March 2010

Zero Carbon New Non-Domestic Buildings

Feedback report from a national programme of events on the Department of Communities and Local Governments consultation on the journey to zero carbon for non-domestic buildings, organised by the UK Green Building Council

This project was funded by the Department for Communities and Local Government.

Report written by Simon McWhirter, The Message Hub

Technical support and workshop contributions from Arup

Copyright (2010) UK Green Building Council UK Green Building Council The Building Centre 26 Store Street London WC1E 7BT T: +44 (0) 20 7580 0623 E: info@ukgbc.org W: www.ukgbc.org

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Defining Zero Carbon Non-Domestic Buildings

Foreword
Zero carbon new non-domestic buildings are an issue of huge significance for the UK Green Building Council, our members and the wider industry and I am encouraged that government has set out some ambitious aspirations in this area. A lot of the content of the proposed zero carbon non-domestic definition carries on from the work done in the homes sector, building on the body of work carried out by the Zero Carbon Hub, in which the UK-GBC and many of our members were heavily involved. The non-domestic consultation takes, we think sensibly, the same hierarchical approach to the zero carbon definition as that for homes; first focusing on the efficiency of the building itself, before considering what low or zero carbon energy can be generated on or near the building, then lastly looking at the more remote, and often more contentious, options to mitigate any remaining emissions. Government asked UK-GBC to lead a series of workshops across England to further investigate the industry response to the proposals set out in the consultation on zero carbon non-domestic buildings. This report summarises the outcomes of these workshops and aims to provide an objective assessment of the participants feedback. While there is still a lot of work to do, it feels at long last as if this policy is beginning to take shape. There are naturally different points of view on the detail, but I take confidence from a broad consensus about the need for an ambitious, deliverable and effective policy. I believe this shows a maturity in the relationship between government, the industry and other stakeholders and Im grateful to everyone who has taken part in this process.

Paul King Chief Executive, UK Green Building Council

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Defining Zero Carbon Non-Domestic Buildings

Contents
Foreword Introduction The workshops Energy efficiency standard Beyond energy efficiency: Carbon compliance Allowable Solutions Defining the zero carbon destination Zero carbon for public sector buildings Cost impact assessment Delivery and next steps Conclusions 2 5 5 7 8 10 13 14 15 16 17

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Defining Zero Carbon Non-Domestic Buildings

Introduction
PURPOSE OF THE CONSULATION
Communities and Local Governments latest consultation on the ambition for zero carbon new non domestic buildings ran from November 2009 to February 2010. Government wanted to seek views on options for the overall routemap for all new non-domestic buildings to be zero carbon from 2019, and on how the public sector should be at the vanguard, with all new central government public sector buildings being zero carbon from 2018. The zero carbon homes policy is the foundation for the non-domestic buildings policy.

PURPOSE OF THE WORKSHOP EVENTS

The purpose of the series of workshops, which were carried out by the UK Green Building Council, was twofold; to provide both a platform for stakeholders to get a better understanding of the issues in the consultation and also a channel for providing comprehensive feedback to the department of Communities and Local Government (CLG). For both those who were planning to respond to the consultation officially and those who werent, these workshops were an opportunity to input to the process and allowed an opportunity for stakeholders to pose questions on the issues in the consultation. CLG officials presented the rationale behind the policy at each event, and were on hand to answer questions.

PURPOSE OF THE REPORT

The UK Green Building Council has produced this report to form part of the evidence base for how the government delivers on this agenda. The report presents an objective analysis of the workshop process and outputs, and does not necessarily represent the views of the UK Green Building Council. The report, which will be publicly available, sets out the combined feedback from a wide range of stakeholders from the trade, industry and NGO sectors among others - on the zero carbon non-domestic proposals. The report will be used by government to develop policy in this area further.

The workshops
The UK-GBC arranged a series of five workshops during January and February 2010. These were held in Bristol, Manchester and Birmingham, followed by two workshops in London. The workshops were free to attend allowing for the participation of a wide range of stakeholders. Each workshop followed a similar programme consisting of an introduction to the key issues, and a series of interactive audience participation sessions using hand held voting sets. Each workshop began with a presentation by CLG which set out the policy context for the consultation. The technical content of the workshops was presented by Arup, on behalf of UK-GBC. Feedback from the workshops was gathered using as combination of three methods: 1. Hand-held voting equipment was used to gather quantitative feedback throughout each workshop (with the same questions asked at each workshop); 2. Delegates provided additional qualitative feedback by completing comments cards; and 3. Verbal comments and questions raised during the workshops were also recorded. This report summarises the key issues and views identified through this feedback. The results presented are an amalgamation of all five workshops. The individual workshop results and the summarized qualitative feedback from the comment cards completed by the delegates are included in the appendices. There was limited on the day verbal feed-back on the consultation contents. Many of the workshop attendees commented that they had attended the workshops to learn more

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Defining Zero Carbon Non-Domestic Buildings

about the consultation and to inform their own formal consultation responses, and therefore had not formulated responses to the consultation content prior to attending the workshop. The feedback has been analysed (a) on an aggregate basis; (b) by region (as represented by workshop location) and (c) by the industry sector the participant represented. Generally, there was no material variation in the responses by region. However, the comparisons by sector should be treated with care as when asked to indicate which option from a list of sectors they worked in, 31% of workshop participants chose the Other option. This makes accurate voting analysis by this sectoral method imprecise. Delegates were asked to consider the proposals in the consultation in terms of what they considered to be technically feasible and/or desirable, and to separately consider the issue of cost.

PARTICIPANTS AND FEEDBACK

There were 209 attendees overall at the five workshops. A wide range of sectors was represented. Particularly well represented were the architecture, product manufacturing and engineering and construction/development disciplines, together with national and local government. Unless specified to the contrary, no sector presented a markedly different view than that expressed by the entire body of participants. Before the workshops began, 94% of participants considered themselves as having some level of understanding of the Governments proposals for zero carbon non-domestic buildings, but only 3% viewed themselves as experts. After the workshop events, 65% of delegates indicated that the complete package of measures provided them with clear guidance on the direction of the zero carbon policy, and felt they were supportive of it. While 28% of the workshop participants were either unsure of the policy direction or felt they need more information, only 7% indicated a lack of support for it. The delegates represented a wide array of business areas, with the commercial real estate, education and policy/regulation fields being those that most delegates were involved in. We have, however, not analysed the delegates voting responses based upon the area of business they operate in. As each workshop participant was entitled to indicate that they worked in multiple business areas the votes cast dont apportion equally across the individuals working in any specific area of business, and trends therefore may be misleading. The sample audience from the workshops was relatively small and specific analysis at this level could be considered to lack statistical robustness. In total 88% of the participants had read some of the consultation material, but only 4% had read it fully. Only 1% of participants had also fully read the Impact Assessment. When asked whether the materials were too complex or too simple, 73% considered them to be the right level of complexity for them. 97% of the participants said that the event had helped them understand the consultation. Although only 42% of the delegates were UK Green Building Council members, over half of them said they have previously been involved in some way with very low energy buildings 1. There were few instances where delegates previous experience of low or zero construction led to a distinct variation from the overall voting pattern. Where significant this has been noted through the report. All participants were encouraged to submit their own individual responses to the consultation. The workshops followed the same order as the consultation document, addressing each of the following topics in turn: 1. Energy efficiency standard (Chapter 2) 2. How much of remaining regulated carbon is dealt with on-site (Chapter 3) 3. Allowable Solutions measures for remaining regulated & unregulated carbon (Chapter 4)
1

For this question, buildings with EPC ratings of A or B, BREEAM Outstanding ratings or zero carbon were considered to be very low energy buildings.

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Defining Zero Carbon Non-Domestic Buildings

4. 5. 6. 7.

Defining the zero carbon destination (Chapter 5) Zero carbon for new public sector buildings (Chapter 6) Cost impact assessment2 (separate document to the consultation paper) Delivery and next steps (Chapter 7)

Energy efficiency standard

Summary: A significant majority of delegates (94%) supported a challenging energy efficiency backstop. However, 71% felt this needed to be judged on a sectoral basis, and only 23% favoured an identical standard across all building types. Across the delegates, views were split evenly on whether a passive building fabric calculation should be employed, or whether mechanical systems should be included. Similarly, delegates were split three ways between primary energy, delivered energy, and carbon emissions - as to the metric to be used. Mirroring the approach that has been adopted for housing, the non-domestic zero carbon definition is intended to allow flexibility in its application, avoiding direct prescription of how each element of the standard should be achieved. However, to ensure the twin aims of both energy and emissions reduction, CLG has proposed that the ..unless challenging zero carbon standards standards are across the underlying environmental whole, implementation will robustness is strengthened be delayed as the sectors through an energy efficiency argue their corner and the backstop to ensure a reasons they cannot achieve minimum performance the requirement. standard for the building fabric. (Consultant on energy efficiency Bristol, January Workshop delegates were asked whether there should be such an 2010) energy efficiency backstop as a component of the non-domestic zero carbon target, and whether a flat rate calculation should be Aggregate approach needs used to determine the standard ..it is imperative to be fair and based on (as was done for homes) or that we regulate and what is achievable for each whether the much greater tax inefficient sector. (Workshop building diversity in nonbuildings into delegate, Manchester domestic buildings requires a obsolescence January 2010) differential approach. I.e., (Workshop delegate similar to the aggregate comment on energy approach proposed in Part L1:2010, different building types could efficiency London, have different energy efficiency improvement targets. February 2010) While the workshop participants were strongly behind the concept of a challenging efficiency standard covering space heating and cooling (94% positive), almost three quarters felt that this standard needed to be assessed on a sector-by-sector basis, rather than as an across-the-board flat rate improvement.3 However, the architectural/design delegates slightly favoured the flat rate approach across all. Of delegates with previous experience in low or zero carbon housing development through the entire construction process, there was a stronger vote for the flat rate approach across all sectors (36%, uplifted from the entire workshop series result of 23%). For those with low carbon nondomestic experience, there was no significant deviation from the average.
2

This cost issue was addressed after delegates had considered what was felt to be technically achievable if cost was not considered to be an influencing factor 3 Question B1, slide 45, Appendix 2

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Defining Zero Carbon Non-Domestic Buildings

..should be consistent with homes because of the difficulty in administration and implementation." (Consultant - London, February 2010)

It was questioned by a delegate at the Bristol workshop how much analysis had gone into assessing the impact on the competitiveness of different sectors of applying either a flat rate or sector specific energy efficiency standard. Not all delegates favoured all aspects of the approaches taken for the domestic sector, but there was a distinct theme that where possible it was advantageous to utilise parallel mechanisms. The delegates were split down the middle as to whether the standard should be based on passive systems only (42%), rather than taking the Part L approach of incorporating mechanical systems (including ventilation systems) into the standard (46%). Delegates from the engineering sector were more strongly (66%) in favour of the inclusion of mechanical ventilation in the standard. The vote was split several ways when it came to the metric of choice. While half the delegates favoured the use of the kWh/m2/year metric, they were split between the use of delivered energy (31%) and primary energy (19%). Carbon emissions (measured in kgCO 2/m2/year) were preferred by 29%, and delegates from central and local government came out strongly in favour of this approach (47%). Workshop participants from the construction sector voted strongly against the use of primary energy as the metric (with only 5% of delegates in favour of this, versus the workshop average of 19%). These delegates votes fell more strongly in favour of the use of either delivered energy or carbon emissions as the metric to be used. Delegates with past experience of the masterplanning stage only (as opposed to delegates with an experience of the masterplanning and construction stage) of both low or zero carbon housing or non-domestic development voted more strongly in favour of a carbon emission metric (up from 29% to 38%, and from 29% to 40% respectively for homes and non-domestic). Of all delegates with an experience of the masterplanning and construction stage in the non-domestic sector, 38% voted for delivered energy, followed by carbon emissions (24%), primary energy (18%) and sector-specific measurements (6%). For housing, respective numbers were 33% (delivered energy), 24% (primary energy), 24% (carbon emissions) and 12% sector-specific. Other suggestions for methods to determine an energy efficiency backstop were provided on comments cards and included a combination of an energy and CO 2 metric, with minimum elemental backstops, and a suggestion for a need for a balance depending on site and use. Non-domestic covers a wide range of uses. Each sector requires a different approach to ensure the correct considerations have been made. (Workshop delegate comment - Birmingham, February 2010)

Both in the energy efficiency section, and in later stages, a material number of comment cards were submitted stating that the embodied energy impacts, or whole life cost, of the materials should be a component of the zero carbon definition.

Beyond energy efficiency: Carbon compliance

Summary: Perhaps surprisingly only a minority of delegates (11%) were in favour of the off-site rich scenario which is generally seen as the cheapest cost option. The largest proportion of participants favoured a balanced approach (46%), with a strong showing for the on-site, high microgeneration option (36%). However, it was noted by delegates at more than one workshop that they found it

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difficult to analyse the technical and practical delivery of the various scenarios in isolation without considering the cost implications, which were dealt with separately at the workshops. At the London workshop, where participants answered the carbon compliance question a second time after the section covering costs, there was a small but marked shift from on-site to off-site as the preferred solution (although a balanced approach was still preferred overall). Carbon compliance determines the level of on-site measures (and the use of directly connected communal heat) for carbon reduction, expressed as a carbon emissions target through the Building Regulations4. As proposed in the zero carbon homes policy, 5 the modes of carbon reduction that are likely to be used are: higher building energy efficiency further than the minimum standard set; the use of building-mounted low and zero carbon energy generation technologies; onsite low and zero carbon generation technologies; or where feasible in the immediate environs, directly connected heat or coolth (via pipework). For the consultation, three scenarios were modelled. Each of these is an aggregate target, so there would be different targets for different building types: On-site rich (63% regulated carbon emission reduction on-site + remainder under Allowable Solutions) Off-site rich (44% regulated carbon emission reduction on-site + remainder under allowable solutions) Balanced (54% regulated carbon emission reduction on-site + remainder under Allowable Solutions) Using comments cards delegates expressed a wide range of views on the question of where to find the balance between on-site and off-site solutions: Balanced is certainly best, and this can be achieved through planning, construction and operation. However, I do think that the emerging policy approach should be more market and transaction savvy. The problem with offsite is the dependency on third party to deliver and manage the power. This is very tricky, given [that] investment requires control and certainty. (Workshop delegate comment on carbon compliance - Developer, Bristol, January 2010) On-site rich. Allowable solutions are essentially a fudge to deal with residual emissions. Just as we should be pushing to minimise the energy demanded by the building, we should also be minimising the grid energy consumed. It may not be the most cost effective but what price avoiding the worst ravages of climate change? If it is tougher and more complicated to deal with the top of the pyramid - we should make it as small as possible. (Workshop delegate comment on carbon compliance - Engineer, London, February 2010) Offsite-rich moving towards onsite through financing incentives and tax breaks. (Workshop delegate comment on carbon compliance Designer, Bristol, January 2010)

The workshop delegates were presented with a brief outline of pros and cons of each scenario and asked which scenario they favoured 6. At this stage delegates were directed to exclude the cost implications of each scenario as this was to be tested later in the workshop. In response to the question about which scenario they favoured, the delegates were split between all three but with most favouring either the onsite rich (36%) or a balanced scenario (45%). Delegates from the development sector indicated a greater preference for the offsite rich scenario than other participants. A number of delegates felt that there was a need to increase the focus on district heating systems.
4

The end destination of net zero carbon emissions should not differ regardless of which carbon compliance choice is made at this stage, but it will impact on the amount of residual carbon which would need to be mitigated using allowable solutions, i.e. a higher carbon compliance requirement will reduce the residual emissions to be mitigated, whereas a low carbon compliance level will mean that more work must be done with the allowable solutions framework. 5 Which set a carbon compliance level for homes of 70% reduction in regulated carbon emissions from 2016 6 Slides 50-52, Appendix 2

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Defining Zero Carbon Non-Domestic Buildings

Unlike the combined workshop responses, those from delegates who had been involved in low carbon housing development through the process voted for an onsite approach ahead of the balanced approach (45% opting for onsite, and 33% for a balanced approach). In the London workshops, delegates were asked this question again after running through the modeling of cost implications of the scenarios. See below in the Cost Impact Assessment chapter for the results. At the Manchester workshop an NGO delegate queried why the upper level of ambition under the carbon compliance level was so unambitious given that the consultation stated that all public sector buildings were capable of achieving 80% carbon reductions onsite (versus the on-site rich scenario setting a 63% target) 7. It was queried why, if the public sector could do it, the upper level was not also set at 80% 8. Numerous questions seeking additional details on these aspects of the policy, and statements about further complexities, were noted by delegates on their comment cards. A few have been reproduced here and the full compilation of responses is in Appendix 1. Are on site rich renewable technologies sufficiently robust over their life cycle to ensure cost savings? If Im in the middle of Wales or in the middle of London, I would have a different answer. You will need targets based on the local population density and region of the UK. But I think on-site rich is the best answer in terms of the resiliency of the UK infrastructure. I feel the balanced or offsite scenarios would be the best-cost, i.e. will the government pay to increase resiliency of the nation. Onsite would promote local economies within every region: sustainable in a wider context. Whilst in favour of pushing on-site as far as possible, Local Planning Authorities need to look at buildings in the context of local masterplans to look at future potential supplies to district schemes. Depends on which one will 'mesh' best with housing - not as in 'identical' but as in 'complementary'. It must enable housing and non-domestic schemes to work together. It is all about matching supply and demand. In the workshops themselves, the difficulties of separating cost from deliverability was brought up on a couple of occasions as well as subsequently in the comment cards with one developer at the Bristol workshop emphasising that for them, it isnt so much cost, but who pays. Each sector presents radically different opportunities in different areas. How is a level playing field to be set? This is particularly true for energy efficient appliances do we know enough about appliance performance and how there is likely to be real variation between design and final fit out. (Consultant opinion on allowable solutions Bristol, January 2010)

Allowable Solutions
Summary: Workshop participants were broadly in favour of using the same Allowable Solutions delivery model for nondomestic buildings as for homes, but this was an area where a number of the delegates commented that the combination of undefined elements, i.e. a fixed carbon compliance level and the lack of certainty over the composition and detail of the list of Allowable Solutions made some of the conceptual questions difficult to respond to. Most of the Allowable Solutions
7

Paragraph 6.11 of consultation All the types of public sector building modelled can reach 80 per cent reductions on-site apart from the acute hospital. Schools, some military buildings and prisons are all able to achieve close to 100 per cent reductions on-site. 8 However, the IA suggests that some public buildings could not do 80% on-site. Only selected building types tested could. Other office type town centre buildings, for example, could not achieve 80% on-site.

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proposed for the domestic sector were seen to have a good degree of potential for non-domestic buildings, however there were significant reservations over the use of energy efficient appliances. Over half the delegates thought Allowable Solutions should be available for voluntary take-up at least from 2016. Allowable Solutions are used to mitigate the carbon emissions at the top of the zero carbon hierarchy (i.e. those remaining after the minimum energy efficiency and carbon compliance requirements have been met). The intent is to enable flexibility in approaching these remaining emissions to meet the zero carbon destination point. In the zero carbon homes definition consultation a list of possible Allowable Solutions were set out by CLG. Government is still refining this list. The delivery mechanism for Allowable Solutions is also currently under review, as are ancillary, but vital, issues such as how to ensure the additionality of emissions reductions9. Although different delivery models are being considered, a single system to cover both homes and the non-domestic sector has been proposed, which would cover accreditation of the Allowable Solutions, their additionality over extant emissions reduction commitments and provide robust monitoring processes. Delegates from the development sector voiced concern at two of the workshops about the implications for mixed use developments if the same system was not used. Workshop delegates were asked how much potential each of the Allowable Solutions, set out in the consultation, had. While most of the proposed solutions were deemed by delegates to have some or high potential for zero carbon non-domestic buildings, many delegates responded with concern about the inclusion of energy efficient appliances in Allowable Solutions. It was indicated at most of the workshops that the extremely wide range of appliances which may be found or incorporated in non-domestic buildings (as opposed to homes, which have a more standardised range of white goods, and the like), makes this extremely difficult to assess and regulate. Furthermore, it was highlighted by several delegates at the workshops that appliances are rarely fitted as part of the builders works for non-domestic buildings. A few delegates commented in the feedback that appliances would better fit in carbon compliance (see diagram below). Similarly, four delegates indicated on their feedback cards that the inclusion of building control systems was inappropriate in the non-domestic sector. In principle, it would seem simpler to have a common approach. [But] unless we have an understanding of what the delivery model is for domestic, we cannot know whether it is suitable for non-domestic. (Workshop delegate comment on delivery mechanism for allowable solutions Bristol, January 2010)

The key to the inclusion of any Allowable Solution is the need to prove that it results in additional carbon mitigation measures that no other party claims for. This "additionality" should not be defined as a mitigation measure that would otherwise not occur. If it is a technically and financially viable solution then it should occur, with or without a building project, the key is that it is not claimed as carbon mitigation by any other party or mechanism, and ideally does not result in a change to the grid carbon intensity in future updates to the building regulations.

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Energy efficient appliances and building control systems should be included as part of carbon compliance to avoid double counting. (Engineer - Birmingham, February 2010) Appliances what stops the user taking the equipment out? This will have a minimal impact. Advanced control systems how do you measure the impact? (Engineer Bristol, January 2010) Energy efficient appliances and advanced building control systems should be in carbon compliance. (Engineer - Manchester, February 2010) To stimulate some thoughts around other possible Allowable Solutions that delegates might wish Government to include in the final list, UK-GBC prepared a few proposals for consideration by the delegates. These were discussed and voted on by workshop attendees, as shown below.

Great fan of the energy fund idea, but the regulatory/policing issues are complex. And getting credit for exporting heat or investing in district heating infrastructure is a very exciting option for dealing with the tricky issue of heat. National energy fund could be of interest if there are strong guidelines on what they would invest in and if it has a social element. (Consultant - London, February 2010)

Some other Allowable Solutions proposed by workshop participants included; the trading of emissions reductions between properties held across a portfolio; the purchase of CRC allowances; the linking of adjacent developments or other carbon credits such as through the Clean Development Mechanism or the decommissioning of existing inefficient buildings. In one form or other at each workshop, delegates concurred with this delegates statement that it is, crucial that all Allowable Solutions are measurable, reportable and verifiable. Just over half of delegates were positively in favour of a common Allowable Solutions delivery model for homes and the non-domestic sector, with delegates from the architecture and design sector being marginally more in favour of this common approach. 15% of all workshop participants stated that a separate non-domestic model is needed (with the remainder declining to vote either way).

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TIMESCALE
When asked whether Allowable Solutions should be available for new non-domestic construction from 2016, of those voters who made a positive choice, over half voted for an introduction in 2016, but seven delegates specifically stated (in the comment cards) that a 2016 availability of Allowable Solutions should not mean that higher carbon standards were required before 2019.

Defining the zero carbon destination

Summary: When evaluating whether the zero carbon definition should include unregulated energy (and if so how much), only 5 % of delegates were against its inclusion (30% of these were developers). 9% expressed a preference for a flat rate across all sectors. Over half the delegates thought that each sector should have a different zero carbon end point, with 20% going further, responding that it should be done on an individual building basis. SBEM was criticized at the workshops and on numerous comment cards for its perceived inadequacies as an assessment tool for this policy. Only some of the carbon emissions from buildings are currently covered through Building Regulations. Therefore the proportion of energy that is not regulated which is to be included in the zero carbon definition must be calculated10. This remaining energy usage the unregulated energy - covers sources such as computer use, plug in appliances, lifts, air curtains, external lighting and numerous other sources. The Government is already considering whether some of these Regulations. [There is an] urgent need to update and improve NCM and SBEM to incorporate more of the buildings operating energy consumption. (Architect - Birmingham, February 2010) SBEM is too crude a tool in its present guise to give accurate assessments. (Engineer - Manchester, February 2010) SBEM is a dreadful simulation tool. It is a compliance tool only and represents the lowest common denominator. (Engineer - London, February 2010)

(including air curtains and lifts) should be included in Building

Many delegates commented on the comment cards and verbally with concern upon the use of the non-domestic sector calculation tool, SBEM, for unregulated energy due to various assumptions in the underlying National Calculation Methodology about building usage. It was highlighted by ten delegates that they felt that the use of SBEM is an imprecise way to calculate unregulated energy use. Also, the wide variety of building types and uses across the nondomestic sector mean that the unregulated energy use from building to building comparing supermarkets to distribution warehouses for example - can differ greatly. Delegates were first asked whether they favoured including allowances for unregulated energy in the zero carbon standard. The majority agreed that it should be included. 55% of delegates indicated that a sector-specific approach was required to determine the appropriate level of unregulated energy to be included in the zero carbon definition, with one in five stating that it should be calculated on a building-by-building basis. Less than one in ten delegates thought the zero carbon destination for non-domestic buildings should be "Do it properly or not at all! A flat rate is too crude, and open to criticism and it will also be wrong in most cases." (Workshop delegate Birmingham, February 2010)

10

For homes, where there is a much more standardised building typology and energy use pattern, unregulated energy use was taken as a flat 50% of regulated energy. Therefore the zero carbon destination for homes is 150% of the regulated energy use for the dwelling.

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a flat figure across all sectors. Delegates from the design and architectural fields were twice as likely to support a flat rate as those from other sectors. Delegates at the Bristol, Manchester and London workshops voiced the opinion verbally or via the workshop feedback cards that the policy needs to cover all carbon emissions from the building, not just a theoretical, calculated rate of emissions. As a follow up, those who agreed that unregulated energy should be taken account of were asked about the precise level at which the allowances should be set. 56% favoured a sector specific approach based on real building benchmarks. 18% said that a flat rate should apply to all building types (but still determined from real building benchmarks). Less than 5% believed it should be based on a flat rate of 10% or 20%. Concerns were raised during two separate workshops by pharmaceutical and materials processing delegates, in Manchester and Bristol - about the proper accounting for process energy and its exclusion from the definition.

Zero carbon for public sector buildings

Summary: Over half of all delegates felt that even if all the proposed actions by the government estate were taken, the public sector would still not be doing enough to drive this agenda forward. While two thirds of delegates stated that the public sector should begin trialling Allowable Solutions from 2015, and many others from an earlier date, concerns were raised about the speed at which any lessons learned could be fed back into the system for the private sector. It was raised in more than one workshop, and on several response cards, that it was difficult to comment on these issues conceptually, without having a greater degree of detail on the proposals. Workshop attendees strongly favoured local government following the central government estate by taking up the baton of the 2018 ambition to demonstrate their commitment. In the 2008 Budget, the public sector was set the ambition 11 of building to zero carbon standards ahead of the proposed regulatory timetable, so as to meet the standard from 2018. The delegates were asked to rate the proposals for public sector action which were set out in the consultation. Ongoing monitoring and reporting of public sector buildings was rated a top priority (scoring five out of five) by over three quarters of delegates. All the other suggestions that the public sector should carry out an exemplar building programme; trialling Allowable Solutions; testing the financial options for delivery; and showing local leadership and engagement - were also ranked highly for the progression of the wider policy. Over half of the delegates felt that even if all these options were undertaken the public sector would still not be showing sufficient leadership in this arena (with 17% of delegates answering no, they would not be showing enough leadership and 36% voting there are other aspects they could do).

Details of build programme and figures for exemplar building numbers would be required to assess whether the consultation proposals are sufficient. (Surveyor - Manchester workshop, February 2010)

It was felt that without more quantitative and qualitative information, such as the number of exemplar buildings that would be constructed, it was extremely difficult to answer this question
11

This advance-of-regulation public sector commitment covers all new central Government buildings, including hospitals, the defence estate, prisons, courts and schools (although schools are subject to an even more rigorous zero carbon target). The local government estate is not currently covered by the 2018 zero carbon ambition.

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with any degree of certainty. At the Manchester workshop alone, over half a dozen people stated that they required this additional information before answering. A majority of delegates felt that the public sector should begin trialling Allowable Solutions very early to support the development and delivery of the solutions in advance of 2019, with 63% thinking they should be available for use from 2015. A small number of delegates indicated a preference for either 2018 or 2019, but of the remaining 29% who indicated an alternative preference, the comment cards showed an overwhelming preference for a date sooner than 2015, with numerous calls for ASAP and NOW!, and repeated references to the fact that there was no time to wait. It was noted in discussion by several delegates that unless the Allowable Solutions were trialled by the public sector at least a couple of years in advance of the regulation there would be no time for the lessons to be processed and fed back into the private sector timetable. Specifically at the Birmingham and London workshops, delegates commented ASAP! This that due to the long lead in times for the non-domestic sector, private sector needs to decisions would have to be made before public sector lessons would have happen in gone through the machine. The majority of delegates who provided order for the qualitative feedback on this point indicated they thought this should begin as feedback to soon as possible. help other buildings CLG was also keen to explore what role local government could play in wider make the public sector leadership on this zero carbon agenda. The highest rated option transition. was for local government to follow the central government estate by taking up (Product the baton of the 2018 ambition to demonstrate their commitment. At both manufacturer - Manchester London workshops, delegates voiced concerns about the ability of planning workshop, departments to deliver against this agenda if, as suggested, local planning February 2010) guidance was to contain details of local Allowable Solutions. This reflected wider comments at both the workshops themselves and in the comment cards - about the ability of both Building Control and planning departments to deliver on this agenda. Other suggestions as to local leadership on this agenda included: a database to link up local development opportunities for shared approaches to the development of Allowable Solutions; local communities running Allowable Solutions schemes as social enterprises; a local carbon tax gathered through business rates. Training needs were also a strong theme, with delegates suggesting more needs to be done to help architects, developers and installers gain new skills to build to zero carbon standards, and then also for Building Control and Planning Officers to be able to assess more complex projects. It was pointed out by a few delegates that they felt public sector control over district heating networks would conflict with a free market approach.

Cost impact assessment

Summary: 84% of participants had read little or none of the Impact Assessment before their workshop. From this starting point, 76% of delegates felt unable to answer whether they felt the approach used to model the costs was reasonable, or disagreed with the approach that had been taken. Only 12% of participants actively stated that the cost build up was about right for their sector. A few participants both in the workshops and in subsequent qualitative feedback, stated that they found it impossible to split the cost factor out of their decision-making process in delivering zero carbon non-domestic buildings. For the purposes of the workshop process, it was decided to separate the cost implications of the zero carbon ambition out from the deliverability. Delegates were asked firstly to respond to the

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questions as to the technical achievability or the suitability of various elements of the proposed policy. In the latter stages, the issue of costs was then approached separately. The Impact Assessment12 (IA) was carried out to understand the relative base cost (by indicative building type) of the policy and to consider the costs of achieving various energy efficiency and carbon compliance scenarios. 61% of delegates who had read the IA previously felt that the guidance for the Impact Assessment was spot on, while 100% of delegates from the development sector felt that it was too complex. Some too high (retail), some too low (offices). It generally doesnt seem to be based on reality. (Developer comment London workshop, February 2010) This doesnt make sense. Anything can be done. It is just a case of what it costs to do it and whether it is good business. (Workshop delegate at Bristol workshop, January 2010)

As was done at each stage of each workshop, the technical presentation team from Arup took delegates briefly through the policy and methodology used - first, the cumulative cost and carbon savings for increasingly energy efficient measures, and then the costs associated with low and zero carbon on-site technologies to reduce overall carbon emissions. 13

It was difficult to draw strong threads of opinion from the delegates on the costs issue as 70% of participants felt unable, with the information they had considered in advance together with the workshop presentation, to indicate whether the approach was reasonable. There seemed to be a marginal increase in opinion that the costs were about right among workshop participants who had been involved with either domestic or non-domestic development from start to finish. After the second London workshop, following discussion of the costs component, delegates were asked to once again indicate what level carbon compliance should be set at. While the favoured view was still to take a balanced approach, there was a shift, after the costs explanation, from the onsite rich to the offsite rich scenario (from 36% and 11% respectively to 23% and 21%).

I believe there is a real financial value in zero carbon but this isnt a universal opinion in my sector. Demonstrating the value with real examples would sway this. (Workshop delegate Bristol, February 2010)

Delivery and next steps

Delegates were asked about delivery mechanisms and next steps. A common theme through both the workshop responses and the post-workshop feedback submitted was that the systems for nondomestic must fit with housing solutions. Not be same as, but must fit with.14 Delegates were asked to provide their opinion as to how important various factors would be in the practical delivery of the zero carbon ambition. All the factors considered, namely roles of Building Control and Local Planning Authorities (LPA); completed demonstration projects; improved construction industry skills; zero carbon to have clear financial value in the market place; improved assessment tools; mechanisms for capturing operating costs benefits; and a joint Government/industry body were deemed of real importance in delivering against this agenda.

12 13

http://www.communities.gov.uk/publications/planningandbuilding/newnondomesticbuildimpact The allowable solutions component in each scenario was calculated on a presumed cost per tonne of carbon. Under the IA modeling, different building types end up with the application of different sets of energy efficiency measures, and renewable energy generation capacity. 14 Quote from delegate during London morning workshop

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However, it was raised by several delegates in their post-workshop feedback that both Building Control and LPA had vital roles to play, but concern was raised about the capacity of both to deliver. In the qualitative feedback, mixed views were expressed as to whether a body such as the Zero Carbon Hub was needed to oversee delivery for the non-domestic sector.

I dont think Building Control and Local Planning Authorities (LPAs) can do this very well. They are under-skilled and under-resourced. (Local government representative Manchester workshop, February 2010) Enforcement by Building Control will be critical. (Workshop delegate - Birmingham) Just expand the Zero Carbon Hub to cover non-dom buildings. (Services engineer London workshop, February 2010) At both the Birmingham and the first London workshops, participants raised concerns about how tensions would be resolved between national schemes (commenting that the Merton Rule led to uncertain outcomes) and local delivery.

Conclusions
KEY MESSAGES
1. The non-domestic sector is embracing, rather than rejecting, the zero carbon challenge. Participants were generally strongly in favour of the drive towards zero carbon non-domestic buildings, subject to the issues raised through the report. The workshops themselves were very well received with 85% of participants rating them as very good or excellent. Asked after their participation in the interactive workshop process, 65% of delegates thought that the complete package of measures provided them with clear guidance on the direction of the zero carbon policy, and felt they were supportive of it. Only 7% indicated a lack of support for the policy, though around 30% were unsure or needed more information. 2. The zero carbon definition developed for homes is a good basis for the zero carbon definition for non-domestic buildings provided that it is intelligently and sympathetically adapted to meet the specific needs of the non-domestic sector. In terms of the responses to the substantive aspects of the zero carbon non-domestic definition, there were some areas of confluence with the approach taken in the housing sector the hierarchical approach was favoured, as were the use of an energy efficiency backstop, an onsite carbon compliance requirement and most of the Allowable Solutions favoured for homes - but also many areas of divergence notably due to the greater complexities of the non-domestic sector, requiring differential energy efficiency standards by sector and a wider, more sophisticated range of Allowable Solutions. 3. Delegates generally did not read the Impact Assessment and did not feel engaged on costrelated issues Delegates felt there was insufficient cost information to evaluate (even in high-level strategic terms) the cost impact of zero carbon on the various construction industry stakeholders. The presentation of the cost assessment information was necessarily brief, given the time available and the complexity of the modelling and impact assessment. This may explain the lack of proper engagement on these issues, and as such there was no strong steer on the approach taken to assess the costs and benefits.

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Before the workshops, less than a third of delegates had read most or all of the consultation (and only 10% had read an equivalent amount of the IA), but two thirds of participants still considered themselves somewhat familiar with the zero carbon policy, although not as experts (only 6% admitted to having no knowledge). Of the workshop participants who had read it, 60% found it at least reasonably clear. However, there was a strong indication, both at the workshops and in the qualitative feedback, that the way the Impact Assessment is presented does not easily correlate to the way the construction industry members themselves would go about analyzing costs.

ENERGY EFFICIENCY
Although split on the precise details, over 90% of delegates were supportive of a challenging energy efficiency standard. Over 70% thought that this should be differentiated approach by building type (as is planned for future Building Regulations).

CARBON COMPLIANCE
The most popular approach for the carbon compliance standard was to take the middle ground balanced approach. More than three times as many delegates favoured the on-site rich scenario over the off-site rich scenario, despite the fact that the latter is seen as the least cost option.15

ALLOWABLE SOLUTIONS
Of the participants who answered positively, almost 80% supported the same delivery model for Allowable Solutions as for homes. Most of the Allowable Solutions proposed for the housing sector also found favour with the delegates for the non-domestic definition, but there were numerous concerns over the inclusion of energy efficient appliances in this area (and to a lesser extent, advanced building control systems). There was general feedback that a wider range of Allowable Solutions (including off-site electricity generation) would be needed for the non-domestic sector compared with the residential sector. Over half of participants saw a benefit in being able to trial Allowable Solutions from 2016, ahead of regulation, with strong support that the public sector should do so even earlier.

VOTING PATTERNS
Over two thirds of participants had been involved in a low energy development (either in housing or non-domestic), or are considering one at the moment. However, it was notable that except for a few instances indicated through the report, there was little marked difference in the voting results for those delegates with hands-on experience. Similarly, there was no significant regional shift in the voting results.

15

As noted previously, at one of the London workshops, this balance shifted slightly towards the offsite rich scenario when the delegates were asked the same question again after having had the costs section explained

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Appendices
1. 2. 3. 4. 5. 6. 7. 8. Compiled comments cards submitted by workshop delegates Workshop presentation as delivered to delegates 16 Combined voting summary from all workshops Voting summary Bristol Voting summary Manchester Voting summary Birmingham Voting summary London 1 Voting summary London 2

(See separate Appendices file)

16

The presentation was refined throughout the course of the first couple of workshops, and the presentation as appended, is the final version

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