Memorandum submitted by Ceres Power Ltd
INTRODUCTION TO
CERES POWER
Ceres Power is an AIM listed company developing
global mass market alternative energy products using its unique
fuel cell technology. The Company is based in Crawley, near Gatwick
Airport.
Fuel cells are solid state electrochemical devices
that quietly and efficiently convert chemical energy from fuel
directly into electricity and heat. Ceres is developing products
for a range of applications, including a residential combined
heat and power (`microCHP') system designed to supply electricity
and all of the central heating and hot water for the home, from
a single integrated wall-mountable unit. The unit is suitable
for both replacement and new build markets, and offers the potential
to substantially reduce both the home's carbon footprint and its
energy costs. In January 2008, Ceres announced a significant commercial
relationship with Centrica (the owner of British Gas, the largest
utility in the UK) to bring this product to market in the UK mainland.
Further information is available at www.cerespower.com
SUMMARY OF
RESPONSE
— The Government's 2010-13 targets
appear to be achievable, primarily via advanced insulation methods
to reduce the thermal load of the home, together with use of efficient
electrical appliances (ie. SEDBUK A rating) and a modest level
of renewable energy (eg solar thermal).
— However, compliance with the intended
2016 "zero carbon home" appears to need substantial
renewable energy (eg solar PV, biomass heating), with associated
problems of capital cost, fuel logistics and site applicability.
These problems are likely to severely limit mass market use.
— There are cost effective solutions
to reduce carbon emissions in new build, which would be precluded
by current low/zero carbon (LZC) definitions. We suggest that
regulations be made flexible enough to allow diverse solutions
achieving overall emissions reduction objectives, rather than
tightly cast and effectively prescribing a small number of expensive
renewable technologies.
— The definition of a "zero carbon
home" should be "net zero carbon" ie it should
be possible to:
— install low carbon heat / hot water
technology which reduces the carbon emitted to supply the heat
requirement for the building;
— use on-site micro-generation technology,
to displace centrally generated power which has a high embedded
carbon profile; and
— offset any remaining carbon emissions
via renewable generation, which can be on-site or directly connected
as per the Code for Sustainable Homes, since the actual amount
of carbon offset required is likely to be small.
— In addition, measures to assess effectiveness
(eg SAP) should be revised to correctly account for the impact
of emerging solutions (eg micro-CHP) for net zero carbon new build.
RESPONSES TO
QUESTIONS
Reducing carbon emissions from new homes
1. Is the target for all new homes to be
zero-carbon by 2016 on track to be achieved?
— The Government's 2010-13 targets
appear to be achievable, primarily via advanced insulation methods
to reduce the thermal load of the home, together with use of efficient
electrical appliances (ie. SEDBUK A rating) and a modest level
of renewable energy (eg solar thermal).
— 2016 "zero carbon home"
compliance currently appears to be achievable using renewable
sources (eg solar PV to provide power for lighting and appliances,
biomass for renewable heating). There are problems associated
with this approach:
— The high capital cost of solar PV,
making zero carbon very expensive to implement, in conflict with
mass market deployment.
— The availability of sufficient quantities
of biomass, and the embedded carbon and logistics of transporting
it to site.
2. Does the Government need to do any more
to deliver this target?
— Government needs to focus on the
high level objective of emissions reduction, and avoid drafting
regulations that effectively prescribe expensive and hard to implement
solutions.
— There are cost effective solutions
to reduce carbon emissions in new build, which would be precluded
by current definitions of the "zero carbon home". This
includes micro-CHP powered by conventional fuels such as natural
gas or LPG.
— Government should examine these definitions,
together with measures to assess their effectiveness (ie SAP)
in order to have a wider array of solutions suitable for mass
market new build deployment.
3. How should "zero-carbon" be
defined? What role should carbon offsets play in meeting this
target?
— The definition should be `net zero
carbon' ie it should be possible to:
— install low carbon heat / hot water
technology which reduces the carbon emitted to supply the heat
requirement for the building;
— use on-site micro-generation technology,
to displace centrally generated power which has a high embedded
carbon profile; and
— offset any remaining carbon emissions
via renewable generation, which can be on-site or directly connected
as per the Code for Sustainable Homes, since the actual amount
of carbon offset required is likely to be small.
4. What impact will the progressive tightening
of energy efficiency building regulations have up to 2016? Are
the targets for 2010 and 2013 achievable?
— Targets for 2010-13 look achievable
mainly by using cost effective building techniques, primarily
addressing the thermal load of the building.
— Having a "staircase" to
progressively tighten energy efficiency in new build appears sensible,
to encourage early emergence of solutions and provide a thermally
efficient construction approach, on which power efficiency measures
can then build.
5. How should compliance with the targets
be measured and enforced?
— Compliance at present is largely
demonstrated at design stage through SAP2005 calculations. There
are problems associated with SAP2005:
— it does not accurately reflect the
electricity footprint of the home (ie only power for lighting
and heating is included); and
— it does not accurately reflect the
impact of micro-CHP technology on the home (ie it assumes a heat-driven
technology such as stirling engine or organic rankin cycle, rather
than fuel cell technology which has a much lower heat-to-power
ratio).
— The performance of LZC products needs
to be accurately assessed via an agreed test protocol (eg PAS67).
This protocol needs to be constructed properly to take into account
the differences between micro-generation technologies.
6. What is the likely scale of environmental
impacts (especially carbon emissions) of the construction of three
million new homes (ie, irrespective of where they are sited)?
How should these impacts be reported? What should be the role
of central Government in minimising them?
— An average UK as-built home emits
5-6 tonnes CO2 per annum.
— Based on 5.6 million UK homes having
natural gas micro-CHP systems installed by 2020, the CO2 saved
would be equivalent to the emissions from eight (750 MW) new Combined
Cycle Gas Turbine power stations (Centrica estimate).
— Building regulations play a key role
in ensuring that the newly-built element of the building fleet
minimizes its emissions.
Code for Sustainable Homes
7. What impact is the Code for Sustainable
Homes likely to have on the construction and purchase of new homes?
How well is the mandatory rating likely to be enforced? Should
the Code be changed in any way?
— The Code for Sustainable Homes needs
to reflect LZC technologies via a `net zero carbon' methodology,
as described above.
Greenfield and green belt developments
8. To what extent do, and should, planning
controls protect greenfield and green belt land from development
of new housing? How adequately are environmental considerations
(for instance, biodiversity and rural landscapes) being taken
into account in deciding the location of new developments?
Infrastructure
9. What progress has the Government made,
in the two years since EAC's last report on this issue, in ensuring
that new developments are being built with adequate infrastructure
in order to make them successful and sustainable?
— Widespread residential CHP would
reduce the strain on the grid, providing better overall load balancing
and reducing the overall need for infrastructure investment. Recent
Ofgem reports support these findings.
25 April 2008
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