The "Housing Standards
Review" is set to eliminate a crucially important driver for renewable
energy uptake in the UK and the way the government has gone about it is an
absolute disgrace.
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| Solar panels on new homes - soon to be a thing of the past? |
In a recently launched consultation, the Department for Communities and Local
Government (DCLG) has revealed its intention to halt a practice where local authorities can require property developers to build to an energy efficiency standard higher
than the current building regulations or insist on renewable energy (the
so-called Merton Rule).
The background to
the Housing Standards Review is that there has been a proliferation of
overlapping (and sometimes conflicting) technical standards created in recent years, and local authorities are imposing a variety of these on developers, creating an unnecessary regulatory burden.
DCLG convened a
series of working groups covering eight thematic areas, one of which was energy. The Energy Working Group concluded that the
government should scrap rules that allow local decisions on the energy
efficiency of new construction and rely solely on the national Building
Regulations to drive future improvements in new build housing.
The justification
for this change is that the Building Regulations are ‘moving towards Zero
Carbon Homes’ by 2016 so there’s no need to have these alternative requirements
– you can’t get better than zero carbon, right?
While this
argument is superficially persuasive, as
soon as you scratch the surface you quickly find otherwise – let's take a look at what’s been happening at DCLG since the ‘Greenest Government Ever’ came into power:
- New Social housing was intended to be at zero carbon by 2013, paving the way for the commercial developers to follow. This was scrapped and social housing is now built to the same energy performance as commercial housing.
- The definition of a ‘Zero Carbon Home’ has been diluted so that electricity use from plug-in appliances is misleadingly not included, making it more like ‘30% Carbon Home’
- The 2013 building regulations are late and will not be implemented until well into 2014, allowing at least 100,000 homes to be built to a lower energy efficiency.
- These new regulations represent only a tiny (6%) improvement on the previous ones for energy efficiency, when a 50% improvement was required to have any realistic chance of delivering 30% Carbon Homes by 2016.
- The ‘Allowable Solutions’ consultation may allow developers to pay a tax instead of building genuinely low energy properties.
(See my earlier blog on progress towards Zero Carbon Homes here)
If you had a
suspicious mind, you might suspect that DCLG held back on the spectacularly
unambitious 2013 building regulations to allow the Housing Standards Review to
reach its conclusions based on a belief in government intentions to
actually deliver Zero Carbon Homes in 2016, a belief that would have been
difficult to continue to hold once the 2013 regulations were revealed.
If you were also of
a cynical disposition, you might predict that DCLG is going to announce that it
will put back Zero Carbon Homes to 2019 (just keeping within the 2020 deadline
in the EU Energy Performance of Buildings Directive), but only after leaving the 2016 target in place long
enough to use it to justify killing off local rules for higher energy
performance and renewable energy.
Houses are not
built to new regulations immediately; it takes many years until granted
planning permissions turn into completed homes.
If Zero Carbon Homes is delayed until 2019, it will be 2022 before large
numbers of homes are built to this level of performance. DCLG will have created a ‘Lost Decade’ and a
million homes built with unnecessarily low energy efficiency.
Economics not your Strongest Suit?
The ‘Impact
Assessment’ for the changes proposed in the consultation claims a net benefit
to the economy of more than £0.5bn. It
is claimed that £93m would be saved over the next 10 years by abolishing the
Code for Sustainable Homes and £195m from abolishing local targets for renewable
energy.
So that’s around
£30m a year.
To put this saving in context, have a look a the turnover and profit of just the top three commercial housebuilders in the UK:
The Impact
Assessment claims that this £30m/year is the ‘net benefit to business’, but what it
actually presents is the net benefit to property developers, who no longer have to
pay for environmental technologies or renewable energy.
An Impact Assessment
should assess the benefit to the economy,
not one favoured sector.
The businesses
that would have supplied environmental technologies to help these new homes
outperform the Building Regulations will be adversely affected, but the Impact
Assessment takes no account of this. Nor
does it attempt to estimate the cost of improving these low efficiency homes
later on.
The Impact
Assessment in support of the proposal is flawed and should be repeated taking into account the net effect of the changes on the whole economy.
Not Helping Anyone…. Except Rich Landowners
If building
regulations are clearly signalled in advance and consistently applied, then
developers can decide how much to pay for land with certainty about their build
costs. So the only thing
building to a higher environmental standard will do is slightly reduce the
massive windfall that landowners get when they convince a local authority to
allow them to sell to property developers.
Conversely, if
building costs are reduced then developers, in a competitive market for building
plots, will bid up the value of land to a point where their profit margins are
maintained.
Surely this isn’t
the government’s intention? To hamper
the development of a clean energy industry and land the country with extra
costs for upgrading homes that could have been built to a higher standard of
energy efficiency – all so that a few rich landowners get a bit richer. Not this government, surely?
Whatever Joined up Government Looks Like, it Ain't This
At the same time
that DCLG is busy paving the way for a million low-efficiency homes, another government
department has to shell out taxpayers’ hard-earned money to financially support
people in improving the energy efficiency of existing homes.
The Department of
Energy and Climate Change (DECC) is spending your money trying to convince
people to upgrade the energy performance of their homes.
And boy is it
hard work.
It is simply much
easier and cheaper to install energy efficiency into a new home as it’s built rather
than doing it later once someone is living in it. It’s ‘common sense’ isn’t it? It’s so much simpler to do it properly the
first time than have to come back and do it all again later.
Compare the cost
of putting thicker insulation into the wall as its built with the cost of
fixing more insulation to the outside of a building, rendering it, and
re-setting all the windows.
Or the hassle of
getting a rig into your garden to drill a bore hole for a ground source heat
pump – knocking down walls, tearing up your beautiful lawn – compared to doing
it when it’s already a building site.
Or the cost of
replacing all your radiators, - suitable for a gas boiler, but not big enough
for an air source heat pump - compared to installing suitable ones in the first
place.
Consider the cost
savings from installing solar panels in the roof at the same time as the
scaffolding is there for the roofers to tile the roof.
You get the idea.
DECCs incentives
such as the Feed in Tariff, Renewable Heat Incentive, and Green Deal need to be set at an even higher level than simply supporting the extra costs to overcome
people’s aversion to turning their house upside down to do the improvements. (So called barrier costs).
The lack of
progress in driving up standards in new homes is going to cost the country more
in the long run.
How to Fix This
A situation where
each and every local authority makes up its own environmental targets is an
unnecessary burden on developers. In my own business, we’ve helped many house builders discharge local authority renewable energy requirements in all parts of the country, and while they are all similar they are also all ever-so slightly different. There is definitely a case for
simplification.
However, the
Building Regulations are not providing a pace of improvement that is
sufficient. Nor is the Zero Carbon Homes
‘end point’ adequate – the definition is too weak and proposals to allow property developers to ‘buy’ their way to Zero Carbon will
result in homes that are little improved over today's.
The Building Regulations are not some 'gold standard' for energy efficiency that it is impossible to improve upon, they are nothing more than a minimum standard, a lowest common denominator. Local authorities
should be encouraged to exceed this minimum standard where is is viable, and the assessment of viability
should be a local decision in keeping with the DCLG's own Localism Act.
The route to
simplification is not for central government to impose a one-size fits all,
lowest common denominator standard, but instead to provide a limited menu from
which local people can choose. Fortunately the hard work has already been done because this is a description of the system in Scotland. Here the building regulations have a special section with a limited number of alternatives to the minimum standard (Bronze) so providing local choice and simplification of regulatory burden for developers at the same time.
See my earlier
blog on what we can learn from sustainable construction in Scotland here.
Why not adopt or adapt this sensible Scottish idea for the rest of the UK?
