Friday, November 28, 2014

Exemptions from zero carbon homes consultation

This is the link for the current consultation on exemptions from the commitment to zero carbon homes by 2016 (already not strictly zero carbon)

Please look at it and reply to DCLG by 7 January 2015.   My thoughts are as set out below. It is not the proposed exemption that will make the difference but the repeated signal that the Government does not " get it" when it comes to carbon reductions.  The main point is the false dichotomy set up to excuse the inadequate attempts at carbon reductions as, to take effective action, might threaten economic growth.  In fact it is not paying for carbon reductions which might undermine GDP but a low carbon economy, if it were ever achieved, is likely to be one where growth in GDP would not be discernible.  There might well be growth in all sorts of more worthwhile ways.  Anyway I am sure that the DCLG would welcome more reaction to its consultation.


This consultation is fundamentally about carbon emissions but lacks the understanding necessary to produce a coherent and effective policy.  Two basic elements are missing from the analysis:

1.   The building sector (including residential development) is possibly the only and definitely the easiest sector within which to achieve early reductions consistent with the statutory (ie 80%) cuts in carbon emissions required by 2050.  In fact residential development has the potential for 100% + carbon emission cuts – “carbon negative” or “solar positive”.  This will be essential to meet the overall targets as there is no workable plan for agriculture, industry, power generation, and transport (including aviation and shipping) to meet the necessary  80% savings.
2.   It is not the level of carbon emissions in 2050 that will matter. What are required are substantial reductions as early as possible. The 6% annual reductions that might be sufficient if achieved now, will very soon reach 10% (already the minimum necessary according to the Tyndall Institute).  Whilst with existing technology and knowhow, housing has the potential to reduce its contribution to carbon emissions, even this is proving to be very challenging particularly in respect of the 22million  existing homes.  This emphasises the need not to add to the burden and to move towards carbon negative building to make up for the challenges in other sectors and the problems with the Green Deal and the massive stock of solid wall houses.
3.   Paras 8 and 25 set up a false dichotomy between economic growth and reducing carbon.  There will be no recognisable economy in a Country with more than 2 degrees of planetry warming.  In other words economic growth has to be defined and, if necessary, adjusted, to be compatible with carbon reductions known to be necessary to limit warming 2 degrees (350 to 400 ppm).

Very little weight should be given to responses received to the 6 questions in this consultation that are not based on the premises that the housing sector must make a disproportionate contribution to carbon emissions particularly in the immediate future during which other sectors are needing to research, innovate and develop.  The only evidence that that zero carbon housing would not be compatible with the Climate Change Act is that even higher standards might be required – without delay.

Question 1 should the exemption be targeted at site size, developer size, or a combination of both? Is there any evidence to support the choice made?  The consultation makes a compelling case for having no exemptions by describing the various traps and false and perverse incentives which arise when thresholds are created.  The occupiers of the house will not know that their heating bill is higher because of the number of builders employed in its construction or the number or size of dwellings on the site.  Passivhaus developments are often relatively small and the extra cost (est 12% as the industry matures) is recovered in 7 years.

Question 2 – if the Government chose a site size exemption, what level should this be set and why?  There is no ‘carbon reduction’ argument or justification for any exemption.  The Government would like to see more small builders and sees building standards as a brake on their growth.  If exemptions succeed in the growth of this sector then an increasing and  substantial number of sub-standard dwellings would be built – all adding to a burden that will have to made good.  As there should be no pretence that any of these houses will actually be upgraded, where will this locked-in deficit be recovered by 2050 and beyond?

There are many good planning reasons for large sites to be developed in phases (CIL has already caused this – a positive but unintended incentive) and areas reserved for self/group – builders or finishers. Similar reservations could be made for relatively small builders. Thresholds in the proposed regulations would complicate and interfere with these desirable trends.

Question 3 – if the Government chose a developer size exemption, what criteria should it apply and why?

Same as above –exemptions from zero carbon (or carbon negative) in the housing sector, will never be made good.

Question 4 – What do you think the scope of the exemption should cover? An exemption for the allowable solutions scheme only, or an additional exemption from Building Regulations requirements? Do you have any evidence to support the choice between these options?

It may be that,  “29.The Government’s preferred approach is to exempt small sites from the allowable solutions component only.” and it is essential that at least the new houses are all built to zero carbon.  However, even If it is only the allowable solutions that are relaxed then there must be a programme for how this deficit is made good without delay.   As allowable solutions should be concentrated on reducing carbon from housing (eg building materials, associated infrastructure and electricity/heat) any exemptions will make it impossible for the housing sector to achieve the necessary quick and deep carbon emission reductions.

Question 5 – What are your views on the proposed review period for the exemption? All regulations can be reviewed.  There would be no obvious positive or perverse incentives for the industry to reduce emissions faster and deeper if a review period was set up at the outset. If no exemptions should be made in the first place the industry will quickly adapt – it is the large scale developers that are least adaptable and agile.

Question 6(?) – Do you have any further evidence that would help inform the impact assessment?

It is essential to remember that the purpose of zero carbon housing is to incentivise faster and deeper reductions in carbon emissions from the building and occupation of housing.  There is no reason why the industry would not adapt to a positive, coherent and lasting regulatory regime. There is no time in the house-building sector for the prevarication implied by this consultation.  Exemptions will create unintended and possibly perverse incentives that would detract from the industry’s job of delivering new housing that would not add to the problem of carbon reductions in this sector and across the board.

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