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A Low Carbon Building Standards Strategy for Scotland (The Sullivan Report) - 2013 Update

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Eventual and Staged Standards - Ambition and pace of change

We revisited our recommendations made in 2007 for a staged progression towards 'net zero carbon' new buildings in 2016/17, discussing both the Scottish Government's divergence from that route map and the reasons for this divergence.

In acknowledging the introduction of the Climate Change (Scotland) Act 2009 and its legally binding greenhouse gas abatement targets, we recognise that balancing action towards meeting climate change targets and supporting continued economic growth during a period of economic downturn is essential. Our level of ambition has not changed but we consider this must be moderated to reflect the economic climate and downturn in construction. We also recognise that, as less new building is taking place, greater emphasis is needed on energy and carbon improvement to the existing building stock.

For the next staged improvement, we recognise that the proposals within the recent energy consultation[1] are beyond the scope of this Panel. However, we judged that it was still relevant to discuss the timing of this next staged improvement. Some Panel members emphasised the potential impact, on development and investment, of standards which are more challenging than those elsewhere in the UK, particularly during a period of recovery from recession.

We also deliberated on whether a longer lead-in time would allow the industry time to prepare for changes whilst continuing to build on the momentum achieved since we last reported. There was support for this approach, which would also help maintain economic recovery in the sector and provide greater opportunity to prepare for and deliver change.

Looking beyond the next change in standards we considered the European commitment set out in Article 9 of the recast Energy Performance of Buildings Directive[2], for all new buildings to be 'nearly zero energy' from 2021, or 2019 for new non-domestic public buildings. We deem that this sets a timetable for subsequent review of energy standards.

In our 2007 Report, we recommended staged improvements programmed for 2013 of 75% reduction in carbon dioxide emissions for non-domestic buildings and a 60% reduction in carbon dioxide emissions for domestic buildings, when compared to 2007 standards. We consider that further investigation into these levels is still required in support of both the Scottish Government's climate change agenda and the EU requirement for 'nearly zero energy' new buildings. However, future review must continue to recognise the practical and economic conditions that apply.

Furthermore, we noted research would be needed to assess if such levels of carbon dioxide emissions reduction would meet or exceed requirements for 'nearly zero energy' new buildings. We consider that this may also require review of how energy and emissions are presented within the standards. We discussed whether this staged improvement could be aligned with the timing of this European obligation. The Panel noted that work with the UK Government will define 'nearly zero energy' for new buildings, to inform future review.

We reflected on discussions on 'Allowable Solutions' (see 'Process' topic) and support investigation of this concept to address remaining emissions and enable a 'net zero carbon' standard for new development to be delivered.

Ministers asked us to consider whether departure from our original recommendations on staged standards has resulted in 'lost opportunities' to deliver emissions abatement. Discussion highlighted the challenges of constructing in the current economic environment. It was suggested that not constructing new buildings also reduces overall emissions. However, we agreed that, although correct, this is not a desirable outcome from a social and economic point of view. On this basis, we agreed there is no need to further explore these issues in terms of any perceived shortfall.

On skills, we discussed and agreed that a skilled workforce is key to the successful delivery of improved standards. Recent years of recession have also resulted in job losses within this workforce. We thought that slowing the rate of improvement would provide additional time for the industry to develop and implement the skills needed to support low carbon buildings. This is an area where we consider there is a need for continued action and leadership both by government and industry.

On the energy performance of new buildings, we also confirmed the need to better understand potential performance gaps between designed and as-built performance and the factors which can contribute to this. Industry and government should work together to gather evidence on the factors which can affect performance to support action on this topic[3]. We noted the Scottish Government intends to work on this as part of the ongoing review of energy standards.

We also believe that the early availability of the National Calculation Methodologies, namely, Standard Assessment Procedure (SAP) and Simplified Building Energy Model (SBEM), is crucial when implementing improved energy standards.

We noted there are examples, such as the Greener Homes Innovation Scheme, demonstrating how the Scottish Government continues to support industry led innovation, research and development to bring about reliable, robust and deliverable solutions. We would encourage this to continue. Additionally, we discussed what work could be undertaken by the Scottish Government and industry to assist in the delivery of these staged improvements. Foremost, we considered that an 'Action Plan' should map out work needed to support successful delivery of the next set of standards and to further the transition to 'nearly zero energy' buildings.

Whilst a range of possible items for inclusion in such an 'Action Plan' was suggested at our meeting, we recognise this is best addressed by further review and development of proposals by government and industry. However, during discussion, we highlighted a number of potential themes, including:

  • Better availability of information and resources on low carbon buildings, including feedback on performance and lessons learned.
  • Revision of processes to give greater assurance on designed performance being achieved in practice.
  • Training and delivery of low carbon construction skills.
  • Early availability of calculation tools and software.
  • Promotion of the value of low carbon/energy buildings, including the role of incentives.

We noted that concerns can arise from requirements and prescription on low carbon equipment within the Scottish Planning system, in addition to provisions under building regulations. In reviewing the staged improvements, we ask the Scottish Government to examine elements of the Planning and Building Standards systems which address greenhouse gas emissions. These should offer consistency and alignment in policy approach and delivery, providing clarity to developers.

Eventual and Staged Standards - we recommend:

  • To support a more successful implementation through a longer lead-in time, the energy standards proposed and already consulted on for 2014 should instead be published in 2014, but implemented a year later in 2015.
  • The Scottish Government investigates whether the 60% and 75% reductions in carbon dioxide emissions, originally recommended for 2013 in the 2007 Sullivan Report, would also deliver new buildings which meet the definition of 'nearly zero energy' new buildings in the EU Directive.
  • Subject to the previous recommendation, subsequent review of energy standards should be programmed to align with the EU Directive requirement for 'nearly zero energy' new buildings from 2019.
  • Beyond the current review, delivery of a 'net zero carbon' standard is linked to the development of the concept of 'Allowable Solutions'.
  • In tandem, the Scottish Government publishes an 'Action Plan' setting out a range of work elements to support the successful implementation of each staged improvement.
  • That Scottish Government aligns the emissions abatement aspects of both the Planning and Building Standards systems.