Memorandum submitted by the Electric Heating
and Ventilation Association (CCB 03)
INTRODUCTION
The Electric Heating and Ventilation Association
(TEHVA) welcomes the opportunity to submit evidence to the Environment,
Food and Rural Affairs Committee inquiry into the Draft Climate
Change Bill. TEHVA is the trade association with responsibility
for promoting electric heating, hot water and mechanical ventilation
products and systems, and was launched in 2004 in recognition
of the wide consumer and political demands to reduce energy consumption
and associated carbon emissions.
This submission focuses specifically on question
18 of the Committee's inquiry which asks whether there are other
domestic climate change issues which it would be appropriate to
include in the Draft Bill.
The way we heat our homes and buildings in future
will have to change due to the increased pressure to reduce carbon
emissions and the need to reduce energy costs. Modern electric
heating and hot water products are positive steps in this direction.
TEHVA believes there is a clear need for government defined carbon
milestones to be included in the Draft Bill, in order to effectively
forecast the carbon intensity of grid electricity which will in
turn aid planners and housebuilders to design long-term low/zero
carbon housing. We believe that over the long-term these milestones
would demonstrate that electric heating (using de-carbonised grid
electricity) will reduce the carbon footprint of a business or
domestic dwelling more effectively than other energy sources.
This would for example enable zero carbon houses, a key tool in
tackling Climate Change, to become a reality.
LOW CARBON
MILESTONES
The Electric Heating & Ventilation Association
(TEHVA) believes there is a key policy gap in recent Government
announcements on zero carbon housing that will significantly reduce
their impact and therefore the extent to which we can address
climate change. Our concern is that none of the announcements
include any consideration of the lifetime carbon footprint of
a dwelling based on the projected carbon content of grid electricity.
The key point to note is that over a 50 year period the carbon
impact of electricity will be less than that for gas and other
energy sources, therefore making, in the long term, electricity
a more favourable low carbon energy source. A fact that has so
far not been fully acknowledged and appreciated by government.
It is quite clear that carbon trajectories will not be valid or
a useful planning aid unless forward grid electricity carbon content
levels are known.
As members of the EFRA Select Committee will
be aware, electricity is the only central energy source that can
be de-carbonised. Grid electricity must be de-carbonised in order
for government to reach its carbon reduction targets of 60% by
2050. This is given some credence by renewed government interest
in new nuclear plant and a push for wide scale take up of carbon
capture and storage technology. Projected figures suggest that
the carbon content of grid electricity will be less than half
the 2007 content by 2020 ie moving from 0.43kg CO2/kWh to 0.20kg
CO2/kWh (nearly at parity with gas which is a constant 0.19kg
CO2/kWh). Without a set of forward thinking carbon milestones—say
to 2050—it is impossible to plan carbon trends or to consider
what the true lifetime carbon mitigation programme for energy
sources should be.
PRACTICAL EXAMPLE—NEW
BUILD HOUSING
Consider a notional yet conceivable scenario
and compare the CO2 that can be emitted from a dwelling
over a 60 year lifetime to that using 2007 figures.
Table 1
NOTIONAL DWELLING CONSUMPTION AND CARBON
FIGURES
|
| | 2007—11
| 2012—16 |
2017—21 | 2022—26
|
|
| CO2/kWh Elec | 0.43 kg
| 0.30 kg | 0.25 kg
| 0.20 kg |
| CO2/kWh Gas | 0.19 kg
| 0.19 kg | 0.19 kg
| 0.19 kg |
| Total kWh p/ann | 10,000
| 10,000 | 10,000
| 10,000 |
| Elec kWh p/ann | 4,000
| 4,000 | 4,000
| 4,000 |
| Gas kWh p/ann | 6,000
| 6,000 | 6,000
| 6,000 |
| Elec CO2 p/ann | 1,720 kg
| 1,200 kg | 1,000 kg
| 800 kg |
| Gas CO2 p/ann | 1,140 kg
| 1,140 kg | 1,140 kg
| 1,140 kg |
| Elec CO2 5 years | 8,600 kg
| 6,000 kg | 5,000 kg
| 4,000 kg |
| Gas CO2 5 years | 5,700 kg
| 5,700 kg | 5,700 kg
| 5,700 kg |
|
Assuming the CO2 for electricity stabilises at
0.20kg post 2020, the lifetime 60-year electricity CO2
emissions for the dwelling would be 55,600 kg CO2 or
an average of 927kg CO2 per annum. This is compared
with a 60-year lifetime of 103,200 kg CO2 or an average
of 1,720 kg CO2 per annum based on 2007 figures. This
clearly demonstrates the better carbon impact of electricity within
20 years.
The challenge for the housebuilder is to specify building
services and de-centralised energy systems that can mitigate the
annual average CO2 over the lifetime. With low electricity
CO2, the housebuilder may decide to pursue a strategy of heat
pumps (turning each kWh or electricity into 3 or 4 kWh of useful
heating and hot water service) or electric heating and hot water
systems with mitigation from local electricity generation sized
according to the average needs.
This puts the focus firmly on carbon and gives strategic
flexibility to house builders in design. It also pushes the housebuilder
towards utilising sustainable energy sources either locally or
centrally to tackle the CO2 challenge and not necessarily
rely on gas, which could well be a high priced energy option linked
to secure supply problems into the future.
HOW CARBON
MILESTONES CAN
WORK IN
PRACTICE
At the building regulations application stage, a housebuilder
will complete a Target and Design Emission Rating calculation
using the government Standard Assessment Procedure (SAP). The
calculation considers the heat loss parameters of a dwelling and
the overall energy consumption and carbon footprint based on real
time figures (in fact they are three year averages for energy
prices and carbon figures). The results are however determined
by carbon today rather than lifetime averages.
A practical method of using carbon milestones is to add a
feature that enables the housebuilder to calculate a five year
period carbon emission figure using data from a set of published
carbon milestones/projections. The carbon milestones could be
built into the software and adjusted forwards every five years
in line with the 5 year periodicity of changing SAP, determined
and managed by DEFRA.
The planning application would then include a 60-year lifetime
carbon projection and SAP could then calculate whether the overall
target will be met by the lifetime design characteristics specified.
This simple policy step would bring housing and energy strategies
close together for the first time and will really enable a more
flexible and cost effective opportunity for housebuilders and
builder service equipment suppliers to meet the challenge (ie
the right services, for the whole lifetime using the right energy
to provide a zero carbon footprint).
CONCLUSION
TEHVA's submission focuses specifically on further elements
the Draft Climate Change Bill should consider, mentioned in question
18 of the consultation document. As highlighted above, the Association
believes there is a key policy gap in the climate change arena
that the Draft Climate Change Bill could address.
TEHVA would like to see the Government recognize the long
term carbon reducing advantages of electricity over other energy
sources and to publish a set of forward-thinking milestones—say
to 2050—to demonstrate this and enable carbon trends to
be planned. This can then give energy use planners, house builders
for example, the opportunity of considering what the true lifetime
carbon mitigation programme for a new build dwelling should be.
At its most basic, this may mean that they will consider the use
of electric heating over other energy sources as in the long term,
electric heating is going to be more carbon efficient. This would
enable zero carbon houses to become a reality and bolster our
ability to tackle climate change.
TEHVA
April 2007
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