The announcement that the Greenest Government, Ever is to drop the fully zero carbon requirement for housing for 2016 is a surprise,but not a shock. The fact that the mythical ‘allowable solutions’ have not advanced in the two years since they were mooted means that they were never an easy solution to adopt. They were introduced by the Zero Carbon Hub as a solution to the problem caused by sites being unable to achieve zero carbon cost-effectively.
The new aim is to continue with the targets set by the Zero Carbon Hub for new dwellings up to 2016 and add the percentage required to cover all building regulations emissions and to stop there. Code level 5 for energy in old money.
This means that the emissions for non-regulated activities such as cooking and equipment such as TV’s, set top boxes etc., are not to be covered by this legislation. This leaves the problem of the additional CO2 emissions produced by those homes which has not been considered in any Govt plan for emissions. By their own numbers set out in the Carbon Plan, the GG,E expected one third of homes in 2050 to be built between now and then. The remaining emissions from new build housing will be around one tonne per dwelling. So that means that a minimum of 4Mt CO2 per annum between now and 2050, or a total of 156Mt Co2 are now unaccounted for in the Carbon Plan. Its good that the Carbon Plan is only a draft!
Grant Shapps tweeted that ‘New standard for zero carbon homes means a 100% reduction in emissions from homes without unfair costs for housebuilders’
No it doesn’t, it means that 100% of regulated emissions are dealt with, but regulated emissions can be half the total emissions actually produced.
Item 2.300 of the Growth document suggests that the unregulated emissions will be dealt with by the Green Deal.
I interpret this to mean that housebuilders will build to the equivalent Code level 4/5 using the Fabric Energy Efficiency targets, bring the homes up to Zero Regulated Emissions by including some allowable solution payments, and the uplift to Zero Carbon will be converted into a Green Deal payment from the energy companies/Green investment Bank to a Local Sustainable Community Fund which will then be repaid through the occupants energy bills. The positive thing about this is that the householder has some involovement in the issue, where previously they didn’t. Confused?
One of the many interesting issues about this is whether this is taxation or not. Essentially the householder is being taxed to pay for the offset of their carbon emissions over a twenty five to thirty year period, but no-one is calling it a tax.
This is all fine so far as it goes, and it solves the carbon accountancy problem, but it introduces yet another level of complexity and regulation into housing that will need to be managed, it is definitely going to complicate matters, not make them simpler.What happened to the one in and one out for regulation?
I think that the housebuilder should have the choice about which route they take, on some large sites it will be cost-effective to go to Code 6 onsite and be done with it. On many sites it will make sense to go to 100% of regulated emissions and use allowable solutions, and on many small sites it will make sense to use the Green Deal. It would be a mistake and counterproductive to use a one size fits all approach rather than allowing different approaches to be used to match the different site scales that are available.
Finally, why is this issue being decided now, after a year of Government? Grant Shapps has been shadow housing minister for a long time, why has this never been suggested by him before now? If he thought that housebuilders were being asked to do something unreasonable, why didn’t he say so when in opposition? There have been so many attempts to define zero carbon that the idea has lost all credibility now, it has become a joke, not a policy.
It isn’t zero and it isn’t carbon.