Implementing Zero Carbon in London

Now that we are almost upon the deadline for the introduction of zero-carbon (GLA) in London I thought that it was timely to comment on it. 

Firstly. Brilliant! In a time when politicians appear to have taken leave of their senses permanently, it is reassuring that here (surrounded by the metropolitan elite) some things stay the same. We have a group of politicians willing to lead on principles rather than on the basis of prompting by tabloids or by their lesser selves. Well done London!

Secondly: Brilliant! We have a piece of zero-carbon legislation that has learned from the recent past, from multiple consultations by DCLG and the Zero Carbon Hub and run with it rather than reinventing this particular wheel. More importantly, it sets a precedent for other devolved authorities to follow. London can afford to lead on this one, to get the idea moving, to introduce developers and their design teams to the idea and to pioneer mechanisms for using the funds in a transparent and timely way so that developers can see the benefits to them. 

Thirdly: There is work still to do, as there is little clear understanding about many of the aspects of the new legislation. Can we claim a credit for making improvements above regulation? For example if the team introduce dimming into the building, can they claim some CO2 reductions below the line of the regulatory calculations. If the designers use a timber structure, can they claim some embodied energy reductions? When are the payments to be made? When the building is designed, or when it is built? There are likely to be differences between the two.

I think that it would be useful if the GLA held some workshops about this new legislation and had an open discussion about these questions, to help to introduce the legislation and to hear from design teams and clients how it can work best for them and for the GLA. It is very important that this new effort succeeds, it is practically the only star left in the low-carbon buildings firmament, so let’s make sure that it burns brightly and it isn’t extinguished at the first sign of difficulty.


Why we need to stay in the EU

The prospect of the UK Leaving the EU fills me with dismay. I listen to the rhetoric from politicians and wonder about their motivations in proposing an exit. Do any of those proposing to leave have any real understanding of what it would mean? What would a future for the UK be like outside of the EU. Sitting like an unwelcome houseguest at the fringes of the party, furtively stealing beers from the fridge?

When I survey the landscape I am most familiar with, particularly around sustainable buildings, I reflect that much of the impetus for environmental legislation in the UK has come about through pressure from the EU through the Energy Performance in Buildings Directive (EPBD). I suspect that, left to its own devices, due to the UK Housing sector being dominated by a small number of housebuilders, the industry would have fought off all attempts to implement energy efficiency improvements.  Without the gentle but firm push in the small of the back from the EU, our homes would probably be much less efficient. We wouldn’t have an EPC, and whatever it’s faults, at least it is a step in the right direction.

Now that the Govt has scrapped the planned 2016 zero carbon legislation, the next push for improving our buildings will come from Europe, the EPBD requires that all EU states enact legislation leading to Nearly Zero Energy Buildings from 2020. Again, that gentle but firm push. This is something that will be good for consumers who buy homes, good for the businesses that build them and help to push down our CO2 emissions.

I imagine that the same goes for the car industry, and even though the image of the EU industry has been seriously damaged by the recent emissions scandals, at least the intention to reduce emissions is there in legislation. Given that the UK’s default position on improving emissions regulations has been to vote against them, and given that London in particular has been failing to meet EU emission standards for some time, and will continue to do so for some time to come, our record of standing alone on this issue is not a particularly proud one.

On renewable energy we are again struggling to meet EU targets, and thanks to recent Govt cuts, are not even sure how we plan to meet them. There has been no suggestion that these targets are unwelcome, or that we are unable to meet them, in fact the minister stated that the Govt has every intention of meeting its obligations. While the arrival of wind turbines have been unwelcome in some areas, they  enable us to reduce our imports of coal and oil and help us to reduce pollution levels and CO2 emissions. Again, without a push from the EU, would we have adopted these targets? On the evidence of the current Government, probably not. Or if we had, they would be voted out again with every change in the political landscape.

While our politicians vacillate every five years or so, whether they like wind farms or don’t, whether they like nuclear or don’t, and whether they think fracking is a good idea or they don’t, in the background there sits the EU,with a long term plan to reform the energy markets, to reduce emissions, to introduce more renewable energy and to make our buildings more efficient. Politicians come and go, but the EU remains as a stable influence on our policies and standards. This stability helps business to invest, and gives purpose and direction to research and development, as EU strategies tend to remain in place longer than national or local government cycles.

The exitmongers complain that this is interference in our democratically elected system of government, I say it’s a good thing. Without it we would be worse off. The EU acts as a brake on occasional foolishness, a calm voice in times of crisis and a firm guide on environmental matters. It’s a bit like a parent, the interference is unwelcome at times, but it’s reassuring that someone is there for guidance when you need it.

Zero Carbon(2016) Exemption Proposals

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.

Announcement on Zero Carbon Homes in the Queens Speech

Here is the text of the background document to today’s announcement on zero-carbon Homes.

New homes built to a zero carbon standard

The Government is committed to implementing a zero carbon standard for
new homes from 2016. But it is not always technically feasible or cost
effective for house builders to mitigate all emissions on-site.

The Government would set a minimum energy performance standard through
the building regulations. The remainder of the zero carbon target can be met
through cost effective off-site carbon abatement measures – known as
‘allowable solutions’. These provide an optional, cost-effective and flexible
means for house builders to meet the zero carbon homes standard, as an

alternative to increased on-site energy efficiency measures or renewable
energy (such as solar panels). Small sites, which are most commonly
developed by small scale house builders, will be exempt. The definition of a
small site will be consulted on shortly, and set out in regulation.

The Zero Carbon Home standard will be set at Level 5 of the Code for
Sustainable Homes, but the legislation will allow developers to build to Level 4
as long as they offset through the allowable solutions scheme to achieve
Code 5.

(This is a strange piece of text,  the Coalition is using Code Levels to explain an energy compliance scheme. The 2016 standard has almost nothing to do with Code Level 5 and Code Level 4 has very little to do with Building Regulations 2014. Its as though the Code was only an energy standard, and all the other elements didn’t matter so much)

Energy efficiency requirements for homes are set in the Building Regulations
2010 and are made under powers in the Building Act 1984. But there are
insufficient powers in the Building Act to introduce off-site allowable solutions,
so the Government will now bring forward enabling powers for this.


I am assuming that this exemption applies to London, and that anything built within the London Plan zone will continue to meet London Plan requirements irrespective of scale.

The question of what represents ‘small’ is going to be interesting. How small is small?

Allowable Solutions Consultation

The Allowable Solutions consultation has finally been published, and in the middle of the holiday season (thanks DCLG). For new readers the Allowable Solutions is the third and final section of the proposed 2016 Zero-carbon Standard. The other two are Fabric Energy Efficiency and Carbon Compliance. To recap:

Fabric Energy Efficiency sets a base building efficiency target set in kwh/sqm/annum which depends on the building type and its connections to other buildings.

Carbon Compliance is also an absolute target set in kg/CO2/sqm/annum and also depends on building type.

Allowable Solutions sets out how to offset any remaining emissions over a thirty year period following the buildings construction, if the combination of FEES and CC don’t equate to the definition of zero.

I should point out that zero in this context is a number derived from the emissions produced by heating, lighting, providing hot water, ventilating and cooling the building; it does not include power for rainwater harvesting, powering the TV or computer or any other non regulated equipment. The reasoning for this is that other EU legislation is driving down the energy use of such equipment and there is no need to enshrine such measures in the Building Regulations. (I think that this is a weak argument and a missed opportunity, but lets not go into that right now)

The modelling for the proposals was done in 2011 by the Zero Carbon Hub, but this work is incomplete and doesn’t include high-rise apartments or flats over garages, both commonly used building types.

The consultation sets out to provide a clear framework for projects after 2016 so that developers and housebuilders can predict their development costs with some confidence. This will help to ensure delivery of new housing continues to rise, and that the costs of additional legislation can be managed down as much as possible.

The proposal includes four options for the Allowable Solutions mechanism.

-That housebuilders/developers build to zero carbon and therefore don’t need to use it; this is the equivalent of Code Level 5 energy targets in the Code for Sustainable Homes.

-That Local authorities or other bodies provide a carbon offset mechanism through local low energy or retrofit projects.

-That housebuilders do the low carbon works themselves by retrofitting existing homes or buildings, or, by improving the performance of other schemes before 2016 and ‘banking’ the difference.

-That housebuilders/developers pay into a fund that carries out the work or arranges projects on their behalf. A sort of English Clean Development Mechanism where multiple sources of funding could be brought together to fund low carbon projects.

This is all very complex and represents the type of thing that successive governments seem to like doing, spending years on writing position papers, developing complex mechanisms, and spending many  hours of civil servants lives struggling to understand how the housing industry works so that they can ‘improve’ it.

There is another way.

By making it financially and tax efficient to design, build and sell zero carbon homes, the government could incentivise the market to produce zero carbon homes in any way it sees fit. Consumers would ask for lower carbon homes because they would represent better long term value to them, and mortgage lenders would provide funds to purchase them. housebuilders and developers would strain every sinew to innovate in all three areas of the Zero Carbon standard and they would succeed, because that is what the housing industry is good at.

It worries me that we are planning to take a route to housing delivery where two homes are going to be pronounced as zero carbon, one that meets the FEES and CC standards and achieves Zero Carbon by paying into a fund for the remaining carbon emissions, and one where the total emissions reductions are mitigated on site. The second of these two homes will be much cheaper to occupy that the first and the difference will not be obvious to the bulk of consumers. We are in danger of setting up a complicated mechanism to make life easier for housebuilders and developers, but which will has the potential to strain their relationship with their market.

EcoBuild 2013 – Review

I spent two days at EcoBuild this year, and had a very positive experience. I have heard a few complaints that the exhibition wasn’t as impressive as other years, which may have been true, but I don’t go to look at exhibition stands. I look at large expensive exhibition stands at EcoBuild and other trade fairs and generally think that the money could have been better spent. Bah humbug.

Instead of wearing out my feet traversing the several football fields that is the show, I arranged to meet people. Lots of people. Manufacturers, developers, go-betweens, distributors, contractors and researchers, and managed to fit them all in, and had good meetings with them all. I drank a LOT of coffee in the central space, in fact I spent two thirds of the time there rather than in the halls. For me the great thing about EcoBuild has always been the quality of the people who attend it. There is a huge group of serious professionals, clients and manufacturers who are interested in making this world a more sustainable place, and come to EcoBuild to learn about how to do that and to network with other like-minded people that they want to work with. Manufacturers and suppliers can come and go, but the people will remain, and so long as they do, so shall I.

Things that caught my eye this year? A LED bulb in the innovation zone that uses AC power and doesn’t need to transform AC to DC, so its more efficient and last longer, and can provide mood lighting. Vacuum Insulated Panels from Kingspan and others, can’t we make this futuristic product work and bring the costs down?I liked the electric bike test track, that’s a good way of using a bit of spare space, why not have some electric cars and scooters as well? UKTI did a great speed dating service for the show, my colleagues tell me the Life cycle assessment seminars were very good, UKGBC launched the PinPoint website, so as a Pinpoint champion, I am championing it!

I’m already planning 2014 and its going to take me days to get through the to-do list I have accumulated over the last week, so its been a good EcoBuild for me.

The Sustainability Implications of the NPPF

Here is my summary of the NPPF for sustainability practitioners. I am highlighting the elements that strike me as being particularly relevant. This is no substitute for reading the document yourself!

Overall the document strikes me as being better than the draft but not as good as it could have been from a sustainability perspective. While the document is ostensibly about Sustainable Development, it doesn’t really add anything to the discussion about what that actually means in practice. Many concepts are mentioned but not defined. Garden Cities are a good example. There is a rather woolly reference to the ‘principles of Garden Cities’

There are many positives, the recognition that town centres need to be protected and expanded, that employment land shouldn’t be protected from development when there is no reasonable expectation of the land being used for employment uses, encouragement for low carbon development. But in all cases the question ‘what does this really mean in practice’ has to be answered.


The National Planning Policy Framework contains a presumption in favour of sustainable development: The entire document aims to set out what sustainable development means in the UK. It states “to achieve sustainable development, economic, social and environmental gains should be sought jointly and simultaneously through the planning system”. This includes development that ‘supports the transition to a low carbon future in a changing climate’, ‘encourages the use of renewable resources’ and includes ‘moving from a net loss of bio-diversity to achieving net gains for nature’.

The NPPF encourages the use of brownfield land, it supports the protection of town centres from urban sprawl, and recognises that residential development can play a part in maintaining their vitality.

It promotes sustainable transport, ‘solutions which support reductions in greenhouse gas emission and reduce congestion’. It encourages ‘sustainable transport modes’ but refrains from defining them.

It states that ‘..developments should be located and designed to give priority to pedestrian and cycle movements and have access to high quality public transport systems’

Empty homes should be identified and brought back into use, and where large scale development is appropriate it should follow the principles of Garden Cities. These principles are not defined, nor is any account taken of the particular circumstances that led to the development of the Garden Cities in the UK.

Good design is given high importance in the document including supporting buildings or infrastructure which promote high levels of sustainability.

Place-making is supported including places where there are ‘opportunities for meetings between members of the community who might otherwise not come into contact with each other’. The document then helpfully lists places such as pubs and places of worship where this might happen!

Local authorities are asked to adopt proactive strategies to mitigate and adapt to climate change, including supporting energy efficiency improvements to existing buildings, setting local requirements to be consistent with the zero carbon buildings strategy. The NPPF seeks strategies that promote renewable energy, maximise renewable energy development, identify areas suitable for renewable energy, support community-led initiatives, and identify opportunities for renewable or low carbon energy supply systems.

Local plans should include policies to deliver: climate change mitigation and adaptation, conservation and enhancement of the natural and historic environment including landscape.

Neighbourhood plans give communities direct power to develop a shared vision for their neighbourhood and deliver the sustainable development that they need.

The flood risk is assessed as per old PPS 25 and all development sites less than 1 ha are exempt. The NPPF states that SUDs Approving Body (SAB) has to approve the drainage system plans for new development. However the Schedule 3 at the Floods and Water Management Act 2010  that introduces SAB has not been formally introduced.

Zero Carbon Hub Annual Conference 2012

Today was the annual Zero Carbon Hub conference to review the progress of the Zero Carbon agenda. There were a few significant highlights from the speakers and the Q&A afterwards:
– there was a lot of mutual backslapping regarding the progress to date, Paul King commented that we are about half-way along the path from 2007 when the policy was introduced by Yvette Cooper, to 2016 when the policy becomes reality.
– many speakers bemoaned the fact that SAP is not fit for purpose, and the fact that it is owned by DECC, managed by the BRE on behalf of DCLG is at the heart of the problem. One representative of a major house builder declared (privately)that they would be happy to fund its development along with others, if the result was a transparent, reliable and useable system of compliance assessment. What is the point of doing R&D to gain 5% of benefits to find that this is wiped out by the next update to SAP?, he asked, quite reasonably.
– there was welcome news from the NHBC that owners of low carbon homes are satisfied with them and there is research to back this up.
– there was welcome news from Lloyds Bank that there is an emerging Green Mortgage market. There is also evidence that low carbon homes may command a premium because fuel bills are lower than for existing homes and other newbuild homes. As newbuild performance increases and the gap in running costs opens up between existing and new homes, there is an expectation that the market for new homes will grow.
– there was an explanation of the proposed changes to Building Regs from DCLG that didn’t leave me any the wiser, so I’ll just have to read the consultation.
– there was a speech from Ray Morgan that managed to annoy just about the entire room, doing what Ricky Gervais did for the Golden Globes, and Paul King invited him back to chair next year.
Next year can we have the conference somewhere with daylight? Not at the bottom of a deep cave in Kings Cross.

Zero Carbon London

I attended a roundtable hosted by the NLA last week on Zero Carbon housing in London. The purpose was to discuss the issues around zero carbon, whether the current definition is appropriate in London, and how to develop policy in this area. The event was well attended by housing consultants, with the NLA, Zero Carbon Hub and DCLG represented.

It was interesting to hear that little analysis has been done to date on the impact of the new definition of Zero Carbon on housing projects over four stories. The current definition is aimed primarily at the housebuilder market who mainly develop suburban sites, rather than on developers who bring denser urban sites to market. DCLG and the ZCH acknowledged that there is a piece of work to do on assessing medium and high-rise dwellings.

The likelihood is that the Fabric Energy Efficiency Standard will not be difficult for higher rise buildings because of the inherent efficiencies in building more dense developments. But achieving Carbon Compliance will be much more difficult because the use of PV as a proxy for CO2 reductions will not work in this context. The ratio of roof to floorspace won’t be high enough.

There was a lot of discussion about the potential for district heating schemes to fill this gap, some were in favour, and some against. There was some realism from the engineers present, acknowledging that some district heating schemes have an efficiency of only 30%. This may be caused by poor design and implementation, and would change dramatically as such systems proliferate. But the problem is that there is no sign that these systems will proliferate, they are simply too expensive in capital terms to be viable in the current market.

The alternative which was discussed at length, is the upgrading of the existing housing stock. In London there is a huge backlog of poorly performing dwellings that need energy efficiency upgrades and the Allowable Solutions monies coming from new development in London could be pooled to fund these upgrades. A likely figure for the monies available is £1500 per new dwelling after 2016, and if London achieves a target of 30,000 units per year, this could deliver £45M of annual funding. This could pay for 4,500 external wall insulation retrofits per year.

While it may be chickenfeed in the context of the Green Deal it is still worth doing, and worth delivering guaranteed emission savings, immediately. That is worth having.

Q.16 Response to Zero Carbon Consultation

There were a few very bad ideas in this years consultation on the definitionof zero carbon: Here is one of them with my response.

Question 16: Do you agree that this issue is renamed from ENE7 Low and Zero Carbon Technologies to ENE3: Renewable Technologies to better reflect the zero carbon hierarchy?

A:NO, renumbering Code issues is a very bad idea. Assessors have been working with the current numbering for some years now and there is a widespread understanding of the current arrangements. Renaming is acceptable, as the new name is similar to the old name, but renumbering will cause massive confusion to assessors many of whom will be using different Code versions on different projects at the same time. Errors will result from this renumbering if it goes ahead. We suggest the following naming and numbering system.

Current ENE issues

ENE1: Dwelling Emission Rate

2010 ENE issues

ENE1: Dwelling Emission Rate

ENE2: Building Fabric ENE2: Fabric Energy Efficiency
ENE3: Internal lighting ENE3: Energy Display devices
ENE4: Drying Space ENE4: Drying Space
ENE5: Energy labelled white goods ENE5: Energy labelled white goods
ENE6: External Lighting ENE6: External Lighting
ENE7: Low and zero carbon ENE7: Renewable Technologies
ENE8: Cycle storage ENE8: Cycle storage
ENE9: Home Office ENE9: Home Office