Comment - Allowable Solutions

Colin Morrison
Director of Sustainability
0121 233 0902
[email protected]

We finally have the Allowable Solutions consultation document, which is a crucial part of the Zero Carbon Policy.

Has the delay been worth it and does this give us renewed confidence in the policy or simply leave us with more questions (51 to be precise) than answers?

For some time now, there has been considerable lobbying from industry for the Government to provide clarity on the Allowable Solutions Policy.

Rightly so, given that it is now estimated to cost the housebuilding industry an additional £224* million every year.

This is a substantial ‘in’ in the context of the red tape challenge of ‘one in, two out’. So to compensate, house building needs one or more major ‘outs’ to balance costs and ensure we do not derail the growing recovery of the house building sector. Could we see these ‘outs’ coming forward in the keenly anticipated, but also delayed, Technical Housing Standards Review?

Allowable solutions is arguably the most complex and ambitious part of the Zero Carbon Policy. Given that we are only three years away from implementation, the industry needs as much certainty and clarity as soon possible to budget and plan for this policy and Zero Carbon.

On the positive side, we now at last have the Government’s thoughts on the possible structure, price and direction of allowable solutions.

This may go some way to informing the growing number of local authorities that are establishing their own carbon abatement programmes. Our experience of such schemes confirms a wide range of existing and proposed carbon abatement projects and an equally diverse range in the cost of carbon. Without guidance, this will continue unchecked given the number of allowable solutions policies coming through in Local Plans.

The consultation attempts to provide some clarity to house building by:

The consultation raises some interesting questions including the possibility that house builders could ‘bank carbon savings’ by building to higher standards of Part L on extant planning permissions before 2016. This is worth further exploration, particular to those with extensive development portfolios.

The spatial criteria are also interesting. There could, indeed, be some advantages to delivering allowable solutions in the locality of development, but allowing projects across the UK does open new possibilities and geographies.

Efficient delivery of allowable solutions is critical. The policy should deliver maximum carbon savings for minimum costs (including administrative). Of the Government’s suggested delivery options – a private sector driven matching/brokerage service could, in theory, offer a simple and quick route to identifying the most costeffective allowable solutions projects. Such a system, however, will need to be in place in advance of 2016 which in turn will require considerable investment to ensure the system is up and running with sufficient time to trial. Like so many aspects of this policy, considerable work (and certainty) is needed to encourage this innovation and investment. On the positive side, this should create strong competition to drive down the carbon price.

Any one of the 51 consultation questions could justify an extended debate which is, of course, important to ensure that the Government receives a thorough consultation response.

If the Government’s strategic ambitions of a ‘commercially and technically viable’ Zero Carbon Homes Policy are to be met then it must work with industry and respond quickly to this consultation to create a workable, efficient and deliverable policy. There is a huge amount of work to be done in a very short space of time. We look forward to contributing to the debate.

Download

You can read the full article as a downloadable pdf here.

Allowable Solutions