Consultation for Whitewash

The government is currently consulting us, the great unwashed public, on Allowable Solutions for ‘Zero Carbon’ homes. The scope and extent of these consultations makes it clear that the term ‘Zero Carbon’ is about to become pretty meaningless. I do hope that we are not being asked to consult on a whitewash.

The working definition of ‘Zero Carbon’ has been prepared by the Zero Carbon Hub. This definition includes three components: fabric energy efficiency, onsite Carbon Compliance (Renewables & LZCTs) and finally allowable solutions. The first two components are presently regulated under Part L of the Building Regulations. Allowable Solutions is essentially an offsetting scheme, which allows house builders, where necessary, to make up the final gap to ‘Zero Carbon’ by funding offsite Carbon mitigation measures.

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This structure is entirely logical and should have been workable had it been developed as a complete system. Unfortunately, as in so many other aspects of energy policy, the policymakers do not understand the importance of systems. The ‘Zero Carbon’ working definition was broken down into its three components and each was subject to separate consultation and agreement.

Fabric Energy Efficiency was the first to be considered. However, rather than adopting a challenging new standard for British construction, such as the Passivhaus fabric energy standard, this working party backed off, presumably under pressure from the builders. But that was felt to be OK as the Carbon Compliance layer would surely ensure that the overall Carbon reduction targets were achieved.

The debate around Carbon Compliance unfortunately also fell short of what should have been possible in an enlightened construction industry. The final proposal was that Fabric Energy Efficiency & Carbon Compliance together should achieve a 60% reduction below 2006 Part L. This was felt to be a target that could be achieved by 90% of house builders by 2020, four years after ‘Zero Carbon’ becomes a requirement. Hardly a challenge sufficient to promote step change in working practices.

But this did not matter, as the consultees were certain that the Allowable Solutions would be drawn sufficiently tightly to encourage on-site Energy Efficiency and Carbon Compliance to at least this level.

Since then of course we have had the long delayed announcement of the 2013 Part L revisions (now only coming into force in 2014). This sets the Target Carbon Emissions Rate for housing just 6% below the 2010 Part L (cumulatively 29.5% below 2006 Part L). So in 2016 ‘Zero Carbon’ will comprise 29.5% cumulative reduction in Part L emissions to date, a huge step of 30.5% reduction in the 2016 Part L, with the expectation that 10% of the industry will still be unable to comply four years after that, and 40% Allowable Solutions.

Now we are beginning to see the true picture of Allowable Solutions as well. The Government feels that house builders who are unable to build low carbon housing should not be penalised by the expense of Allowable Solutions. Thus the cost of abating a tonne of Carbon will be capped. This means that the builder may not have to pay the actual cost of abatement or may not achieve the full abatement required, depending on the abatement methods available.

One of the suggestions to overcome the price barrier is that Allowable Solutions ‘Providers’ will spring up to take money from house builders to deliver aggregated abatement projects. That sounds like a great opportunity for bankers who are already making a great deal out of the Green Deal and the renewables incentives. Further, in order to ensure that Allowable Solutions are available at the lowest cost it is proposed that they could include abating Carbon emissions from existing buildings.

What?! I hear you ask.

Yes. Under these proposals it could be possible for a very ordinary new house, without substantial improvement in energy performance to be classified as ‘Zero Carbon’ if some money is spent on improving an existing, worse performing building.

But surely, in order to meet our 2050 Carbon budget we need ‘Zero Carbon’ new homes in addition to ALL existing buildings becoming Nearly Zero Carbon too. Does this suggestion not simply lead to double counting of Carbon abatement whilst actually achieving very little?

Well, actually, yes it does.

I thought that the point of gradually tightening the performance standards of buildings through the Building Regulations towards ‘Zero Carbon’ was to encourage the construction  of better performing buildings and stimulate innovation and improvement in our industry. Now I see it for what it is:

House builders will be able to continue with business as usual. They will take a bit more money from house buyers on the sale price to funnel into offsetting schemes. The offsetting schemes will be arranged by financiers to invest in profitable, easy energy efficiency retrofits in existing buildings. The bankers will harvest the profit that should have been financing these measures independently in the first place. House builders, Government and the Banks all win. The only buildings that will be left out of the abatement gravy train are those that are classified as hard to deal with. These will only get refurbished under the Green Deal ECO mechanism and subsidised by – you’ve guessed it – energy bill payers.

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