Allowable solutions – who are they trying to kid?

This is by way of an open letter to DCLG – which I sent as a covering letter to my response to (questions 1&2 of) the allowable solutions consultation – see previous blog

“I believe the whole idea of (1) “zero carbon” and (2) defining this or any standard not by how well the subject of the standard performs, but how many other people can be bribed to perform well on its behalf, is dreadfully misguided.

If you want to reduce the carbon emissions from new homes, then reduce the carbon emissions from new homes. Don’t reduce them some of the way to your target, then faff around erecting huge, complicated structures to reduce emissions from sectors other than new homes, and then pretend to yourselves and the world that somehow the new homes are low or “zero” carbon. Manifestly, they are not. What a colossal waste of effort!

If it isn’t possible, practicable, or affordable to make a new home zero carbon on-site (and it almost certainly isn’t) then for heavens’ sake don’t carry on pretending to yourselves or anyone else that it is. As you have found, the pretence requires a positively rococo structure of pretend emissions savings – your “allowable solutions” —  cumbersome, inconsistent, full of internal contradictions, and beset with potential loopholes.

And worse, what a colossal diversion of yours and the industry’s precious time and energy. All this effort going into refining the way you will trick out this delusion with regulations, price caps, verification procedures etc etc, when:

a)     the net impact on carbon emissions overall will be minimal (how can you ever know an action is truly additional, especially if people are competing for the cheapest actions – which, naturally, would be the ones most likely to happen anyway), and;

b)     you are incurring a huge opportunity cost in terms of effort, time, expense, and individual and corporate head-space – meaning the impact on emissions from new homes will probably be to INCREASE them relative to what they could have been, had you and your predecessors focused on reducing home energy in the first place.

Although mass housebuilders are notoriously uninterested in producing a high-quality product, seeing as they can sell what they produce anyway, given the housing shortage prevailing in this country,  some landlords/developers are now starting to take an interest in delivering really high quality homes. A significant number in the ‘affordable’ and social rented sectors, and now some building speculatively for the private market, are building or actively planning to build to the Passivhaus standard (the low energy standard I happen to know about). They are opting to build to truly low energy standards not because of any leadership from DCLG, but because they think it’s a good idea for users/purchasers, and it is possible to make it stack up financially, especially after the first one or two builds have been completed.

They don’t have any special trick, other than the right attitude. If they can make it work financially, then so can the big housebuilders. Perhaps the big housebuilders don’t want to change their ways, perhaps because their business model is based on shoddy workmanship. But the Zero Carbon Hub has told us this has to change anyway, to reduce the performance gap.

If the big firms adopted very low energy design, the marginal cost would fall considerably, as components would drop in price. And of course if all housebuilders were under the same obligation, then there would be no competitive disadvantage. (Your impact assessment cites a theoretical disadvantage versus older homes, but your own research suggest this is a diminishing effect, given that old homes are cold and/or expensive to run until they have had money spent on them, and I mean proper money, not just a Green Deal’s worth.)

I’m not saying this could happen overnight – it would of course take some time to build the expertise. But in what way is this not a desirable goal? How would using less energy not be more desirable than simply wasting energy (by building worse buildings than you could do), and getting someone else to produce some more low-carbon energy somewhere else – or getting them to save some energy that they should be saving anyway?

Given that ultra low energy homes (and buildings of all kinds) are desirable, feasible, affordable and indeed necessary, there isn’t any excuse for not starting out now on a clear path to bring all new homes to a proper truly low energy standard, delivered via the fabric, so it’s built in.  Zero Carbon and allowable solutions are by contrast an unforgiveable diversion up a blind alley.”

The Green Deal and the ECO

This article, originally pubished in Green Building Magazine (Spring 2013) is the second part of my look at the Green Deal, and considers whether and how the Energy Company Obligations (ECOs) might work, and whether and how individual contractors and householders might be able to take advantage of them to help install solid wall insulation, in particular.

I concluded that it was quite unlikely that most private SWI intallations (outside of some defined areas/categories of deprivation) would qualify for 100% funding, because the energy companies will be chasing the cheapest “carbon points” as calculated in SAP – but useful grants might be available for households who were keen enough to fund the difference themselves. It was also not yet clear how smaller and independent contractors might secure ECO funding for their customers, and thus, work for themselves – however, various avenues look possible.

In short, the ECOs should offer some help to some people, but are far from bridging the yawning gap between what the Green Deal can achieve (rather little, see previous article on the Green Deal) and the 80-odd-% cut in energy consumption/emissions that we desperately need to achieve. I suggest that as energy efficiency benefits building occupants, public services (notably health & education), the benefits bill, energy security and the cost of energy, and the balance of payments,  then perhaps all these benefiting entities and sectors should be contributing in a co-ordinated way.

View/download The Green Deal and the ECO (pdf – version without illustrations)

And here you can download a pdf of Green Deal and the ECO as it appeared in the magazine, complete with illustrations.

Institute for European Environmental Policy report challenges “misleading” biomass GHG accounting

The Institute for European Environmental Policy (IEEP) has reviewed current thinking about the life cycle analysis conventions for bioenergy (and woody biomass in particular) and found that the routinely used metrics are “increasingly recognised as flawed”.  “This applies particularly to commonly used approaches to life cycle analysis that presume carbon neutrality of the bioenergy feedstock,” the Institute says.

Without a better system for evaluating the greenhouse gas impacts of our policies, they conclude, we cannot know if (or when) our bioenergy use might actually cut greenhouse gas emissions.

The review, The GHG Emissions Intensity of Bioenergy (56pp pdf) was published in October 2012.

The authors reviewed a wide range of recent papers on the subject of the greenhouse gas balance of biomass burning, and found that far from being generally accepted that bioenergy is ‘carbon neutral’ there was now “a general appreciation that increasing the intensity of forestry management and increasing biomass extraction rates over time will lead to a carbon deficit.”

“This then needs to be ‘repaid’ before the exploitation of bioenergy from such resources can deliver emission savings compared to burning fossil fuels,” they say. For example, a paper published in 2011 by McKechnie and colleagues calculated that even over 100 years, and even eschewing whole trees and only burning residues, biomass energy only delivered 73 per cent of the savings anticipated in conventional assumptions (as used by the EU and UK government).

According to this and many other analyses, if whole trees are burned, if a different (lower carbon) energy source is displaced, or if the focus is on a shorter timescale, these presumed savings are eroded still further, and may indeed be eliminated, IEEP warn. (The McKechnie paper was cited by the UK Committee on Climate Change in its 2011 Bioenergy Review.)

IEEP warn that to begin with, when biomass is burned “there is an excess of GHG emissions from the burning of a source of bioenergy over that from the fossil fuel reference energy source.” They also point out that the eventual savings are usually predicated on the source of the biomass being left to return to its pre-harvest state, whereas “in reality, successive episodes of bioenery exploitation may well occur, and keep creating a GHG emission debt.” In other words, we’re not talking about a discrete bioenergy harvesting event, but a new mode of intensified extraction, to feed a new industry.

The report also echoes the concern highlighted in the report for DECC by Forest Research and North Energy Associates (Carbon impacts of using bioenergy in energy and other sectors: forests) that burning biomass might not be the best way to use it to reduce carbon emissions, if that same biomass is being diverted from manufacturing, which then turns to higher-carbon substitutes such as steel, concrete or plastic.

IEEP conclude that we urgently need new ways to evaluate the best way to use land and biomass products to reduce carbon emissions – that have a stonger basis in the evidence. “Utilisation for energy represents only one potential use of diverse biomass materials within society … in a variety of situations other uses will be prefereable purely in terms of climate impact … irrespective of other considerations.”

“Policies based on misleading LCAs need to be revisited and revised as appropriate,” and “the evidence base for making informed decisions about bioenergy in relation to climate change needs to be strengthened considerably as a matter of urgency.”

They end: “It is not currently possible to define the emissions profile and savings associated with Europe’s expanding use of biomass for energy, nor is there any policy process currently in place to secure this. As a consequence, at present there is only the certainty of commitment to bioenergy use up to 2020, but no associated guarantee of emission reduction.”