SC(3) CR-R12
Sustainability Committee
Inquiry into Carbon Reduction in Wales: Residential Carbon Reduction
Response (1) from Swansea Housing Association
General questions
1. Is the proposed 3 per cent annual reduction target by 2011 'in areas of devolved competence sufficient to enable Wales to make its full contribution to meeting UK-wide targets? If not, what targets should be put in place?
More ambitious targets should be set wherever possible provided the risks of failure are acceptable
2. Should the emission reduction target be based on Welsh consumption, or production, or both (ie should it take into consideration the carbon dioxide generated in Wales (production), or the carbon dioxide emissions that Wales' residents are responsible for, regardless of their source (consumption))?
Consumption - to encourage local production and local purchasing
Questions specific to household emissions of carbon dioxide:
3. What particular challenges does Wales face in reducing carbon dioxide emissions from households, and how can these challenges be overcome?
The 'old' stock; to encourage micro generation of all types, seek to remove any planning obstacles for all but exceptional areas; to encourageand promote external and internal wall insulation where this can improve the performance of solid walled homes, and clarify the position of homes that are directly on to the pavement and wish to add external wall insulation.
out of town retail offers; ensure that no more are built;
'in-town' revitalisation / regeneration; co-ordinate activities and actively encourage mixed use developments with substantial residential components to give a local energy use balance.If a town / city centre is being repaved, sponsor a centralised energy centre as one of the major retrofit costs is removing and replacing paving as private hot water mains and private wire electricity cables are installed. Ensure that 'large' redevelopments become 'energy centres' and can serve their surrounding areas profitably by providing energy at below the market costs.
public transport that has high cost for short journeys, a poor image andhas difficultydelivering the frequency and duration required for limited 'car' replacement; Comparitive example; Sketty to City Centre Swansea - £3; return trip across zone 1 in London - £2; Marginal cost of car to city centre and back - 40 pence. The 'sketty fare should be around say a £1 to be attractive. A member of staff tried using public transport where ever possible for a 12 month period. In summery, the experience was that journey times doubled; that places where you wait are not particularly hospitable and generally don't have wifi, and that total 'travel cost' including reduced car use from 15k to 3k miles as significantly greater than car use alone.
Education - after all it is that generation that is likely to most effected.
The temptation to concentrate on 'new build'; I'd like to suggest that the home grown version of zero carbon be slightly more relaxed so that funds can be targeted at more difficult areas for emission reduction.
4. To what extent has the Welsh Assembly Government been successful in utilising the powers available to it in order to reduce household carbon dioxide emissions?
the requirement to meet high standards on Assembly land is welcome.
zero carbon statement is a milestone
RSL's have been building to high standards for some time - and are willing to go further provided costs can be met.
5. Could alternative targeting of Welsh Assembly Government financial resources lead to greater household emissions reduction than is currently being achieved? If so, where could additional resources lead to greatest impact? (Please provide detail to support your evidence).
No evidence, but concentration of resources on existing stock is likely to have greater beneficial impact. Best impact is likely to be achieved by simple solutions, with emerging micro chp generation technologies likely to provide easy rapid emissions reduction. Maximum benefit may be impeded by local electricity distribution issues. Powergen have done significant work in this area and can provide a lot of evidence. Please advise if you need contact information.
6. What examples from other administrations (devolved, UK, and overseas), where other means have been used to achieve reductions in household carbon dioxide emissions, could be adopted in Wales under current powers?
Use of the Passivehaus standard from Germany (there is a Passivehaus UK: http://www.passivehouse.co.uk/.
Use of the R2000 standard from Canada: http://r2000.chba.ca/.
7. In the context of the Government of Wales Act 2006, which further means of reducing carbon dioxide emissions from households could only
be achieved with the introduction of further legislative competence for the National Assembly for Wales.
Devolved Building Regulations.
8. If specific carbon dioxide emissions targets are to be set for Wales, should those targets be subdivided into shares by sector? If so, what share of the total should reductions by households comprise?
Difficult: it is possible to see different requirements being set for different areas; for example, Port Talbot has a lot of energy intensive industries - an incentive for those industries to use their waste energy to supply the local area would have a major impact on both the industrial and residential footprints. It is arguable that targets need to be quite specific to avoid unintended consequences, for example, requiring different 'footprints' for areas where longer distance commuting is a major activity.
If this approach is not possible, you should consider using all your levers to improve the carbon footprintof users where there is notlikely to be an adverseeconomic impact in the first instance.
SC(3) CR-R12
Sustainability Committee
Inquiry into Carbon Reduction in Wales: Residential Carbon Reduction
Response (2) from Swansea Housing Association
General questions
1. Is the proposed 3 per cent annual reduction target by 2011 'in areas of devolved competence sufficient to enable Wales to make its full contribution to meeting UK-wide targets? If not, what targets should be put in place?
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2. Should the emission reduction target be based on Welsh consumption, or production, or both (ie should it take into consideration the carbon dioxide generated in Wales (production), or the carbon dioxide emissions that Wales' residents are responsible for, regardless of their source (consumption))?
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Questions specific to household emissions of carbon dioxide:
3. What particular challenges does Wales face in reducing carbon dioxide emissions from households, and how can these challenges be overcome?
In summary CO2 emissions need to be reduced from the manufacture and supply of construction materials, space and water heating, power for appliances and lighting, water and sewage treatment, and transport.
New developments
For new developments both RSL built residential units and privately built residential units must adhere to the same standards. There are many examples in Wales where RSLs evaluate and implement methods to go beyond the current Approved Documents, particularly Part L of the building regulations, within their schemes. For example, a number of RSLs within the INTEGRATE consortia adopt a core principle of increased insulation standards beyond ADL1a and also the inclusion of renewable energy provision on all their schemes, which has been the case since 2005. The latter includes solar hot water systems and district heating systems. There are very few examples in Wales, where private residential developers adopt methods to reduce CO2 emissions, other than that stipulated in ADL1a of the Building Regulations.
Challenge One
To implement targets to all new developments including land banked schemes, where planning permission may have already been achieved in earlier years. In February 2007, WAG made an announcement that all new buildings should be zero carbon by 2011 (code 6 of CSH), which is very challenging. Perhaps a more realistic target is that of 5th October 2007, the code for sustainable homes and PPS22 should be the minimum standard for achieving planning permission or commencing a project on site, with two routes.
Fast-track route: 2007/08 code 3; 2009, code 4; 2010, code 5; from 2011 code 6.
Minimum route:2007/08 code 3; 2009/10 code 4; 2011/12 code 5; 2013/2014 code 6.
Overcoming Challenge One
The building regulations must be devolved to Wales in 2007/8 and the above targets must be part of Planning Conditions with a condition that where schemes have already achieved planning permission i.e. they are land banked they must adhere to the latest yearly target when construction commences and this should be implemented on the 5th October 2007.
Adopt the AECB energy performance standard by 2011 (Silver) and by 2014 (Gold.
Provide an incentive scheme if projects follow the fast-track route, for RSLs should be increased funding to their ACG allocation. For private developers, this should be through reduced VAT and stamp duty for the purchasers. The stamp duty reduction should encourage increased demand from purchasers for the more ecologically and energy efficient units.
Design standards and calculation methods for building energy use must be improved and as a minimum should include a dynamic thermal model, to replace SAP that illustrates how units perform in worst case scenario climatic conditions (hot and cold) over the lifecycle of the building.
A new pattern book for each code level, that illustrates high performance standards with detailing for reduced energy use.
Mandatory pressure testing on all schemes before a completion certificate can be achieved.
A set number of both private and public schemes should be monitored.
Existing developments
As with new developments, all owners (RSLs, private owners etc) of existing residential developments must follow the same standards and the current ADL1b does not set high enough standards for reduced energy use.
Challenge two
The challenge from the existing stock is enormous and one which poses problems across the UK due to the various age ranges of the stock and the varying degrees to energy saving techniques adopted. The challenge is spread across three possibilities: no improvement, elemental improvement and whole house maintenance or refurbishment is undertaken the challenge is of a lesser obstacle, but where
Overcoming challenge two
Where there is whole-house maintenance/refurbishment either from a private or public owner, such as an RSL, then these units should be brought up to the current code level for that year, as illustrated above in either the fast-track or minimum route.
Where there is elemental maintenance, i.e. the windows are replaced or the roof covering is being upgraded then these elements should be brought to the same standard as outlined in the code level for that particular year. In the case of the roof this should relate to the insulation levels in the roof, ventilation rates and installation of renewable energy system for both space/water heating and power generation.
For both public and private owners grants should be available which can be bid upon to reach targets for space/water heating saving (e.g. evacuated solar tubes), water use saving (e.g. rainwater harvesting systems) and renewable systems for power generation (e.g. photovoltaic cell). These grants should be available to encourage home occupiers to implement improvements, where there elemental maintenance and where there is whole house maintenance or refurbishment.
To what extent has the Welsh Assembly Government been successful in utilising the powers available to it in order to reduce household carbon dioxide emissions?
The SHIP scheme had merits. ? There should be annual round for both new and existing development, as detailed in the response to question 3 above.
The February 2007 zero carbon statement was very brave, the Assembly now needs to act to achieve this requirement following the targets and providing the incentives and grants outlined in the response to question three above.
The land sale protocol will help, although the Assembly should commit further to RSL’s until the private sector meet higher targets.
4. Could alternative targeting of Welsh Assembly Government financial resources lead to greater household emissions reduction than is currently being achieved? If so, where could additional resources lead to greatest impact? (Please provide detail to support your evidence).
Implement the code for sustainable homes as of the 5th October 2007 following two routes.
Fast-track route: 2007/08 code 3; 2009, code 4; 2010, code 5; from 2011 code 6.
Minimum route:2007/08 code 3; 2009/10 code 4; 2011/12 code 5;2013/2014 code 6.Inject funding into the planning and building control process so that Planning permission for new developments is only granted and projects can only commence if proof is provided (to include a dynamic thermal model) that projects meet the current code level for the code for sustainable homes for that year of development.
The building regulations must be devolved to Wales in 2007/8.
Provide funding to enforce land banked schemes to meet current annual code level targets.
Provide an incentive scheme if projects follow the fast-track route, for RSLs should be increased funding to their ACG allocation. For private developers, this should be through reduced VAT and stamp duty for the purchasers. The stamp duty reduction should encourage increased demand from purchasers for the more ecologically and energy efficient units.
Provide funding so that design standards and calculation methods for building energy use are improved and as a minimum should include a dynamic thermal model, to replace SAP that illustrates how units perform in worst case scenario climatic conditions (hot and cold) over the lifecycle of the building.
Provide funding for a new pattern book for each code level, that illustrates high performance standards with detailing for reduced energy use.
Provide funding to implement mandatory pressure testing on all schemes before a completion certificate can be achieved.
Provide funding so that from each RSL consortia and a number of private developments that meet each code level from code 3 are monitored over at least two years of occupation.
5. What examples from other administrations (devolved, UK, and overseas), where other means have been used to achieve reductions in household carbon dioxide emissions, could be adopted in Wales under current powers?
Use of the Passivehaus standard from Germany (there is a Passivehaus UK: http://www.passivehouse.co.uk/.
Use of the R2000 standard from Canada: http://r2000.chba.ca/.
6. In the context of the Government of Wales Act 2006, which further means of reducing carbon dioxide emissions from households could only
be achieved with the introduction of further legislative competence for the National Assembly for Wales.
Devolved Building Regulations.
7. If specific carbon dioxide emissions targets are to be set for Wales, should those targets be subdivided into shares by sector? If so, what share of the total should reductions by households comprise?
??
