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.”