I have just received a response to my request to see the officer advice to ministers behind the decision by the Chancellor and Business Secretary to remove the Zero Carbon Homes (and Allowable Solutions) target found in their publication "Fixing the Foundations". I was referred to two well reasoned reports on Allowable Solutions in which I could find no justification for abandoning the ZCH target and a suggestion that the position will be reviewed by 2021 when a recent small upgrading of the building regulations had bedded in.
This is my letter in response (copied to my MP.
"Dear Mr Hayward
Thank you for your letter in response to my attempt to understand the removal of the Zero Carbon Homes (and Allowable Solutions) by the Chancellor and Business Secretary (I remain unclear what part Mr Clark played in this).
My first reaction is that the two reports on Allowable Solutions have been extremely well argued and presented but do nothing to support the case for lowering of the energy efficiency of new build houses. Quite the opposite.
You then deny me the opportunity to see the advice on which the overarching ministerial advice was based (I assume this to be the Chancellor).
I then have a list of other reasons why this downgrading is so unfortunate without being able to understand if these are point already taken into account.
1.We know from DECC that the UK is seriously below its carbon reduction commitments.
2.We know that agriculture, transport, and manufacturing (inc imports)have next to no chance of contributing to the required carbon reduction targets. Power generation could have done were it not for the Government's recent attack on renewables. That leaves new buildings that could very easily have moved to carbon negative.
3. The collapse of the Green Deal will leave 80% of the housing stock at the equivalent of EPC D for the foreseeable future.
4.The removal of ZCH and AS will add over a million dwellings by 2021 requiring expensive retrofits to add to the 25million existing.
5.The building industry did not seem best pleased as the 'goal posts' were moved once again but with a suggestion that this might be temporary. How can they know the price of building land if the implied costs keep changing?
6. Community energy schemes that could have represented 'allowable solutions' are collapsing around the country.
7.One of the most frequently asked questions about new building is why 'the planners' allow new buildings without PV?
8. There is still the 'presumption in favour of sustainable development' in the NPPF. Mr Clark says that the main purpose of the planning system is to achieve sustainable development (as is s39(2) of the 2004 Act) which should not disadvantage future generations. How can they seek to require developments to 'consume their own smoke' in accordance with the Community's Secretaries wishes and their statutory duty whilst being undermined by the Chancellor?
In summary, the refusal to provide the official advice to ministers leaves me with the impression that the retreat on energy efficiency standards has been made for ideological and short term economic reasons in the face of carbon reduction targets and the interests of industry."