The principle, developed by the Zero Carbon Hub since 2008, is based upon the fact that on many sites it is infeasible to improve the envelope sufficiently that all regulated energy uses can be provided by on-site green and renewable energy production methods. It is proposed, that once you have proven you have done all you can, in compliance with Part L fabric efficiency requirements, that there is a level of carbon that is required to be abated using Allowable Solutions. The consultation focussed on the type of solutions, the delivery of them and a price cap.
When the consultation on this began in 2008 the proposal was for Local Authorities to guide the Allowable Solutions so they were more strategic projects, such as CHP or heat networks linking different developments, tied into Local Development plans. The documentation seems to have changed focus since then to concentrate on a market based approach where private companies, offering AS verified projects across the UK, compete under a ceiling price to 'buy' housebuilders carbon abatement Allowable Solutions obligation.
Our concern with this approach is:
1. The lack of strategic planning and focussing of funds to projects that will benefit communities. For example, setting up a heat network that would benefit several different private developments would be harder for a private company to invest in that an offshore wind farm in Scotland.
2. The possible lack of incentive for housebuilders to work harder to provide more energy reduction using on site methods.
3. The difficulties in verifying carbon savings achieved by a specific project and setting an appropriate sanction in the event that a project fails to deliver.
4. Carbon abatement projects are proposed to have a paid lifespan of 30 years. However, homes that are designed to reduce energy use on site and allow their occupants to enjoy living in them provide value for much longer periods than this. We need to jncentivise better quality housing in the long run.
5. By effectively privatising the provision of AS, the cost of these changes will inevitably be passed onto the homeowner, further exacerbating housing affordability issues.
We have made our comments and will review the results in the next issue of the documentation.