The UK Government has published its Green Finance Strategy, which seeks to tune capital markets to the ambitions of its Industrial and Green Growth Strategies and its commitment to the Paris Agreement on Climate Change. Significantly, the new Strategy looks beyond aligning and unblocking capital flows to green assets and solutions (“Financing Green”) by placing equal emphasis on the imperative to integrate climate and environmental factors into financial decision-making across all asset classes (“Greening Finance”). In addition, it seeks to cement the UK as a global centre for green financial products and services (“Capturing the Opportunity”).
The new Strategy gives a strong signal of intent, with some notable measures, but it is lacking in the detail and level of commitment that owners and managers of commercial and residential property ought now to expect.
The two central objectives of the Green Finance Strategy are:
- to align private sector financial flows with clean, environmentally sustainable and resilient growth, supported by Government action; and
- to strengthen the competitiveness of the UK financial sector.
There are many parallels to be drawn with the ongoing efforts of the European Union, through its Action Plan on Sustainable Finance, to:
- reorient capital flows towards sustainable investment, in order to achieve sustainable and inclusive growth;
- manage financial risks stemming from climate change, environmental degradation and social issues; and
- foster transparency and long-termism in financial and economic activity.
The combined and accelerating weight of effort both domestically and at the European level to address capital market deficiencies in relation to the climate and ecological emergencies should, therefore, not be underestimated by investors or their fiduciaries. Indeed, the new Green Finance Strategy commits the Government to at least match the ambition of the three key objectives included in the EU Action Plan.
Climate and environmental integration
Considerable emphasis is placed on clarifying and enhancing the roles and responsibilities of an array of market regulators, such as the Financial Conduct Authority and Prudential Regulatory Authority, combined with a commitment to develop Sustainable Finance Standards. There is also a clear signal that Government policy will drive stranded asset risks, including through its push for complete divestment from unabated coal facilities.
Alongside the European Union’s own regulatory programmes for improved ESG disclosures, there are also specific proposals to mandate disclosure in accordance with the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD) for listed companies and large asset owners by 2022. This is catalytic; within the real estate sector, whilst some REITs such as the BMO Commercial Property Trust and LandSec have begun to incorporate disclosures expressly aligned to TCFD, these are very much the exception to the market rule.
Financing green buildings
For real estate owners and managers, there are a number of notable declarations, some of which have admittedly been trailed previously. Examples include the commitment to explore further the disclosure of operational energy use within buildings, including a strong nod to the Design for Performance work of the Better Buildings Partnership, as well as a commitment to consult formally on the future trajectory for Minimum Energy Efficiency Standards (and for which a programme of Government dialogue with the industry is already underway). For the domestic sector, funding support for private sector pilot projects to trial green mortgages and other innovations are notable, especially bearing in mind that all existing PRS leases will fall within the purview of Minimum Energy Efficiency Standards in nine months’ time. Potential financial measures to support the existing aspiration to upgrade homes to EPC band C by 2035 are also set out, including the possibility that lenders will be mandated to help homeowners finance energy improvements, alongside improvements to the much-maligned Green Deal framework.
In our view, the new Green Finance Strategy is significant for real estate asset owners and managers, particularly in relation to the measures proposed to green the finance system through, for instance, enhanced mandatory disclosures, improved sustainable finance standards and clearer oversight responsibilities. However, although there are several notable statements that relate specifically to the financing of climate and environmental solutions in property, these remain, for the most part, tentative and subject to further consultation and investigation. Given the pivotal role of the built environment in the context of the climate emergency and environmental breakdown, together with the extensive work and engagement that has already been undertaken on many of these proposed measures over the last decade, the time for provisional measures has arguably now passed. Whilst there are several welcome elements within the Strategy, as a package of measures it falls short of the market transformation that is needed.