The following is my complete and unexpurgated response to the Allowable Solutions Consultation for anyone who is interested.
Prof. Doug King FREng FInstP FCIBSE FEI HonFRIBA
This is a personal response and not on behalf of any organisation
Business Sector: Building Services Consultant
Business Size: Micro
You will receive responses to the consultation from a number of institutions and other bodies which will go into detail addressing the specific questions you have asked. I have contributed to some of these, but I feel that there is a larger issue that needs to be addressed and hence this personal response. Since it does not easily conform to the questions asked in the consultation I trust that you will forgive me for not using the response form in this instance.
The underlying aim of the legislation is surely to help deliver the requirement of 80% reduction in carbon dioxide emissions from the UK. The danger in addressing such overarching goals with piecemeal legislation is in creating unforeseen precedents and perverse incentives which actually make it harder to achieve the ultimate goal. I would like us to keep the ultimate goal in mind when formulating the present legislation.
The zero carbon standard for housing that we define now will have to be valid and robust to serve us for the next four decades. By defining a zero carbon standard now which includes a high level of small scale renewable generation and Allowable Solutions we will set a precedent for the approach to be taken in zero carbon non-domestic buildings and in near-zero carbon refurbishment of the existing building stock (domestic and non-domestic).
In order to achieve the overall target we will likely need to make several incremental improvements in building energy performance. How can we define a standard for housing performance that is beyond zero carbon? That would be meaningless. Thus, if we now define a zero carbon standard that does not genuinely address zero carbon we risk depriving ourselves of any viable mechanism to reach the ultimate goal.
The combined fabric efficiency standard and carbon compliance, as proposed, will deliver a present day carbon reduction from new housing of around 70%, averaged across the stock, against the 1990 baseline.
However, the carbon compliance standard could be met by the installation of small scale renewable electricity generation. Whilst such renewable generation represents a carbon offset in the present day, the value of this offset will diminish over time, until it is close to zero, as the UK electricity supply is decarbonised in line with the national targets.
Thus, the only sustainable carbon reduction for zero carbon housing delivered by the proposed approach is actually that which is achieved by the fabric energy efficiency standards. This must be our focus. The combination of carbon compliance and Allowable Solutions must be discounted if we are to achieve a robust solution which is still delivering valid carbon reductions in 2050.
We cannot assume that carbon reduction measures which are deliverable at a reasonable economic cost in this decade or the next decade, will be sufficient to meet the 2050 carbon target alone. In fact it is becoming increasingly apparent that appropriate short-term measures to reduce carbon emissions in the next two decades may be different from the ultimate solutions in 2050 and beyond.
It is therefore vital that legislation introduced to reduce carbon emissions in this decade does not nullify opportunities for the further actions that will be necessary to meet our overall target.
The Green Construction Board’s ‘Low Carbon Routemap for the UK Built Environment’ identifies that: “It is technically possible to deliver the government’s target of an 80% reduction in carbon emissions in the built environment; however, this would require maximum uptake of technically viable solutions in all sectors, including implementation of technologies that at present do not have a financial return on investment over their lifetime.”
It should be noted that in modelling the GCB Routemap scenarios, it appears to have been assumed that all new buildings are truly zero carbon as far as emissions from the built environment are concerned. It seems that the offsets from Allowable Solutions and small scale renewable generation are delivered outside the built environment model. In other words it will require the maximum uptake of technically viable solutions within the built environment sector plus offsets from Allowable Solutions without any overlap.
Clause 2.4(c) of the Consultation Document states that “The carbon savings deriving from Allowable Solutions should be additional and over and above the carbon savings that would have been delivered without the availability of Allowable Solutions.”
We need to ensure that this is not only true for this implementation of legislation, but future ones too. We must avoid double accounting for Allowable Solutions offsets if we are to achieve the ultimate goal.
In order to deliver near zero carbon buildings across the stock it is likely that further legislation will be required in the future. The standards that we then set for zero carbon non-domestic buildings and near zero carbon refurbishments will inevitably follow the precedent we set now and we must allow them to include Allowable Solutions. Where are these Allowable Solutions to come from?
If the standard for zero carbon housing set now includes the opportunity for carbon offsetting from the existing building stock through Allowable Solutions then we risk creating a paradox when it comes to refurbishing the existing stock.
Further, under such a scenario the task of completely refurbishing the existing building stock to near zero carbon standards becomes much harder and will probably require substantial financial support. A great deal of building refurbishment can presently be funded directly as it will achieve a return on investment. However, if all the simple, low cost interventions have already been allocated against Allowable Solutions for zero carbon new buildings this will make the task of undertaking the residual refurbishment much harder and more expensive.
In summary I suggest that the structuring of Allowable Solutions is fraught with difficulty unless it is made very simple indeed.
We should not delude ourselves that achieving 80% reduction in carbon emissions by 2050 can be delivered at low cost. I reiterate: delivering this target will “require maximum uptake of technically viable solutions in all sectors, including implementation of technologies that at present do not have a financial return on investment over their lifetime.”
It is a mistake to consider that the housebuilding sector is somehow exempt from taking real action on the issue of carbon reduction simply because it is considered too expensive. This is an issue that we all have to face together. The precedent set now will have repercussions on all future legislation in the built environment sector.
The penalty that the UK will pay for the construction industry not delivering on-site carbon emissions reduction will be the need to deliver greater overall low carbon generation capacity. This deficit will simply grow as Allowable Solutions are extended to new non-domestic buildings and thence to refurbishments. Simply allocating emissions reduction from one part of the built environment sector to another through Allowable Solutions will not increase the overall reduction achieved by the sector.
Logically this argument can be extended to cover any sector of the UK economy. All sectors have to achieve the same target reduction in the end. Achieving these targets will require decarbonisation of the energy supply. Thus, the only allowable solution for zero carbon or near zero carbon buildings should be direct investment in large scale, low carbon generation capacity.
Further, since the only sustainable carbon reduction will be that delivered through fabric energy efficiency standards, the calculation of offset required from grid scale low carbon generation should relate to the discounted future value of offsets of on-site electrical generation by renewables in addition to the Allowable Solutions level set in this legislation.