Zero Carbon New Non-Domestic Buildings Consultation Report

7/31/2019 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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2 www.ukgbc.org Defining Zero Carbon Non-Domestic Buildings

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

Documents

Zero Carbon New Non-Domestic Buildings Consultation Report