Tag Archives: Alternative Solutions

Allowable Solutions Response

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The following is my complete and unexpurgated response to the Allowable Solutions Consultation for anyone who is interested.

Response by:
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.

Consultation for Whitewash

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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.