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.