So as we still await the revised Part L 2010, which we seem to have been waiting for, well almost for ever! for a great post on this click here. Needless to say, that I have read the consultation document and have a great deal to say about them, but will leave this for when the finished documents are issued.
I want to instead discuss an issue which I feel needs addressing. As a skeptic, I like to think that I consider all of the evidence and provide a balanced, factual and rational opinion. With this in mind I feel that the issue of the provision of on site renewable energy is one which needs addressing.
Soon after the release of the 2006 edition of Part L, Merton Council produced a planning condition which was adopted by many local authorities across the country. This condition was that developments must install a minimum of 10% on site renewable energy. Now on the face of it people may think this is a good thing, but is it really a good thing?
The European Parliament Building Directive, which is the legal drive behind the revision to the building regulations, requires that nations reduce the CO2 emissions from buildings. There are few people who could argue that this is a good thing. The overwhelming scientific evidence suggests that rising CO2 emissions are the major cause of global warming. There are of course people who call themselves global warming sceptics, though the correct name for these people is global warming deniers, in much the same way people deny the holocaust or AIDS. So it is accepted science that we need to reduce our CO2 emissions.
Part L 2006 was published with the aim of not only measuring the CO2 emissions from buildings, but also reducing them by a measured amount. For those who want to know my feelings on the 2006 Part L, you should read my post on this blog, entitled Pathetic Part L. Within the document, a reduction in CO2 was allowed for what was called LZC technology (Low and Zero Carbon). This was a fixed 10% reduction which was required to be met by the proposed building, in order to achieve building regulations approval. My own personnel feeling was that Merton council misunderstood this and called for this LZC allowance to be provided by the physical provision of on site LZC technology. So the Approved document allowed this 10% CO2 reduction to be met by the physical reduction of CO2, but ear marked it as a 10% reduction for the provision of LZC technology.
So what is wrong with this approach I hear you ask? Well in this instance, Part L took the more pragmatic approach. It actually allows us to reduce CO2 emissions, without providing any on site renewable energy. So how is this achieved, well simply by reducing the energy consumption of the building, which means the CO2 is not produced in the first place. The Merton rule however, requires us to install technology which is designated as an LZC technology, but which is still using energy. Let me illustrate this with an example.
Building A has a target CO2 emission rate to hit of lets say 50 kg CO2/m2/annum, for simplicity I will refer to this as 50 kg. The building is well designed, making use of good lighting control with high daylight factors, good insulation levels and correct orientation. Coupled with this, the installed services are highly efficient, low energy fans and air handling units with demand controlled ventilation and variable speed fans. The building has no installed renewable technology, but due to good design it has a Building Emission Rate of 40, a 20% reduction on the TER.
Building B is an identical building, so has the same TER of 50. Building B however is badly designed, with poor lighting controls, poor daylight provisions, standard insulation levels and wrongly orientated. The building services which are installed are merely just compliant with the minimum provisions of Part L and the ventilation system is not demand controlled, it runs at full volume for the whole of the occupied hours. However unlike Building A, Building B is provided with a Biomass boiler. The BER of Building A is slightly better than the target at 45, so it passes, though not as well as Building A. However because of the provision of the biomass boiler it has well in excess of 10% on site renewable energy.
So if the Merton rule was applied to these buildings, only building B would comply, yet building B has a greater CO2 emission rate and uses a great deal more energy. Biomass, though classifies as an LZC technology, still uses energy and in fact biomass boilers are generally less efficient than a traditional condensing gas fired boilers. So using the Merton rule, which people assume produces green and sustainable buildings, we have a building which not only emits more CO2, but uses more energy than a building which does not comply with the Merton rule!
The above example may be hypothetical, but it is quite realistic. The cost of LZC technologies is high and the benefits are generally minimal. Having said that Biomass produces very good results, but I will be posting about Biomass soon, where I will explain why I feel Biomass is a mistake. It can be cheaper to provide a good design, with efficient building form and fabric and efficient services, than it can to install on site renewable energy and achieve the same results. Building A in the above example has the added benefit of reducing energy consumption, which ultimately, whether you believe in global warming or not, no one can deny that our energy stocks are running out.
There are two main reasons why the Merton rule has gained such popularity. The first is simple, it looks good and provides a design which demonstrates tokenism. It can be claimed that the buildings are green and sustainable as they have biomass, ground source heat pumps or PV cells installed. The second is a point which I feel is true more and more. The whole of the design team feel that building energy consumption is very much the responsibility of the building services engineers. Architects and builders are not educated enough on how energy is used within a building to take any interest in the process. It is still very much regarded as a problem for the building services engineers to solve. If it is the problem of the building services engineer to solve, it is often best solved by adding renewable energy technology to the development.
So whats the problem with the addition of on site renewable energy? Well let me tell you. You have to remember that I strongly believe that CO2 emissions and energy consumption need to be reduced from buildings, I am not a climate change denier, I am a Skeptic. For any one who is unsure of the difference between a Skeptic and a Sceptic, then click on this link. I strongly believe in the use and installation of renewable energy sources, but I do not believe that this should be done on site, I believe it should be done off site. ON site renewables are generally a token gesture and not the correct solution for the building in which they are installed, or they are largely ineffective.
Consider the installation of a wind turbine on site. This is wholly the wrong place to install a wind turbine. The performance of a wind turbine is greatly reduced by nearby buildings and the terrain around for several miles. The manufacturers stated performance will never be achieved in an urban environment, so it becomes even less effective than it appears in feasibility studies, which is very poor to start with. The correct location for a wind turbine is in a rural environment or at sea.
Biomass boilers have been a very popular element over the past few years. The reason for this is that they produce great CO2 emissions at a very cost-effective rate. My feelings on Biomass as a sustainable option will be explored in a future post in detail. However, it is a fact that plenty of biomass boilers have been installed to meet renewable targets etc and once the first load of fuel has been used, the boilers never fire again!
Photovoltaics have become more popular over the past few years as prices have dropped and the new feed in tariffs which were launched this year make the use even more attractive. The problem I have with PV is that firstly, they are not very effective, they produce a limited amount of energy and secondly what is the embedded energy used in PV’s, well nobody seems to know!
I could go on, but I do not intend to appraise all LZC technologies. My feelings are simple, LZC and renewable technologies are best installed off site, where they can be installed in positions which best suits the technology. As fossil fuels are running out, how are we to best provide energy to buildings? Well to me the answer is simple, via electricity and the electrical supply must be decarbonized. All of the major developments in reducing building energy consumption have been made by the refrigeration manufacturers over the past few years. The efficiencies of these technologies is getting better and better.
So the 2010 Part L is soon to be published and the headline is that CO2 emissions will need to reduce by 25% from the existing targets. This will be a major challenge, one which building services engineers alone will not be able to achieve. It will be imperative that the rest of the design team are involved in reducing the energy demand of the building, before any LZC technology is provided. It has also been hinted that the European Parliament Building Directive will be revised this year and from what I hear the focus will be on energy reduction rather than CO2 reduction, this can only be a good thing. So my hope is that the Merton rule will be dropped by those authorities who employ is, as I hope I have demonstrated that it is a pointless rule.