This is the link for the current consultation on exemptions from the commitment to zero carbon homes by 2016 (already not strictly zero carbon)
https://www.gov.uk/government/consultations/next-steps-to-zero-carbon-homes-small-sites-exemption
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.
Consultation
Introduction
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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