carbon limited

In case you don’t fancy wading through it, this is a brief summary of the zero carbon consultation doc. While nothing will be finalised until next summer (after they’ve ruminated over the responses), the document does give some insight into the way CLG is leaning on some issues.

At the core of the document is the government’s preferred framework for reaching zero carbon. In order of priority:

1. A minimum standard of energy efficiency will be required.
2. A minimum carbon reduction should be achieved through a combination of energy efficiency, onsite low and zero carbon (LZC) technologies, and directly connected heat. This is referred to as achieving carbon compliance.
3. Any remaining emissions should be dealt with using allowable solutions, including offsite energy.

It’s not clear what standard of energy efficiency will be required, although they appear to be leaning toward EST’s “advanced practice” standard, based on Passiv Haus. This is a big point of contention as it will almost certainly force all new homes to have MVHR. This would be very bad on several levels and I’ll come back to this point in a future post.

The required emissions reduction to achieve carbon compliance is also open for discussion. As a minimum, it will be 44% because the building regs will already require this reduction from 2013. As an upper limit, it looks like there’s no longer any possibility that carbon compliance could be set to include all emissions (i.e. regulated emissions plus cooking and appliances). Following the UKGBC report and further cost study by CLG, this has gone out the window. So the maximum reduction required will be 100% of regulated emissions. The consultation hints that a 70% emissions reduction might be a nice compromise.

Once homes have achieved carbon compliance, they will be required to address all remaining emissions through allowable solutions. I get the feeling we’ll be hearing the phrase allowable solutions a lot from now on.  The list of possible solutions includes:

• energy efficient appliances
• low carbon heat or cooling exported from the development – why do they suggest that exported electricity would count towards carbon compliance while exported heat would only be an allowable solution?
• a credit for section 106 payments made toward LZC energy infrastructure (e.g. heat networks)
• retrofitting of nearby existing stock
• investment into LZC technology anywhere in the UK or UK waters
• payments under the Community Infrastructure Levy
• any other measures the government decides to add in future. Although they say they’re not minded to establish a buyout fund a la the UKGBC report, they’re obviously keeping their options open here.

CLG are treading a very fine line as regards the setting of the carbon compliance level and the list of allowable solutions. While they may be faced with a meltdown in the housebuilding sector, they’re unable to back away from the zero carbon target, especially now that the Climate Bill has been passed. So they’ve stuck in a getout clause in the form of “capped cost”. This is effectively a maximum cost per tonne of CO2 that developers would have to pay to achieve zero carbon once they’d reached carbon compliance through efficiency and onsite measures.

In 2012, CLG plan to review the state of the industry and the available technology to see if we’re on track to hit zero carbon from 2016. If it looks like industry is not going to deliver, the Government may add to the list of allowable solutions (read: buyout fund).

So that’s the gist in a nutshell. There are many interesting bits and pieces in the document as well. Here are a few:

• It looks like the zero carbon definition could be divorced from Code level 6. I think in practice we’ll see Code 6 brought into line after the consultation but it’s interesting that they’re being kept separate for now.
• There’s some clarification over the issue of private wire, with CLG moving away from the requirement for a direct connection between LZC technology and individual homes. This is great news. However there’s still a lot of confusion over what exactly “on site” energy is and how it’s dealt with. CLG seem to think SAP already does an adequate job of dealing with on site energy when actually it doesn’t. More on that later.
• Part L and SAP consultations will be out early in 2009. Thank goodness! Revising SAP, which is currently riddled with quirks and loopholes, is an essential next step.