of bio-based material must be used. The whole idea is to use public procurement to drive change in the market.

Mr. Giovanni Impoco

IGBC is leading a project on circular building funded by the EPA. We are leading the project and working with three partners, ATU, the University of Galway and TU Dublin. The research we have done maps out what was already done in Europe.

Some countries are pushing the circular economy through three main pillars, namely policy, measurement and market development.

In the context of measurement, as my colleagues have said, some targets have already been set. In Italy, 50% of the total material used must contain recycled content. In France, they are measuring the amount of reusable materials in building.

On policy, in Italy, green public procurement is mandatory. Public tenders above €50 million must use green methodologies so all the material is tracked.

We do not have that sort of stuff.

Mr. Giovanni Impoco

In the area of market development, the Netherlands is supporting the development of new and innovative products and services. What do I mean by that? The Netherlands is the best in terms of circularity because using innovative products and services means it is not extracting materials. That is why it is at the top of the circularity ratings. Lighting is a service, as are facade and elevators. They keep the material alive.

Italy ensures the viability of secondary material to respond to green public procurement so it is doing the market push. The research we did was already done in Ireland as the witnesses from the CIF mentioned regarding Articles 27 and 28. We also participated in the CSG Group, which released guidance for the circular economy. We marked all that, took all the best that had already been done in Ireland and tried to better it. We held a number of workshops in Dublin, Limerick and Cork and interrogated people from the whole value chain from the insurance company to the local authorities to governmental authorities and policymakers to manufacturers to real estate companies and developers because the circular economy cannot be tackled by just one player. Everyone should work together. We asked some questions about timelines. A question was asked about pathways. Regarding pushing innovative areas like the sharing economy, product as a service and a standard responsibility but also how we can use design and procurement.

In the context of materials, what is really missing to recertify all the materials is certification standards and testing. We should also permit the matching of demand. Italy could provide an example. We should attend to insurance, buying materials and skills. We need to set some circular requirements for tools and processes in procurement. There are some good examples from the UK, where they started asking the right questions early in the process. This means you know how you can push the circular economy.

We also need to specify the percentage of recycled content and different design methodologies that can push the circular economy. One member of the committee mentioned modularity. Modularity is also important for change of destination, which means that we will retain the value of the asset throughout the lifespan of the product or the building. This is one of the core principles of the circular economy. It also allows you to build less.

There are two different ways to tackle the circular economy.

Looking at some good examples outside the country, you can find a solution which could be really applied in this context as well.

Mr. Eamonn Stapleton

I will address two of the points raised by Deputy Bruton with regard to where one would start and the procurement. At this stage the procurement is more qualitative in how one address the green procurement and so on as opposed to quantitative. The measures are not there yet. The Office of Government Procurement is progressing that. We will all welcome this when it comes because it will create clarity around what people should be doing.

On the question of whether we are starting from the right point, the answer is that we are where we are. There are two significant infrastructure projects coming down the line. There is the metro and, to a lesser extent, BusConnects. These are challenges in themselves. They are sustainable projects to provide sustainable solutions but in constructing them there will be challenges around minimising their impact. There is still an opportunity to make sure they are procured in the manner the Irish Green Building Council is talking about with other people's experiences. These should be included in the procurement of both of those projects because they will have significant impacts.

Mr. Hubert Fitzpatrick

The re-purposing and renovation of properties are securing greater use but the biggest problem is that many people who are finished with a four-bedroom house and do not have the use for it do not want to move elsewhere because they want to stay in their locality. That is a big challenge. With repurposing and renovation, the town renewal schemes have terrific potential here for many of the vacant houses within the town centre areas. The existing schemes for vacant or derelict properties are actually fabulous schemes. There is major potential in many of the towns and villages right across the country when it comes to vacant stock. If we can have active renewal schemes to actually repurpose those village centres and town centres it will make them attractive places for people to live in and ensure all those properties are renovated. It would be a terrific initiative to maintain that.

Is it difficult to turn a three-bedroom house into a duplex with a downstairs unit and a two-storey overhead? It strikes me that this is very difficult to do in Ireland.

Mr. Hubert Fitzpatrick

One would have major problems in the context of compliance with the building regulations. They are two separate units, and there may be fire issues to do with that. There would be planning issues as well.

Ms Marion Jammet

I agree with what was said by the Construction Industry Federation about the importance of prioritising reuse. If we look at the vacancy rates in our town and city centres they are very high by European standards. It is correct to say that there are things that need to be looked at with regard to building regulations. Maybe there are barriers, or at least perhaps perceived barriers, in relation to accessibility and fire safety, as was said. Definitely there are things to be looked at but it is still important to consider the embodied carbon. For example, the embodied carbon of deep retrofit is one quarter of a new build so even from a carbon footprint aspect, not to mention the-----

Will the Irish Green Building Council look at this? It is a very practical way of starting to get better occupancy of our existing buildings, if that could be done relatively easy. It is very standard. The appearance of a street would not dramatically change because it would be duplex. Perhaps the next time the witnesses are here they will have done an evaluation of whether all the certificates and all the planning restrictions are necessary.

Ms Marion Jammet

That is something we plan to work on for the next year; so perhaps in a year's time.

I thank Deputy Bruton. I wish to add to Mr. Fitzpatrick's point about the renovation of derelict properties and vacant properties in town centres. From a recent experience in County Limerick, I am aware that an incredible number of properties have been renovated over the past year or two. We are seeing new life being breathed into our towns and villages. That is very welcome, and long may it continue. I presume the witnesses support the continuation of the grants that have been made available in recent years.

I thank the witnesses for coming in. I will continue on the same theme. On the barriers to retrofitting, it strikes me the default position seems to be demolition and rebuild rather than retrofitting or refitting. Will both organisations touch on some of the barriers as they see them?

The next issue is for CIF. I see many recently-developed housing estates. I am in County Meath and there is a requirement for a minimum amount of green space. When I grew up the green space was a flat green space where you could play a game of football. What we have in our new housing developments are drumlins with little lanes running through them where you could not put a football or set of goalposts down. I am told that is because builders want to get rid of their waste soil. They are building these little drumlins where children cannot play. Is that the case and will this change in policy improve that situation?

Is this Meath's excuse for not winning so many games?

It is one of them, although they have drumlins in Monaghan and they manage to beat us. What of that policy of burying waste soil and covering it with a lawn of grass? Maybe CIF can start with that one and we can touch on the retrofitting barriers.

Mr. Hubert Fitzpatrick

I thank the Deputy. The key objective is minimising the amount of stone and soil we have to remove from a site. Can it be utilised effectively on site? That is an environmental objective of building. By and large, the design of the open space is always approved in planning.

On barriers to retrofitting, in many cases we could be talking about commercial buildings or office buildings that cannot be retrofitted. It might be a case of the internal design. It could be floor-to-ceiling heights being inadequate. It could be internal layouts. There could be WC facilities on half-floors or not on floors. There could be difficulties with compliance with building regulations. Also, in a lot of cases these offices are in areas where there is much development air space around them, where good, sustainable use is not being made of the plot. It might be well-served by traffic and all the services, but there is not enough density onsite to ensure there is proper footfall on it. Under the current planning regime, if one intends to demolish a building one must demonstrate to the planning authority and indeed to An Bord Pleanála that it is more sustainable to demolish than it would be to retrofit. We have to be concerned about the longer-term use of the buildings, the long-term occupancy and the environmental performance of the building when finished. Under the planning regime everything has to be looked at now. If one wants to demolish one must substantiate why that is more environmental than it would be to retrofit.

Does Mr. Fitzpatrick think that equation will change with a change in regime, increased circularity and everything we are talking about here? How does he think a change in the regime in the sense of increasing the amount of circularity, the reuse of construction and demolition waste will work? Will that lend itself to more demolition or less?

Mr. Hubert Fitzpatrick

It will all have to be factored into the equation that is being determined on a case-by-case basis. We must look at the planning sustainability at the outset. If there are city centre plots where the land space is not being effectively used and we are restricting the occupancy for those uses going forward, it may make more sense to demolish and rebuild to the environmental standard and get the proper footfall on it. However, all these issues are subject to assessment on a case-by-case basis and they are assessed by the local authority as part of the planning process or indeed assessed subsequently by An Bord Pleanála. Where it is found it is more environmental to maintain the existing structure and adapt it, that comes out in the assessments.

However, there are other assessments where it may be found that it is more realistic to demolish and put an entirely new, modern building on site to make effective use of the space that is well served by transportation and all the other services that are in place.

Ms Marion Jammet

I think that, in general, the data we have with regard to buildings and the embodied carbon are really like the elements with the highest embodied carbon or like structure and substructure, and there is clearly a case, as the Deputy put it, and in most cases, to retain at least the structure and substructure if we can.

One thing that would be very important would be to try to submit a rationale for demolition - asking for a rationale for demolition, including an assessment of an alternative proposal incorporating existing buildings or not, and also a look at a life cycle assessment for the alternative proposal and not only for the new build. Really then, if the permission to demolish is granted, as it can be on a case-by-case basis, as was mentioned, it is important that in that case, we have mitigation measures in place. That can be like a circularity statement to see if the new building is designed for resource efficiency, adaptability and disassembly but also trying to make sure it is done early and there is a pre-demolition audit, as was done in Limerick for the Opera Square project, where there was a good pre-demolition audit. You know which products are there and if they can be reused.

I thank the witnesses for both presentations. They were thought-provoking. I wonder, with regard to the innovation, should we be leaving it to the industry to innovate or should we have a State agency that is looking at best practice across the globe, in terms of trying to reach a firm decision on the direction we take? We have to take into account what Mr. Fitzpatrick said. There is a deficit here with regard to infrastructure in comparison to other countries. There is also a deficit, to some extent, in the knowledge and evolution of where we are going. Should we, at a State level, be providing more research, ideas and potential solutions that ultimately become the guidelines, the building regulations and the planning regulations, rather than putting the onus on the industry? It goes back to what, I think, Mr. Stapleton said. If the client is looking for it, we will deliver it. Rather than forcing it as a requirement of the construction sector, should the State be taking a greater role on that? I would appreciate a response to that.

Mr. Eamonn Stapleton

I will give Senator Dooley a quick response. We should, of course, leave it to the industry to innovate. We should be innovating, and I think we are innovating but we can only innovate within the constraints of what is required of us. On this particular subject, while we do not want everything to be prescriptive, because you are not allowed to innovate, take opportunities and so on-----

It is competitive. You are bidding against X or Y so you are not going to go 10% above because you have got to innovate for potentially more green, where there is a price differential as well. What I am trying to get to is whether a standard should be set to a level.

Mr. Eamonn Stapleton

For this subject, yes. I believe it should be. There should be a higher bar set by the client, whether they are public or private clients, that recognises the situation we are in regarding sustainability and so on. There will always be room, I hope, for the industry to innovate. It will, whether it is the modular method of construction, digitalisation and so on.

Innovation is generally driven by trying to reduce cost. Of course, there is the green piece now.

Mr. Eamonn Stapleton

That is what a commercial entity will focus on.

Mr. Hubert Fitzpatrick

We have various initiatives from Government, including construct innovate, which is an initiative with University of Galway and other colleges. A number of initiatives are under way. This is a big, wide subject.

Ms Marion Jammet

We have two pieces there. We can drive demand with public procurement and that is important, but it is also about supporting innovation and the supply chain. Financial incentives could be useful. I think we mentioned that in our statement. Capital funding, at least initially, could support innovative technology.

I am thinking more of the planning side. If you have the advice and experience from elsewhere, you can to some extent force a change of direction. Witnesses mentioned methods in different countries that would not necessarily be germane to our culture and the way we live. Change has been forced in the past through planning, such as making it more difficult for people live in rural isolation, as they might have wanted to. Is there a role for changes in planning law to bring that about?

Ms Marion Jammet

There is an opportunity in planning in general to support more circularity. In Opera Square, Limerick there was a requirement for a pre-demolition audit. That is also done in London for larger projects. We are not taking about one-off housing like the Senator mentioned, but there is definitely room there.

On the point Deputy Bruton rightly identified, some of the Georgian buildings in this city in the 1970s and 1980s were brass-plate offices for smaller solicitors, accountancy firms and so on and are vacant now, yet heritage in various local authorities require them to be maintained in exactly the same format. I do not suggest we should not try to protect and preserve our heritage but in London there are similar buildings within a stone's throw of Buckingham Palace. As long as the facade and general structure is maintained, they can change the internal character of the building. That recognises insulation, ensures they are appropriately protected against the spread of fire and brings them to a standard acceptable for people to live in today. It is virtually impossible to do that here, unless the changes were made prior to 1963, when the first Planning Act came in. Should we look to utilise those properties better, rather than letting them fall into dereliction?

There are issues around escape or egress from the backs of these buildings. In other countries, it is easier to construct a fire escape at the back. If we are serious about the circular economy and reusing and making better use of residential spaces, do we not have to look at protecting and preserving our heritage without maintaining it in exactly the same form? There is a view held by some that some of these houses with eight or ten bedrooms should go back to the residences of the past; however, there are not many people who need to be in an eight-bedroom house on Haddington Road or wherever. The nature of the requirement has changed. Do we need to look at that as well?

Mr. Hubert Fitzpatrick

On forcing changes through planning law, the Senator needs to differentiate between public sector projects and private sector projects. It is incumbent on the public sector, perhaps, to lead. For private sector projects, we have to always be conscious of the cost. It is a major factor. If planning restrictions are quite serious, it may make a project unviable. Each project has to be affordable to the end user. Perhaps the public sector could lead in innovation under the planning process.

Some planning requirements are particularly onerous and put an encumbrance on a developer or somebody who wants to go ahead with a project. It may not be for anything other than aesthetics or trying to be in character with the area.

Mr. Hubert Fitzpatrick

That is exactly right. That is why planning permission for various buildings has not been taken up. It is too expensive to build them, and no client can afford to do so.

The Senator made a point abut Georgian buildings with which I agree. We need to talk about appropriate standards that are safe. There are building regulations. It would be important to get all of those buildings back into use. They do not necessarily have to be put to the same use as they were previously. I agree we need to consider how to protect the facade. If a building is not viable and has been unoccupied for many years, the internal fabric is deteriorating.

That is an issue in every village and town. In Ennis, tremendous work is being done by the State and the local authority in upgrading the public realm. However, the above-the-shop spaces, if you want to use that term, are largely unutilised. We need to find a way to use those spaces. I suspect we will need to do so by offering more supports. The grant scheme that is there at the moment is working well for buildings that might have originally been residential. Those grants of €50,000 or €70,000 are adequate. I would like to hear some suggestions as to how we can get the spaces above shops operational and into the kinds of units that Deputy Bruton talked about. Perhaps the witnesses will not be able to make suggestions now but they could come back to us because that would be a useful way of getting people into accommodation and breathing life back into towns. It would play into the notion that there is no need for people to drive into towns when they live in them. The demand is there.

Mr. Hubert Fitzpatrick

The Senator mentioned an appropriate standard. The key challenge is how we devise that.

Ms Marion Jammet

We must also remember the cost of not acting in terms of climate fines and things like that. It will be important to take that into consideration if we miss our targets. That is why we need financial incentives to reduce the cost. There can be a financial incentive for innovation or other measures to provide better support for reuse. To give an example from another sector, there is a reduced VAT rate for repairing clothes and shoes in Sweden. There are other ways to ensure that the real cost is incorporated and we make these things more viable.

VAT on repairing and upgrading a building in Ireland is different to the rate in the UK. The relevant figure may not be one that our witnesses have off the cuff but they might provide that to us. There is a difference in how VAT is applied depending on the cost above which a property requires renovation. I have heard the situation in Ireland makes it less interesting for those who would seek to upgrade a house or a building on the residential side.

Mr. Hubert Fitzpatrick

For new property in the UK, a zero rate applies for VAT where the relevant rate here is 13.5%. If you renovate a building here for resale, you have to charge VAT back on the entire sales price.

That is the point.

Mr. Hubert Fitzpatrick

That makes it unattractive for someone to acquire a property, renovate it and resell it. Such a person would be hit immediately with a 13.5% VAT rate. We have made a suggestion in previous years and in our overall budget submission that a credit should be given in respect of the acquisition price and that would be offset for VAT purposes.

That would generate more activity in the development sector. Certain people in the development sector would bring those to the market. It is not everybody who wants to purchase a property and do it up themselves. Perhaps Mr. Fitzpatrick could provide to the committee a note on that topic.

We might pass that on to the new Minister for Finance. That would be an easy one for him.

I thank both groups for coming in. I will start with Ms Jammet, if I could. She has said that Ireland is not good on this front compared with other countries in Europe. We have one of the lowest rates of circular material use. Why is that the case? Why are we worse than the EU average?

Ms Marion Jammet

This is data from Eurostat. The circularity is rated at 1.8%. The EU average is about 12.8%. We are at an early stage with construction. We have done much good work on energy efficiency but perhaps the focus has not been so much on the circularity aspect to date. A number of things are not there which had perhaps been considered earlier in countries like the Netherlands. As has been said, that may be because it just does not have the same amount of materials in the country in the first place. Perhaps that is why that was considered earlier. As we said earlier, we need a more co-ordinated approach to increase the rate of circularity. There are some positive developments, like the national criteria from Articles 27 and 28 which are about to be approved by the EPA. We need to have this co-ordinated approach to support circularity, to support the demand side and the supply side. That would focus on public procurement, financial incentive and having the right infrastructure in place for storage, for example, which we currently do not have, or digital infrastructure. Skills are another thing. I think it was mentioned earlier. There needs to be a stronger focus on skills.

In her opening remarks, Ms Jammet mentioned the need for these circularity principles to be integrated into planning. That includes, for example, pre-demolition audits on larger projects. That makes sense to me. I agree with the point that Senator Dooley was getting at, that if it is not in planning regulations then the tendency and incentive will be for the lowest costs to be taken, and this will be externalised, so it is an enormous cost to society, including as a financial cost. Does Ms Jammet see any reason why the new planning regulations would only apply to the public sector and should not also apply to the private sector?

Ms Marion Jammet

It is clear that the public sector needs to lead by example on the policy and can drive demand. If we look at how planning is done in London, for instance, it is for all projects over a certain size.

It is not related to public or private, but simply the size of the project?

Ms Marion Jammet

For larger projects. We are not talking about one-off housing or small projects.

The environment does not care whether it is done by the public sector or private sector. Is that fair to say?

Ms Marion Jammet

We can start with the public sector, which makes sense.

I have a final question and then will go to CIF. A big issue here is vacant properties. They already exist and have a lot of embodied carbon. Even if they are in bad condition, full retrofits are still a fraction of the cost of building new properties. What is the main obstacle, as Ms Jammet sees it, to bringing vacant properties into use, which will obviously significantly reduce material throughput in the construction sector?

Ms Marion Jammet

There are a number of obstacles. The additional financial support that we have seen in recent years to bring these properties back into use is extremely positive. It could be improved. For instance, payment by instalment would be positive for the grants. I know it is complicated, but to make things easier for homeowners or small building owners, there could be a one-stop-shop system for reuse or links.

It might be the case that perhaps there is not enough co-ordination between grants for energy efficiency for reuse. I know it is challenging for that one thing. There are questions also on the building regulations. They must be reviewed to look at the challenges and also in regard to the provision of a guidance document on best practice.

I will now turn to the CIF. Do the witnesses broadly agree with the recommendations being made in terms of planning about pre-demolition audits?

Mr. Hubert Fitzpatrick

Planning is concerned with the sustainable development of the area. There is absolutely nothing wrong with those questions being asked about planning purposes because it means we have to review the appropriate way to approach each site. If it is more sustainable to retain the existing structures, that is fine. Any assessment will come up with what is the most appropriate or relevant approach on a case-by-case basis.

I might just turn to one of the previous points raised by the Deputy. We did refer to the fact that 7.7 million tonnes of existing construction demolition waste is soil and stone. If we were able to take the soil and stone and have it no longer classified as waste, we would be talking about a massive drop in the tonnage of waste produced in the economy. That is the whole objective of articles 27 and 28. The proper functioning of those articles would result in a huge diminution in the quantity we produce of what is classified as waste.

In response to the point on vacant properties, the biggest impediment to their renovation is the building regulations and how we come up with the appropriate standard that should apply to those units in order that people can safely and securely occupy them. The existing supports that are available should incentivise people to look at these properties in a different way because they are ideally located in town and village centres that are well serviced by public transport and other services. We should certainly support that.

Mr. Fitzpatrick says CIF is broadly in favour of a more circular approach to the construction industry. The CIF lobbies the Government a lot. Is this something it has lobbied for over the past year or in recent years? I refer to an increase in standards and so on.

Mr. Hubert Fitzpatrick

We support appropriate standards. We must ensure that we do not overregulate at the expense of making development unviable. The industry has been subject to huge cost inflation in recent years. Very often, many of the biggest challenges to development mean that it is just not viable to build. We support an appropriate standard that protects people to live and work in those units. We do not do anything that would endanger public safety, but at the end of the day the Deputy must bear in mind that for a development to take place it must be viable. In many cases, overregulation can result in development becoming increasingly unviable. That is perhaps a cause of some of the vacant or underutilised buildings at the moment.

Mr. Eamonn Stapleton

I wish to add a broader response to Deputy Murphy's question. The reason I am here is that I am chair of the CIF's environmental, social and governance, ESG, committee. We established our ESG committee two years ago to try to address the issues relating to climate change. We have invested heavily in the membership of various organisations that will inform our members on best practice. We are not necessarily waiting for the regulation that we are talking about here to compel us to do something either commercially or by regulation. We see an opportunity for the CIF itself to identify the right approach. Hence our engagement here and with other parties, so that it is not done unilaterally in a manner that ends up with an ineffective solution. We embrace fully the need to make changes.

To ask the question again, in all of the Construction Industry Federation's lobbying of the Government, has it lobbied in favour of increased standards in service of environmental standards for building in terms of circularity?

Mr. Hubert Fitzpatrick

The Government itself has introduced significant environmental standards in building over the past number of years. The performance standards of buildings today are equal if not higher than in many other parts of Europe. Regarding the energy performance of buildings today, they are all A-rated buildings, which is a terrific performance standard. Further to what Mr. Stapleton stated, we invested in the carbon calculator - a significant investment by the industry to enable all members to determine their carbon footprint. We backed the supply chain sustainability school - further education within the industry on this most important issue. It is an issue the industry has to be on top of and is progressively supporting. I would not like the message to go out that the industry did not support greater environmental performance; it does but we want to ensure we have a more effective industry delivering on the required standards and that we still operate in an industry that can be viable to work in.

It seems to me that the Construction Industry Federation is coming before the Joint Committee on Environment and Climate Action and saying it is all for circulatory but in terms of its engagements with the Government, I think the witness said the Construction Industry Federation has never lobbied for increased standards. When I asked about increased standards, the representatives immediately went to the danger of overregulation and increased costs, that it would prefer not to be forced to do this and that it would take care of it themselves. That was the argument. It seems that this ESG stuff the CIF engaged in, as are lots of corporate lobbyists, is about covering itself and saying not to worry, please do not regulate us and we will take care of it in order to avoid these costs increasing. Is that a fair summation of the CIF's position?

In fairness to our guests, they are here in a voluntary capacity. They have engaged in good faith in the session. There has been good engagement with them.

It has come out here that the difference is that when we got the actual points, they gave out about overregulation.

They are not lobbying against it.

We did not even hear-----

That would be-----

They would have previously lobbied against it. I agree; we are in here in good faith and I am engaging in good faith with them. I am interested in the response.

I am happy to hear the response, but to be fair to the guests, they have engaged positively and in good faith with us today, which is to be welcomed. Did Mr. Stapleton wish to comment?

Mr. Eamonn Stapleton

I accept the Chair's prompting and interjection. I am an active contractor. I am in infrastructure primarily; I am not involved in the housing and building side of things but I work with those people all the time. Attendance at our ESG committee has overtaken some of our other committees in the CIF, which are more commercially-orientated. Involvement in those committees is by builders, infrastructure people, demolition people and services people. They all want to know how to do it better. Whether that has yet resulted in lobbying of the Government to address it, I do not know. That is for Mr. Fitzpatrick. Whether it is done through an official channel, about which someone can say that is lobbying in favour of it, I am sure we can find out. The motivation is there, to reassure Deputy Murphy. It will come through the membership to the executive because that is where our interest is. We recognise there is a problem. The IGBC has articulated the difficulties and the different strands to it. We are only the poor guys at the tail end who will do what we have to, but we are investing heavily in becoming more aware of how we can do better.

Mr. Hubert Fitzpatrick

To reiterate, we have invested heavily in the whole education piece, for example, the supply chain sustainability school. We were not asked to do that by the Government. It was done willingly by our ESG committee. There is also the measurement of carbon. We have lobbied the Government to see if we could use more efficient fuel on-site. We lobbied the Government to see if the cost of HVO fuel could be reduced to make it more attractive on-site because it is more expensive than ordinary diesel fuel. I do not see anything wrong with that. If we can operate more efficiently on-site using environmental fuels, that is a perfectly legitimate thing for the federation to do.

Mr. Giovanni Impoco

Perhaps something that facilitates EU member states is a common language for measuring the circular economy. Perhaps introducing other metrics, such as the economy and volume, would facilitate green public procurement. The Netherlands uses more services, which allows value to be retained longer in the market. This is one part of it. In Italy, cheap targets can be specified and facilitated using percentages. The rate of the reuse of certain parts of buildings by manufacturing can also be specified. An area where Ireland is improving is with regard to the quantification of the material stock it has. The Department has asked Circle Economy, which is a Dutch entity, to report on the circularity gap. This will allow the material stock in Ireland to be quantified. Senator Dooley asked about an investment player. Ireland has done a lot. As my colleague from the CIF already mentioned, there was a discussion on VAT in construction. A player such as Teagasc, which could bridge between industry needs and governmental targets, is missing from the construction sector.

These questions are very important. They are not about criticising any individual. Our task as a committee is to identify what is going to work and what is going to happen. We cannot take gambles because there is far less space now. We hear concerns about the profit margin and development. There is far less leeway in the space we have to address our climate crisis. We have no leeway. We have deep debt in terms of where we are at. We need to know things that would be efficient. It strikes me that there needs to be an element of being convinced, if not by the profits, because they may or may not come through, then by regulation. We need to look to drivers we know will deliver. We cannot take a gamble on it happening to align.

I question the idea that it is difficult and non-profitable to develop. I went through the previous crisis and I saw people who went bankrupt and somehow they are multimillionaires again on the back of development. If very high levels of profitability not being profitable enough is a block, then it points to questions about the State construction agency that is spoken about. Many working in the construction industry work on State contracts, so it is not necessarily a block. We cannot have a vulnerability through solely relying on incentives and solely hoping that green construction will turn out to be profitable. We absolutely need to reduce our emissions and this is the underlying goal. This is why we need to look at what the stronger tools are.

I want to pick up on the topic of procurement which was discussed earlier. Mr. Impoco has spoken about procurement. It is something on which I have pushed very strongly in the past. We know that choices are already available, for example, the choice to go with lowest cost procurement. I have had very constructive engagement with the Construction Industry Federation with regard to this. Price-quality ratio is one of the options available, as is lowest cost. We can go for life cycle, price-value ratio, which means the best ratio between quality and price, or lowest price.

Very often, the lowest price tends to prevail or we see a low weighting attached to the quality criteria. We saw that in regard to the national children's hospital where the ratio was 70% on cost and only 30% on quality criteria. However, within those quality criteria I suggest there is the space for us to look at really strong criteria and not simply the specifications. It is not realistic to ask that everybody who is procuring something would use recycled paint or a particular material. It would be ideal if that was looked for as well, but if you have a quality weighting environment, it allows those in the construction industry who are actually innovating and who are actually raising their standards to have a competitive advantage when they are tendering for State contracts. Will the witnesses comment on that? There are two pieces. There is the technical list that comes with the request for tender where such issues as recycled paint and reusable materials are mentioned, but perhaps there could be an even higher premium for reused materials, so it is not just the reusable but materials that have actually been reused. That could be an issue that could give an advantage. Also, there is the separate question of a quality criterion that allows for those who are innovating in emissions reduction to come in. I would like comments on that.

The other area that I would love both groups to comment on is the measurement of embodied emissions. It was somewhat touched on, the idea of refurbishment and so forth. There is often talk of measuring the emissions in the materials that go into construction but demolition creates a huge amount of emissions in itself. Will the witnesses comment on, for example, where a green building with a solar panel on top is being put up but where a building has also been demolished? There might be a 70- or 80-year debt in terms of emissions. Of course, it is the next ten years that matter most. Do we need a moratorium or a really strict limitation on demolition? Should demolition become an exception rather than any kind of rule during the next crucial ten-year period?

My questions are addressed to both organisations.

Mr. Eamonn Stapleton

I will respond to the question on procurement and the balance of price and quality. That has been out there for a number of years. It varies from 70% price and 30% quality to 30% price and 70% quality. Quality is not always necessarily associated with green procurement. Historically it might be associated with other aspects of the job. Whether it works is open to debate in terms of whether it is an objective enough way of procuring.

Is it better than price only?

Mr. Eamonn Stapleton

I believe the CIF has always advocated that. We would see that innovation should be rewarded in our membership and investment in research. Probably the missing part the Senator touched on briefly would be the metrics associated with measuring the implications of emissions. That is in the very early stages. The OGP is developing that such that it will be inclusive in procurement. It will be a further column in the pricing element that will address the emissions impact. That is moving in the right direction and it will be encouraged by the CIF. I do not think there is any problem with that.

Regarding the priority of profitability, as a member, there would be no point in me being the most sustainable business around if I am not profitable at the end of the day. There has to be a consideration for profit all the time. That would be accepted by everybody. There is room for a change in public procurement to include a greater metric associated with concern for the climate impact.

That is the question because, sometimes in certain areas, public delivery can be in a position such as, for example, where for a long period of time the State has had access to finance on perhaps a more favourable rate than the private sector. There is certainly scope there in terms of being able to do this without going through the market and where it would actually be more expensive to do it through the market.

Mr. Hubert Fitzpatrick

We need to reduce our emissions. One of the key objectives of the federation is to support members in reducing their emissions. That is why the carbon calculator has been launched across the industry.

I referred to demolition earlier. We have to be able to support demolition in the context of any planning application going forward so that it is more sustainable. We look at whether the more sustainable option is to demolish or to renovate. As Mr. Stapleton pointed out, the question of profitability arises here. I would use the word "viability" because if a project is not viable, it will not start. The land will lie idle and the development simply will not take place without that viability issue being addressed.

Mr. P.J. Ryan

On the renovation piece, we need to be careful with renovation and embodied carbon. At the moment we are running out of serviced land that has infrastructure available. We need to be careful that we are not limiting what we can do on our city centre sites where we have a lot of infrastructure. We need to be careful there. Looking at a building on its own is fine. In that case, renovation is probably more carbon efficient. However, we might be able to say that the site could sustain a higher block of apartments, for example. If those apartments are not built on the city centre site but are built on a greenfield site and new infrastructure has to be installed there, it is more nuanced than simple saying that renovation is the solution because it saves carbon in the long run. Those considerations are important as well.

I have two more questions. Will I put them now so that they get answered, instead of going back to everybody twice?

I am sure the Senator has more than two questions.

I have two specific questions.

Okay, go ahead.

It saves the need for everybody to come in twice. This is around planning issues. We talk about housing but actually what we see in the city centre is many empty office blocks. I live in the city centre in Dublin and we are surrounded by empty office blocks. There is that question and there is talk about reusing and repurposing them. There is also the question of appropriate use of scarce sites when we are looking to facilitate development. While I understand that they were profitable in terms of portfolio, they have not actually delivered very much for us.

There are questions about higher buildings. There is a lot of talk about delivering environmentally. However, we just see a lot of high office buildings. That can diminish light. Has there been much examination of the issue of light, from an environmental perspective? We know it is a really key issue in terms of reducing energy usage, besides all the associated health issues. I am asking about proper analysis of light as an environmental issue within building design and building standards. We need to strengthen provisions in terms of light. That could be clarified-----

It is not quite on the circularity piece.

It is not quite on circularity but it relates very much to the environmental footprint of buildings and their design. It relates to that question. I was really answering the point that Mr. Ryan made about the belief that if you build higher, it will automatically be better. In fact, repurposing a development at a mid-level can sometimes be better in terms of light, which has an environmental aspect.

The last question I want to ask is on the circularity piece. It has been highlighted that if we are to engage in a circular economy, we actually need spaces in which to do that. There were comments from the Irish Green Building Council, or perhaps the CIF, around materials. It was suggested that if we are to have soil and stone reuse, we need to have places where soil and stone can be appropriately stored. It literally almost needs a physical infrastructure for recycling and reusing materials. That in itself needs to be allocated space. That is just a piece I want to ask about because it is actually part of the circularity piece. I wanted to add those points.

Mr. Giovanni Impoco

When the Senator mentioned evaluation and using the right evaluation criteria, one good example came to mind. In the Netherlands, there was a municipality that needed a public building. It knew that the municipality would eventually be absorbed by the Amsterdam area so there was a limited time, of 15 years, in which this building would be used. They conducted a good evaluation that included economics and CO2 emissions. They also specified criteria and reached the conclusion that building with a design for reconstruction would be a win-win for everyone. That is what they did and after 15 years they moved this building somewhere else and it became a library. As the Senator said, we can specify different metrics apart from CO2 emissions which include cost, percentage rates and so on to facilitate green public procurement.

Regarding demolition, the question can only be answered on a case-by-case basis. To take the example of Opera Square, they used a pre-demolition audit and a waste management plan which allowed them to achieve 98% of secondary material use off site and on site. More than one tonne of stones were used elsewhere in Limerick, as well as bricks using the channel in Limerick. All of the timber was recycled, the metal was quantified and 100% of it was sent for recycling. On the issue of incentives, the introduction of some bands for the use of the right tools could be applied as well. We need a carrot-and-stick approach.

It is interesting that Mr. Impoco mentioned the Dutch model, which is what my procurement legislation is based on. It is still about value for money but it is framing value for money within a wider lens.

Ms Marion Jammet

On public procurement, it is interesting that the Senator is looking at the Dutch model. Another thing we are doing is piloting what is called the carbon performance ladder tool. I do not know if the Senator is familiar with it but it is a Dutch model that is currently being piloted by Transport Infrastructure Ireland in a number of its tenders. The idea is that if an organisation reaches a certain level of certification in relation to addressing its carbon emissions, the price will look lower because the public bodies can apply a discount rate. It is up to public body to decide what the discount rate is on the final price. That is one example.

On demolition, what the Senator said it is interesting. It is determined on a case-by-case basis, but, in general, it would be important to have a real rationale for demolition and to encourage a proper assessment of the impact of the demolition and any alternative proposal that may be put forward. That means looking at the life cycle assessment associated with renovating and with the alternative proposal which includes demolition and rebuilding. As Mr. Impoco was saying, if we do decide to go ahead with demolition because that is the right thing to do for a specific building, we need to look then at circularity statements, pre-demolition audits and so on. Generally speaking, we probably need to reassess the need for demolition for larger buildings and see if it is the right thing to do in that specific context.

In relation to storage for products, in all of the pilot projects we have done on circularity that has come up as an issue. Questions have arisen as to where we store these materials, as well as issues around the schedule in terms of not having the right materials in the right place at the right time. It would be useful to have a catalogue to know what is available.

Soil and stone were mentioned earlier and it would be useful to have that information in advance. In terms of storage, a few issues arise. In Helsinki, for instance, there is a central place for soil and stone storage but it depends on the materials. The main thing is to make sure the materials are stored in the proper conditions and can be recertified or tested, as necessary.

On that storage piece, I am wondering-----

I am sorry Senator, but you have already had about 20 minutes.

We will go back for a second round but I want to come in myself now, if I may. The Opera project in Limerick has been referenced by the Irish Green Building Council quite a few times. I am familiar with it as a representative for Limerick city. What is happening there is really good in terms of circularity, the use of demolition waste and making sure it is repurposed. It is quite exciting that Limerick is leading the way in that regard. The interesting thing about the project is that its genesis is a bit murkier. There was a late 1970s concrete structure and about ten years ago it was mooted that it would be demolished. There was some merit in doing that. There are all kinds of things one would look at in trying to assess whether it should be demolished or not. In any case, that was the thinking and that is what gave rise to the new Opera project, which in itself required some demolition but ultimately, a new lead-standard, very modern construction. If we were looking at that now, we probably would not justify moving out of what is actually a public building. The Revenue Commissioners are based in Sarsfield House in Limerick and the idea is that they would move across to this new Opera project. If we were looking at it now or if the OPW, which is the owner of the buildings, was looking at it now, it might not as easily justify the new build because the question of embodied carbon would come into the judgment. That said, it might weigh it all up, look at various things and decide that it is still justified. I would not come down on one side or the other in that regard but certainly the conversation around embodied carbon has advanced incredibly and has been referenced so many times in this hearing. It is really in the front of people's minds and that is a good thing.

One of the challenges with embodied carbon is that there are so many variables. It is such a complex thing to really properly assess and measure. It is coming in, as per the European directive, in 2028 but I wonder how that will nudge things in the right direction. It is very important to be able to measure it but there also has to be incentives to nudge developers and prospective developers away from demolition and towards renovation and retrofitting. It seems that it is not really an exact science and a lot of these decisions are made on a case-by-case basis. We have got to look at things very carefully and there are so many things to weigh up. If it is not an exact science as to whether one should demolish or retain and repurpose, then it is a subjective call which means we need very qualified people to properly assess the application that is being made. I wonder if we have the level of expertise in our planning authorities, including An Bórd Pleanála and the local authorities, to really properly assess this very complex issue on a case-by-case basis. Do we need to upskill local authority and An Bórd Pleanála staff? Do we need to bring in more resources? Are we well set up for the situation that will emerge in a few years' time, where embodied carbon is one of the main drivers of decisions around demolition?

Mr. Hubert Fitzpatrick

I am aware that local authorities are actively looking at this in the context of the assessment of planning applications. Some have written more prescriptive approaches into their development plans. Once it is written into the development plan, each planning application has to be assessed on a case-by-case basis. The situation is very similar with An Bórd Pleanála which has upskilled its resources across quite a wide range of areas over the last 12 months.

The board is assessing this, effectively, on a case-by-case basis as it is obliged to do once it is written into the development plan and according to the directives. It is a case of balancing land use with retention of existing structures and the Cathaoirleach referenced there being an element of subjectivity to it. There is also a reference to viability. As Mr. Ryan referred to, there are cases where if we do not go for greater intensification of the particular land in question, we are just going to drive that development out to perhaps more unsustainable locations outside town or city boundaries. It is a scarce product.

My next question is perhaps not one for CIF. The IGBC might be better placed to answer it, or maybe the CCMA, representatives of the local authorities or An Bord Pleanála itself. Due to the element of subjectivity, surely very qualified people are required to make these judgments. Otherwise the door is open for judicial challenge and so on. Ms Jammet may want to come in.

Ms Marion Jammet

Circularity is really like a change of mindset, so obviously it requires upskilling, including among public bodies and not only architects and engineers, but also procurers. They need to know what we are asking for when we assess things. On the whole-life carbon measurement and the requirements, we are doing work at the moment on the national methodology in partnership with the SEAI. We have also tested the methodology on a number of buildings of different typologies with the idea of having a good baseline. Then when it is time and the targets are introduced - because it is another requirement in the directive from 2030 that we have this data - it might be the case-----

Which targets?

Ms Marion Jammet

The targets for whole-life carbon reduction for new builds. It is complicated because then you bring transport emissions into consideration as well as density and all that. Something we are looking at currently as part of a project called Viable Homes to make it easier for planners to identify carbon hotspots and things like that.

On the methodology, we are looking at developing our own. We see now with the European performance of buildings directive we are looking at a consistent methodology across Europe for energy labelling. We are moving away from the BER we have had for the last ten or 12 years, I think, or at least the bands for the BERs across member states are going to be consistent now, which they have not been until recently. That is for the operational energy use of the buildings. If we are looking at developing a methodology for whole-life carbon here with SEAI, which is really important work, I am curious about what is happening in other countries. Are we perhaps going down the road of being inconsistent with what other countries are doing?

Ms Marion Jammet

No, it is aligned with what we have in the levels. The European framework for sustainable buildings is aligned with the taxonomy. We are not doing anything that is not aligned with requirements at European level. What is useful as well as part of the development of the methodology and the pilots is very much to identify the hotspots, so perhaps we do not to look at all materials, or at least we do not need to give the same level of consideration to everything. It is really about the hotspots. What we see is very much in terms of carbon. It is the substructure and the facade. Maybe that is another thing to keep in mind with respect to where our focus is.

Okay. I thank Ms Jammet for that. Does anyone else want to come in or are there any more questions from members?

That was very useful. I just wanted to highlight something. I was going to ask about the methodologies, but that is what the Chair asked about. Has there been engagement around the development of methodology?

Has the council or the federation had any engagement with the Government on the question of the new methodologies being formed? How has that gone? What kinds of points have the witnesses been raising in that engagement?

It is also worth noting those little small pieces such as I mentioned on reuse and reused. Sometimes we have things that are reusable but they are never reused. We know from the Rediscovery Centre and others that paint can be reused. Is it a matter of rewarding and encouraging not just reusable but also reused materials?

The other question comes almost into the area of right to repair, which we have been looking at in other areas. These are things that are designed to be deconstructible. Reference was made to not using adhesive but using screws, for example, and things like that. Are there specific small elements like that that should be happening right away? We have been talking and focusing on the big decisions such as whether to demolish or build, but some of those small pieces can be very significant and could be become almost standardised as technical specifications, where possible, in building. Perhaps we could look at strengthening those technical specifications on those small little issues.

There was also my question on the witnesses' engagement with Government on the methodologies as we try to craft our new methodologies.

Mr. Hubert Fitzpatrick

The industry wants to reuse on site to the maximum extent possible where it meets the appropriate standard.

Mr. P.J. Ryan

Sometimes there are materials like raised access floors. There were examples of that recently where people want to reuse those, but with the insurance sector and warranties and such, it becomes difficult to reuse those materials even though they are probably perfectly good to use. It is just that the manufacturer will not stand over them and then the developer will not be able to get-----

Is this to do with certification?

Mr. P.J. Ryan

Exactly, yes. That whole piece needs to be aligned with the insurance sector so that perfectly good materials can be reused. It does happen occasionally on projects where the owner is involved but in a lot of offices, for example, it is developer led and we do not know who the final tenant will be. You cannot really start reusing second-hand materials if there is an insurance or warranty issue.

Would Mr. Ryan agree that re-certification is a mechanism we need to have for material we reuse?

Ms Marion Jammet

Absolutely, and the rates for access. It is something that can be done whereby we can reuse more. It is easier to reuse in the UK but a recertification system is in place there. It is definitely something that needs to be considered.

It strikes me it is the big projects where we would probably need it most. Green space is an issue in terms of larger developments. Maybe there is something in that. It was mentioned that materials can be stored for only six months. Is that correct? What is that based on? Is it a rule or is that based on-----

Mr. P.J. Ryan

Yes, it is a regulation. They do not want to stockpile materials for long times on site. It just makes it difficult. Once it leaves a site, you need to have a location for it that has planning. Up to now this is how a lot of it has ended up being deemed waste because-----

It strikes me that on large sites, if there was something that could be stored for longer, for example, within a large development site, then down the line that could potentially be repurposed as being additional green space in the development. It seems a pity to simply have that six-month rule block when there could be quite large-scale use of soil and stone.

Mr. P.J. Ryan

It is not just soil and stone. There are other materials from demolition that potentially could be reused potentially. On the municipal waste side, we have all these recycling centres where people can take materials. That infrastructure exists and there is no reason to dump a microwave into the bin as there is actually somewhere now to take it. On the construction side, that infrastructure is not in place so it ends up having to be dumped. We do not have that infrastructure so we need to build all that out.

At the other end, there is the extraction piece. The Green Building Council in the UK is holding a symposium - I believe it is today - where one of the issues is looking at the extraction of sand from Lough Neagh. That extraction piece is an issue.

Mr. P.J. Ryan

The other point that was mentioned about statistics is that Ireland exports a great deal of precast concrete. Many countries, including the Netherlands, are aggregate poor, so they import and we export. On circularity, it will never come back into the economy once it goes away. That is a piece other countries do not have. We have had a lot more aggregates up to now.

That is an area in construction where it is about looking for standards at the production points with regard to what is going into the concrete we export and not just the concrete used in building. The standards that apply in respect of materials at the point of production is another issue that needs to be addressed. I am just trying to get a sense of what the different aspects are. It is useful.

Mr. P.J. Ryan

Yes. I hope the work we will be doing with the EPA and other bodies to recycle crushed concrete and perhaps bring it into the concrete process will help in that regard.

I am not sure if Ms Jammet has anything to add.

Ms Marion Jammet

With respect to things that are simpler - the Senator said the small things - my colleague, Mr. Impoco, mentioned extended producer guarantees or product-as-a-service that is being done in the Netherlands. A good example is the airport in Amsterdam, which does not own the light. It is a product as a service. It is the same for elevators in the Netherlands. They are rented as a product or service for 40 years, which means the maintenance is given to someone else. Mitsubishi will be responsible for maintaining the elevator for 40 years. This kind of alternative model keeps value in the chain.

On the methodology, yes the Department of housing is also involved with us on this.

Mr. Giovanni Impoco

In Amsterdam airport Philips provides the lighting service. In that case the airport pays less upfront costs and all the responsibility and the materials used are the responsibility of Philips. The circular economy comes in. You do everything, still have the value, they can sell the full vision and Amsterdam airport receives more frequent upgrades.

As was said, some infrastructure is missing in Ireland. For instance, we already have some good examples of extended producer responsibility, such as WEEE Ireland, Repak and for tyres, but unfortunately there is nothing at the construction level, which would be good.

The Senator also spoke about materials. Certification is an issue, but the problem can also be tackled with material passports which are coming in the new regulation in a few years.

There are little choices to be made, such as not over-using adhesives and repurposing paint where possible, which should become standard practices where possible. The overuse of adhesives instead of screws was mentioned making things more disposable. We are almost into the consumer durable discussion we had.

Mr. Giovanni Impoco

The manufacturers need to decide on more circular approaches, even for them to give back to the user.

It is like the right to repair but it is also the right to deconstruct - that something should be deconstructable.

We will wrap up soon but I have a few more questions about embodied carbon. It was mentioned that there will be a mandatory methodology across Europe to measure embodied carbon in new builds from 2030. Is that correct?

Ms Marion Jammet

It will be for larger buildings from 2028 and for all new buildings from 2030. That is measurement. However, there will also be a requirement for member states to start introducing targets from 2030, with the idea of having a downward trajectory to 2050.

That all relates to new construction.

Ms Marion Jammet

It relates to the energy performance of buildings or EPB.

I refer to the context of new buildings, as well as the challenge of using more sustainable materials and reducing the carbon that will be built into the buildings at construction stage. I am thinking about timber and how in this country there is a regulatory barrier to using timber, particularly in taller buildings. If I remember correctly, in an earlier meeting of the housing committee it was stated that there is a problem with Technical Guidance Document B, TGD-B, which relates to fire. As I understand it, that is just guidance and not law, but it is what everybody ultimately follows. Has there been any work on that? This is a question for the Department, but has the Irish Green Building Council engaged with the Department on this particular barrier to using timber in larger and taller buildings, as is happening in other European countries?

Ms Marion Jammet

The timber in construction steering group that was set up by the Minister of State, Senator Hackett, is actually looking at that. There is a subgroup that is specifically looking at regulation and I believe that TGD-B is a big part of its work. This will ensure that this will remain on track and that we deliver as soon as possible on the specific area.

Is that with the Minister of State, Senator Hackett, who is in the Department of agriculture?

Ms Marion Jammet

Yes, that is correct, but a number of Departments are involved.

I thank Ms Jammet for that. Does she have any experience with the Department on that issue?

Mr. Hubert Fitzpatrick

We are aware that work is under way at this stage. We will be looking forward to some form of recommendations on it.

Mr. P.J. Ryan

I have just one comment on this. People have been before our committee to speak about Forest Stewardship Council, FSC, timber and that side of things. One of the comments it made was that much of our wood is imported. We have to use wood from Norway and other places but there is probably more scope to use Irish timber. There is a tendency to over-specify. The impression it gave was that a lot of Irish timber could be used and we are just setting a standard that may not be necessary. That is probably something to bear in mind, to try to keep our own industry-----

Yes, and if we are to take the truly sustainable approach, it might make far more sense to use the lower quality timber in the appropriate circumstance. I am referring to the Irish timber, which is certainly different to the Scandinavian product.

I do not have any more questions. Do our guests have any more comments? Do our members have any other questions? If not, we will finish up there. I thank you all for coming in this afternoon. It has been a really interesting session that will help us to form a report with recommendations for Government. The engagements we have had today, the witnesses’ opening statements and the other sessions we have had on the circular economy will all feed into a report by this committee, which the secretariat will prepare. We as members will agree on it. If the guests have anything to add, and if, for example, they walk out of this room, have their lunch and think of something that was not said and that is important, they should please feel free to send it in to us.

I wish to make a comment on that. Regarding the report on the circular economy, it is all about utilising assets insofar as we can. This goes back to the couple of points I made on VAT and the issue of Georgian property. There is a difference between the way in which properties such as those are treated here and in the UK. The witnesses might share information on that.

This may be picked up-----

It is not part of the circular economy, but it is about making better use of an existing asset. While I am not talking about the life cycle of the material, at the end of the day this is about reducing our carbon footprint.

Our guests may wish to send in more information on that-----

That would be helpful.

-----but I think it will be picked up because it was discussed quite thoroughly.

On that issue, if something occurs to anybody we would be grateful.

Mr. Hubert Fitzpatrick

On that issue, an analysis is being undertaken in respect of planning applications and high-rise buildings so that it is considered at planning stage.

The environmental aspect is one of the issues that I think has been underestimated.

I again thank the witnesses for their attendance this afternoon. We look forward to preparing that report.

The joint committee adjourned at 1.15 p.m. until 11 a.m. on Tuesday, 9 July 2024.
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