OPINION


BACKING THE WRONG HORSE


There is a danger that Allowable Solutions will result in the adoption of complex, unproven technology, rather than projects with long-lasting benefits, says Max Fordham’s Bill Watts


The government has put into place a requirement for all homes built


after 2016 to be zero carbon. Having made the statement, it has to define what it means by zero carbon and what constitutes compliance. The overall goal is clear – new homes


will not contribute to the world’s carbon emissions – but the way to achieve it is not comprehensive. The carbon in construction is not included, neither is the carbon associated with cooking or plugging in appliances. That leaves the services – heating, ventilation, hot water and fixed lighting – to deliver the ‘zero carbon’ promise. In a nutshell, zero carbon compliance


broadly consists of three measures: ●Fabric energy efficiency – reduce the energy requirement of the dwelling with good standards of insulation


●Carbon compliance – generate the energy needed on-site using renewable energy


●Allowable Solutions – on the basis that it is not technically feasible to generate enough energy on-site to meet most building’s needs, pay someone or do something off-site to save the equivalent carbon emitted from your remaining energy-related carbon emissions


In my view, Allowable Solutions can best be described as a tax on development to save carbon emissions. Finding the right route to spending that money appropriately – without opening it up to fraud, undue administrative overheads or ineffective installation – is a complex task, and one that the current consultation seeks to undertake. For building services engineers, there


are a number of issues. The government argues that it is politically neutral on what types of technology a designer uses to meet their targets, when in fact, it is anything but neutral. Planning, Building Regulations and assessment models have preset performance criteria for various systems – often with little


18 CIBSE Journal September 2013


Allowable Solutions should be biased towards passive systems that will reduce energy


consumption rather than active systems that rely on unrealistic levels of


performance


Insulation will never be a stranded asset: Max Fordham’s strategy to insulate Grade I Listed Trinity College, Cambridge, was granted planning permission in February 2013


bearing on reality – that drive a designer down a particular route. The presets are often not based on


field data but on an idealised theoretical view of engineering. As anyone who has commissioned a building knows, the theoretical view is quite far from reality. As a result, systems are installed that


are often inappropriate, more expensive and energy intensive. Designers should be left to get on with devising a scheme with both the client’s and users’ current and future interests at heart. District heating could be seen as


the darling of Allowable Solutions, as it is mentioned many times in the consultation. It has successfully evaded evidence-based analysis, despite actual energy usage regularly being higher than models predict, leading to problems if a supply contract is based on those predicted figures. An energy strategy is led by the


services engineer to meet policy requirements, but a services engineer has enough to design without deciding on the best carbon savings off-site. Without an engaged developer or champion with clearly defined


responsibilities, it seems the Allowable Solutions route taken will be the cheapest option – certainly the easiest – but possibly not the most beneficial. Fundamentally, it’s important to


think about the longer term. Allowable Solutions should be biased towards passive systems that will reduce energy use, rather than active systems that rely on unrealistic levels of performance. Incentivising alternative resources is


also premature. The use of biomass or community heating are not well enough defined in a national context, and could lead to stranded assets of inappropriate technology. Investment in reducing energy use can never be a stranded asset but, on paper, may be a more expensive form of carbon reduction. In this model, the savings come in the longer term through efficient use, reliable operation and simple maintenance. For this policy to be effective,


the solutions need to be based on real results, taking account of real consequences.


l BILL WATTS is a senior partner at Max Fordham


www.cibsejournal.com


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