Memorandum submitted by Energy Saving
Trust
The Energy Saving Trust was established in 1993
to reduce carbon emissions from the domestic sector. We run a
range of support programmes to this end, with the aim of transforming
markets for sustainable energy. You will see that the Energy Saving
Trust's key points are:
— There is a need to adopt a scientific
approach, including a comprehensive energy monitoring programme,
ongoing evaluation of liveability, and widespread dissemination
of the results to inform future projects.
— There is a need to engage the public
early on, in order to ensure that low and zero-carbon homes can
be sold, and are subsequently used appropriately.
EXECUTIVE SUMMARY
The Trust's mission is to reduce carbon emissions
from the domestic sector, and this is the focus of our submission.
The Energy Saving Trust is fully behind the
zero-carbon target. As well as delivering much needed carbon savings
from an expanding housing sector, we believe it will impact on
the development of products and methods in refurbishment of the
existing stock. It is therefore important that we do not abandon
the target on the basis of narrowly based arguments around immediate
cost-effectiveness.
We support the definition of "zero-carbon"
as one that ensures additionality of carbon savings, over and
above other policies such as the Renewables Obligation, but equally,
one that does not require technically inappropriate solutions
such as microgeneration on properties where this is impracticable.
In terms of what more Government can do, we
would like to see rapid and co-ordinated implementation, with
clear roles for relevant organisations such as the Energy Saving
Trust. We are concerned about further delays with the setting
up of the "delivery hub."
We would also like the Government to adopt a
scientific approach, with appropriate resources behind this. Essentially,
this means: the establishment of a large-scale energy monitoring
programme; ongoing evaluation of the liveability of actual developments,
and widespread dissemination of the findings to inform further
projects moving forwards.
The Energy Saving Trust is the organisation
tasked with raising awareness of sustainable energy and climate
change among the British public. Accordingly, we are keen that
the Government put resources behind educating the public about
the benefits of low and zero-carbon homes, so that these homes
can be sold and are appropriately used once built.
INTRODUCTION
This is the Energy Saving Trust's submission
into the inquiry by the Environmental Audit Committee on the housebuilding
agenda. This submission should not be taken to represent the views
of individual members of the Trust.
The Energy Saving Trust was established in 1993
to reduce carbon emissions from the domestic sector. We run a
range of support programmes to this end, with the aim of transforming
markets for sustainable energy. This includes markets not only
in consumer products, but also in housing—both new and existing—as
well as in road transport. Programmes most relevant to new house
building include:
— Best Practice, producing a range
of technical reports and guidance for the industry, together with
a technical advice hotline and website.
— Newbuild Outreach, offering project-specific
technical support and energy monitoring of individual developments.
— Practical Help, providing general
guidance to local authorities, notably planners, on the issues
around low-carbon newbuild housing.
In view of the above, the Energy Saving Trust's
response focuses on the Committee's first area of enquiry, i.e:
carbon emissions from new homes. We make more general points about
other aspects of the inquiry.
Is the target for all new homes to be zero-carbon
by 2016 on track to be achieved? Does the Government need to do
any more to deliver this target?
The Energy Saving Trust believes the target
is achievable, albeit challenging. The technologies for zero-carbon
exist today. How difficult or easy it is to roll out "zero-carbon"
across the country will depend on the final definition, and it
is important that this definition is tailored to what is best
for carbon reduction, not to what is easiest for meeting the target.
Co-ordinated Implementation
Since the announcement of the target in December
2006, over 10% of the time has already elapsed, with little progress
in terms of co-ordinated implementation. Whilst it has probably
been healthy to have a period of debate and "bedding down,"
it is imperative now to deliver real action. The proposal for
a "delivery hub" to co-ordinate activity is welcome,
and we look forward to the establishment of this hub. However,
we are concerned at the time it may take to do this and the negative
impact potential delays may have. Organisations that already run
relevant programmes, such as the Energy Saving Trust, are not
able to go full out with their activities because it is not clear
how these might need to be adapted to fit in with the eventual
hub workstreams.
A Scientific Approach
The zero-carbon target is best met through a
scientific approach, i.e: design š build š evaluate
š learn lessons š design better. Without such a cycle
of systematic learning and feedback, there will be a protracted
process of "trial and error." This cannot be accommodated
within the challenging timescale before us. A scientific approach
in this context means:
— consistent and coherent energy monitoring
of actual developments, identifying what works well and what doesn't;
— evaluation of the functionality and
liveability of actual developments, including householder behaviour
within them; and
— widescale dissemination of the findings,
feeding into a large-scale training programme, product development,
and regulation.
The Energy Saving Trust is pursuing activity
in all of these areas, using the budgets at its disposal. These
budgets were established well before the announcement of the zero-carbon
target, to promote incremental improvement. Inevitably, much more
resource is needed to roll out these activities on a scale that
can transform the whole housebuilding industry by 2016. This includes
resource for monitoring equipment and resource for more research.
Compliance
It is important that homes claiming to achieve
any particular carbon performance actually do so in practice.
It is important not only for immediate carbon savings; but also
to maintain credibility in the claims, and in the associated quality
and performance of the homes in question. This does not need every
home to be monitored for its energy consumption, but it does need
compliance with the relevant standards.
Currently there are a number of standards and
rating schemes—Building Regulations Part L, Energy Performance
Certificates, Code for Sustainable Homes—but only the last
of these requires an on-site inspection. The first two essentially
rely on theoretical design-based performance. We believe there
should be more thorough on-site inspection by an agent expert
in identifying the most significant energy performance features
of the home. We also believe that a development receiving planning
permission for achieving a particular carbon performance should
be checked against this upon completion, with appropriate sanctions
if this performance is not met.
Research commissioned by the Energy Efficiency
Partnership for Homes under the last regime of Building Regulations
Part L (2002) showed one third of all new homes not to meet the
indicative airtightness requirements of the time. This was a highly
suggestive indicator of more general non-compliance with Part
L (2002). It is not yet clear whether compliance under the new
Part L (2006) regime has improved, and the current joint investigation
by the Partnership and CLG is welcome, although the investigation
is limited by funding.
The Government is currently consulting on the
future of building control, and this consultation and the proposals
within it are also welcome. It is important that the necessary
reforms are completed in time for the next round of Building Regulations
in 2010.
Bringing the Consumer on Board
Ultimately, the low and zero-carbon homes we
build need to be the kinds of homes that people want to buy and
live in. Whilst it is possible that some of these homes will have
a traditional look, all will inevitably have design features and
functionalities that will need to be conveyed to the householder.
This may be as part of the sales process—for example, explaining
why the home without a bath is still desirable, how to substitute
children's bath time, etc.—or part of the after-sales service—for
example, explaining why a bath or power shower should not be installed
as soon as the new owner has moved in.
It is important for Government and consumer-facing
organisations to engage the public early on this issue, to develop
consumer pull and cultivate consumer acceptance and behaviour
change. An Energy Performance Certificate and a Code for Sustainable
Homes assessment are both now mandatory for newbuild housing,
but without a significant publicity campaign to help potential
purchasers distinguish between newbuild property according to
performance, the value of these ratings is diminished. These tools
for market differentiation are likely to remain redundant until
Government invests in promoting them to the public.
How should "zero-carbon" be defined?
What role should carbon offsets play in meeting this target?
"Zero-carbon" should be defined in
a way that delivers maximum carbon reductions and market transformation
in a technically realistic scenario. Accordingly, it should secure
carbon savings additional to those achieved through other policies.
This means that there is no point in claiming
zero-carbon by simply allowing the use of renewable electricity
from the grid—electricity that is already committed to under
the Renewables Obligation. If zero-carbon is to allow for the
use of such electricity, then the Renewables Obligation should
be increased accordingly.
Equally, zero-carbon should not require technically
unrealistic solutions—for example, the installation of significant
amounts of microgeneration technologies on a building where, owing
to location, these technologies cannot operate effectively. We
believe that energy generated on the development site, or even
within the community should count towards the zero-carbon target.
The zero-carbon target is important for more
than just direct carbon-saving reasons. It is a stretch target
that has galvanised the industry to work towards something that
is way beyond business-as-usual and current cost-effectiveness
arguments. The target should foster collaboration and innovation
that may break through barriers such as cost. And its impact should
permeate into other sectors, notably the existing stock, where
newbuild technologies and methods will be transferred. These technologies
will include microgeneration, as well as products such as advanced
glazing.
Accordingly, it is important that "zero-carbon"
is not watered down through narrowly rational or economic arguments
about marginal carbon savings, or offsetting by more cost-effective
improvements to the existing stock.
What impact will the progressive tightening of
energy efficiency building regulations have up to 2016? Are the
targets for 2010 and 2013 achievable?
The direct impact of the tightening of Building
Regulations to 2016 is illustrated in the figures below:[33]
Figure 1
CARBON EMISSIONS FROM NEWBUILD WITH NO TIGHTENING
OF BUILDING REGULATIONS
Figure 2
CARBON EMISSIONS FROM NEWBUILD WITH 2016
ZERO-CARBON REQUIREMENT
Clearly, the zero-carbon target will lead to
substantial savings over the period to 2050.
The 2010 and 2013 targets are important because
they focus the mind and avoid too much distribution in performance,
i.e: keep the slower movers to the longer-term schedule. As the
timescale for the overall zero-carbon target is 10 years, three-year
milestones are appropriate, although not ideal for the construction
industry where projects may take around this time from beginning
to end. However, since the timescale for the overall zero-carbon
target is 10 years, three-year milestones seem appropriate.
The 2010 target (Code level 3 energy performance)
is certainly achievable even now. The Energy Saving Trust's guidance
shows how this can be done without recourse to microgeneration
technologies (see attachment). The solution is however reliant
on quality workmanship, good detailing (for example, avoiding
thermal bridges), and appropriate ventilation. To achieve this
on a volume scale requires changes to quality control and design
processes within developers; and upskilling and training of the
workforce.
The 2013 target (Code level 4 energy performance)
is likewise achievable, as set out in our guidance, though in
most realistic cases it necessitates the use of some microgeneration.
It is likely that the cost of microgeneration will have reduced
substantially over the intervening period.
How should compliance with the targets be measured
and enforced?
Note this question has been answered under "what
more should government do." In summary, there is a need for
on-site inspection for all carbon performance levels, and there
is a need to ensure that planning policy requirements are delivered
on the ground.
This is not just about appropriate regulation;
it is also about providing planners and building control with
the necessary training and resources (time and priority) to be
in a position to pursue carbon performance issues.
What is the likely scale of environmental impacts
(especially carbon emissions) of the construction of three million
new homes (i.e: irrespective of where they are sited)? How should
these impacts be reported? What should be the role of central
Government in minimising them?
The Energy Saving Trust's focus in this area
is on the energy performance of these homes and associated carbon
emissions. The absolute impact on newbuild emissions reductions
has already been shown in Figures 1 and 2. But it is also worth
noting the significance in terms of carbon emissions from the
housing stock as a whole. The figure below assumes that we will
need to achieve a minimum of 60% emissions reductions from our
housing stock by 2050.[34]
It also shows the contribution of emissions from newbuild housing,
relative to the existing stock, if new homes continue to be built
to the Building Regulations requirements of 2006.
Figure 3
THE CONTRIBUTION OF NEWBUILD TO TOTAL HOUSING
EMISSIONS IF LEFT UNCHECKED
What this figure shows is that, if we continue
to build to today's standards, we would need to improve our existing
stock by 82% by 2050, not 60%. The conclusion is that it is essential
to impose tough targets on the newbuild sector if we are not to
place an unduly high burden on refurbishment of the existing housing
stock.
The question of the role of central Government
in reducing the impact of carbon emissions from newbuild has been
dealt with in the answers above.
From the Energy Saving Trust's experience with
road transport, we believe it is important that the wider implications
of building three million new homes are considered. For instance
planning and travel should be a priority in ensuring transport
emissions from new developments are kept to a minimum. If the
new homes build in car dependency this will have significant implications
for carbon emissions. Whereas access to local amenities, sustainable
travel options such as well lit, safe walking and cycling paths
and ready access to public transport will ensure that the developments
are genuinely low carbon.
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 has a number
of anticipated benefits:
— It should help the industry prepare
for the next round of Building Regulations, and direct investment,
supply chains, and training accordingly.
— It should make it clear to publicly
funded or otherwise publicly supported developers what specific
sustainability performance levels they are expected to achieve.
— It should help developers who build
to higher levels of sustainability sell their homes, by providing
independent recognition for what they have done.
In practice, it is unlikely that the third benefit—that
of creating a consumer brand and ultimately consumer pull—will
be realised. This will only change with a well thought-out, independent
publicity campaign, demonstrating to potential buyers the benefits
of a sustainable home and how to recognise one.
The Energy Saving Trust does not support changes
to the Code until the next round of the Building Regulations Part
L in 2010. The aim of the Code is to bring predictability to the
industry. If it is constantly changed, this undermines the objective.
If, for unforeseen technical reasons, a change must be made, it
is essential this is communicated clearly to the industry, through
well-recognised and easily accessible means. These have yet to
be established.
How big a contribution will Eco-Towns make to
reducing the environmental impacts of housing in England, both
in their own right, and in the development of design and techniques
that could be rolled out in other developments?
The Energy Saving Trust has not to date been
heavily involved with the Eco-Towns initiative. We understand
the Eco-Towns to be approaching completion around 2015. This is
very late for providing evidence on completed developments in
time to reach the 2016 zero-carbon target. Owing to the scale
of Eco-Towns, and the need to establish new and extensive energy
infrastructure for them, it is not clear how much they will help
pave the way for smaller developments to reach zero-carbon. However,
the advanced thinking, master-planning processes, and ongoing
monitoring and publicity should raise wider levels of awareness
and understanding that will undoubtedly inform other projects.
What is clear to the Energy Saving Trust is
that the new residents of Eco-Towns will need comprehensive support
and advice, in order to match the eco-buildings with suitable
eco-behaviour and lifestyles. This needs to be provided from the
beginning, to ensure that a culture of sustainability is adopted.
To what extent do, and should, planning controls
protect greenfield and green belt land from development of new
housing?
The Energy Saving Trust limits its detailed
views to the carbon performance of homes. Clearly, there is generally
more scope for microgeneration technologies outside of urban areas,
but we recognise that the issues around environmental impact go
beyond the carbon performance of the homes in question.
Personal travel accounts for over a third of
the average individual's carbon footprint. Therefore sustainable
travel should be a priority and the demand for new roads should
be minimised.
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?
The Energy Saving Trust has had no practical
involvement in wider infrastructure issues. However, it recently
commissioned research into the potential avoided costs of low-carbon
developments. The proposition is that, by reducing the energy
needs of the development, some capital cost of energy provision
can be avoided—in addition to the annual fuel bill savings.
The research concluded that there was indeed
scope for capital cost savings, around energy performance levels
of 4-5 of the Code for Sustainable Homes. Across all newbuild,
simply avoiding the cost of installing a central heating system
could save some £720M p.a. in construction costs.
In order to realise such savings, however, it
is important that Government and Ofgem reform the regulatory and
planning framework, to address a range of split incentives, ie:
to ensure that those investing in low-carbon homes are those that
benefit from the costs that are avoided as a result.
The research was limited to the edge of the
development. The Energy Saving Trust is considering commissioning
a further phase to this research, to consider the impact on wider
infrastructure costs.
25 April 2008
33 These graphs are indicative and are based on extrapolations
rather than detailed projections of housebuilding rates. Back
34
In reality this goal is likely to increase to 80% in the context
of the review of targets under the Climate Change Bill. Back
| 
