Next steps to Zero Carbon Homes – Allowable Solutions
Consultation outcome reveals further concerns for zero carbon homes - By Anna Livesey
This week, some nine months after the consultation closed, the Department for Communities and Local Government finally revealed its response to Next steps to zero carbon homes – Allowable Solutions.
Some of the document contents were no surprise having been made available a few weeks ago in the Queen’s speech; namely the intention to set on-site energy performance requirements at a level equivalent to level 4 energy standards for the Code for Sustainable Homes.
The decision to choose this level is wrong. Quite simply it is not high enough. It only goes halfway towards to standard originally proposed by the Zero Carbon Hub in 2011. Furthermore, 70 per cent of respondents to the consultation were in favour of the Zero Carbon standard; agreeing that Government should base its consideration for energy performance standards for 2016 on this. So Government has ignored the view of the majority of respondents.
Also creating speculation following the Queen’s speech was a definition for ‘small sites’ which will be exempt from meeting the zero carbon homes standard in 2016. The commonly quoted figure is 50 homes or less which Barbour ABI suggests made up over one third of planned sites. This makes up a significant proportion of the market and means that the Government are not maintaining their promise on ALL homes being zero carbon.
Confirmed in the response is the intention to use proposed design principles for allowable solutions. Allowing house builders to decide how they deliver additional carbon abatement actions which could include a mix and match of; doing more on-site (e.g. connected measures like a heat network), doing more through off-site action (e.g. retrofit), contracting a third party (which includes local authorities) or making a payment into a fund.
Handing the choice to house builders means the price cap is all the more important. Government intends to carry out further analysis before setting the price cap because of concerns, from house builders, about the potential costs and impacts on house building. But setting the cap at the higher end of the spectrum should drive more action on-site, which is preferable. Ultimately, any analysis must take into consideration the long term outlook; the locked in benefits of built in measures over the lifetime of the building will outweigh short term costs.
Still also to be defined is the actual definition of what is an allowed ‘allowable solution’. Available information is the delivery of a criteria based approach (not a defined list), which will not be restricted to the non-traded sector and will include work to domestic and non-domestic buildings. The Sustainable Energy Association is currently putting together thoughts on options for allowable solutions focussing on the need for in-built measures.
The details of this policy are crucial. Government must take a long-term vision for our buildings and set carbon compliance standards at an appropriately high level. Abatement measures for remaining carbon must also take this long-term approach. Failure to do so will result in higher fuel bills for consumers and also a huge bill for the future Governments dealing with retrofit improvements to poorly functioning buildings.