Zero Carbon New Non-Domestic Buildings Consultation Report
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Transcript of Zero Carbon New Non-Domestic Buildings Consultation Report
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March 2010
Zero Carbon New
Non-DomesticBuildingsFeedback report from a national programme of events on the
Department of Communities and Local Governments
consultation on the journey to zero carbon for non-domestic
buildings, organised by the UK Green Building Council
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This project was funded by the Department
for Communities and Local Government.
Report written by Simon McWhirter,
The Message Hub
Technical support and workshop
contributions from Arup
Copyright (2010)
UK Green Building Council
UK Green Building Council
The Building Centre
26 Store Street
London WC1E 7BT
T: +44 (0) 20 7580 0623
E: [email protected]: www.ukgbc.org
http://www.ukgbc.org/http://www.ukgbc.org/ -
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Foreword
Zero carbon new non-domestic buildings are an issue of huge significance for the UK Green
Building Council, our members and the wider industry and I am encouraged that government has
set out some ambitious aspirations in this area.
A lot of the content of the proposed zero carbon non-domestic definition carries on from the
work done in the homes sector, building on the body of work carried out by the Zero Carbon
Hub, in which the UK-GBC and many of our members were heavily involved. The non-domestic
consultation takes, we think sensibly, the same hierarchical approach to the zero carbon
definition as that for homes; first focusing on the efficiency of the building itself, before
considering what low or zero carbon energy can be generated on or near the building, then lastly
looking at the more remote, and often more contentious, options to mitigate any remaining
emissions.
Government asked UK-GBC to lead a series of workshops across England to further investigate
the industry response to the proposals set out in the consultation on zero carbon non-domesticbuildings. This report summarises the outcomes of these workshops and aims to provide an
objective assessment of the participants feedback.
While there is still a lot of work to do, it feels at long last as if this policy is beginning to take
shape. There are naturally different points of view on the detail, but I take confidence from a
broad consensus about the need for an ambitious, deliverable and effective policy. I believe this
shows a maturity in the relationship between government, the industry and other stakeholders
and Im grateful to everyone who has taken part in this process.
Paul King
Chief Executive, UK Green Building Council
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Contents
Foreword 2Introduction 5The workshops 5Energy efficiency standard 7Beyond energy efficiency: Carbon compliance 8Allowable Solutions 10Defining the zero carbon destination 13Zero carbon for public sector buildings 14Cost impact assessment 15Delivery and next steps 16Conclusions 17
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Introduction
PURPOSE OF THE CONSULATION
Communities and Local Governments latest consultation on the ambition for zero carbon new non
domestic buildings ran from November 2009 to February 2010. Government wanted to seek viewson options for the overall routemap for all new non-domestic buildings to be zero carbon from
2019, and on how the public sector should be at the vanguard, with all new central government
public sector buildings being zero carbon from 2018. The zero carbon homes policy is the
foundation for the non-domestic buildings policy.
PURPOSE OF THE WORKSHOP EVENTS
The purpose of the series of workshops, which were carried out by the UK Green Building Council,
was twofold; to provide both a platform for stakeholders to get a better understanding of the issues
in the consultation and also a channel for providing comprehensive feedback to the department of
Communities and Local Government (CLG). For both those who were planning to respond to the
consultation officially and those who werent, these workshops were an opportunity to input to the
process and allowed an opportunity for stakeholders to pose questions on the issues in the
consultation. CLG officials presented the rationale behind the policy at each event, and were on
hand to answer questions.
PURPOSE OF THE REPORT
The UK Green Building Council has produced this report to form part of the evidence base for how
the government delivers on this agenda. The report presents an objective analysis of the workshop
process and outputs, and does not necessarily represent the views of the UK Green Building
Council. The report, which will be publicly available, sets out the combined feedback from a wide
range of stakeholders from the trade, industry and NGO sectors among others - on the zero carbon
non-domestic proposals. The report will be used by government to develop policy in this area
further.
The workshops
The UK-GBC arranged a series of five workshops during January and February 2010. These were
held in Bristol, Manchester and Birmingham, followed by two workshops in London. The workshops
were free to attend allowing for the participation of a wide range of stakeholders. Each workshop
followed a similar programme consisting of an introduction to the key issues, and a series of
interactive audience participation sessions using hand held voting sets. Each workshop began with
a presentation by CLG which set out the policy context for the consultation. The technical content
of the workshops was presented by Arup, on behalf of UK-GBC.
Feedback from the workshops was gathered using as combination of three methods:
1. Hand-held voting equipment was used to gather quantitative feedback throughout eachworkshop (with the same questions asked at each workshop);
2. Delegates provided additional qualitative feedback by completing comments cards; and3. Verbal comments and questions raised during the workshops were also recorded.
This report summarises the key issues and views identified through this feedback. The results
presented are an amalgamation of all five workshops. The individual workshop results and the
summarized qualitative feedback from the comment cards completed by the delegates are included
in the appendices. There was limited on the day verbal feed-back on the consultation contents.Many of the workshop attendees commented that they had attended the workshops to learn more
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about the consultation and to inform their own formal consultation responses, and therefore had
not formulated responses to the consultation content prior to attending the workshop.
The feedback has been analysed (a) on an aggregate basis; (b) by region (as represented by
workshop location) and (c) by the industry sector the participant represented. Generally, there
was no material variation in the responses by region. However, the comparisons by sector should be
treated with care as when asked to indicate which option from a list of sectors they worked in, 31%
of workshop participants chose the Other option. This makes accurate voting analysis by thissectoral method imprecise.
Delegates were asked to consider the proposals in the consultation in terms of what they
considered to be technically feasible and/or desirable, and to separately consider the issue of cost.PARTICIPANTS AND FEEDBACK
There were 209 attendees overall at the five workshops. A wide range of sectors was represented.
Particularly well represented were the architecture, product manufacturing and engineering and
construction/development disciplines, together with national and local government. Unless
specified to the contrary, no sector presented a markedly different view than that expressed by the
entire body of participants. Before the workshops began, 94% of participants considered themselvesas having some level of understanding of the Governments proposals for zero carbon non-domestic
buildings, but only 3% viewed themselves as experts.
After the workshop events, 65% of delegates indicated that the complete package of measures
provided them with clear guidance on the direction of the zero carbon policy, and felt they were
supportive of it. While 28% of the workshop participants were either unsure of the policy direction
or felt they need more information, only 7% indicated a lack of support for it.
The delegates represented a wide array of business areas, with the commercial real estate,
education and policy/regulation fields being those that most delegates were involved in. We have,
however, not analysed the delegates voting responses based upon the area of business they
operate in. As each workshop participant was entitled to indicate that they worked in multiple
business areas the votes cast dont apportion equally across the individuals working in any specificarea of business, and trends therefore may be misleading. The sample audience from the
workshops was relatively small and specific analysis at this level could be considered to lack
statistical robustness.
In total 88% of the participants had read some of the consultation material, but only 4% had read it
fully. Only 1% of participants had also fully read the Impact Assessment. When asked whether the
materials were too complex or too simple, 73% considered them to be the right level of complexity
for them. 97% of the participants said that the event had helped them understand the
consultation.
Although only 42% of the delegates were UK Green Building Council members, over half of them
said they have previously been involved in some way with very low energy buildings1
. There werefew instances where delegates previous experience of low or zero construction led to a distinct
variation from the overall voting pattern. Where significant this has been noted through the report.
All participants were encouraged to submit their own individual responses to the consultation.
The workshops followed the same order as the consultation document, addressing each of the
following topics in turn:
1. Energy efficiency standard (Chapter 2)2. How much of remaining regulated carbon is dealt with on-site (Chapter 3)3. Allowable Solutions measures for remaining regulated & unregulated carbon (Chapter 4)
1 For this question, buildings with EPC ratings of A or B, BREEAM Outstanding ratings or zero carbon were considered to bevery low energy buildings.
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4. Defining the zero carbon destination (Chapter 5)5. Zero carbon for new public sector buildings (Chapter 6)6. Cost impact assessment2 (separate document to the consultation paper)7. Delivery and next steps (Chapter 7)
Energy efficiency standard
Summary: A significant majority of delegates (94%) supported a challenging energy efficiency
backstop. However, 71% felt this needed to be judged on a sectoral basis, and only 23% favoured an
identical standard across all building types. Across the delegates, views were split evenly on
whether a passive building fabric calculation should be employed, or whether mechanical systems
should be included. Similarly, delegates were split three ways between primary energy, delivered
energy, and carbon emissions - as to the metric to be used.
Mirroring the approach that has been adopted for housing, the
non-domestic zero carbon definition is intended to allowflexibility in its application, avoiding direct prescription of how
each element of the standard should be achieved. However, to
ensure the twin aims of both energy and emissions reduction,
CLG has proposed that the
zero carbon standards
underlying environmental
robustness is strengthened
through an energy efficiency
backstop to ensure a
minimum performance
standard for the building fabric.
Workshop delegates were asked whether there should be such anenergy efficiency backstop as a component of the non-domestic
zero carbon target, and whether a flat rate calculation should be
used to determine the standard
(as was done for homes) or
whether the much greater
building diversity in non-
domestic buildings requires a
differential approach. I.e.,
similar to the aggregate
approach proposed in Part L1:2010, different building types could
have different energy efficiency improvement targets.
While the workshop participants were strongly behind the concept of a challenging efficiency
standard covering space heating and cooling (94% positive), almost three quarters felt that this
standard needed to be assessed on a sector-by-sector basis, rather than as an across-the-board flat
rate improvement.3 However, the architectural/design delegates slightly favoured the flat rate
approach across all.
Of delegates with previous experience in low or zero carbon housing development through the
entire construction process, there was a stronger vote for the flat rate approach across all sectors
(36%, uplifted from the entire workshop series result of 23%). For those with low carbon non-
domestic experience, there was no significant deviation from the average.
2 This cost issue was addressed after delegates had considered what was felt to be technically achievable if cost was notconsidered to be an influencing factor3 Question B1, slide 45, Appendix 2
..unless challenging
standards are across the
whole, implementation will
be delayed as the sectors
argue their corner and the
reasons they cannot achieve
the requirement.
(Consultant on energy
efficiency Bristol, January2010)
Aggregate approach needsto be fair and based onwhat is achievable for eachsector. (Workshopdelegate, ManchesterJanuary 2010)
..it is imperative
that we regulate and
tax inefficient
buildings into
obsolescence
(Workshop delegate
comment on energy
efficiency London,
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It was questioned by a delegate at the Bristol workshop how much analysis had gone into assessing
the impact on the competitiveness of different sectors of applying either a flat rate or sectorspecific energy efficiency standard.
Not all delegates favoured all aspects of the approaches taken for the domestic sector, but there
was a distinct theme that where possible it was advantageous to utilise parallel mechanisms.
The delegates were split down the middle as to whether the standard should be based on passive
systems only (42%), rather than taking the Part L approach of incorporating mechanical systems
(including ventilation systems) into the standard (46%). Delegates from the engineering sector were
more strongly (66%) in favour of the inclusion of mechanical ventilation in the standard.
The vote was split several ways when it came to the metric of choice. While half the delegates
favoured the use of the kWh/m2
/year metric, they were split between the use of delivered energy(31%) and primary energy (19%). Carbon emissions (measured in kgCO2/m
2/year) were preferred by
29%, and delegates from central and local government came out strongly in favour of this approach
(47%). Workshop participants from the construction sector voted strongly against the use of
primary energy as the metric (with only 5% of delegates in favour of this, versus the workshop
average of 19%). These delegates votes fell more strongly in favour of the use of either delivered
energy or carbon emissions as the metric to be used.
Delegates with past experience of the masterplanning stage only (as opposed to delegates with an
experience of the masterplanning and construction stage) of both low or zero carbon housing or
non-domestic development voted more strongly in favour of a carbon emission metric (up from 29%
to 38%, and from 29% to 40% respectively for homes and non-domestic). Of all delegates with an
experience of the masterplanning and construction stage in the non-domestic sector, 38% voted for
delivered energy, followed by carbon emissions (24%), primary energy (18%) and sector-specific
measurements (6%). For housing, respective numbers were 33% (delivered energy), 24% (primary
energy), 24% (carbon emissions) and 12% sector-specific.
Other suggestions for methods to determine an energy efficiency backstop were provided on
comments cards and included a combination of an energy and CO2 metric, with minimum elemental
backstops, and a suggestion for a need for a balance depending on site and use.
Both in the energy efficiency section, and in later stages, a material number of comment cards
were submitted stating that the embodied energy impacts, or whole life cost, of the materials
should be a component of the zero carbon definition.
Beyond energy efficiency: Carbon compliance
Summary: Perhaps surprisingly only a minority of delegates (11%) were in favour of the off-site rich
scenario which is generally seen as the cheapest cost option. The largest proportion of participantsfavoured a balanced approach (46%), with a strong showing for the on-site, high microgeneration
option (36%). However, it was noted by delegates at more than one workshop that they found it
..should be consistent with homes because of the difficulty in administration and
implementation."(Consultant - London, February 2010)
Non-domestic covers a wide range of uses. Each sector requires a different
approach to ensure the correct considerations have been made. (Workshop
delegate comment - Birmingham, February 2010)
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difficult to analyse the technical and practical delivery of the various scenarios in isolation without
considering the cost implications, which were dealt with separately at the workshops. At the
London workshop, where participants answered the carbon compliance question a second time
after the section covering costs, there was a small but marked shift from on-site to off-site as the
preferred solution (although a balanced approach was still preferred overall).
Carbon compliance determines the level of on-site measures (and the use of directly connectedcommunal heat) for carbon reduction, expressed as a carbon emissions target through the Building
Regulations4. As proposed in the zero carbon homes policy,5 the modes of carbon reduction that are
likely to be used are:
higher building energy
efficiency further than the
minimum standard set;
the use of building-mounted
low and zero carbon energy
generation technologies;
onsite low and zero carbon
generation technologies; orwhere feasible in the
immediate environs,
directly connected heat or
coolth (via pipework).
For the consultation, three scenarios
were modelled. Each of these is an
aggregate target, so there would be
different targets for different
building types:
On-site rich (63% regulated
carbon emission reduction
on-site + remainder under
Allowable Solutions)
Off-site rich (44% regulated
carbon emission reduction
on-site + remainder under
allowable solutions)
Balanced (54% regulated
carbon emission reductionon-site + remainder under
Allowable Solutions)
The workshop delegates were presented with a brief outline of pros and cons of each scenario andasked which scenario they favoured6. At this stage delegates were directed to exclude the cost
implications of each scenario as this was to be tested later in the workshop.
In response to the question about which scenario they favoured, the delegates were split between
all three but with most favouring either the onsite rich (36%) or a balanced scenario (45%).
Delegates from the development sector indicated a greater preference for the offsite rich scenario
than other participants. A number of delegates felt that there was a need to increase the focus on
district heating systems.
4 The end destination of net zero carbon emissions should not differ regardless of which carbon compliance choice is madeat this stage, but it will impact on the amount of residual carbon which would need to be mitigated using allowablesolutions, i.e. a higher carbon compliance requirement will reduce the residual emissions to be mitigated, whereas a lowcarbon compliance level will mean that more work must be done with the allowable solutions framework.5 Which set a carbon compliance level for homes of 70% reduction in regulated carbon emissions from 20166 Slides 50-52, Appendix 2
Using comments cards delegates expressed a wide
range of views on the question of where to find the
balance between on-site and off-site solutions:
Balanced is certainly best, and this can be achieved
through planning, construction and operation.
However, I do think that the emerging policy
approach should be more market and transaction
savvy. The problem with offsite is the dependency onthird party to deliver and manage the power. This is
very tricky, given [that] investment requires control
and certainty. (Workshop delegate comment on
carbon compliance - Developer, Bristol, January
2010)
On-site rich. Allowable solutions are essentially a
fudge to deal with residual emissions. Just as we
should be pushing to minimise the energy demanded
by the building, we should also be minimising the
grid energy consumed. It may not be the most cost
effective but what price avoiding the worst ravagesof climate change? If it is tougher and more
complicated to deal with the top of the pyramid - we
should make it as small as possible. (Workshop
delegate comment on carbon compliance - Engineer,
London, February 2010)
Offsite-rich moving towards onsite through financing
incentives and tax breaks. (Workshop delegate
comment on carbon compliance Designer, Bristol,
January 2010)
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Unlike the combined workshop responses, those from delegates who had been involved in low
carbon housing development through the process voted for an onsite approach ahead of the
balanced approach (45% opting for onsite, and 33% for a balanced approach).
In the London workshops, delegates were asked this question again after running through the
modeling of cost implications of the scenarios. See below in the Cost Impact Assessment chapter
for the results.
At the Manchester workshop an NGO delegate queried why the upper level of ambition under the
carbon compliance level was so unambitious given that the consultation stated that all public
sector buildings were capable of achieving 80% carbon reductions onsite (versus the on-site rich
scenario setting a 63% target) 7. It was queried why, if the public sector could do it, the upper level
was not also set at 80%8.
Numerous questions seeking additional details on these aspects of the policy, and statements about
further complexities, were noted by delegates on their comment cards. A few have been
reproduced here and the full compilation of responses is in Appendix 1.
Are on site rich renewable technologies sufficiently robust over their life cycle to ensurecost savings?
If Im in the middle of Wales or in the middle of London, I would have a different answer.
You will need targets based on the local population density and region of the UK. But I
think on-site rich is the best answer in terms of the resiliency of the UK infrastructure. I
feel the balanced or offsite scenarios would be the best-cost, i.e. will the government pay
to increase resiliency of the nation. Onsite would promote local economies within every
region: sustainable in a wider context.
Whilst in favour of pushing on-site as far as possible, Local Planning Authorities need to
look at buildings in the context of local masterplans to look at future potential supplies to
district schemes.
Depends on which one will 'mesh' best with housing - not as in 'identical' but as in'complementary'. It must enable housing and non-domestic schemes to work together. It isall about matching supply and demand.
In the workshops themselves, the difficulties of separating cost from deliverability was brought upon a couple of occasions as well as subsequently in the comment cards with one developer at theBristol workshop emphasising that for them, it isnt so much cost, but who pays.
Allowable Solutions
Summary: Workshop participants were broadly in favour of
using the same Allowable Solutions delivery model for non-
domestic buildings as for homes, but this was an area where a
number of the delegates commented that the combination of
undefined elements, i.e. a fixed carbon compliance level andthe lack of certainty over the composition and detail of the list
of Allowable Solutions made some of the conceptual questions
difficult to respond to. Most of the Allowable Solutions
7 Paragraph 6.11 of consultation All the types of public sector building modelled can reach 80 per cent reductions on-siteapart from the acute hospital. Schools, some military buildings and prisons are all able to achieve close to 100 per centreductions on-site.8 However, the IA suggests that some public buildings could not do 80% on-site. Only selected building types tested could.Other office type town centre buildings, for example, could not achieve 80% on-site.
Each sector presents radically
different opportunities in
different areas. How is a levelplaying field to be set? This is
particularly true for energy
efficient appliances do we know
enough about appliance
performance and how there is
likely to be real variation between
design and final fit out.
(Consultant opinion on allowable
solutions Bristol, January 2010)
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proposed for the domestic sector were seen to have a good degree of potential for non-domestic
buildings, however there were significant reservations over the use of energy efficient appliances.
Over half the delegates thought Allowable Solutions should be available for voluntary take-up at
least from 2016.
Allowable Solutions are used to mitigate the carbon
emissions at the top of the zero carbon hierarchy (i.e.those remaining after the minimum energy efficiency and
carbon compliance requirements have been met). The
intent is to enable flexibility in approaching these
remaining emissions to meet the zero carbon destination
point. In the zero carbon homes definition consultation a
list of possible Allowable Solutions were set out by CLG.
Government is still refining this list. The delivery
mechanism for Allowable Solutions is also currently under
review, as are ancillary, but vital, issues such as how to
ensure the additionality of emissions reductions9.
Although different delivery models are being considered, a single system to cover both homes andthe non-domestic sector has been proposed, which would cover accreditation of the Allowable
Solutions, their additionality over extant emissions reduction commitments and provide robust
monitoring processes. Delegates from the development sector voiced concern at two of the
workshops about the implications for mixed use developments if the same system was not used.
Workshop delegates were asked how much potential each of the Allowable Solutions, set out in the
consultation, had. While most of the proposed solutions were deemed by delegates to have some or
high potential for zero carbon non-domestic buildings, many delegates responded with concern
about the inclusion of energy efficient appliances in Allowable Solutions. It was indicated at most
of the workshops that the extremely wide range of appliances which may be found or incorporated
in non-domestic buildings (as opposed to homes, which have a more standardised range of white
goods, and the like), makes this extremely difficult to assess and regulate. Furthermore, it was
highlighted by several delegates at the workshops that appliances are rarely fitted as part of the
builders works for non-domestic buildings. A few delegates commented in the feedback that
appliances would better fit in carbon compliance (see diagram below).
Similarly, four delegates indicated on their feedback cards that the inclusion of building control
systems was inappropriate in the non-domestic sector.
9 The key to the inclusion of any Allowable Solution is the need to prove that it results in additional carbon mitigationmeasures that no other party claims for. This "additionality" should not be defined as a mitigation measure that wouldotherwise not occur. If it is a technically and financially viable solution then it should occur, with or without a buildingproject, the key is that it is not claimed as carbon mitigation by any other party or mechanism, and ideally does not result ina change to the grid carbon intensity in future updates to the building regulations.
In principle, it would seem
simpler to have a commonapproach. [But] unless we have an
understanding of what the
delivery model is for domestic, we
cannot know whether it is suitable
for non-domestic. (Workshop
delegate comment on delivery
mechanism for allowable solutions
Bristol, January 2010)
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Energy efficient appliances and building control systems should be included as part of carbon
compliance to avoid double counting. (Engineer - Birmingham, February 2010)
Appliances what stops the user taking the equipment out? This will have a minimal impact.
Advanced control systems how do you measure the impact? (Engineer Bristol, January 2010)
Energy efficient appliances and advanced building control systems should be in carboncompliance. (Engineer - Manchester, February 2010)
To stimulate some thoughts around other possible Allowable Solutions that delegates might wish
Government to include in the final list, UK-GBC prepared a few proposals for consideration by the
delegates. These were discussed and voted on by workshop attendees, as shown below.
Some other Allowable Solutions proposed by workshop participants included; the trading of
emissions reductions between properties held across a portfolio; the purchase of CRC allowances;
the linking of adjacent developments or other carbon credits such as through the CleanDevelopment Mechanism or the decommissioning of existing inefficient buildings.
In one form or other at each workshop, delegates concurred with this delegates statement that it
is, crucial that all Allowable Solutions are measurable, reportable and verifiable.
Just over half of delegates were positively in favour of a common Allowable Solutions delivery
model for homes and the non-domestic sector, with delegates from the architecture and design
sector being marginally more in favour of this common approach. 15% of all workshop participants
stated that a separate non-domestic model is needed (with the remainder declining to vote either
way).
Great fan of the energy fund idea, but the regulatory/policing issues are complex. And
getting credit for exporting heat or investing in district heating infrastructure is a very
exciting option for dealing with the tricky issue of heat. National energy fund could be
of interest if there are strong guidelines on what they would invest in and if it has a
social element. (Consultant - London, February 2010)
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TIMESCALE
When asked whether Allowable Solutions should be available for new non-domestic construction
from 2016, of those voters who made a positive choice, over half voted for an introduction in 2016,
but seven delegates specifically stated (in the comment cards) that a 2016 availability of Allowable
Solutions should not mean that higher carbon standards were required before 2019.
Defining the zero carbon destination
Summary: When evaluating whether the zero carbon definition should include unregulated energy
(and if so how much), only 5 % of delegates were against its inclusion (30% of these were
developers). 9% expressed a preference for a flat rate across all sectors. Over half the delegates
thought that each sector should have a different zero carbon end point, with 20% going further,
responding that it should be done on an individual building basis. SBEM was criticized at the
workshops and on numerous comment cards for its perceived inadequacies as an assessment tool
for this policy.
Only some of the carbonemissions from buildings arecurrently covered throughBuilding Regulations. Thereforethe proportion of energy that isnot regulated which is to beincluded in the zero carbondefinition must be calculated10.This remaining energy usage the unregulated energy - coverssources such as computer use,plug in appliances, lifts, aircurtains, external lighting andnumerous other sources. TheGovernment is alreadyconsidering whether some of these (including air curtains and lifts) should be included in BuildingRegulations.
Many delegates commented on the comment cards and verbally with concern upon the use ofthe non-domestic sector calculation tool, SBEM, for unregulated energy due to various assumptionsin the underlying National Calculation Methodology about building usage.
It was highlighted by ten delegates that they felt that the use of SBEM is an imprecise way tocalculate unregulated energy use. Also, the wide variety of building types and uses across the non-domestic sector mean that the unregulated energy use from building to building comparing
supermarkets to distribution warehouses for example - can differ greatly.
Delegates were first asked whether they favoured
including allowances for unregulated energy in the
zero carbon standard. The majority agreed that it
should be included. 55% of delegates indicated
that a sector-specific approach was required to
determine the appropriate level of unregulated
energy to be included in the zero carbon
definition, with one in five stating that it should be calculated on a building-by-building basis. Less
than one in ten delegates thought the zero carbon destination for non-domestic buildings should be
10 For homes, where there is a much more standardised building typology and energy use pattern, unregulated energy usewas taken as a flat 50% of regulated energy. Therefore the zero carbon destination for homes is 150% of the regulatedenergy use for the dwelling.
[There is an] urgent need to update and improve NCM andSBEM to incorporate more of the buildings operatingenergy consumption. (Architect - Birmingham, February2010)
SBEM is too crude a tool in its present guise to give
accurate assessments. (Engineer - Manchester, February
2010)
SBEM is a dreadful simulation tool. It is a compliance tool
only and represents the lowest common denominator.
(Engineer - London, February 2010)
"Do it properly or not at all! A flat rate is
too crude, and open to criticism and it will
also be wrong in most cases."(Workshop
delegate Birmingham, February 2010)
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a flat figure across all sectors. Delegates from the design and architectural fields were twice as
likely to support a flat rate as those from other sectors.
Delegates at the Bristol, Manchester and London workshops voiced the opinion verbally or via the
workshop feedback cards that the policy needs to cover all carbon emissions from the building,
not just a theoretical, calculated rate of emissions.
As a follow up, those who agreed that unregulated energy should be taken account of were asked
about the precise level at which the allowances should be set. 56% favoured a sector specific
approach based on real building benchmarks. 18% said that a flat rate should apply to all building
types (but still determined from real building benchmarks). Less than 5% believed it should be
based on a flat rate of 10% or 20%.
Concerns were raised during two separate workshops by pharmaceutical and materials processing
delegates, in Manchester and Bristol - about the proper accounting for process energy and its
exclusion from the definition.
Zero carbon for public sector buildings
Summary: Over half of all delegates felt that even if all the proposed actions by the government
estate were taken, the public sector would still not be doing enough to drive this agenda forward.
While two thirds of delegates stated that the public sector should begin trialling Allowable
Solutions from 2015, and many others from an earlier date, concerns were raised about the speed
at which any lessons learned could be fed back into the system for the private sector. It was raised
in more than one workshop, and on several response cards, that it was difficult to comment on
these issues conceptually, without having a greater degree of detail on the proposals. Workshop
attendees strongly favoured local government following the central government estate by taking up
the baton of the 2018 ambition to demonstrate their commitment.
In the 2008 Budget, the public sector was set the ambition11 of building to zero carbon standards
ahead of the proposed regulatory timetable, so as to meet the standard from 2018.
The delegates were asked to rate the proposals for public sector action which were set out in the
consultation. Ongoing monitoring and reporting of public sector buildings was rated a top priority
(scoring five out of five) by over three quarters of delegates. All the other suggestions that the
public sector should carry out an exemplar building programme; trialling Allowable Solutions;
testing the financial options for delivery; and showing local leadership and engagement - were alsoranked highly for the progression of the wider policy.
Over half of the delegates felt that even if
all these options were undertaken thepublic sector would still not be showing
sufficient leadership in this arena (with
17% of delegates answering no, they
would not be showing enough leadership
and 36% voting there are other aspects
they could do).
It was felt that without more quantitative and qualitative information, such as the number of
exemplar buildings that would be constructed, it was extremely difficult to answer this question
11This advance-of-regulation public sector commitment covers all new central Government buildings, including hospitals,the defence estate, prisons, courts and schools (although schools are subject to an even more rigorous zero carbon target).The local government estate is not currently covered by the 2018 zero carbon ambition.
Details of build programme and figures forexemplar building numbers would be required
to assess whether the consultation proposals
are sufficient. (Surveyor - Manchester
workshop, February 2010)
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with any degree of certainty. At the Manchester workshop alone, over half a dozen people stated
that they required this additional information before answering.
A majority of delegates felt that the public sector should begin trialling Allowable Solutions very
early to support the development and delivery of the solutions in advance of 2019, with 63%
thinking they should be available for use from 2015. A small number of delegates indicated a
preference for either 2018 or 2019, but of the remaining 29% who indicated an alternativepreference, the comment cards showed an overwhelming preference for a date sooner than 2015,
with numerous calls for ASAP and NOW!, and repeated references to the fact that there was no
time to wait.
It was noted in discussion by several delegates that unless the Allowable Solutions were trialled by
the public sector at least a couple of years in advance of the regulation there would be no time for
the lessons to be processed and fed back into the private sector timetable.
Specifically at the Birmingham and London workshops, delegates commented
that due to the long lead in times for the non-domestic sector, private sector
decisions would have to be made before public sector lessons would have
gone through the machine. The majority of delegates who provided
qualitative feedback on this point indicated they thought this should begin assoon as possible.
CLG was also keen to explore what role local government could play in wider
public sector leadership on this zero carbon agenda. The highest rated option
was for local government to follow the central government estate by taking up
the baton of the 2018 ambition to demonstrate their commitment. At both
London workshops, delegates voiced concerns about the ability of planning
departments to deliver against this agenda if, as suggested, local planning
guidance was to contain details of local Allowable Solutions. This reflected
wider comments at both the workshops themselves and in the comment cards
- about the ability of both Building Control and planning departments to deliver on this agenda.
Other suggestions as to local leadership on this agenda included: a database to link up local
development opportunities for shared approaches to the development of Allowable Solutions; local
communities running Allowable Solutions schemes as social enterprises; a local carbon tax gathered
through business rates. Training needs were also a strong theme, with delegates suggesting more
needs to be done to help architects, developers and installers gain new skills to build to zero
carbon standards, and then also for Building Control and Planning Officers to be able to assess more
complex projects.
It was pointed out by a few delegates that they felt public sector control over district heating
networks would conflict with a free market approach.
Cost impact assessment
Summary: 84% of participants had read little or none of the Impact Assessment before their
workshop. From this starting point, 76% of delegates felt unable to answer whether they felt the
approach used to model the costs was reasonable, or disagreed with the approach that had been
taken. Only 12% of participants actively stated that the cost build up was about right for their
sector. A few participants both in the workshops and in subsequent qualitative feedback, stated
that they found it impossible to split the cost factor out of their decision-making process in
delivering zero carbon non-domestic buildings.
For the purposes of the workshop process, it was decided to separate the cost implications of thezero carbon ambition out from the deliverability. Delegates were asked firstly to respond to the
ASAP! Thisneeds tohappen inorder for the
feedback tohelp otherbuildingsmake thetransition.(Productmanufacturer- Manchesterworkshop,
February 2010)
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questions as to the technical achievability or the suitability of various elements of the proposed
policy. In the latter stages, the issue of costs was then approached separately.
The Impact Assessment12 (IA) was carried out to understand the relative base
cost (by indicative building type) of the policy and to consider the costs of
achieving various energy efficiency and carbon compliance scenarios. 61% of
delegates who had read the IA previously felt that the guidance for the ImpactAssessment was spot on, while 100% of delegates from the development sector
felt that it was too complex.
As was done at each stage of each workshop, the
technical presentation team from Arup took
delegates briefly through the policy and
methodology used - first, the cumulative cost and
carbon savings for increasingly energy efficient measures, and then
the costs associated with low and zero carbon on-site technologies
to reduce overall carbon emissions.13
It was difficult to draw strong threads of opinion from the delegateson the costs issue as 70% of participants felt unable, with the information they had considered in
advance together with the workshop presentation, to indicate whether the approach was
reasonable.
There seemed to be a marginal increase in opinion that the costs were about right among
workshop participants who had been involved with either domestic or non-domestic development
from start to finish.
After the second London workshop, following
discussion of the costs component, delegates
were asked to once again indicate what level
carbon compliance should be set at. While the
favoured view was still to take a balanced
approach, there was a shift, after the costs
explanation, from the onsite rich to the offsite
rich scenario (from 36% and 11% respectively to
23% and 21%).
Delivery and next steps
Delegates were asked about delivery mechanisms and next steps. A common theme through both
the workshop responses and the post-workshop feedback submitted was that the systems for non-domestic must fit with housing solutions. Not be same as, but must fit with.14
Delegates were asked to provide their opinion as to how important various factors would be in the
practical delivery of the zero carbon ambition. All the factors considered, namely roles of Building
Control and Local Planning Authorities (LPA); completed demonstration projects; improved
construction industry skills; zero carbon to have clear financial value in the market place; improved
assessment tools; mechanisms for capturing operating costs benefits; and a joint
Government/industry body were deemed of real importance in delivering against this agenda.
12 http://www.communities.gov.uk/publications/planningandbuilding/newnondomesticbuildimpact13 The allowable solutions component in each scenario was calculated on a presumed cost per tonne of carbon. Under the IAmodeling, different building types end up with the application of different sets of energy efficiency measures, andrenewable energy generation capacity.14 Quote from delegate during London morning workshop
Some too high (retail),
some too low (offices). It
generally doesnt seem to
be based on reality.
(Developer comment -
London workshop,
February 2010)
I believe there is a real financial value
in zero carbon but this isnt a universal
opinion in my sector. Demonstrating thevalue with real examples would sway
this. (Workshop delegate Bristol,
February 2010)
This doesnt make
sense. Anything can
be done. It is just acase of what it costs
to do it and whether
it is good business.
(Workshop delegate
at Bristol workshop,
January 2010)
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However, it was raised by several delegates in their post-workshop feedbackthat both BuildingControl and LPA had vital roles to play, but concern was raised about the capacity of both to
deliver. In the qualitative feedback, mixed views were expressed as to whether a body such as the
Zero Carbon Hub was needed to oversee delivery for the non-domestic sector.
At both the Birmingham and the first London workshops, participants raised concerns about how
tensions would be resolved between national schemes (commenting that the Merton Rule led to
uncertain outcomes) and local delivery.
Conclusions
KEY MESSAGES
1. The non-domestic sector is embracing, rather than rejecting, the zero carbon challenge.Participants were generally strongly in favour of the drive towards zero carbon non-domestic
buildings, subject to the issues raised through the report. The workshops themselves were very well
received with 85% of participants rating them as very good or excellent. Asked after their
participation in the interactive workshop process, 65% of delegates thought that the complete
package of measures provided them with clear guidance on the direction of the zero carbon policy,
and felt they were supportive of it. Only 7% indicated a lack of support for the policy, though
around 30% were unsure or needed more information.
2. The zero carbon definition developed for homes is a good basis for the zero carbondefinition for non-domestic buildings provided that it is intelligently and sympathetically
adapted to meet the specific needs of the non-domestic sector.
In terms of the responses to the substantive aspects of the zero carbon non-domestic definition,
there were some areas of confluence with the approach taken in the housing sector the
hierarchical approach was favoured, as were the use of an energy efficiency backstop, an onsitecarbon compliance requirement and most of the Allowable Solutions favoured for homes - but also
many areas of divergence notably due to the greater complexities of the non-domestic sector,
requiring differential energy efficiency standards by sector and a wider, more sophisticated range
of Allowable Solutions.
3. Delegates generally did not read the Impact Assessment and did not feel engaged on cost-related issues
Delegates felt there was insufficient cost information to evaluate (even in high-level strategic
terms) the cost impact of zero carbon on the various construction industry stakeholders. The
presentation of the cost assessment information was necessarily brief, given the time available and
the complexity of the modelling and impact assessment. This may explain the lack of properengagement on these issues, and as such there was no strong steer on the approach taken to assess
the costs and benefits.
I dont think Building Control and Local Planning Authorities (LPAs) can do this very
well. They are under-skilled and under-resourced. (Local government representative -
Manchester workshop, February 2010)
Enforcement by Building Control will be critical. (Workshop delegate - Birmingham)
Just expand the Zero Carbon Hub to cover non-dom buildings. (Services engineer -
London workshop, February 2010)
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Before the workshops, less than a third of delegates had read most or all of the consultation (and
only 10% had read an equivalent amount of the IA), but two thirds of participants still considered
themselves somewhat familiar with the zero carbon policy, although not as experts (only 6%
admitted to having no knowledge). Of the workshop participants who had read it, 60% found it at
least reasonably clear. However, there was a strong indication, both at the workshops and in the
qualitative feedback, that the way the Impact Assessment is presented does not easily correlate to
the way the construction industry members themselves would go about analyzing costs.
ENERGY EFFICIENCY
Although split on the precise details, over 90% of delegates were supportive of a challenging energy
efficiency standard. Over 70% thought that this should be differentiated approach by building type
(as is planned for future Building Regulations).
CARBON COMPLIANCE
The most popular approach for the carbon compliance standard was to take the middle ground
balanced approach. More than three times as many delegates favoured the on-site rich scenario
over the off-site rich scenario, despite the fact that the latter is seen as the least cost option.15
ALLOWABLE SOLUTIONS
Of the participants who answered positively, almost 80% supported the same delivery model for
Allowable Solutions as for homes.
Most of the Allowable Solutions proposed for the housing sector also found favour with the
delegates for the non-domestic definition, but there were numerous concerns over the inclusion of
energy efficient appliances in this area (and to a lesser extent, advanced building control systems).
There was general feedback that a wider range of Allowable Solutions (including off-site electricity
generation) would be needed for the non-domestic sector compared with the residential sector.
Over half of participants saw a benefit in being able to trial Allowable Solutions from 2016, ahead
of regulation, with strong support that the public sector should do so even earlier.
VOTING PATTERNS
Over two thirds of participants had been involved in a low energy development (either in housing or
non-domestic), or are considering one at the moment. However, it was notable that except for a
few instances indicated through the report, there was little marked difference in the voting results
for those delegates with hands-on experience. Similarly, there was no significant regional shift in
the voting results.
15 As noted previously, at one of the London workshops, this balance shifted slightly towards the offsite rich scenario whenthe delegates were asked the same question again after having had the costs section explained
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Appendices
1. Compiled comments cards submitted by workshop delegates2. Workshop presentation as delivered to delegates163. Combined voting summary from all workshops4. Voting summary Bristol5. Voting summary Manchester6. Voting summary Birmingham7. Voting summary London 18. Voting summary London 2
(See separate Appendices file)
16 The presentation was refined throughout the course of the first couple of workshops, and the presentation as appended, isthe final version