The plan to exempt small sites from zero-carbon legislation strikes me as being a total waste of time, energy and money and I cannot fathom why DCLG are wasting their precious time (and mine if it comes to that) with it.
The consultation document can be read here. The main elements are
– The proposal is to exempt small sites from the Allowable Solutions element of the Zero Carbon(2016) proposals. That is, the CO2 offset payment for that CO2 not mitigated on site by the development multiplied by 30 years multiplied by the agreed cost of CO2 per tonne.
– The consultation seeks views on the proposals including
The definition of small sites
Whether the exemption should relate to developers who are small or to any developer developing small sites
Whether the exemption should relate to Allowable Solutions only or whether the exemption should relate to Carbon Compliance as well
How long a time-frame the exemption should last for.
The problem I have with this is: where is the evidence that this is going to promote development? I haven’t seen any. Figures from the consultation document point out that 10% of planning applications in the UK measured by unit number were for single dwellings. That amounted to 24,000 units. So that tells me that there is a lot of activity in this sector and we can expect that to continue.
The Allowable Solutions impact of about £2-3k per plot will act as a small disincentive to development, but since many of those applications (my conjecture) are for the people who will actually live in those homes, the additional costs can be weighed against a lower cost of living for the occupants. The savings in fuel bills over the lifetime of the dwelling will pay for the relatively small additional cost. This is a calculation that many people will be able to do, and probably will realise that if they increase the build specification slightly they will reduce the Allowable Solutions costs and save themselves even more money. This seems to me to be a virtuous circle. People build more efficient homes for themselves, and they save money over and lifetime and there is less CO2 produced. This sounds like a market actually working. So why does the Government think that this is a market they need to interfere in before they actually have it in place?
The likely time frame would be from 2016 until the next issue of the Building Regulations, around 2020. This would allow the costs of the Zero Carbon (2016) to drop and the costs of Allowable Solutions to be absorbed. Again this seems to me to be counter productive. The way to reduce the costs of the Zero Carbon (2016) standard is to have everyone use it as soon as possible. This will bring down the cost of the insulation and window products that are needed to reach the standard, and then they will be available to all and not just the large housebuilders with very cost-effective supply chains. This proposal risks creating a two tier industry with higher costs of smaller builders and lower costs to larger builders.
The problem lies with the speculative nature of so much of our housebuilding. The builder of some of these small plots doesn’t know who the buyer has, and therefore has no interest in how that buyer lives in the home. There is no way for the lower costs of living in a more efficient home to be passed on to the developer in a beneficial way. A developer cannot build a more efficient home and offer it on the market for a small premium, this benefit is simply not recognised in the valuation of a property.
So, can I suggest that a more effective way for the Department to spend its time and mine, would be to investigate ways of making the speculative housing market function as a better market instead of trying to undermine those elements of future legislation that are likely to help it to function as a better market. But in an election year, perhaps that is too much to hope for.