Code for Unsustainable Homes

I’ve been looking at options for sustainable housing recently following a raft of competitions for housing associations who want to achieve Level 5 of the Code for Sustainable Homes. Level 5 requires zero carbon emissions from heating lighting and ventilation, so you have 2 options; install a conventional boiler and enough extra PV to offset the carbon or install a biofuel boiler. Since PV is vastly expensive, this really only leaves the biofuel boiler.

Now, we can design well insulated housing these days with peak heating loads well below 5kW. However, can you find a fully automatic  woodfuel boiler below about 15kW in output? No – at these low loads the only option seems to be manually fuelled room heaters. Wood boilers really need to be fired at full power for a reasonable period to avoid problems with tarring up. In other words the smallest automatic boiler is sufficient for 3-4 homes at CSH Level 5 or 6. This is great if you are a housing association and can install common plant and distribution, but what about developing housing for private sale, or even single properties.

The Government insists that all new housing shall be CSH Level 6 by 2016. So, if you are building a single house and don’t fancy inconvenient manual fuelling, you’d be better off not insulating the house at all in order to create sufficient load for long term reliable operation of your woodfuel boiler After all, the fuel is carbon neutral so you get all the credit even if your consumption is excessive. How stupid is that?

I think that this is another example of legislators adopting a voluntary code and forcing it on the market without ever considering the implications.

Not a Glowing Record

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.

Consult for Better Policy

Chris Huhne’s first annual statement to Parliament on energy policy correctly identified that reducing demand is far more cost effective than building new generating capacity whether renewable, nuclear or burying the carbon problem in the ground. However, no mention was made of undoing some of the damage done by ill thought out legislation already on the statute books.

For example, should you be tempted by the forthcoming renewable heat incentive to invest in solar water heating, you will not be able to buy a washing machine that can use the carbon free hot water thanks to a botched piece of previous legislation (see here).

Before the Coalition Government introduces further tiers of legislation and incentives they really should re-examine the impact of previous regulations and develop a coherent approach to energy efficiency. We can make substantial inroads into our excessive energy demands through the application of some basic science to the design and refurbishment of buildings and their services. This will yield the desired results far more economically and without the unintended consequences that come about through manipulation of the market for low carbon technologies.

The Coalition now has the opportunity to reverse the approach of the previous Government by actually consulting with industry experts in order to examine the broader implications of their policy ambitions and so avoid such un-intended consequences. I do hope that they take it.

Unintended Consequences

Someone mentioned to me the other day that it was next to impossible to find a new washing machine with both hot and cold fill. So how are we supposed to reduce carbon emissions from domestic laundry by using water from low carbon sources such as solar thermal?

To check whether this was true, I did a quick survey online. Of the 50 top selling washing machines from 13 different manufacturers, none has the option to fill with hot water. Yet all of these machines are A or A+ rated for energy efficiency. I wondered why this had come about, so I did a bit of further research.

The Energy Information (Washing Machines) Regulations 1996 is the UK enactment of the EC Directive on the energy labeling of domestic appliances. These explicitly state that “These Regulations shall apply only to appliances which are electric mains operated and unable to use other energy sources”

The second bit of this statement is the significant one. In order to deliver a universal rating system it must be possible to compare like for like. How could you compare the efficiency of an electrically heated machine with one that receives hot water from an external source of unknown quality. This little get out clause is clearly included to ensure that the energy efficiency ratings will be equivalent across the board. What this means in practice of course is that a washing machine with a hot fill cannot be given an energy label.

Now when it comes to heating water, even a conventional boiler will do it with less carbon emission than an electric heating element in a washing machine. Since energy labels are mandatory this little sentence, buried in the verbiage, creates a prohibition on what are potentially the most carbon efficient washing machines.

The washing machine manufacturers must have been delighted. As the sale of appliances without energy labels was prohibited they no longer needed to include a second set of water control valves in their machines, thus reducing manufacturing costs. I don’t suppose that the savings were passed on to consumers, but just try to get them to add back the hot fill now without putting the price up.

Then we have to factor in the fact that the energy label rating is based on a very specific wash cycle, whilst consumers apparently are tending to use more energy intensive quick wash cycles. According to a number of studies the electricity consumption for laundry is much higher than would be inferred from the energy labels.

In the UK, Building Regulations and policies like the Renewable Heat Incentive are designed to reduce carbon emissions in building services installations, including hot water generation. Washing machines are excluded from these policy instruments because they are already covered by the energy labelling regulations. But water heating is water heating and probably best dealt with as an efficient integrated system, not in isolation in your washing machine.

So, in drafting regulation which is supposed to promote energy efficiency the European Union scribes have actually written one that prohibits the most carbon efficient means of operation. Maybe one day our Governments will consult people who understand the issues before writing new laws.

Not enough wind for the Olympics

It is somewhat surprising to read the comment in The Times from Shaun McCarthy, Chair of the Commission for a Sustainable London 2012, that the Olympic Park wind turbine is to be scrapped because there is not enough wind on the site.

The Olympic wind turbine was announced in March 2008 in a blaze of glory. Since then has no-one bothered to check the Government’s Wind Energy Database now maintained by the Department of Energy and Climate Change? This clearly indicates that the location for the Olympic turbine is marginal for economic wind generation.

Generating electricity from the wind is critically dependent on the wind speed which is affected by location. Wind speed is dramatically reduced over cities due to friction with buildings dissipating much of the energy as turbulence. It would be unreasonable to expect the Stratford turbine to generate much more than about half that of an identical machine in open country.

Large wind turbines are a significant investment and if the generation potential of a site is poor then wind energy developers will look elsewhere. This may explain why the ODA has failed to find a new developer prepared to step into the breach after the preferred bidder for the turbine withdrew.

There are few other renewable technologies that can match wind power economically. One must hope therefore that the ODA rigorously enforces energy efficiency standards for the new buildings in order to reduce demand. This would be far preferable to wasting public money on expensive renewable technologies to offset 20% of unnecessarily high demand.