Not so Zero after all. A response to the 2014 Queen’s Speech.
The Queen’s Speech (2014) yesterday set out the Government’s proposed legislative programme for the year ahead. Amongst the various bills put forward was a little more information about how they intend ‘Zero Carbon’ housebuilding to be shaped from 2016…
The snippets of information were in amongst the various government business raised for the year ahead, under the section introducing :
“a Bill to bolster investment in infrastructure and reform planning law to improve economic competitiveness. The Bill will enhance the United Kingdom’s energy independence and security by opening up access to shale and geothermal sites and maximising North Sea resources. Legislation will allow for the creation of an allowable solutions scheme to enable all new homes to be built to a zero carbon standard and will guarantee long-term investment in the road network.”
The detail however was in the supporting information published on the Government’s website, under the section ‘New homes to be built to a zero carbon standard’. It runs as follows:
- The Government is committed to implementing a zero carbon standard for new homes from 2016. But it is not always technically feasible or cost effective for house builders to mitigate all emissions on-site.
- The Government would set a minimum energy performance standard through the building regulations. The remainder of the zero carbon target can be met through cost effective off-site carbon abatement measures – known as ‘allowable solutions’. These provide an optional, cost-effective and flexible means for house builders to meet the zero carbon homes standard, as an alternative to increased on-site energy efficiency measures or renewable energy (such as solar panels). Small sites, which are most commonly developed by small scale house builders, will be exempt. The definition of a small site will be consulted on shortly, and set out in regulation.
- The Zero Carbon Home standard will be set at Level 5 of the Code for Sustainable Homes, but the legislation will allow developers to build to Level 4 as long as they offset through the allowable solutions scheme to achieve Code 5.
- Energy efficiency requirements for homes are set in the Building Regulations 2010 and are made under powers in the Building Act 1984. But there are insufficient powers in the Building Act to introduce off-site allowable solutions, so the Government will now bring forward enabling powers for this.
So what can we pick out of the above?
The zero-carbon home proposals follow a long period of industry uncertainty over the Government’s 2016 low/zero carbon new housing commitment (the lack of anything concrete on allowable solutions was casting the whole timescale into doubt), so it’s promising that something has been put forward. However, the watering down of the proposals is a significant cause for concern.
Work by the Zero Carbon Hub and others had previously identified that it would not always be technically feasible or cost effective for house builders to mitigate all emissions on-site (for all types of dwelling).
The costs of doing so have actually dropped significantly since the original commitment was made, so their proposed limit as to what is realistic and cost effective on site could perhaps be pushed further.
‘Allowable Solutions’ was proposed as a concept and mechanism for covering any shortfall in achieved emissions between a ‘Carbon Compliance level’, (the proposed limit of what’s economically do-able on site) and zero carbon emissions. The Allowable Solutions mechanism would allow off-site or near site carbon savings to offset what is achieved on site, possibly by developers paying into a fund to finance other carbon saving projects.
However the Government’s statement supporting work on introducing Allowable Solutions points to a further scaling back in the on-site low carbon housing performance ambition :
“The Zero Carbon Home standard will be set at Level 5 of the Code for Sustainable Homes, but the legislation will allow developers to build to Level 4 as long as they offset through the allowable solutions scheme to achieve Code 5.”
The hub had previously proposed the on-site Carbon Compliance limit as 52% of the way to zero from 2010 levels.
In 2009, Carbon Compliance was 70% of the way to zero!
The latest statement now sets out the new proposed limit for developers to target on-site as Code level 4 (which is only 25% better than 2010 levels). Developers will then make up the residual carbon emissions shortfall to Code 5 (zero emissions excluding cooking and appiances) via payment towards ‘allowable solutions’ at a rate to be determined.
If it’s too low a rate, then developers will be disencentivised to do more than the minimum on site.
On top of that, the statement notes that:
“Small sites, which are most commonly developed by small scale house builders, will be exempt. The definition of a small site will be consulted on shortly, and set out in regulation.”
It is unclear which housing projects will qualify as small sites and can be exempted from the rules, presumably, these would still have to reach Code 4 if that becomes the new regulatory minimum new build target, but then its builder woudn’t have to pay anything to offset the remainder of their shortfall to zero? Or will they not have to reach Code 4 in the first place and just pay up for the shortfall to zero, based on current regulations performance levels?
It will be interesting to see where this is going, but it’s looking like creative accounting.
“Honest Guv, it is Zero Carbon housing!”
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