Green Deal consultation documents published

[KATE DE SELINCOURT]

The government has finally published its extremely lenghty consultation documents for the Green Deal and associated Energy Company Obligation.

I am hoping to get a 'some things to look out for' companion to the consultation onto aecb.net during next week, but just in case anyone can't wait to start on all 238 pages (plus 298 page impact assessment plus, plus…) they can be found here:

http://www.decc.gov.uk/en/content/cms/consultations/green_deal/green_deal.aspx#ia

And of course if anyone wants to comment, please post here!

Kate de S

[Anonymous]

There is a fundamental problem with the whole of the Green Deal and that is the so called Golden Rule, the idea that savings should outweigh the costs. There are many many issues with the Golden Rule but a simple example will suffice. A high energy using household obtains a loan, and has improvements made to their house, and benefits because their energy bills are overall lower than they would have paid before, indeed the more wasteful they are to begin with and following the improvements the better off they will be. A low energy household then moves in to the same house and has to pay higher energy bills than they would have had to if they had been no improvements. The Golden Rule works best for high energy using households, who one might presume are also least likely to apply for the loan in the first place, and penalises low energy using households.

[KATE DE SELINCOURT]

Thanks Nigel, you're right, a number of people have commented on the uneasy relationship between what a building 'needs', what might be best for particular occupants, and who should pay (as well as Green Deal loans, some grants will be available, but only to certain households in certain circumstances). When you look at the situation of people in fuel poverty (which you may be hinting at too?) it gets even trickier to square the circle.

I must say my initial impression is that DECC have really struggled with this, and are aware its almost impossible to arrive at a 'right answer'. There is certainly a lot of criticism out there of the answers they have come up with to date, but to some extent they do admit they may not have cracked it; so perhaps its up to everyone to pitch in?

We're hoping to get at least some commentary on the consultation up on the AECB news pages by the end of the week, and when its is up there, I'll add a link here too.

Thanks again,

Kate de S

[KATE DE SELINCOURT]

A general introduction to the Green Deal is now on the AECB news pages here:

http://aecb.net/news/2011/12/the-government-consultation-on-the-green-deal-and-the-associated-energy-company-obligation-eco-has-now-been-published-2/#more-2259

No downloads yet, sorry, there should be some available from early next week.

Kate

[AECB admin]

One download now available – Assessment, Advice, Measures.

[AECB admin]

Second download available – Who's who in the Green Deal.

[KATE DE SELINCOURT]

I enjoyed this short video featuring Peter Rickaby and Mark Elton – making a good case for architects to get stuck in to low energy retrofit, and suggesting the possible scaling up of carefully worked-out solutions (which is something I think will be crucial).

Here's the link (also on RIBA sustainability hub)
http://vimeo.com/30381286
tip – if it stops & starts, just let it play through by itself once, while you go and do something else, then play it again!

Kate de S

[KATE DE SELINCOURT]

You can now download all of AECB's 4-part guide to what's proposed in the Green Deal & ECO – we've tried to dig down into the detail for at least some of it, and make it more readable than the DECC original!

The four sections are:

• Who’s who in the Green Deal

  Assessment-Advice-Measures

  Customers – Who Will Get What?

  Who will be doing the work?

And they can all be downloaded from http://aecb.net/news/2011/12/the-government-consultation-on-the-green-deal-and-the-associated-energy-company-obligation-eco-has-now-been-published-2/#more-2259

Hopefully they offer a digestible guide to what is proposed, so you can work out what DECC needs to change, and also understand a bit better if and how it might be relevant to your own work.

[Martin Sherring]

Nigel, presumably the issue you raise (about the measures working for a high-user family, but not for a lower-user family who succeeds them) would be dealt with through the price of the house – i.e. the low-user family would know about the Green Deal charge and would take that into account when they made an offer. At least it would in an ideal world, in reality I'm not sure how much people think about energy bills when they buy a house.

The biggest problem with the scheme seems to me that it just won't deliver. The fundamental idea was that this was going to unlock a huge new market for retrofit, but the research seems to indicate that people don't want a long-term financial obligation, so the only measures that will be taken up are the ones with quite fast pay-back. Meanwhile, there are extra costs being added in for the assessor and the finance, which mean the pay-back has to be even quicker.

[SimmondsMills]

So what are the fundamental tests of 'fitness for purpose' to gauge the GD against?

1. a GHG reduction target and deadline for this sector?
2. Risk – assess risk level that GD wont achieve this target for UK stock?
3. Risk – of unintended consequences – what are the top 10?
4. any more?!

What a complex scheme, that relies sadly on 'the market' alone to deliver.

Obviously we dont have 1 above and the risk in 2 has to be 100% (?), 3 we can manage some of these risks to a degree – but what is the point if we can't achieve 1? If we cant achieve 1 what does that mean for UK energy security, warmth and health.

What do we suggest as the alternative apporach that works at scale to a 2050ish deadline?

or lets just agree to be cold and in fuel poverty (I wont be as I'm already in an EnerPHit home)

We can demand that those aecb members with the ability, be supported in doing a good job at small – medium scale retrofit (ripple effect, exemplars, best practice, shared learning, models to follow etc) but we obviously need to say 'the emporer has no clothes' yet suggest an alternative that works for the UK on a large scale.

I will try and articulate this with David Olvier and get up here on the forum, also finding yoru comments below useful, keep em coming.

Tell me if I am avoiding the detail of the GD and should be engaging more with it, rather than moving straight to the big picture stuff….

[Paul Buckingham]

I think the big picture stuff is very relevant, the GD is really only offering an idea of what could be achieved if everyone takes on the scheme and all who work on it really know what they are aiming to achieve! The big picture is that we all need to do something now (apart from Andy who's already done it! ;D) if we want to live in warm comfortable homes in the future without having to rely on loads of energy.
I very much doubt that the GD is the definitive answer and it will probably be replaced in due course with something else that will also achieve very little. The main driver for energy efficient refurb en-mass in the future will not start to kick in until we start to run out of energy, experience power cuts and gas shortages and energy bills need delivering by lorry. We only start to make changes when we actually have to (when it starts to hurt) not when we are told to or can by choice.

Paul.

[Philip Newbold]

Kate et al,

As you will have read in my Soapbox article, I am afraid that the Green Deal (and all the other supposedly energy-saving initiatives) are just Government con-tricks devised to make the UK electorate and other countries think that they are doing something about climate change. I know that the AECB is an adult organisation that has to be seen to be offering constructive input but in my forty years in the construction industry I am still waiting for the first Government action that will make a significant contribution to reducing energy use in the built environment. The buildings we are erecting now to current regulations are, with a handful of admirable exceptions, badly designed and badly constructed by a de-skilled workforce, poorly insulated and full of holes. I agree that we should offer comment on the Government's hollow, short-term proposals but we should not lose sight of the fact that the current benchmark for construction standards in the UK is abysmally low and that lobbying by vested interests in the energy and construction industries will always carry much more weight with millionaire Ministers than anything proposed by those of us who actually want to make a difference. Recent attempts to overhaul planning regulations have shown us where the real power lies.

As you are all well aware, many older properties that we would aspire to upgrade to reduce energy consumption have exterior materials and/or architectural features which make a significant contribution to the local vernacular. Internal insulation reduces room sizes and leaves the existing fabric cold and damp. Our draconian, conservation-based (though not of the 'energy' variety) planning legislation prevents the addition of external insulation and triple-glazed casement windows and ensures that in all but the poorest areas, we are permanently condemned to pump energy into largely uninsulated, leaky, masonry structures which are often doubly cursed with huge, single-glazed, double-hung sash windows. In fact, so popular is this practical but grossly inefficient fenestration style with planners in some areas, they even insist on fitting them in new dwellings. I am faced with this very problem with my own self-build Passivhaus project in Weardale. Until we have a drastic overhaul of planning legislation, particularly the conservation zealots who want to preserve everything in aspic, the aspirations of the Green Deal will remain just that, aspirations.

I can understand the architectural value of Conservation Areas and Listed Buildings but soon homes within these categories will either be occupied solely by the very rich who can afford the astronomical fuel bills or they will stand empty and un-heated. Add to this the problem of semi-detached and terraced dwellings or flats in multiple occupation and you soon realise that the application of external, insulated cladding for retrofit upgrading can only be considered practical in a very limited number of cases. The prime candidates for large-scale upgrading are the streets of empty homes shown recently by George Clarke on Channel 4. In many northern UK towns and cities, whole streets of (usually) terraced and semi-detached, habitable houses have been emptied and abandoned, pending demolition, as a result of misguided and failed Local and National Government housing renewal initiatives. These substantially sound homes, most with little architectural merit, should be our main target for Passivhaus EnerPHit upgrading. The highways and services infrastructures are already there and even though they may currently be unattractive and/or in undesirable locations, the combination of a modern, external make-over and very low fuel bills would soon attract new occupants. It seems to be a no-brainer but as most of these abandoned homes belong to the Government, nothing sensible is likely to happen anytime soon.

As Alex Hunt has already mentioned, the Green Deal will end up lining the pockets of a handful of financiers, insurance companies and other parasitic hangers-on, all at the expense of ordinary folk. As we have seen with the FiT debacle, if the various Government bodies can manage to cobble together a deal for home-owners that does encourage an increased take-up of real energy-saving measures (as opposed to energy-generating ones), subsidies and grants will be short-lived and soon withdrawn. Looking at the current (so-called) energy conservation initiatives that receive subsidy from Government (ie. you and me through taxation), they are all predicated on generating more energy (electricity) from expensive renewables rather than reducing consumption with cheap insulation. Alterations to existing buildings still attracts 20% VAT and there are no direct Government incentives currently available to construct a new building with better energy conservation performance than the pathetic requirements of Part L of our Building Regulations.

I will continue to campaign for the adoption of Passivhaus standards for new build in the UK and I shortly hope to demonstrate, by example, how we can build real low-energy, traditional-looking homes on a tight budget. Unfortunately, this will have to be achieved without any help at all from Government energy conservation incentives. By all means let's provide our expert opinions on the likely success, or otherwise, of the Green Deal our but let's not kid ourselves that anyone is really listening in the Government.

[J3 Building Futures]

Do I take it that the AECB intend to present the more salient points of its members to DECC as a combined response?

I just don't have time to read and respond to the document (like who does?) and I suppose I'm hoping someone will represent me instead!

My concerns regard being or becoming an assessor, the quality/independence of the advice given, and the long or even medium term effects of the measures installed.

I/we have been involved in the audit/assessment and retrofit of buildings for 8 years, a figure that no doubt pales into insignificance compared to some AECB members, and yet it seems that this experience, this dedication to the cause, may not be taken into account – it really must be! We are they who have the knowledge and the experience, and we are largely independent. We are also, I suspect, more likely to be SMEs or OMBs and less likely to be able to afford yet more accreditation. I have spent £10k on my Environmental Architecture education to date, when will it stop???

Not only will this approach potentially price the innovators and most experienced out of the market, it will also very much price the Big Boys in, and I have no faith whatsoever that the Big Boys will be able to provide the same independent, specialist, quality advice. So what happens in 10 years time when all those homes that Kingspan has advised are having problems with rot and mould and damp and asthma?

When we design and build buildings we all adhere to a set of standards called Building Regulations. We do not have to complete courses to become Accredited Building Regulation Comprehenders – so why must the Green Deal be made all the more complicated? Why not simply publish a simple (ha!) set of regulations to which all must legally adhere? Or is it that accrediting people will make DECC some money?

Another concern of mine regards planning and conservation officers – will they all be sent on courses to educate them as to how important this stuff is? Because in my experience 18th century cornicing trumps internal insulation everytime, and a subjective perceived aesthetic will always beat double-glazing, no matter its undoubted quality and ability to safeguard the place for another 200 years…

(Also, why are oil-fired boilers covered? I don't get that..)

[KATE DE SELINCOURT]

I have carried out a 'thought experiment' on tackling fuel poverty via the ECO (and also, by using the solar FiT) and come to the conclusion that the government is onto a hiding to nothing trying to place the costs of these programmes onto fuel bills. See http://aecb.net/news/2012/01/fit-and-eco-are-never-going-to-solve-fuel-poverty/ ; because the more you try to fix fuel poverty though fuel bills, the worse the poverty gets. I conclude that the ECO should be left to tackle carbon/energy use, and fuel poverty should be separated out to its own, clear, funding stream.

A contact at CSE Bristol assures me that it is perfectly possible to carry out an integrated 'on the ground' energy refurb programme, while drawing in funding from various sources (this is what they do all the time!) – and in fact this is what the ECO is supposed to do anyway, though Govt isn't currently proposing to put any more resources in itself, they are hoping it will be topped up with Green Deals and local govt / charity grants.

Meanwhile we still have the centrally funded Warm Front programme (cavity, loft and heating programmes for benefit recipients). Though this is due to be axed and 'replaced' by the ECO there seems to me an extremely good case for retaining it, and indeed beefing it up. This is what I'll be suggesting in my personal Green Deal response, and I'd like AECB to say the same in the 'corporate' response: anyone have thoughts on that?

[SimmondsMills]

Frustrating – if we want to insulate a building using the well known and effective larsen truss idea (or other robust IWI or EWI methods), installed by the contractor, self builder etc, we wont be able to get ECO funding on it. This is a brake on innovation and also reduces peoples access to potentially lower cost solutions, as well as being prescriptive in terms of materials used etc.

Jeremy Richings advice on what the GD says on this is useful:

“Our reading of the current consultation documents, etc., suggests that with Green Deal & ECO funded schemes, EIW/IWI systems that are supplied under GD/ECO must carry third party accreditation provided by a UKAS accredited body, such as BBA or BRE. CE marking is not a requirement for EWI systems since at the present time there is no harmonised European standard for such systems.

For EWI systems, the European Technical Approval Guidance ETAG 004 forms the basis of the testing regime that many proprietary EWI systems follow as a route to achieving, for example, a BBA or BRE Certificate in the UK.

Even under the current CESP/CERT funded programmes, third party certification through BBA or BRE is a requirement for EWI systems, and Ofgen carry out checks to ensure that systems being used under these funding arrangements have the necessary compliance.

For GD/ECO, in addition to systems being required to be suitably accredited, the installers of these systems must also be assessed by the approved body (BBA) and registered as Installers for the particular system that they are installing. System suppliers must provide training of the installers, and be able to provide method statements, details of the system installation to BBA.

There is to be a Green Deal Register which will be a register of all products or systems (e.g. EWI systems) that have been declared (via a third party accreditation route) to comply with the GD Code of Practice, and a Product Performance Database which will record those products/systems that have had their performance verified by a 3rd party (BRE/BBA etc.)

Therefore, using a non-proprietary iwi or ewi approach is likely to be problematic unless it is tested and assessed to the same level and standards as proprietary systems. The Insurance-backed Guarantees that Green Deal providers are obliged to provide will almost certainly necessitate that products/systems are fully tested/assessed so that they can reasonably claim to be of a satisfactory quality and fit for purpose and such products and systems must be listed on the Product Performance Database and Green Deal Register

Jeremy Richings (Dr.)

Technical Director

PermaRock,

[SimmondsMills]

It prob also precludes at the moment, insulating lots of wall types that UK is full of, TF, steel etc, and sets the thing up for larger companies to invest in the required testing etc.

we need an affordable calc method that allows us to prove our case w.o. major costs so becoming eleigible for ECO funds.

ideas?

[Alex Hunt]

Yes agreed. I said in my draft re consultation that there is no need for yet another layer for Green Deal accredited materials because BS, Codes of Practice, CE, BRE, already cover standards comprehensively. Indeed BRE are forming their own 'Green Book' as a specialist list, and I should add in for our GD statement that there are other sources like Green Spec that have been around awhile and deserve much credit.

Andy S is worried about even the restrictions of BSs etc, and can understand this as a lot of green building is of necessity experimental and basic so not part of the established construction industry. Same for us when we were trying to use hand-tamped hemcrete.

Jeremy R is right on in his last paragraph especially – anything likely to get a generic GD warranty, as is proposed, is going to have to meet at least the normal industry standard checks. The hope is that most green material manufacturers are going to be pulling out all the stops to get stuff certified if GD comes anywhere near selling green upgrades in quantity.

However I think big danger flags should be raised over how the GD is going to lay on another new bureaucracy by setting up its own methods and materials list – a very lucrative possibility for someone with influence over this – Tesco/Marks&Spencer/Wickes/B&Q?

Another point is that don't we already have a method for demonstrating thermal efficiencies? the U value? Doesn't this then get used in SAP/PHPP etc. and allows inventive detailing? Don't we already use this in Building Regs to prove their validity, just needs values raised and isn't there another improvement on the cards in 2013?

All this layer upon expensive layer of red tape is enough to send anyone crazy and will inevitably just mean people avoid doing anything at all?

???

[Anonymous]

Frustrating – if we want to insulate a building using the well known and effective larsen truss idea (or other robust IWI or EWI methods), installed by the contractor, self builder etc, we wont be able to get ECO funding on it. This is a brake on innovation and also reduces peoples access to potentially lower cost solutions, as well as being prescriptive in terms of materials used etc.

Jeremy Richings advice on what the GD says on this is useful: [snip]

…

Therefore, using a non-proprietary iwi or ewi approach is likely to be problematic unless it is tested and assessed to the same level and standards as proprietary systems. …

Absolutely. It sounds like you might also appreciate why a lot of people got wound up about the way MCS rules destroyed the DIY approach to solar installations.

But what Kate says about fuel poverty and associated issues is much more fundamental. There is an issue about how we reduce carbon emissions. There is an issue about how we overcome poverty, of all types, among our citizens. We have to deal with both those issues, but it is important that we keep them clearly identified and separate. Trying to solve one with special rules about the other is a road to madness and despair.

[SimmondsMills]

The AECB we are thinking will invest properly this year in working with and suppporting member companies to show how to do the green deal the 'right way'. We are starting to think about this behind the scenes – but the need seems clear. It would involve workling with alternative financial providers of finance for measures….

[Alex Hunt]

Congratulations Andy, that's a fine response and more comprehensive than ours (equally beset by time problem), but pleased to say we will complement and certainly not contradict anything you've said. We're nearly there, a few typos and a missing negative (!) but should get it in ok and will publish here too.

PS This process has at least created a lot of response. I haven't yet read one that overturns my impression that this whole Green Deal eruption is just to disguise a new mortgage vehicle as a social benefit. – Fran

[Alex Hunt]

Hi,
so we have just submitted our own response to the DECC consultation.

If you'd like to read it – please download from this link:

http://dl.dropbox.com/u/9496539/GreenDeal_GBPResponse.pdf

Cheers – Alex

[Frances Bradshaw]

Thanks Andy, I think you have said it all!
Fran

[KATE DE SELINCOURT]

Yes indeed, it all needs saying. And Alex your GBP response is excellent – detailed and professional. I think there are going to be quite a lot of very good responses going in to DECC, judging by what's 'out there'. I wonder if it will have an impact. It has to, surely? Lets hope the suggestions can be brought together as the basis for “Son of Green Deal” (or daughter, better yet ;)) …

[SimmondsMills]

Thanks to Kate De Selincourt and Mischa Hewitt for driving and supporting this in getting an AECB response together!
If anyone else made a response (like the great one from Green Building Partnership below) then please feel free to upload them here on this forum for others to see.

[SimmondsMills]

Ecology Building Society response here

[Anonymous]

I know I should read the responses and I promise I will, but its Friday and I've had too many glasses to concentrate, so all I'll say is:

Well said, Alan !

[Alex Hunt]

Hi All,
thought you would all be interested in the RIBA response to GD.

The role of a “Green Deal Project Manager” seems an incredibly sensible idea.

Alex

[Paul Buckingham]

I think the GD could only work with independent GD Project Managers, there are numerous builders out there who would want to jump on the GD band wagon but, from my experience, energy efficiency really seems to be the last thing on their minds.
Putting GD Project Managers in control of each installation would open the market to many builders and also through proper management would help to develop a vital strong understanding of what energy efficiency is all about. The problem with the majority of builders currently is that they do just enough to scrape through building regulations requirements without a full understanding of what they are aiming to achieve. With proper PM by someone who is fully up to speed on the why's and how's of energy efficiency, builders will gain the knowledge that is seriously missing within the industry today.

[Author]

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