Written evidence submitted by Paul Appleby
CEng FCIBSE FRSA - Consultant in Sustainable Design|
This memorandum deals primarily with the impact of
the Budget 2011 and "The Plan for Growth" on sustainable
development and in particular CO2 emissions. These
are addressed in the context of other Government actions, such
as the Fast Track review of Feed-in Tariff, since these have a
cumulative effect which will have a major impact on the ability
of Government to meet its legal obligations under the Climate
Change Act. Specifically the memorandum addresses:
change in definition of zero carbon homes and its impact on the
manufacturers and developers who have been gearing up for 2016.
relationship between the cost of zero carbon and the Feed-in Tariff,
Renewable Heat Incentive, Green Deal and Community Energy Fund.
implications of proposed policy for decarbonisation of the grid
and relationship with the 2050 Pathways Analysis.
implications for zero carbon non-residential buildings from 2019.
implications of the proposed changes to Feed-in Tariff for photovoltaic
installations larger than 50kW.
relationship between Feed-in Tariff (FIT) and Renewable Heat Incentive
and their application to low and zero carbon fuelled combined
heat and power plant and the proposed changes of FIT for anaerobic
I conclude that, where applicable, Government policy
and actions should be assessed for the impact they will have on
achieving the legally binding CO2 reduction of 26%
by 2020 and 80% of GHG by 2050 compared by 1990 baseline values.
1.1 As a freelance consultant I specialise in
the sustainable design of buildings and providing advice to design
and masterplanning teams on all aspects of sustainability. I graduated
with a first class honours degree in Environmental Engineering
in 1975 since when I have worked as a mechanical services design
engineer, a lecturer and researcher, setting up my own consultancy
in 1988. This became Building Health Consultants Ltd, which remains
today as part of URS Scott Wilson. In 2000 I establish the Building
Sustainability Unit at URS, from which I retired at the end of
1.2 I have some 60 publications to my name including
Integrated Sustainable Design of Buildings which was published
in January of this year by Earthscan. It is a comprehensive guide
to sustainable design, masterplanning and construction, designed
for a global marketplace, but with a particular focus on the UK.
2.1 I will leave commentary on fuel duty and
transportation impacts to others more qualified in these areas.
In this memorandum I will focus on those aspects of the Budget
2011, "The Plan for Growth" and other Coalition actions
that impact on climate change and sustainable development.
2.2 It is my view that every Government policy
and action should be tested against predictable and measurable
criteria, such as the requirements for carbon reduction set out
in the 2008 Climate Change Act, as well as the trends illustrated
in Defra's Sustainable Development Indicators (updated July 2010).
2.3 The measures set out in the Budget 2011 also
have to viewed in the context of a number of recent reports from
Government departments, namely:
Plan. March 2011.
Zero Carbon Hub Report. Feb 2011.
Pathways Analysis, DECC. July 2010.
Infrastructure Plan. HMT/Infrastructure UK. October 2010.
Track Review of the Feed-in Tariff, DECC. Consultation responses
due May 2011.
Carbon Construction Innovation and Growth Team's final report.
2.4 Zero carbon homes: Despite pledges
in the Carbon Plan and recommendations in the final report from
the Zero Carbon Hub the Budget has removed the commitment to zero
carbon homes being a requirement of Building Regulations from
2016. The requirement has been watered down to cover only those
parts of the energy demand that depend on the design of the dwelling,
and exclude the so-called "unregulated emissions", such
as white goods, TVs etc, which are likely to make up some 33-50%
of carbon emissions.
2.5 It is understood that the Government is worried
that the cost of achieving zero carbon will make homes unaffordable
and hence inhibit growth. Unfortunately this is likely to result
in a vicious circle since the consequent demand for the materials
and products required for improving carbon performance will be
insufficient to bring the costs down to affordable levels, hence
increasing the cost of low carbon homes. It also means that many
of the manufacturers, suppliers, installers and developers who
have been gearing up for zero carbon will be left high and dry.
Some of these will also be hit by the Government's proposed Fast
Track review of FIT (see below), thus depressing the market for
solar photovoltaics along two fronts.
2.6 One side effect of the redefinition of zero
carbon is that developers are less likely to be required to contribute
to off-site community energy schemes, unless these are leveraged
by Local Authorities through the Community Infrastructure Levy.
2.7 The Zero Carbon Hub report refers to illustrative
marginal costs for achieving zero carbon as £8,700 for semi-detached
houses and £12,300 for detached, compared with 2010 Part
L1A compliance. These include an allowance of £75 per tonne
CO2 for off-site "Allowable Solutions" and
are based on a Carbon Compliance limit of 11 kg CO2eq/m2/year
for the semi and 10 CO2eq/m2/year for the
detached house. The costs are based on projected prices in 2016.
2.8 There are a number of factors that this analysis
appears to ignore:
2.8.1 Although I have not been able to access
the detailed cost analysis carried out by Cyril Sweett, no mention
is made in the Carbon Hub report of allowance for Feed-in Tariff,
Renewable Heat Incentive and Community Energy Fund in the marginal
costs. In essence these will act as a subsidy for the PVs and
other renewables, and potentially for Allowable Solutions.
2.8.2 The Government has proposed that the Green
Deal should apply to new-build dwellings and would reduce the
up-front cost of carbon reduction measures, such as insulation,
although in fact this will simply spread the cost over a specified
period through energy bills (pay-as-you-save).
2.8.3 Both the 2050 Pathways analysis and the
EU Roadmap 2050 study require a decarbonisation of the electricity
grid in order to achieve the 80% greenhouse gas reduction by 2050.
As the grid is decarbonised through some combination of renewable
energy, carbon capture and storage and (possibly) new nuclear,
carbon emissions associated with the electrical demand from all
dwellings will fall proportionately. Bearing in mind that dwellings
built to the Zero Carbon Hub proposed Carbon Compliance limits
will have negligible heating requirements electrical demand will
dominate the energy requirements for future dwellings.
2.8.4 On the other hand the Pathways analysis
assumes a massive reduction in demand from both new and existing
buildings, such that the demand will not be any greater in 2050
than 2011. It has to be remembered that it is predicted that some
10 million new homes will be built between now and 2050, whilst
perhaps 1 million will be decommissioned or demolished. Each new
dwelling will represent an additional burden on the grid and add
to the CO2 and greenhouse gas emissions to atmosphere.
2.9 Zero carbon non-residential buildings:
For non-residential buildings the zero carbon requirement was
scheduled for inclusion in revised Building Regulations by 2019,
although the Zero Carbon Hub has not yet attempted a definition.
There will be a problem in translating the exclusion of non-regulated
emissions from the homes definition since all non-residential
buildings must cater for the heat gains from all internal sources
(regulated and unregulated) in determining either the loads dealt
with by an air conditioning system or assessing summertime temperatures
for natural ventilation feasibility.
3.1 The 2010 Spending Review established a maximum
fund for the Feed- in tariff (FIT). This has placed an artificial
constraint on this vital incentive. The Committee will be aware
that DECC has instigated a Fast Track Review of FIT with a view
to reducing the amount paid for electricity generated from photovoltaics
(PV) larger than 50 KW, with an especially large reduction for
installations larger than 250kW (from 29.3p/kWh to 8.5p/kWh).
It is my view that the impact assessment (IA) for this review
should focus on the impact of this significant reduction on the
ability of this Government in achieving the legally binding CO2
reduction of 26% by 2020 and 80% of GHG by 2050 compared by 1990
baseline values. It is interesting to note that the IA refers
to total CO2 savings until 2020 of between 10.3 and
20.2 million tonnes for the "do nothing" scenario and
between 0.3 and 0.9 million tonnes for the fast track modifications.
The difference between these scenarios approximates to the annual
carbon emissions associated with one or two large coal-fired power
stations. As the Government's own Pathways Analysis shows there
must be an "heroic" effort in renewables development
over the next 10 years, particularly when one considers the loss
in confidence in nuclear power following the Fukushima disaster.
3.1 The Consultation document for the FIT review
refers to 41 solar farms having obtained planning permission or
being under consideration. These are very unlikely to go ahead
with the revised Feed-in Tariff. Indeed it seems likely that very
few installations larger than 50kW will go ahead. In my view this
means that a massive opportunity will have been missed. Although
the cost of PV cells has fallen by 30% since the original IA,
the cost per kWh electricity generated from large-scale solar
installations is still likely to be more than twice that for wind
farms. It is my view that funding should be related to the cost
per kWh of the technology concerned (ideally whole life cost,
if data is available). Clearly the problem lies with the method
being used to support renewable energy. I agree that the FIT should
be able to meet the demand from the domestic market, with a particular
emphasis on retrofit. However it must be made economically viable
for developers to build large-scale solar farms. If there is inadequate
funding within the FIT system, then alternative incentives must
be identified; perhaps via energy company Renewable Obligations
and/or the Green Investment Bank.
3.2 The IA also does not assess the impact on
the UK manufacturers and installers of PV. Evidently with the
focus on the domestic market the installers that serve this sector
will benefit, however the cancellation of around 40 large-scale
solar farm projects would strangle at birth a burgeoning large-scale
3.3 The FIT Fast Track Review also responds to
a poor uptake of the FIT for anaerobic digestion (AD). A small
increase in tariff is proposed which I doubt will increase uptake.
My view is that the rate should reflect the whole life cost per
kWh of energy generated, taking into account diversion of waste
from landfill and the economic benefits of digestate production.
I would also like this category to be expanded to cover the use
of used cooking oil and sewage waste for CHP plant.
3.4 The Government's proposed Renewable Heat
Incentive (RHI) will apply to renewable energy used directly for
generation of heat. However it is unclear how this will be applied
to applications that generate both heat and electricity. This
includes any combined heat & power (CHP) application that
uses a renewable fuel, such as the gas emanating from anaerobic
digestion, sewage, landfill, gasification and pyrolysis, as well
as biomass. There is a "bio-energy" category in the
RHI which refers to heat generated. If the energy from both electricity
and heat are subject to separate payments through FIT and RHI
respectively then the uptake of AD and other zero/low carbon fuelled
CHP could increase markedly once the RHI is launched?
3.5 If crops are to be used for generating energy
then I think it preferable that the conversion be through the
AD process, which is far less polluting than combustion and more
cost effective than gasification and pyrolysis. I think there
should be an incentive for those installations that employ only
waste products as a fuel, such as wood waste and agricultural
by-products, perhaps through a differential in the FIT and RHI.
3.6 Studies have found that small-scale wind
installations that are located where wind resources are inadequate,
such as for individual houses in sheltered spots in towns and
cities, consume more carbon dioxide in the manufacture of the
wind turbines than is saved during the lifetime of the installation.
I would suggest that applicants for FIT for small scale wind turbines
should be required to provide evidence that the wind resources
in the planned location is sufficient to recover the carbon associated
with manufacture of the proposed turbine within its lifetime.
This could, of course, be applied to FIT and RHI applications
for all technologies.
14 April 2011
10 Phillips, R et al. 2007. Micro wind turbines
in urban environments (BRE Report FB17) London: BRE Back