At a time when ambition in environmental legislation is sadly lacking, this week saw two announcements that are going in the right direction. Both of them were about ‘zero carbon’.
Firstly the Govt announced through energy minister Andrea Leadsom that the UK would commit to net zero carbon emissions as there is consensus that an 80% reduction doesn not go far enough. Time will tell what that means, but the signalling of the ambition is positive.
This week also saw an important milestone on the path towards a low carbon housting sector with the release of the London Plan update requiring new homes in London to be ‘zero carbon’ from October 2016. This definition of ‘zero carbon’ is different from all of the others that have gone before, so it’s important to be clear about what it means.
From October 1st all new major applications put before the GLA are required to demonstrate that they meet the London Plan targets as they are currently identified. The main target being a 35% improvement on Building Regulations Part L 2013 predicted regulated CO2 emissions.
The new element is a requirement that the remaining CO2 emissions arising from the development are to be offset in an ‘Allowable Solutions’ style payment of £60 per tonne. This payment is then multiplied by a 30 year period, which is considered a reasonable lifetime for energy producing systems such as boilers or CHP, and the total is paid as part of a s106 agreement.
When I was involved in a pilot project for the original proposed 2016 legislation, the result was a payment of around £1500 per dwelling, but because that was testing the Zero Carbon Hub’s (ZCH) definition (confused?) there are subtle differences and I expect the London Plan payment to be slightly higher. The reason is that the ZCH definition included a high rate of Fabric Energy Efficiency (FEES) which was set as a minimum target for dwellings. This target was reached after analysis carried out by the Hub concluded that a level of 39-46kwh/Sqm/year was a good level of energy efficiency that didn’t necessarily require the use of very expensive fabric. Since then the Building Regulations has introduced a similar Design Fabric Energy Efficiency (DFEE) target, which aimed to be a bridging target between the 2010 regulations and the 2016 regulations, a stepping stone between the two. This current DFEE target aims for a 15% improvement in the base building fabric performance above the previous 2010 Part L Regulations target.
Now that the Government has halted the progress of transition to zero carbon buildings, the 2013 Part L Regulations that are in place are likely to stay in place for some time. Instead of using the ZCH definition of FEES the GLA are using the current Building Regulations instead. This is why this definition of ‘zero carbon’ is different from all other definitions that have gone before.
With that out of the way, what does it mean for construction in the capital?
It will become more expensive to develop new buildings, but by a predictable amount that I estimate to be between £1500-£2000 per dwelling. The GLA are confident that any viability test will demonstrate that this imposition has little or no impact on viability.
In many ways this is exactly what should be happening, using our most valuable market to test new approaches where we can afford to do so, then rolling those approaches out to the wider market as these new approaches become cost effective or even cost neutral.
This is effectively a carbon tax, and it will help to encourage development to produce less of it. Something that is needed in all industries if we are going to avoid extensive climate change. I expect to see some innovation in new buildings to improve the efficiency of services, fabric and ventilation.
There are a couple of caveats, however. Much of the planned development in London is in taller buildings or more dense development, and it is likely that the solutions to help those types of development to meet this new target are going to be quite different to the solutions for the rest of the UK where development is normally less dense. However I expect some benefits to be relevant in the field of building fabric detailing, air tightness techniques and prefabrication.
The second caveat is around district heating. The current SAP assessment of this technology is so poor that it is likely that we are overestimating the efficiency of them by some margin. In turn this affects the amount of CO2 remaining emissions and thus the amount of tonnes paid for by the new regulation. Work needs to be done to assess the performance of recently installed systems to check that their performance is in line with SAP to confirm that the amounts of CO2 being emitted are close to the predicted amount. We can’t afford to fool ourselves that we are achieving greater CO2 savings than we are in reality.
I welcome this development, given the paucity of environmental legislation being introduced compared to the huge amount of it being scrapped in this Parliament, we should cheer the determination of the GLA to maintain environmental leadership at a time when this commodity is sadly lacking from our governing politicians.