My response to Q.11 in the definition of zero carbon consultation.
Question 11: Do you agree that we should adopt the new energy efficiency levels for the 2016 zero carbon definition into the Code as a mandatory requirement at Code levels 5 and 6 and award 5 credits?
A: We think that the FEES should be adopted now, but we don’t think that in its current form it represents a stretching target. We think that the FEES should be expanded as shown in this table to below PassivHaus standards to give the industry a challenging target. There are many affordable forms of construction already available that can meet the Level 5 and 6 target, there is a danger that making the target for 2016 so easy to meet that innovation will not be needed and UK companies will lose an opportunity to be competitive in international markets.
|Energy Demand (Space heating + cooling) kWh/m2/yr|
|Apartments, Mid terrace||End terrace, Semi detached, detached||Credits||Mandatory Requirements|
|≤39||≤46||3||Level 5 & 6|