**Policy Framework for Energy Retrofitting of Built Heritage: A Critical Comparison of UK and Turkey**

#### **Negin Jahed <sup>1</sup> , Yasemin D. Akta¸s 2,3,\* , Peter Rickaby 3,4 and Ay¸se Güliz Bilgin Altınöz <sup>1</sup>**


Received: 31 May 2020; Accepted: 22 June 2020; Published: 26 June 2020

**Abstract:** Energy efficiency is one of the most prominent global challenges of our era. Heritage buildings usually have a poor energy performance, not necessarily because of their intrinsic constructive features but due to their mostly dilapidated condition owed to age and previous damage, exacerbated by other factors such as the limited maintenance allowed by the restrictive legal framework and/or residents not being able to afford retrofit. On both national and international levels, energy efficiency measures are considered the key to answering the global challenge of climate change. This article aims to provide a critical discussion of the policy framework for energy retrofitting targeting built heritage in the UK and in Turkey. To this end, the development of guidance and legislation on cultural heritage, energy efficiency and climate change in both countries were thoroughly reviewed, and the retrofit incentives and constraints were determined in order to identify existing policy gaps and potential problems with implementation in the realm of energy retrofitting and climate resiliency of heritage buildings. As a result of a critical comparative analysis, the paper is concluded with suggestions on policy frames for the retrofitting of heritage buildings for improved energy efficiency.

**Keywords:** built heritage retrofit; energy-efficient retrofit policy; conservation policy; UK; Turkey

## **1. Introduction**

It is claimed that the current energy use trends could lead to a 2 ◦C rise in global temperatures by 2030 [1], which is the level considered by scientists as a tipping point for climate catastrophe [2]. Buildings' energy use is estimated to be responsible for more than 40% of all energy use per nation on average [3]. The situation is considered to be more critical for heritage buildings, which despite their environmental credentials in terms of passive heating/cooling, lighting, ventilation, and good orientation, due to age, lack of maintenance, and previous damage, mainly, may demonstrate a poor energy performance that makes them more vulnerable to the consequences of changing climate [4,5]

Although reducing energy usage in buildings is considered key in national and international efforts to minimise carbon dioxide (CO2) emissions, buildings with heritage values are often excluded from policies and regulatory frameworks on buildings' energy use reduction. A clear example of such exemptions on the international level is stated in the European Commission Directives; 2010/31/EU on the energy performance of buildings [6] and 2012/27/EU on energy efficiency [7]. According to these directives, officially protected buildings and monuments due to their special architectural and historical merits may be excluded from the energy requirements. On the other hand, in the amended directive 2018/844/EU [8], the 'research' for and 'testing' of new solutions for improving energy efficiency of historical buildings are encouraged provided cultural values are preserved. In the case of Turkey, national legislation such as the Turkish Energy Efficiency Law No: 5627 also highlights the exclusion of "protected buildings or monuments" from the scope of the law [9]. Besides, the Turkish National Energy Efficiency Action Plan (NEEAP), released in 2018, highlights the importance of developing a national energy efficiency roadmap to ensure energy demand in various sectors, including buildings, meet global target levels for sustainability. While the action plan calls it a strategic goal to 'reduce building energy demand and carbon emissions; scale up environment-friendly buildings', it does not concern itself with the heritage building stock [10].

This study seeks to assess regulatory frameworks in the UK addressing standards for energy retrofitting of built heritage and then compare these with the existing situation in Turkey. UK was selected as the benchmark case here for a number of reasons. Firstly, the UK's existing housing stock is still one of the oldest and least energy-efficient housing stocks in Europe, 20% of which is composed of pre-1919 homes and another almost 20% were constructed between 1920 and 1939 [11]. Secondly, retrofitting heritage buildings, particularly historic residential buildings, is being given high importance in the UK following the government's commitment on reducing national energy use to achieve 2050 emission reduction target [12]. Thirdly, the UK is one of the first countries in recognizing the economic and security threats of climate change through the Climate Change Act launched in 2008 [13] and has been among the most successful developed countries at growing its economy while reducing emissions [14]. Fourthly, UK policies on energy performance of buildings have been developed towards the strategies to overcome the future overheating problem in building stock [15]. This problem, specifically, makes the UK a comparable case with Turkey, where climate change impacts are mainly characterised by strong warming trends [16].

We believe regulatory policies on energy-efficient retrofitting of historical buildings should be country or even region specific. However, the tensions on the intersection of energy and conservation philosophies are of broader concern. Developing new policy frameworks in this realm, would only be possible in light of an appraisal of both the constraints and incentives in the existing regulatory framework of each country. Several analyses have already been carried out to assess Turkey's current energy efficiency policies [17–19], however, none of them addresses the lack of legal and technical legislative frameworks for improving energy efficiency of historic buildings. The limited number of studies concerning energy-efficient retrofitting of historic buildings in Turkey in comparison to European practices e.g., [20,21] confirm that Turkey needs to be more engaged in research and development activities to be able to increase public awareness and close policy gaps in this field [20]. In this study, we expand on these analyses by discussing the position of energy efficiency within the built heritage conservation legislative and technical guidance frameworks. This paper is organised as follows: Section 2 describes the methodology applied in the study. Section 3 provides a background on national energy efficiency and heritage conservation policies in each country, while analysing the incentives and constraints for retrofit both in the case of the UK and Turkey. In Section 4, a critical comparison of the two countries' policy frameworks is presented and six main suggestions/lessons are pointed out. Following the discussion of other critical factors which play a defining role in the eventual viability/efficiency of policies on the energy efficiency of heritage structures in Section 5, the paper is concluded in Section 6.

#### **2. Methodology**

In order to capture the developmental process of policies, the data collection for this study began with mapping the landmark national policies on cultural heritage conservation, energy efficiency, and climate change for both the UK and Turkey in a chronological order. In the international level, only the policies with a specific focus on energy efficiency for the built heritage sector were considered to

determine the level of alignment between these two countries with international legislative frameworks. The published policy documents, their end goal, and related institutional structures in both countries were gathered from (a) international and multinational sources, (b) government websites, and (c) non-governmental organisations' websites. In order to provide an in-depth understanding of the retrofit incentives and constraints, various information sources, such as research and review articles, project reports, and conference proceedings focused on energy retrofit policy frameworks for built heritage from both UK and Turkey were identified and accessed through widely used research databases, i.e., ScienceDirect, Web of Science, and SpringerLink. Further, retrofit practitioners or experts from academia, from both Turkey and the UK, provided access to country-specific information sources and in-country contacts to supplement the information collated through web-search. In order to establish an even and reliable basis for the review exercise, we covered sources falling under any one of the categories listed below:


As a result of this initial search, in order to reveal the position of each country in terms of the overall policy framework for the energy-efficient retrofit of built heritage, we categorised the policy instruments based on where they fall in the following three key streams of developments:


#### **3. Background to the Policy Frameworks: Decoding the Retrofit Incentives and Constraints**

## *3.1. UK's Legal and Administrative Policies on Improving Energy Performance of Buildings: A Chronological Review*

UK's energy policy development trends can be classified into four distinct phases of (1) Energy conservation phase (1973–1981), (2) Energy efficiency phase (1981–2000), (3) Energy efficiency and environmental awareness phase (2000–2010), and (4) Near-zero carbon phase (2010–Present). Like many other countries all around the world, under the pressures of oil crises in 1973 and 1979, as well as raising energy prices, the UK's energy conservation phase started in the 1970s. Since 1981, the policies have shifted from 'energy conservation' towards 'energy efficiency' and several regional energy efficiency offices were set up at this time. 'Conservation' meant doing without things, which was not attractive in a consumer-led economy. Instead, 'efficiency' was about doing more with the same amount of resources, which makes it easier to sell it to the public emphasizing the economic and social benefits, warmer houses, lower bills, and higher productivity. The year 1983 is known as the UK's golden age of energy efficiency [22]. Underpinned by the establishment of the Intergovernmental Panel on Climate Change (IPCC) (1988), the UK's first meeting to tackle climate change was held in 1988 and one year later in 1989, energy efficiency was positioned as the central means of delivering emissions reduction. Climate policies gradually gained importance in this period with new programmes and energy prices fell. The 1990s were known as the era of energy efficient appliances and energy rating standards. An Energy Labeling Directive and Standard Assessment Procedure (SAP) were launched in 1992 and 1996, respectively, for the energy rating of dwellings. First building energy efficiency regulation under Part L of Schedule1 of Building Regulations in England and Wales was launched in 1990 [23]. Part L comprised four components referring to both existing and new buildings in residential and commercial sectors and in compliance with the EU Directives the 2002 revised version of the

regulation addressed decarbonizing targets. In the late 1990s, the environmental concerns started to emerge through the integration of energy efficiency and climate policies. Government's new climate change programmes were required to comply with the Kyoto Protocol in 1998. At this time, the focus of building performance measures shifted from energy performance towards low carbon dioxide emission. The 2000s saw an explosion of developed regulations in the three main areas of energy efficiency, climate change, and renewable energy. Among the most important ones, are the Royal Commission on Environmental Pollution (2000), the new Climate Change Levy (2001), the 2003 Energy White Paper "Our Energy Future creating a Low Carbon Economy" (the first energy policy statement in 20 years), Energy Efficiency Action Plan [24], and Climate Change Act (2008). Following the requirements of the European Commission Directives (2010/31/EU and 2012/27/EU), UK's energy efficiency policies turned to meet 'near-zero carbon building' standards. The concept of energy-efficient retrofit as a way of improving energy performance of existing buildings appeared in this era. Since 2010, besides the Green Deal there have been several government-sponsored programmes designed to investigate or promote retrofit. There was 'Retrofit for the Future' and 'Scaling Up Retrofit' and now the 'Whole-House Retrofit' competition and a whole series of retrofit supply chain pilots. The Greater London Authority (GLA) has also run domestic retrofit programmes, as have the devolved Scottish and Welsh Governments. None of them focus on historical/listed buildings differently to other buildings, beyond mentioning that they are subject to the requirements of the planning legislation and the Building Regulations Part L.

#### *3.2. UK's Legal and Administrative Policies on Built Heritage Conservation: A Chronological Review*

The UK's strength in building conservation has roots in the 19th century, but really took off from the 1930s onwards, when development blight and mass demolition of significant buildings, followed by considerable bomb destruction during WWII, led to social and Governmental response. There was a need to set up preservation schemes starting from empowering local authorities. Empowering local authorities in the UK dates back to early 1930 when the Ancient Monuments Act (1931) was enforced, by which the concept of the "conservation area" was introduced into protective legislation. In 1932 the Town and Country Planning Act introduced Building Preservation Orders to be served by local authorities on historic buildings including occupied dwellings. The system of grading became more specific in the late 1940s. The responsibilities of local authorities were extended towards offering grants for repairing listed or unlisted buildings in 1962 under the Historic Buildings Act. Consequently, in 1968 the Town and Country Planning Act required owners to obtain Listed Building Consent from local authorities. In the 1970s different campaigns for saving endangered historic buildings from redevelopment and demolition activities gained momentum, among which are Local Covent Garden Fruit Campaign (1971) and Save Britain's Heritage (1975). The 1980s was the era that the majority of the UK's important conservation institutions were founded, such as the Association of Conservation Officers in 1982 (later in 1997 reformed as the Institute of Historic Building Conservation), and English Heritage in 1983. General planning legislation was separated from conservation legislation under the Planning (Listed Buildings and Conservation Areas) Act in 1990. The establishment of numerous funding organisations for heritage projects occurred in the 1990s, like the Heritage Lottery Fund (1994), facilitated through the National Lottery Act (1993). The Royal Commission on the Historical Monuments of England (a government advisory body), which was responsible for documenting buildings and monuments of archaeological, architectural and historical importance, was merged with English Heritage in 1999.

The 2000s can be characterised by the explosion of published works and reports in the area of conservation, such as 'Power of Place: The Future of the Historic Environment' [25], 'State of the Historic Environment Report' [26], 'Conservation Principles, Policies, and Guidance for the Sustainable Management of the Historic Environment' [27], and etc. In the 2010s, the UK's conservation community witnessed fundamental transformations of its institutional structure. The first guidance for application of Part L of the Building Regulations to Historic and Traditionally Constructed Buildings was published by English Heritage in 2011. The National Heritage List for England as the first publicly-searchable

database with the official records of heritage assets (including listed buildings, scheduled monuments, registered parks and gardens, registered battlefields, and protected wrecks and excluding conservation areas) was launched in 2011. The National Heritage Protection Plan (NHPP), comprising a framework for heritage protection based on a clear set of priorities, published by English Heritage in 2012. In 2015, English Heritage was divided into two separate organisations of Historic England and the English Heritage Trust. English Heritage Trust, as a new independent charity, is responsible for looking after the National Heritage Collection. Currently, Historic England continues as an arms-length body that looks after listing, planning, grants, research, advice, and public information.

Heritage buildings in the UK signify pre-1919 buildings, which are sometimes also referred to as 'historic', 'heritage', and 'conservation' buildings, and sometimes as 'older properties' [28]. The Sustainable Traditional Buildings Alliance (STBA) defines heritage property as, "a property that is generally of solid wall or solid timber frame construction, built before 1919". Although in the UK historic buildings are exempt from full compliance, they must still attempt to "improve energy efficiency as far as is reasonably practicable [29]" as "an informed approach can achieve significant energy efficiency improvements" [30]. The decision as to the level of intervention often remains at the discretion of the building owner and their professional advisors, in liaison with the local conservation officer. Overall, there are several levels of protection of older buildings in the UK:

