There’s a lot to welcome here for the green built environment sector – from upgrading cold damp homes and giving renters new rights, to ensuring new developments are sustainable with increased climate resilience and promoting nature recovery. But although Labour has pledged to double investment in home upgrades, our analysis shows this won’t be enough.

How does the Labour manifesto compare to UKGBC’s policy platform?

Make home upgrades an easy choice

  • Labour’s manifesto signals a welcome step-change on upgrading Britain’s cold damp homes. In in 4 renters are in fuel poverty and the new renters rights signalled here would go a long way to addressing this – from requiring an energy performance C rating for lets, extending the ‘Awaab’s Law’ to the private sector to ending no-fault evictions after investment properties are upgraded.
  • As expected, the manifesto pledges to double government investment in home upgrades. But our analysis shows even this boost will not be enough. Investment in the region of 64bn is needed over 10 years as part of a long term strategy. Less government investment means households missing out on lower bills, better health and quality of life and sacrifices much of the large-scale private investment this would crowd in to every neighbourhood.

Make new developments high-quality and green

  • It’s good to see a clear commitment that new homes and places will be high-quality and sustainable with increased climate resilience and supporting nature recovery.  We didn’t see a lot of new detail on this, but any genuinely sustainable approach to new developments must include testing actual in-use performance once they’re built so people get what they’ve paid for, and regulating the carbon emissions ‘embodied’ in construction which currently account for a shocking 1 in 10 tonnes of carbon emissions in the UK economy. This can’t go on.
  • The manifesto promises a focus on brownfield land and commitment to preserving the green belt. The ‘golden rules’ acknowledge the varied reality of land quality amongst the green belt, and will be crucial to ensure developments benefit communities and nature at the same time.
  • The promised ‘immediate update of the National Policy Planning Framework’ is urgent. Labour has a record of voting to align the planning system with the Climate Change Act to make sure every planning decision is part of the solution, not the problem. This didn’t make it into the manifesto, but is the only way they will be able to make good on their pledge to build sustainably in the right places.

Labour has listened to our sector and has committed to increase funding for local authority planning after a collapse in the number of planning officers in recent years. These aren’t huge sums of money but would transform capacity to develop local plans and attract wider investment.

Protect our communities from climate risks

  • Labour’s plans to improve climate resilience with preparation across central government, local authorities, local communities, and emergency services sounds like the kind of joined up, national strategic approach with central high-level leadership we’ve been calling for. We didn’t see here, but would hope this would include a major role for nature-based solutions such as green landscaping and spaces which are often the most effective and cost-effective ways to reduce flash flooding and overheating.
  • The manifesto did pledge millions of new trees, to create new woodlands and expand nature-rich habitats such as wetlands, peat bogs and forests which will be vital. But didn’t specifically extended this to tree cover in our generally sparse in urban areas.

Renew our town centres

  • We’re pleased to see tax reforms to bring empty properties back into use to help regenerate our high streets and neighbourhoods. This should form a big part of the solution to the housing crisis.
  • What’s missing is regulation to improve the energy performance of shops and offices, and specific funding pledges to upgrade public buildings.  This would drive major investment into local economies, bringing skills and jobs, whilst tackling climate emissions and energy security.

Wider climate/Net Zero:

  • When it comes to foreign policy, it is clear that Labour hopes to reposition the UK as a climate leader, with a promise to create a new Clean Power Alliance to collaborate on the energy transition, and greater multilateral action to address the climate and nature crisis. The new global Buildings Breakthrough is an opportunity to drive real action, but any UK leader would need to show tangible progress at home. 


General Elections are all about the opportunity for fresh starts and while the Conservative’s electoral tagline promises much, it fails to deliver on the detailed framework for how we move towards a better future for Britain.

The manifesto doesn’t go anywhere far enough on addressing the linked climate, nature and cost-of-living crises we are facing.

We still need a ‘Clear Plan’ to rapidly decarbonise the country, and upgrade people’s homes and town centres. We need to see the ‘Bold Action’ to address the millions of damp, dangerous and expensive-to-run properties, and protect our communities from climate risks. Instead of inspiring and galvanising us to action, these Conservative commitments add uncertainty and risk, rather than promising a ‘Secure Future’.

How does the Conservative’s manifesto compare to UKGBC’s policy platform?  

In his speech Rishi Sunak again counterposed affordability with action on climate – promising to “put your wallets ahead of eco-zealotry”. Given the health, wellbeing and economic cost of inaction on climate and nature vastly out-ways the cost of action, the task for all parties is to put forward bold new ideas to make action affordable and attractive. We haven’t seen that in this manifesto.  

Here’s what we did see and how it compares with UKGBC’s policy platform:

Make home upgrades the easy choice

  • With millions facing unaffordable energy bills from heating draughty, uninsulated homes, ramping up efforts to upgrade the nation’s homes is now urgent. But the manifesto commitment of £6 billion over 3 years is only a small increase on low-levels of current investment and far behind the minimum £64bn over 10 years our analysis shows is needed. 
  • We’re pleased to see the return of the Renters Reform Bill which should offer some protection for households in the worst performing homes. But much more is needed, including minimum energy performance standards for rented property – a policy thrown out by Rishi Sunak last year.  

Make new developments high quality and green  

  • The manifesto promises 1.6 million ‘well-designed’ homes. It doesn’t set out what ‘well-designed’ means and we are concerned that the Government’s Future Homes and Buildings Standard consultation didn’t go far enough – setting a national standard below that already delivered in several large local authority areas, excluding embodied carbon emissions regulation, and missing an opportunity to introduce nationwide in-use performance testing.  
  • In the context of pledges to speed up the planning system, the manifesto focus on brownfield land, ‘gentle densification’ of urban areas, and building in the right places while protecting the countryside, is welcome. The best way to reduce conflict over the environmental impact of new developments is to legally align the planning system with the Climate Change and Environment Acts. This would ensure all new developments are part of the solution, not the problem and make for a more predictable system for developers and local communities. 
  • We have concerns about restricting local authority Section 106 powers. These have been a critical lever for delivering affordable housing and local amenities. 
  • We are concerned with proposals to abolish ‘nutrient neutrality’ rules and replace them with a one-off mitigation fee for developers in the hope that this would produce ‘no net additional pollution’ from 100,000 new homes. Local planners must be able to assess each development and ensure specific fragile water ecosystems are not destroyed. 

Protect our communities from climate risks 

  • The manifesto acknowledges the risk flooding poses to our communities by doubling capital funding to flood defences. Funding will need to be scaled up over the coming years as locked-in climate change creates more extreme weather. The most effective and cost-effective approach to this is with nature-based solutions such as more green spaces, parks and green landscaping.  
  • The manifesto includes a specific pledge to make planning consent easier for tree planting. That would help a little, but much greater public investment is needed to scale up canopy and green cover to the 3-30-300 we are calling for – this means three trees visible from every home, 30 per cent canopy cover in each neighbourhood, and everyone just 300 metres from a green space.  

Renew our town centres 

  • The manifesto highlights the need for urban regeneration and reviving high streets but misses the opportunity to drive new investment into areas by upgrading our nation’s shops, offices, warehouses and public buildings with insulation, heat pumps and solar panels. Supporting business to decarbonise and lower their energy bills would be a win-win for local economies, skills and jobs, and the environment.  

Green Party

It’s good to see the Greens position ‘fairer, greener homes’ right at the top of their manifesto as central to tackling both the climate and cost-of-living crises. They have understood the scale of long-term investment needed with £29 billion this parliament as part of an ambitious 10 year programme to retrofit homes.  

So far, this election hasn’t been a ‘climate election’ despite the dire warnings from scientists. This manifesto, is a useful contribution to driving the issue up the agenda given the next government will be the last capable of bringing in the game-changing policies needed.

How does the Green’s manifesto compare to UKGBC’s policy platform? 

The Greens have put “fairer, greener homes” at the centre of their manifesto, and have responded to the UK having the worst insulated homes in Europe with a comprehensive green retrofitting programme.  

With pledges across UKGBC’s policy platform, let’s see how their manifesto compares: 

Make home upgrades the easy choice   

  • The local-authority led, street-by-street or area-based retrofit programme is welcome. The Greens have understood the scale of long-term investment needed with £29 billion over 5 years pledged to retrofit homes. This is in line with our estimates of the funding required. The acknowledgement of the importance of retrofitting public and commercial buildings is also positive. 
  • The focus on improvements to the private rental sector through upgrading the Minimum Energy Efficiency Standard to EPC C is vital. We’re also pleased to see rent controls and protection for tenants to ensure a just transition for renters. 

Make new developments high quality and green 

  • The Green’s pledge to ensure that all new homes meet Passivhaus or equivalent standards is very ambitious and goes far beyond the Government’s proposed Future Homes and Buildings Standard. We’re pleased to see the manifesto acknowledge the importance of whole life carbon within the build cycle. 1 in 10 tonnes of UK carbon emissions are ‘embodied’ in construction and are almost completely unregulated.  
  • We welcome the attention to reform of the planning system with greater roles for local authorities and increased protection of the environment. The protection of nature through new developments must be prioritised by aligning the planning system with the Environment Act. 

Protect our communities from climate risks  

  • People are already experiencing the negative impacts of climate change in the UK through flooding and overheating. The Greens pledge to spend £7bn annually adapting overheating buildings and preventing flooding and storm overflows through nature-based solutions. These are a welcome response to the increasing threat posed by extreme weather. 

Renew our town centres   

  • Ensuring that commercial buildings in our town centres are insulated and sustainable is an important part of regenerating our urban centres. The £5bn in grant funding for private sector and public buildings will go some way towards achieving this goal. 

Wider climate/Net Zero plans  

  • As expected there is a major focus in the Green manifesto on the need to transition to a low carbon economy, including decarbonising our energy sources by transitioning to renewable energy. 

Liberal Democrats

The Lib Dems have understood people are looking to politicians to tackle the housing and health crises. We welcome the ‘emergency Home Energy Upgrade programme’ and renter’s rights for millions in cold, mouldy homes they can’t afford to heat. 

Ensuring new homes have public services, green spaces and are protected from climate risks like flooding are all sensible proposals. What we haven’t seen is a commitment to fight for the scale of public investment needed to make this happen. Anything less than £64 billion over 10 years, for home upgrades alone, is unrealistic. 

How does the Lib Dem’s manifesto compare to UKGBC’s policy platform? 

It’s striking that the Lib Dems have put tackling the housing crisis front and centre of their ‘Fair Deal’ offer to the country, alongside a big focus on health and the environment.   

With pledges across all four areas of UKGBC’s policy platform, let’s see how their manifesto compares:

Make home upgrades the easy choice  

  • The promise of an ‘emergency Home Energy Upgrade programme’ is welcome – millions are suffering in cold, mouldy homes they can’t afford to heat. They’re right to give a central role to local authorities in this. And a new ‘energy-saving home scheme’ with pilots signals a willingness to fix the current broken grant and incentives schemes.  
  • But this is a marathon, not a sprint. Our analysis shows anything less than £64bn in public investment over 10 years is unrealistic to meet the needs of people in fuel poverty, let alone other households. They have pledged £8.4bn over five years in their ‘Costings Summary’, to cover everything from home upgrades to transforming the energy system and planting trees.  
  • Requiring private landlords to raise homes to Energy Performance Certificate of C is vital, and we hope that a new commitment to deliver a ‘fair deal’ for renters will ensure protection for renters after home upgrades are carried out. 

Make new developments high quality and green

  • We welcome the commitment to a zero-carbon standard and inclusion of solar panels for new developments, where appropriate. The standard must include regulation of embodied carbon and ensure quality through performance measurement. 
  • The proposal to increase Biodiversity Net Gain, up to a 100% net gain for large developments would be a significant move to stem overall habitat loss and restore nature. 
  • The expansion of neighbourhood planning and inclusion of flood risk considerations is vital. The practical policy missing from the manifesto is legally aligning the planning system with the Climate Change and Environment Acts, which would ensure all new developments are part of the solution, not the problem. 

Protect our communities from climate risks 

  • The manifesto has rightly responded to the need for greater resilience in our built environment to the impacts of climate change already locked in. This includes guarding against flood risks with nature-based solutions and increased tree planting, as well as preventing housing being built in areas at high risk of flooding without adequate mitigation. 
  • We welcome the requirement for the National Infrastructure Commission to take account of the environmental implications of national infrastructure decisions into account. It is crucial that it accounts for climate resilience, to ensure the security of our infrastructure. 

Renew our town centres  

  • Our existing town centres and garden cities should be revitalised by modernising tax and lease systems and encouraging green development, prioritising reuse with community at the core.  
  • The UK public and industry need clarity and commitment on the future of our high street buildings and businesses. 

Wider climate/Net Zero plans 

  • The Lib Dems have proposed a Chief Secretary for Sustainability in the Treasury, which, if implemented, would have a key role in creating a comprehensive, cross-departmental response to the climate crisis. This is crucial, as the responsibility for addressing the climate crisis currently falls across multiple government departments. 

Scottish National Party

With recent political upheaval in Scotland, and the exit of the Green Party from the governing coalition in Holyrood, there’s been apprehension that the SNP could back away from its most ambitious climate commitments. With the publication of the party’s manifesto for the general election, it’s encouraging to see a recommitment to addressing the climate and nature crises, and a recognition of the enormous social and economic opportunities that go together with creating healthy, sustainable, climate-adapted places. 

The party rightly sees Scotland’s vast natural resources as a means to accelerate the UK’s progress towards a net zero, nature-recovered environment. The manifesto calls for greater investment in renewable energy generation, grid infrastructure, and green job creation, while reemphasising the importance of peatland restoration and tree planting in Scotland as a vector for natural carbon capture and wider regeneration efforts. 

But investment in clean energy and nature restoration doesn’t address the full picture of our climate and nature crises. Progress on decarbonising buildings at home in Scotland has fallen behind schedule. The manifesto isn’t silent on this, with the welcome inclusion of a call to equalise VAT on retrofitting and new build that would shift incentives towards effective reuse of our existing built assets. We also know that, in Holyrood, the SNP has recognised the scale of the retrofit challenge by highlighting the £33bn cost to retrofit Scotland’s homes for Net Zero via its Heat in Buildings Strategy.  

But the CCC’s latest progress report for Scotland highlighted just how far off course the net zero transition is. This manifesto doesn’t include commitment to the bold action we know is needed to drive up energy efficiency in our buildings within the timescales needed, or to realise the ambition of the Heat in Buildings commitments.

Retrofitting Scotland’s homes to be healthier and more energy efficient would have direct and long-term benefits on people’s health and wellbeing, as well as realising savings for the NHS and social care that this manifesto rightly pitches as a priority for Scotland. We think this is a missed opportunity.  

The manifesto doesn’t mention any action to start tackling the built environment’s embodied carbon challenge that still remains unaddressed despite representing a huge, and growing, proportion of the built environment’s emissions. Nor does it adequately respond to the imperative to adapt our buildings and places to the climate risks that are already locked in. 

We need real ambition at every level of government if we’re to tackle the climate and nature crises right across the UK. The SNP in Holyrood has shown a willingness to articulate the scale of the challenge we face, but we’re yet to see targets translated into delivery at the scale and speed needed.