Andrew Eagles, Managing Director of Sustainable Homes, analyses the recent government announcements on Allowable Solutions – an article which was published by Sustain magazine on 15 July 2014.
Seldom has a phrase more unbecoming to the Crown’s dignity been uttered in the course of the state opening of Parliament than the phrase dreamt up by policy wonks and Whitehall mandarins to describe an alternative approach to zero carbon homes.[We] saw the publication of the Government’s long-awaited response to the consultation on‘allowable solutions’ – that is, developers off-setting their obligation to build to zero carbon from 2016 by paying for measures ‘off-site’. Indeed, several speakers at Zero Carbon Hub’s conference [on 8th July], which also saw the launch of the Hub’s report on the ‘performance gap’ between theory and practice (design and as-built) for sustainable homes, remarked on the incongruity of its passing from the Queen’s lips in May.
But Allowable Solutions could be much more than a ‘get-out’ for developers to sidestep the complexity and investment of achieving the equivalent of level 5 of the soon-to-be defunct Code for Sustainable Homes, as some have characterised it. If the right incentives are in place, there is a real opportunity to kick-start some major retrofit schemes around the country. Mechanisms and their detail were largely absent from the Government response; there was no decision, for example on the price of carbon –crucial to determining the value of the carbon reductions that can be achieved. As the response acknowledges, this needs to be set at a level which will make a real impact, whilst at the same time not being so onerous as to defeat its purpose and discourage new homes being built.
This lack of detail, however, should be seen as an opportunity. For starters, and in light of changes to the Energy Company Obligation, there are dozens of retrofit schemes around the country that have the potential to be brought back to life, and are in-effect ‘shovel ready’. It should be hoped that by 2016 this will no longer be the case, but the job of work should certainly start here if it is. Next, let’s make sure that parties that are willing and capable to deliver schemes – be that housing associations, local authorities or even (with support) community groups – can access the resources to do so. And finally, let’s think about putting some of the value into the swathes of stock all over the country that we know will be the hardest to reach – namely owner-occupied and private rented properties – through the Green Deal. This could even be done by locality, so that a development on one side of town pays for home improvements on the other, thereby further ‘sweetening the pill’ for development.
Underpinning all of this is the desire that retrofit schemes for housing are prioritised over all other forms of carbon abatement. This, surely, has to be up there at the top of the list as the ‘point’ of allowable solutions, namely zero-carbon homes: whether they are newly built or not is beside the point. What is the ‘case for’?
Firstly, and as is starting to gain a hearing among policy makers, the UK is massively behind in the task. We need to be undertaking northwards of 13,000 ‘deep’ retrofits per week to be in line with the 2050 target we have set ourselves for reducing emissions. Right now our rate is close to zero. Secondly, and quite apart from any lofty target, it is a job which has to be done at some point – so why kick-start it now? Third, by linking retrofit with new build, which commands so much attention, we can start to shine a light on the fact that existing stock is by far the biggest barrier to creating green homes. Fourthly, and as is becoming a well-rehearsed argument, retrofit is much more than a wonky green buzzword – it means upping quality, reducing bills and improving health.
The confirmed three ‘routes’ to allowable solutions – ‘DIY; whereby the developer finds their own scheme to undertake, a ‘match-making’ service, linking the developer with a third party, and the option of paying into a fund which will then invest in offsetting projects of it choosing. It is this third option which is most problematic, since unless safeguards are put in place, could end up meaning a lot of ‘soft’ schemes are invested in, nothing to do with housing. And as we know from their responses to the allowable solutions consultation and not surprisingly, the vast majority of housebuilders will opt simply to pay this ‘tax’ rather than go through the rigmarole of getting involved in a project.
Of course, such is the disparity in the numbers of new build and existing stock that this is no substitute for a properly funded, nationally driven programme of retro-fitting as an infrastructure priority for the UK, as the Homes Fit for the Future and Energy Bill Revolution campaigns are calling for. But it would be a missed opportunity if we did not do all in our power to harness a mechanism linked with housing supply, as pretty much the top political priority in the UK, towards greening as many homes as we can – and the next few months is the time to do it.