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Definition of Zero Carbon Homes

ACE have submitted a written response to the CLG Definition of Zero Carbon Homes and Non-Domestic Buildings consultation.

In summary, ACE welcomes the Governments ambition to make all new domestic buildings zero carbon by 2016, and all non-domestic buildings zero carbon by 2019, and is broadly supportive of many of the proposals set out in the consultation questions below.

To minimise the cost of zero carbon buildings, and remove the need for costly retrofits, it is imperative that new homes require very tough energy efficiency standards. We welcome the suggestion that the required energy efficiency standards will be in line with those required by the PassivHaus standard. However, we would have preferred the Government to have made a firm commitment to such a standard at this stage, rather than suggesting it as an ambition.

ACE has concerns over a number of the proposed ‘allowable solutions’ suggested in the consultation. For some, such as energy efficient appliances, it will be difficult to ensure the persistence of the carbon savings, since the appliances can be replaced with less efficient alternatives. For others, there is a real question mark over how the finance provided equates to carbon savings (S106 Planning Obligations), how the ownership of low carbon investments is managed (Investment in LZC infrastructure), and whether investment will be in addition to, or simply replace, investment that was planned in any case (use of the Community Infrastructure Levy).

ACE would much prefer the allowable solutions to focus on retrofitting the existing buildings in the vicinity of the development with energy efficiency measures. Providing that such activity was in addition to, and not instead of that taking place under the post-2012 supplier obligation, such an approach would incentivise the most cost effective carbon reduction pathway whilst helping local residents to reduce their fuel bills, thus fostering support for developments in the first place.

Finally, ACE is concerned that there are no strong proposals put forward regarding non-domestic buildings.

Click here for the full response

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