Pointless Part L

Posted on November 15, 2012 by Doug King

A question following a lecture I gave at the Building Centre the other morning asked why it is that Part L of the Building Regulations is still failing to deliver substantial improvements in building performance. The answer is so obvious that I thought I’d better share it more widely.

“Commercial competition drives quality standards down”.

In the case of building regulation, a previous government thought that it would be a good idea to open Building Control up to competition from the private sector in the form of Approved Inspectors. Once you remove the protected status of Building Control then the whole field of regulation actually becomes one of competition for work.

Now consider, if a Building Control Officer or an Approved Inspector needs to be concerned about where future work will come from, their priority is to ensure that their clients are happy with their service. Happy clients will return or recommend the service to others. This is a basic requisite of business, but it is entirely contrary to the need for a regulator to enforce unpopular regulations. The basic incentive of continuing employment means that the regulator is unlikely to insist on strict compliance but will work to find loopholes for the client to exploit.

Enforcing regulations will inevitably create conflict. That is why the jobs of the enforcers need to be protected against unhappy clients and developers who have fallen foul of the regulations.

A Shot in the Foot

Posted on November 2, 2011 by Doug King

I have often bemoaned multi-headed government and its total inability to communicate between the left-hand and the right-hand, but this takes the biscuit.

In a valiant attempt to increase the uptake of small-scale renewable energy Secretary of State for Communities and Local Government, Greg Clark, signed into legislation on 30th August an order to extend permitted development rights for the installation of solar panels on properties in Conservation Areas and World Heritage sites. This meant that, for the first time, millions of homeowners could consider the option of installing PV from 1st December 2011.

Then, on 31st October, Greg Barker, Minister for Energy and Climate Change, without warning, announced a dramatic cut in the feed in tariff support for domestic PV effective from 12th December 2011.

At a time when solar installers’ order books are full until spring next year, government has given a large proportion of the population just 12 days to install PV and benefit from the feed in tariffs that many others have enjoyed for the last couple of years. I wonder how many cases will end up in the European Court of human rights over this issue?

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.

Consult for Better Policy

Posted on August 3, 2010 by Doug King

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

Posted on July 3, 2010 by Doug King

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.