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February 17, 2010

Zero carbon: policy options for non-domestic buildings

Responses to the December 2008 consultation Definition of Zero Carbon Homes and Non-Domestic Buildings, according to the Department for Communities & Local Government (CLG), ‘recognised the case for regulation'. In the current consultation on zero carbon policy options, closing on 26th February, it stresses: ‘In the light of current economic conditions, it is also important to consider the costs and potential consequences of such regulation on economic recovery for the construction sector and balance these with the benefits of early certainty around a route-map for future regulatory steps.'

The current consultation on policy sets out proposals for working towards the Government's ambition that all new non-domestic buildings should be zero carbon from 2019, with the public sector leading the way from 2018. This follows on from the consultation on Zero carbon for new domestic buildings and many of the proposals are similar in nature.

According to TRADA Membership & Marketing Manager Rupert Scott, ‘The truth is that very few buildings will be truly zero carbon, because it is not cost justifiable. The Government, however, is reluctant to let go of the "zero carbon" aspiration and is trying to define the rules such that you don't have to achieve utopia to carry the "zero carbon" label.'

One of the key questions is what energy use should be included within the scope of achieving ‘zero carbon' in a practical way.  For domestic it is all currently regulated energy use (broadly heating, cooling, cooking, overhead lighting) plus unregulated use (broadly electricity for appliances).  For non-domestic, non-regulated use varies far more considerably.  The suggestion is current regulated use plus 10% or 20%, to cover uses such as lifts, automatic doors etc.  In other words quite a bit less ambitious than domestic.

The same three-layered triangular hierarchy agreed for domestic is suggested:

  • Set minimum energy efficient fabric standards
  • Set minimum carbon compliance (effectively some on-site energy/heat generation unless the fabric standards are extremely high)
  • Include ‘allowable solutions' - to make up any shortfall.

In other words, said Mr Scott, ‘all buildings will need to meet a minimum level which is not too utopian and the balance will be made up with the "allowable solution" fee/cost'.

In the case of domestic buildings it has been decided that the minimum backstop heating and cooling performance from the fabric is 46kWh/m2/yr for detached dwellings and 39kWh/m2/yr for all other dwelling types, which roughly equates to a 20-25% reduction on a current (2006) compliant gas heated home.  The minimum backstop CO2 reduction for the fabric plus on-site renewable energy equipment is 70% reduction on current permitted design levels. 

TRADA believes that setting the fabric targets in standard physical units (ie kWh/m2/yr) is ‘a very positive step forward. Minimum standards of this nature need to be set for different non-domestic building types, as cost studies have shown that there is a wide variation in the percentage cost increase for upgrading different building types by the same efficiency saving,' Mr Scott stressed.

‘Allowable solutions' are actions that the industry would be permitted to do to make up the shortfall of achieving zero.  ‘Clearly these will not be needed where the buildings achieve the full zero requirement by design. Views are sought on various ideas. It seems that the main issue for developers is what benefits, if any, they or their client might get from each option. If investing in wind farms is one allowable solution and the developer or client keeps the share options, this is obviously going to be better than simply paying for some nearby housing to be upgraded with no prospect of owning a share of the property.'

And he warned, ‘The rules are likely to be far from perfect, and will fall short of what the average man in the street might understand by the term ‘zero carbon', but if we at least have a working definition, this will be a positive step forward, providing the "allowable solution" regime is not financially unreasonable for the developer/client. This is the key issue to watch as the process rolls on.'

To view the consultation click here

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