Consultation for Whitewash

Posted on September 6, 2013 by Doug King

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.

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.

Measure Progress Not Just Carbon

Posted on April 28, 2013 by Doug King

I have been thinking for a little while about the suitability or otherwise of the metrics we use to measure sustainability. Given peoples’ reactions at a few meetings recently, including the Edge Debate on the Politics of Carbon Measurement and a conversation with the UK Consul for Climate Change in Chongqing, I think that the time has come to look seriously at this issue.

Presently we attempt to measure the impacts of what we build, but we rarely measure the beneficial outcomes. Therefore we risk focussing attention on all that is bad and forgetting the good. Taken to extremes we could end up going backwards socially and economically in order to address the political imperative to deliver zero (or at least very low) carbon buildings. For example, many sub-saharan africans live in housing that would easily satisfy the Zero Carbon Hub’s definition. However if we were to adopt housing of this standard in the UK it would not be considered social progress. This rather exaggerated example highlights the need to find some form of metric that acknowledges the benefits of expending some carbon in certain circumstances in order to deliver social and economic progress.

I was involved a few years ago in a new headquarters building for CAFOD in Lambeth. The building followed closely on the heels of two other charity headquarters, Heelis, the National Trust HQ and the Woodland Trust HQ, and it received comparatively little attention. Perhaps this was because the CAFOD building was mechanically ventilated and cooled, whereas the others were natural ventilation exemplars. CAFOD had to be mechanically cooled as the tight urban site available required a very high occupancy density to accommodate the entire organisation, whereas the other buildings were on suburban or extra-urban sites with plenty of space for low occupancy density and natural ventilation. On the face of it this means that the CAFOD building was both more expensive and had higher carbon emissions. However these standard metrics of cost and carbon per square metre of space do not account for how the buildings can subsequently be used. I decided to look again at the buildings in terms of the occupancy. Occupancy rates are after all what office tenants will be most interested in. The results completely reversed the ranking of the three buildings as shown below.

Whilst the metric of carbon per desk or carbon per worker is certainly much more useful than carbon per square metre in linking impact to business targets, an even better metric would link carbon to a measure of business success, such as productive hours or added value. Thus at a stroke we would be able to distinguish between well designed environmental buildings that reduce carbon and promote productivity and those that pay scant attention to the design and bolt on EcoBling to achieve the carbon reduction.

Take hospitals as another example. Lots of good work has been done in the past on identifying the quality design factors that influence patient outcomes, by providing a better working environment or recovery environment. The NHS metric for energy efficiency is presently kWh/m3 per year. Using such measures as targets can create perverse incentives. A hospital could economise on carbon by reducing ventilation rates, but this would increase recovery times and cross infection rates. A better metric for the NHS would surely be kWh per bed, to account for spatial efficiency, but in order to measure the real success of hospitals we should link energy efficiency to patient outcomes. Perhaps a metric of kWh per patient discharged. The shorter the stay in hospital the better the outcome for both the patient and the NHS and the less energy expended in achieving the outcome.

Designing these new metrics will be complicated to get right. As soon as any measure is adopted as a target it creates an incentive and we must ensure that the perverse incentives in the system are as few and as little impact as possible. However any work in this area has got to be better than simply sticking with metrics that incentivise unrealistic outcomes for the businesses that have to occupy the buildings. If those of us who work in sustainability want to see positive outcomes from our efforts then we must find means to set the importance of carbon reduction within social and economic context that will deliver better business outcomes too.

By the Skin of Their Teeth

Posted on November 12, 2010 by Doug King

I’m a big fan of unintended consequences, particularly when they arise due to hasty, ill-considered carbon policy. Well, thank goodness that the coalition has woken up to the unintended consequence of the Carbon Reduction Commitment (CRC). Now that they have revised the scheme I can talk about it freely without letting the cat out of the bag.

Prior to the Comprehensive Spending Review, the CRC would have raised money by charging large businesses for emitting carbon and used the money to reward those that cut their emissions year on year. The scheme started in April with a measurement year to establish a baseline against which future reductions would be rewarded. The blindingly obvious consequence of this is that anyone who wanted to benefit from the CRC would consume as much energy as they possibly could in the measurement year, so that they could then progressively turn their lights off and get the cash reward whilst still emitting more carbon than before the scheme was introduced (call me an old cynic!)

Fortunately, the Coalition has announced that it is now going to keep all the money raised, so the CRC has simply become a Carbon Tax. This will cost millions and has been dropped on the business community with no prior warning, so I can’t see it lasting for long, but at least there is no longer a financial incentive to emit even more carbon than business as usual.

Hooray for Capitalism

Posted on August 7, 2010 by Doug King

The recent announcement that BPs quarterly profits were down as a result of providing for the Gulf of Mexico disaster hid the fact that BP is still making huge annual profits by anybody’s standards. Following this thought I looked up some financial results for other oil companies.

The top 10 oil companies in the world, on average in 2007/2008, cleared profits of around 0.25% of world GDP! This is even when you allow some adjustment for inaccuracy in reported figures for the Chinese and Iranian state owned oil companies. If you extrapolate these figures to total world oil production and include some guesswork for coal and gas then the global profits from fossil fuels could possibly be around 1% of world GDP. Anyway it is in that sort of region.

Now in his review, Sir Nicholas Stern suggests that the ultimate cost of living with a changed climate could be 5% – 20% of world GDP, but that the cost of mitigating climate change would be of the order of 1% of world GDP. Notice any similarity between these numbers?

From my brief investigation it looks a lot like the cost of paying for remediating the climate damage done by our thirst for fossil fuels is about the same as the profit that the oil companies make from it. So the answer has been there all the time, if we had re-invested the profits from fossil fuels in cleaning up the atmosphere over the last century we might well not be in this fix. Unfortunately the profits of a global resource have not been used to benefit mankind, but have instead lined the pockets of a few – hooray for capitalism.

Not a Glowing Record

Posted on August 3, 2010 by Doug King

The Office of National Statistics has published the UK Carbon Dioxide emissions figures for 2009. They make interesting reading. Basically 2 years of recession has achieved a reduction in Carbon Dioxide emissions 8 times greater than 10 years of continuous change to environmental legislation by the Labour Government.

Whilst on the topic of the effectiveness of legislation, here’s an old piece of information that I haven’t posted yet. In March 2003 Labour created a piece of legislation that required minimum environmental performance standards from all new building work or renovations in the Government Estate. A report by the National Audit Office found that 80% of Government procured building works failed to meet their own standard.

It just goes to show that the power of the individual consumer (even those working in Whitehall) to mitigate carbon emissions through behavioural change is far greater than national governments can achieve by legislation. We must radically re-think the way we approach climate change mitigation.