Zero Carbon London

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.

New Nuclear Disaster

If we want New Nuclear, we should be prepared to invest in it ourselves instead of paying others over the odds for electricity in order to de-risk their investment. This decisions isn’t good for the market, for consumers bills,for UK industry or for low-carbon energy when there are more realistic, practical and deliverable alternatives, e.g. onshore wind.

A recent Study by Prognos, published here demonstrates that the cost of nuclear power to the UK will be up to 34% higher than the cost of new Photovoltaic in Germany, or 50% higher than the cost of new onshore wind. The Conservative led backlash against renewable energy looks to be a much worse deal for consumers than large scale renewable energy. Even offshore wind is predicted to be 15% cheaper, so if you are willing to pay an additional 35% for your power to move it offshore, then even that is cheaper than nuclear.

The announcement that China is going to help to support the construction of nuclear power plants in the UK comes as no surprise to people involved in energy in the UK, this has been mooted for some time. The reasons why this is being welcomed by the Treasury are worth examining though, or they would be if there was any particular reasoning behind it. It is happening simply because no-one else wants to fund the addition of nuclear in the UK. The nuclear ‘market’ isn’t working because it doesn’t exist.

New Nuclear has been on the shopping list of successive governments in the UK for a decade, but because of the lengthy delays in bringing such systems to fruition elsewhere, most funders have backed off. There is little support for nuclear among the electorate, none among the banks, and only one power company, EDF, is still willing to consider investing in one, but is unwilling to do so alone, so hence the Chinese investment.

There are at least good reasons why the Chinese would want to do this, it gives them a stake in a major asset in the UK. It would demonstrate to the rest of the world that Chinese construction ability is up there with the best. Don’t we think this already? Do they need to build a nuclear power plant to convince anyone? Apparently they do, because this deal will give them an entry to the UK UK power market which could be followed by their building a new ‘safer’ reactor design that ‘cannot fail’ and if the Chinese can be part of new nuclear in the UK, then the reasoning goes, they could be part of one anywhere.

Whatever happened to the Conservative belief in the market? Let me remind you of Amber Rudd’s Savoy speech a few weeks ago.

“We are committed to climate action; committed to economic security; committed to decarbonising at the least cost.” A. Rudd Aviva speech.
Constructing this type of plant will take at least a decade, and cost £25 billion pounds at current estimates, and EDF haven’t confirmed that they are willing to go ahead, even with Chinese involvement. Costs will double, because that’s what happens with long term high cost infrastructure projects, and the investment of our money will fund technical development in China and France. The Treasury is even going to guarantee the Chinese investment money, so they are going to accept little risk, but will be rewarded if the project succeeds. How any of that contributes to climate action or economic security is unclear. It is very unlikely to deliver low cost power. It is currently projected to be profitable at double the current market rate. Yes, nuclear is low carbon, but it is a lot more risky than a distributed energy generation network based around a wide range of renewable energy systems. The proposed plant is planned to contribute 7% of the UK power demand. So when it goes wrong, and it will go wrong at some point, it is in the nature of technology to fail, then the UK Grid will have a big task to replace it. If a wind turbine in the North sea falls over, the network doesn’t blink. The economic benefits appear to be heading out of the country to other economies, presumably including the construction investment monies.

A 2010 DECC study showed that onshore wind and new nuclear were on a par when it comes to the cost of providing new power at a figure of £80-110/Mwh. What that fails to take into account is the by the time nuclear is delivered, the world will have moved on, inflation will have made nuclear much more expensive, and the changes to oil and gas prices will either have made £80/Mwh look very good or very bad. In either case the current crop of politicians won’t be here to take the blame or the credit. It is the ultimate cop-out, taking a decision that you cannot possible follow through on, for an electorate that cannot think ten years ahead.

Meanwhile a decade when low carbon de-centralised measures that could have been introduced is going to be wasted as effort and time are put into centralised nuclear power which is going to further strengthen the grip of the Big Six on the UK’s energy market.

The UK Government has no obvious decarbonisation or energy policy that makes sense. On the one hand green measures are scrapped ‘to protect taxpayers bills’ and because the Lib Dems supported those polices during the Coalition period; on the other hand a deal is proposed with a Government with an appalling human rights record to fund the riskiest and most expensive power system we can buy, from a market that doesn’t exist because everyone else apart from the UK Treasury thinks it is too risky to invest in.
This deal is being proposed so that this Government can say it has done something positive about energy after all the measures they scrapped in the summer, a deal which will cost us dear in the long run.

Some sobering reading on this subject can be read here:

More Homes Through Manufacture

There are many good reasons why modern homes should be made in a factory. There are no good reasons why they shouldn’t. Practically everything else we use in our lives comes from a factory and we are very happy with them, so why not our homes too? We expect our cars, TV’s computers and phones to be mass-produced, and would be very surprised to find that they weren’t, in fact we wouldn’t buy them if we found that they were hand-made by a group of people brought together in a muddy field and given instructions in how to build them, in a language not their own, and chosen because they provided the lowest price or just happened to be available that day.

Manufactured homes are more likely to meet the stringent quality standards demanded by regulations for new homes because it’s much easier to check quality when the product is being made in a warm building, out of the wind and rain. Workers of all ages and backgrounds can be employed in a factory because they are not expected to carry heavy loads up ladders, or withstand the cold. So the workforce can be from a wider demographic and different backgrounds.

In the current economic conditions this factor is lowering the cost of building homes in a factory as wages for fully employed people are stable. The self-employed sub-contractors who do much of the work on traditional building sites are raising their wages as much as possible because they can. In the rush to build homes, there is a shortage of labour such as bricklayers and carpenters, so the ones that are available can charge a lot for their skills.

Factories are less exposed to this wage inflation because their workers are permanently employed and therefore can’t demand increases in their wages at short notice. Factory owners tell me that last year, their homes were more expensive to build than traditional buildings, but could be built more quickly. This year they can be built for the same price, but more quickly, and next year they will be cheaper to build, and more quickly.

Hotel and Apartment building, Olympic Way, Wembley

Modular Hotel and Apartment Building, Olympic Way, Wembley. ©HTA Design LLP

There is a further promise of factory production which is the expectation that someday we will be able to order our home online and change the design to suit ourselves. If this sounds far-fetched, they have been doing this in Japan for decades. Companies with familiar names like Toyota have constructed tens of thousands of such homes for their customers, most of which have been customised to some degree. Factories with a high degree of automation can cope with a change in design easily, provided that the robot can be given the correct template to use, it doesn’t care if it does the same job ten times a day, or ten different jobs.

The key element is that the robot is given a template to work from. Customisation does not mean that the customer can have what they want in every case, it means that they can choose from a wide range of features that ensures that no two houses are ever the same. It only takes nine variants in a house design to produce over 300,000 different homes, so customers can be satisfied that they have a unique product and the factory can continue to produce a unique design from relatively standardised components.

There is a reason why the difference in quality between a factory-made home and a traditionally built home is not obvious to the average housebuyer or renter. No-one tells them, and the quality difference is not reflected in the sales price. We have the ridiculous situation where the location and number of bedrooms in a property sets the value, and the quality of the finished home counts for very little, apart from its use as a bargaining chip to reduce the price where there are defects, but rarely to increase it beyond what is normally paid in that area.

If a housebuilder does a very good job of building a traditional home, or a bad job, it makes no difference to the price. If the home is hard to heat or very efficient, it may be interesting to the purchaser, but it makes no difference to the price. If the three bedrooms of one property are bigger than the three bedrooms of the other, it makes no difference to the price. In a market like this it is very difficult for a housebuilder to concentrate on a quality product, since it makes no difference to his profits.

In new development this is exacerbated by the lack of previous sales figures in the area. Mortgage providers look at sales values for fifty year old properties in the same location to use as a benchmark for the values of new homes under construction, ignoring the enormous quality gap between the two in terms of performance.

We are trying to change this by introducing a way that purchasers and renters can see the difference in the quality of their new home. By creating a Home Performance Label with the help of BLP Insurance and The Housing Forum, we are enabling people to rank their potential purchases in order of size, if that’s what they care about, or in order of energy efficiency, price per square meter, daylight, or maintenance costs, or many other metrics. This way of making a purchasing choice is familiar to anyone who has bought a car, insurance, a phone, electricity or a fridge in recent years. We think it’s time that such a tool was available to the housing market.

By helping people to make their choices based on quantitive information as well as qualitative information we expect to drive up the quality of new homes in the same way that comparison shopping has driven the market in electronic goods. The product of tomorrow should be better than the product of today and offered at the same price. This is how markets should work. There should be room for low quality products and high quality products, at different price points, but the housing market currently values both the high quality and the low quality products in the same way, leaving no room for a quality premium. Because price is also set by location the current pricing system keeps the housing quality low in poorer areas and reduces the likelihood of regeneration where it is needed most.

Finally, in order to deliver anything like the number of homes we need, the housing industry in the UK must double in size. Output is currently about half of what we need to sustain the market without prices continually rising. This growth won’t be achieved b adding more workers from abroad, working in muddy fields at low productivity levels. It will be achieved if we create a functioning offsite manufacturing sector, distributed across the UK, using a well-organised workforce, operating in a market where higher quality products get the sales prices that they deserve.

A version of this article first appeared in The Housing Forum report, ‘More Homes Through Manufacture‘ supported by the Hyde Group.

Happy City – a Review 

Happy City, a book by Charles Montgomery, should be on the shelf (digital or physical) of everyone interested in the sustainable future of cities. Given that more than half the worlds population now live in them, and that the numbers continue to rise, that should represent a lot of people. For some people, myself among them, the ideas presented in the book are not new. What is new, is the evidence he provides, statistical, personal and independent, that gives new life to those ideas. 

The central theme of the book is that disconnected urban sprawl, the worst kind of supurbia, where people move further and further from major population centres, is bad for the planet, for the people whose lives are spent commuting, and for the rest of us whose taxes go to pay for all the infrastructure that such places need. None of this sounds surprising to me, and I imagine it won’t surprise you either, so why is it that across the world, including here in the UK, we continue to build most of our new homes in exactly these kinds of locations? Far from transport arteries, schools, amenities and services.

Montgomery points out that the appeal of the suburb is based on us lying to ourselves, that we owe it to our children to give them a good life, that crime is lower in the suburbs, and that schools are better. He demolishes these fictions by pointing out that in North America, the value of suburban housing is stagnating, making sprawl a poor investment. Children who grow up in sprawl are more likely to fail in school or end up with a criminal record because their parents are usually absent, working and commuting long hours to pay for the suburban dream, and because new suburbs are particularly bereft of services and activities for children and older people. Instead of the Good Life that buyers imagined, they end up in Breaking Bad. 

I particularly enjoyed the chapter describing how the car manufacturers bought up light rail systems in north America and then dismantled them, as they were a threat to their business. How they introduced the jay-walking laws to criminalise walking when there was a danger that deaths on the road would reduce car sales. When people talk about the dangers of listening only to the private sector, there is a good case study.  The car industry has been a good employer and earner of foreign exchange for a few countries for the last fifty years or so, but look at the legacy it leaves us. We bought the marketing, now we have to live with the consequences.

Happy City is not all about failure, it covers a lot of ground where improvements have been made in enabling cities to deliver a better life for their inhabitants through better public transport systems, cycling lanes, or just more local community life. From Bogota, to Paris, Mexico City to Atlanta, he has drawn on many sources and interviews for evidence of successes and failures. This is a thoroughly researched book, and an enjoyable read. I recommend it!

Book Review: Urbanism in the Age of Climate Change

Written by Peter Calthorpe and published in 2011, this relatively small book sets out a new (to North America) approach to the planning of large scale urban settlements. 
These include 
– building settlements close to public transport
– expanding public transport availability to match demand, in whatever way makes sense locally
– building a diverse range of housing to cater for the smaller family sizes of modern populations
– avoid creating car-dominated infrastructure
– create walkable neighbourhoods where people can work and live within walking distance
– use a tripartite planning structure cascading down from national to regional and local policies, plans and standards
– have an integrated trasnport and development policy

Underpinning all of these is his contention, which I agree with, than urbanism on its own is an inherently sustainable way of living, and that suburban sprawl is not. Even without the addition of high quality homes that produce little or no CO2 emissions, living at densities of 50 dwellings per hectare and above in an environment where public tranport is available and where work can be within a walking distance. 
He points out in a compelling and very clear set of graphics that if North America was to adopt what he calls an Urban-Green scenario for its new housing it could save
-12,000 miles of car journeys per household per year
-reduce air pollution by 43%
-save $15,000 per household per year in transport and heating fuel costs
– save 25,700 square miles of land from development by 2050
– save 75% of potable water use
– save 80% of an individuals CO2 emissions compared to a 1990 baseline, without doing anything else

Some of this may seem obvious to a UK audience, long used to hearing these views expressed in planning policy in various ways over a long period. But when you examine our current direction of travel it is not immediately obvious that we are going to hit these levels of performance in the UK.

– We had a PPG that mandated 50 dwellings per hectare, and it was removed by the current government.
– We had regional development agencies tasked with coordinating development at a regional level, now we do not.
– The same government has recently announced a major road building programme to reduce congestion, when we are all pretty sure that building new roads has almost no impact on congestion.
– Low carbon homes are on the agenda in the UK, but somewhat unwillingly and the level of ambition has been downgraded many times.
– New Garden cities are regularly touted as a great idea despite generally being proposed in places with poor transport, and envisaged as being constructed at low densities.

So while we pride ourselves on being much greener in general than North America, the gap between us and them may not be as great as we think. If we are planning a future that is less green than parts of North America, it may be time to think again.

I strongly recommend this book, it is well written and the ideas are strong and clearly expressed. The graphics are well illustrated and paint a very complex picture in a very clear way. It should find a place on every urban designers bookshelf and It should be recommended reading for every housing minister.

Zero Carbon Exemption Consultation Response

See below for my response to this current consultation, it closes tomorrow, so make sure you get your submissions in. Note that this exemption will require further legislation following on from the introduction of Allowable Solutions in the Infrastructure Bill.

The consultation document can be read on DCLG’s website. 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. (£30-£90)
  • 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

Question 1 – should the exemption be targeted at site size, developer size, or a combination of both?  Is there any evidence to support the choice made?

To act as an encouragement to development, the exemption would be better replaced with a measure that promotes the bringing forward of new land for development in areas of the UK that need it most. By removing any benefit to the Local Authority in the form of the Allowable Solutions payment, any encouragement to the Local Authority or to the local community to grant planning permission is removed. In some cases the Allowable Solutions monies would be spent on improving the energy efficiency of local homes under Local Authority retrofit schemes, replacing lighting in local schools or replacing street lighting with more energy efficient versions, all of which are a benefit to the local community and all of which would encourage the local community to welcome development rather than fighting it. By removing this incentive to welcome development the measure is as likely to restrict development as it is to encourage it.

Any incentive to development should be aimed at the developer, and not the site, and the incentive should be aimed at small developers who build less than 100 homes per annum.

Question 2– if the Government chose a site size exemption, what level should this be set and why?

I don’t agree that introducing a site exemption makes any sense, but if it were to make sense it would be sensible to chose the size of site that the local authority sets as a ‘minor’ application. As this tends to vary across the country, the exemption size should change also.

Question 3 – if the Government chose a developer size exemption, what criteria should it apply and why?

Exempting developers from meeting the zero carbon targets makes no sense, either for the developer or for the local authority giving permission for development. The developer will not make any more profit from the sales than before but will pay less for the land to make the viability calculation work, so the only loser in this equation will be the landowner.

If an incentive is introduced it should only be used to promote new entrants into the market, or small developers offering local custom build homes on small sites.

Question 4 – What do you think the scope of the exemption should cover? An exemption for the allowable solutions scheme only, or an additional exemption from Building Regulations requirements? Do you have any evidence to support the choice between these options?

 I see no benefit in providing the exemption at all, and I certainly see no benefit in increasing the scope for relaxation in Building Regulations beyond Allowable Solutions. Home purchasers in the UK can and should be sold the highest performing homes that can be made available to them to enable the UK to meet its legally binding cuts in CO2 emissions. Reducing the energy efficiency of new homes in one sector sends a dangerous message to all sectors, that energy efficiency is not so important that it cannot be ‘tinkered with’. Reducing the build quality of homes to enable developers to increase their profit is tinkering with the housing market in an unacceptable way. We would not consider reducing the energy efficiency of new cars to enable car sales companies to sell more cars. In addition this confuses the market and weakens the ‘brand’ of new homes. One of the main benefits of a new home over an existing home is the much superior energy efficiency. Purchasers should not be confused by having new homes at different levels of building regulation compliance offered to them at the same time, in the same area, under the same legislation.

Most developers make the profit from their activities by buying land at low values and selling land with housing on it at high values. The cost of delivering the homes is a relatively small part of the financial equation and the impact of this proposal is likely to be small and should not be overestimated.

Question 5 – What are your views on the proposed review period for the exemption?

If an exemption is introduced it should only be retained for the period between 2016 and the following revision to the Building Regulations. This is likely to be 2020 to bring UK regulations into line with EU 2020 Nearly Zero Energy Buildings. Furthermore the exemption should not be capable of being ‘booked’ in advance. Sites that are not completed or substantially under way on the date of the introduction of the new regulations should lose the exemption, it should not be carried forward.


Question 4(sic) – Do you have any further evidence that would help inform the impact assessment?

Many of the smallest sites brought forward for development will be self-build sites. In this case the developer is the future owner of the home and is likely to live in the home for a sustained period of time.

Since self-builders are already exempt from CIL and s106 payments, there is a danger of this incentive becoming an additional incentive to a group that are already benefiting from other exemptions.

The Allowable Solutions system is not yet fully developed and it is concerning that the Department should be considering exemptions to it before it has even been introduced. To work well, it will need Local Authorities in every region to have working projects that can be funded through the Allowable Solutions payments. Projects are likely to include retrofitting of nearby old properties and improving the energy efficiency of street lighting. This will be beneficial to communities and will play a part in helping communities see that there are benefits to them in allowing development to happen. Removing this benefit for some sites weakens the Allowable Solutions before it is introduced and will weaken Local Authorities resolve to bring plans forward that can benefit from the payments. If these local plans are not in place the Allowable Solutions can still work by paying into a national fund, but this will be an opportunity missed. Payments by developers into a national fund will not bring any further benefits to the developers in terms of winning the hearts and minds of the communities that they work with every day, and instead will see their money going elsewhere to an Allowable Solutions fund that they have no control over. Any opportunity to demonstrate to communities that development is a positive thing for them should be taken.

Happy Christmas to all my readers, and welcome to 2015.

Dear All, I wish you all a very happy Christmas and a prosperous New Year. Its been a good year for me, professionally and personally and I am looking forward to 2015.

2015 is going to be an interesting year for two big reasons. Elections and Paris.

In May in the UK, we get to elect the Government we deserve and in December they will participate in the Paris Climate Agreement talks to agree actions worldwide to limit climate changing emissions for the next few decades. If that doesn’t concentrate the mind, what would?

In the UK we have the prospect of coalitions ahead, and having grown up under Proportional Representation, this doesn’t bother me at all. The last five years have shown to the electorate that a coalition government can govern in the UK, whether you like what they have done or not. It also shows the danger to the smaller parties of making promises in pre-election manifestos that they cannot possibly keep.

On the right of the three parties we have the loony right, UKIP, who don’t think climate action is a priority, and slightly to the left of them are the Tories who have managed to make the words ‘greenest government ever’ into a new sort of insult.

On the far left we have the Green Party whose numbers are swelling impressively in recent months and in recent by elections have come in fourth place. Will this lead to more MP’s in Parliament in 2015? I certainly hope so.

Whatever the decisions we make in 2015, who we vote for will have farther reaching consequences than usual. Choose wisely!

Meanwhile enjoy the holiday, rest and relax, and prepare yourself for what is going to be a very busy 2015.


Is There a Need for a Right to Energy?

We have had a Right to Light for a very long time, and good access to daylight in residential buildings is seen as a central issue when designing buildings in many parts of the world. The benefits to well-being and health are well-recognised, even though this can be difficult to assess when it comes to designing buildings in an urban location where it is nearly impossible to build without affecting someones daylight.

But now that we are designing buildings that can be self-sufficient in terms of energy, achieved by using very energy efficient building fabric, passive solar gains and an energy balance achieved with some roof mounted or facade mounted renewable energy production: Do we need a right to the solar energy that such a building is dependent on?

Under Rights to Light legislation a home that suffers a low threshold of light loss has no right to prevent the construction of a building nearby. Taken to its ultimate conclusion, successive buildings can be built around the affected building, each one diminishing the available daylight by a small amount, until the affected building sits in darkness. Call it ‘Darkness by a Thousand Blinds’ instead of ‘Death by a Thousand Cuts’.

In the same way, a self-sustaining building can end up losing its access to solar energy through a gradual encroachment on its surroundings by neighbouring buildings, gradually eroding its access to renewable energy either by casting shade on its solar panels, by preventing solar gains, or by stealing the wind from the blades of a wind turbine.

After 2016 when the zero carbon legislation is enacted, (note I say when, not if) then the use of solar panels will be built into regulation under the Carbon Compliance element of the regulation, and the performance of panels or even solar gains will be an integral element of the performance of the building. Buyers of the building can rightly expect the building to perform in accordance with its energy certificate, and if it doesn’t they have a right to know why not.

How long will it be before neighbours are suing each other for loss of income due to encroachment on one another’s solar gains?

I foresee planning arguments, neighbour disputes and legislation ahead.

Labour’s Green Paper on Energy Efficiency

The Labour party published a Green Paper on their energy efficiency policy entitled ‘An end to cold homes’ last week. There are several key elements in it that are worthy of attention, and it is a useful starting point for what the next Government should consider as priority actions.

The headlines are:

  • Provide half a million home energy reports for householders, mainly aimed at those in fuel poverty to help them realise what the problem is and how they could solve it.
  • Offer free energy efficiency improvements for 200,000 households at risk of fuel poverty per year, with an ambition to improve all 4million homes within 15 years.
  • Set a new target for the private rental sector of a minimum EPC Band C by 2027, increasing the current target for 2018 of Band E
  • Set Energy Efficiency as a national infrastructure priority under the proposed National Infrastructure Commission
  • Streamline regulations and introduce long term strategy to support investment in energy efficiency in non-domestic buildings
  • Less related to energy efficiency policy, but important nonetheless was a commitment to review the zero carbon policy and revert to the Zero Carbon Hubs original definition of Zero being including all unregulated energy and regulated energy in the definition.

My impression of the launch was very positive. The language was reassuring, there was an acknowledgement that Government in general has failed with the Green Deal to either understand the market or to understand the best way of delivering measures to households.

The strongest evidence of this was the statement that we still have

– 4.7million uninsulated cavity walls

– 10 million lofts that could have more insulation added

– 7 million uninsulated solid walls

– 8 million homes without a thermostat

The summary of fuel poverty in the paper is sometimes startling. The poor are often housed in poor buildings, making them cold and poorer. If we as a society think that it is important to give our poorest members a home to live in, isn’t it equally important that we give them a warm home to live in so that they are not spending an above average proportion of their low income on keeping warm?

30% of people living in Band G properties are fuel poor, in total there are over 2.2million households falling in this defined category in England, and another 1 million between Wales and Scotland.

Comment: Energy companies are not the best people to deliver these measures, in one case energy companies spent £50 to pay people to find other people to receive free energy efficiency measure under the Warm Front scheme. There is no available cost data from these schemes to help decide which ones were cost effective and which ones weren’t. (The giving away of energy efficient light bulbs springs to mind). I am equally concerned that Energy companies have bought a number of external wall insulation companies to install these measures. The blind leading the blind.

Green Deal/ECO

The Green Deal has been an expensive waste of time for the companies who engaged in it. It is set to deliver 4,000 improvements out of 355,000 households assessed. That’s about a 1% rate of return. The taxpayer paid for 90% of the assessments. A very poor use of money, and if we want to tackle energy efficiency improvements in a serious way, this isn’t going to do it. The interest payments are simply too high, they have always been too high, the Government was told that they were too high, I won’t go on.

A recent survey by the CBI demonstrates that only 5 percent of businesses considered that the Governments current policy framework is effective in encouraging investment in energy efficiency.

The non-domestic Green Deal has had 63 assessment carried out so far, and no measures delivered.

Labour’s solution to this is to offer interest-free loans to households to carry out energy efficiency improvements. This will be funded out of energy efficiency levies from energy companies and backed by a Government guarantee of the Green Deal Finance Company.

All the ECO funding will be aimed at low-income households in cold homes and who are at risk of fuel poverty.

The measures will be delivered by area-based organisations instead of by the Energy Companies. Local Authorities, Housing Associations, local energy organisations and other trusted partners.

Instead of funding single energy efficiency measures as the current ECO does, the new target would aim to improve properties to Band C. This would significantly improve the property, reduce the risk of fuel poverty significantly and would mean that it would not be necessary to return to this property for a generation.

Comment: I could never understand why DECC refused to understand this point in the past, despite being told it by practically everyone in the industry. The preliminary costs of doing work are always a substantial element of the total cost of refurbishment works, so if you set out to do work on a property, you should do as much as possible while you are there, to reduce the wasted costs of returning to the same property a decade later to install another separate measure. I think that politicians should shoulder a lot of the blame for this as they are always interested in reaching as large a number of households with the smallest sum of money, to win votes and keep themselves in power. But single-measure works is just a waste of taxpayers’ money. If Labour get into power and implement these policies it will be interesting to see if this intention remains.

Private Rented Sector

The idea to raise the target for PRS properties to Band C by 2027 got some headlines as it was initially suggested that the target to achieve Band E by 2018 would be dropped. This was swiftly denied by the party and this new target is a demonstration of a long-term strategy aimed at giving landlords and the industry long term certainty of the direction of travel for policy.

Zero Carbon

The announcement that the definition of zero carbon for new homes would revert to the original definition is interesting. The definition of zero carbon has had an unfortunate history, and became a political football during the early days of the current administration. The exemption for small sites is not to be taken forward by Labour, and extensions to existing properties will have to meet full building regulations.

Comment: It makes sense to revert to the original definition of zero carbon, but given that we are where we are and we have no final policy or regulation for Allowable Solutions, then it may be wise to continue to use the current definition of zero-carbon (regulated energy only) for the next round of regulations in 2016, and then ramp up successive regulations to take account of unregulated energy.

Building on the Green Belt

Paul Cheshire of the London School of Economics came to HTA last month and presented his thoughts on Building on the Green Belt. It was at once appalling and fascinating. I think it is worthwhile to explore ideas that are superficially appalling to analyse why they affect us in this way and whether our sensitivity to them is real or something we have learned without really absorbing the rationale behind it. The history of civilisation is full of bad ideas that were once held to be good ideas but which we now find appalling. By we, I largely mean Western civilisation. By bad ideas I mean racism, fascism, UKIP, factory farming…those sorts of ideas. What seems obvious to one generation can often appal the next one. Think about 70’s fashion!

Building on the Green Belt(BoGB) has come to attract the same strong reactions as some of those ideas above, whether one is for or against, there is no real middle ground. The cause against BoGB is is largely emotional and visceral, its ‘green’ land, the reasoning goes, so it must be nice, its surely full of woodland and trees, it harbours the last vestige of medieval connectivity with the ‘land’ that feeds us. We will all choke to death on the fumes of cars and buildings if we allow this to continue, etc., etc.,We are carpeting over England’s green and pleasant land and we mustn’t allow it to continue, or even think about allowing it to continue. Is any of this true?

The problem with all of this is that there is enough truth in it to make it believable to the average voter, and therefore completely toxic to our current crop of rather spineless politicians. Were BoGB to happen it will inevitably destroy some areas of land that have some ecological value, and will inevitably carpet over some of the ‘green and pleasant’ land. But the argument is more complex than this. By not BoGB we are curtailing the supply of land for housing in a way that was not envisaged when the legislation was enacted. We are in a period of chronic under-supply of homes and young people have little chance of getting an affordable home to live in unless we act to increase supply. London in particular is being constrained to the point where housing ownership is becoming impossible for young people on a normal wage.

To change the housing market we need to be building many more homes that we are currently building, this appears to be generally accepted. Some of these can be delivered in dense new apartment developments close to jobs in city centres. But high density development is slow to bring through the planning system and often controversial. On its own it won’t be enough.

I dislike the idea of BoGB as much, and possibly more than most, I prefer to design dense environments for people to live in, as I believe that high density living brings with it high-quality services. If I had my way we would all live in terraces or apartments and the suburban semi would be banned. Fortunately there are a lot of people who disagree with me and who want to live in the suburbs in a semi and they should have what they want. Shouldn’t they? Is owning an environmentally damaging house with four cars and garden in the suburbs an ‘inalienable human right’ or should it be classified as something that previous generations longed for and could afford, but which we cannot? Do we recognise that the costs of allowing everyone to own their own patch of grass two hours commute from where they work is neither good for them nor good for society as a whole?

To look at the figures dispassionately, 13% of land in the UK is Green Belt land. have produced a nice map illustrating the many designations of land used in England to prevent development. Their research demonstrates that we have built on approximately 10% of our land, leaving the remaining 90%, much of which is unavailable for development. The illustration of Green Belts around the main population centres demonstrates that they are doing their job of curtailing the growth of those centres, and putting pressure on nearby smaller towns to grow instead.

Unfortunately this land use planning strategy is not matched by an economic strategy that is helping to create jobs in those smaller towns. The result is a working population in the cities that must commute long distances to work and puts increasing pressure on the transport system. See here for statistics showing that a decade ago about one third of London’s working population commuted into London. One of the results of this has been the construction of more roads through the Green Belt, which has further degraded it, on top of the highly industrialised agriculture practised in most of the Green Belt which has denuded it of trees and wildlife. It may be green in colour, but much of it is grey in environmental terms, ecologically poor, with sparse areas of ecology poisoned by pesticides and curtailed by the machinery of the supermarket supply chain. Is it really worth protecting? Are we being realistic by calling it the Green Belt? Are we using the right yardstick to measure it against? Should we call it an Environmental Zone or Green Zone instead.

The decades-old principle of home ownership will soon be at an end unless these conflicting strategies are resolved. Land use designations including the Green Belt have become an inconvenient sacred cow that is preventing our cities from expanding. Growth is being pushed out to smaller dormitory towns, and pushing up the price of land outside the Green Belts to levels where starter homes require subsidy to be affordable. The policies discussed in the recent round of conferences include subsidies for first time buyers is a direct result of a set of planning policies that limit the opportunities for development.

I suspect that the Green Belt could be made smaller, more environmentally beneficial, and much more meaningful in real terms by being ‘masterplanned’ and ‘activated’ more thoroughly. The reality is that most Green Belt land currently performs little useful function other than to curtail development. Given that our wildlife population continues to plummet, we cannot argue that Green Belts have fulfilled a function of protecting wildlife. To live up to its designation Green Belts need to be transformed into places where nature can thrive and also be enjoyed by the urban population they are intended to support. A series of Environmental Zones surrounding our cities which contain leisure activities as well as a proportion of responsible farming, new woodlands, wind turbines, biodiverse places rich in ecology and protected by future generations and bounded by dense high quality homes seems to me to engender the best of both worlds. The costs of these changes would be borne by the sale of a proportion of the land for new housing.

Since many of these areas are already well-served by public transport little new infrastructure would be needed. The existing infrastructure is currently under-used as these outlying areas have not been able to expand since the transport network was installed decades ago. By creating jobs in these locations we would also reduce the need for expansion in the transport network and balance the current concentration of jobs in the centres of our cities with a new set of suburban desirable locations for people to live and work. The Green Belt was a good idea and it has left us a legacy of potential that we can use, but on its own it is not enough to guarantee a positive future for our major cities.