13 May 2008

On the Sullivan Report

I am really impressed by the Sullivan Report. Living in England, I’d not heard of it before today because it refers to Scotland. But as I’m lecturing in Glasgow this weekend, I have been mugging up on what lies in store for the Scots on the road to zero carbon, aware that the remit of the Code for Sustainable Homes (CSH) doesn’t spread north of the border.

In its place, in August last year, the new SNP government commissioned Lynne Sullivan, Broadway Malyon’s Head of Sustainability, to chair a panel of energy experts to create a roadmap for Scotland. It’s officially called A Low Carbon Building Standards Strategy for Scotland and unlike the CSH, it’s full of common sense and good ideas. For a start, it doesn’t veer off into water saving issues (possibly because Scotland is not and is never likely to be short of water). Nor is there any of that noise about improving ecology, waste management and sustainable drainage. No, the report just sticks to carbon. Like the CSH, there are some roadmap dates for changes in building regulations: in fact the dates, 2010, 2013 and 2016 are identical to the CSH dates.

So far so good. But what really caught my eye was that its really realistic about what is achievable and what isn’t. Two points in particular stand out.

First, a pull back from making micro renewables compulsory. The previous Labour government in Scotland had put in place a strategy that looked suspiciously like the Merton rule whereby new developments would have to produce 15% of their electricity from onsite equipment. I always thought this was a ridiculous target. Sullivan agrees:

We do not consider that the industry is yet sufficiently developed to justify mandatory requirements in building regulations for low carbon equipment or to require all buildings to become generators of electricity.

The report is suggesting that community-wide schemes, particularly CHP, would be far more effective and that it is expensive and pointless to insist on building specific solutions.

Secondly, there is some scepticism about whether to adopt wholesale the PassivHaus standard, as CSH appears to do. Sullivan’s panel had members on it from Austria, Denmark and Norway and their input was listened to and absorbed. In particular, the Austrian delegate expressed concern about wholesale adoption of PassivHaus.

Although having many examples of ‘PassivHaus’ (2,500 in total) in his own country, one of our European members was most insistent that you could not impose ‘PassivHaus’ living habits on home owners and occupiers. The main issue associated with ‘PassivHaus’ is that to realise the enhanced energy performance and to avoid mould growth arising from condensation, the occupants must be prepared to adjust their lifestyle to rely solely on mechanical ventilation with heat recovery (MVHR), including frequent changes of filters and the associated running costs. In his country there was significant subsidy for those who elected to build and occupy such houses, but most importantly these people had made the decision themselves and had not been forced to live this way through regulation.

This is such an important point and it appears to have been completely missed by DCLG in London who produced the Code for Sustainable Homes. At the moment, England is on course to impose PassivHaus by 2013 and microrenewables by 2016. No one seems to have sat down and asked whether this is sensible, let alone possible.

So I award full marks to Lynne Sullivan for putting this report together so quickly and making so many sensible suggestions. And having the courage to point out where Westminster has gone wrong with its vision for low and zero carbon homes. And full marks to the SNP for commissioning it. It’s a shame they don’t run in England: I’d be sorely tempted to vote for them.


  1. AnonymousMay 14, 2008

    This is a very good guide with a lot of suggestions for upcoming regulations, rather than throwing people in the deep end as our Government is doing.

    The panel members know it will be a very difficult task to implement so they try to get Scotland to adapt there ways in plenty of time.

    Do you have any idea when your next edition of housebuilders bible will be in the shops Mark?

    Will the new edition have CSH somewhere in the booklet?



  2. I am working on Edition 8 at the moment. I would guess it will be published in time for Xmas this year.

    And yes the CSH will feature!

  3. AnonymousJune 03, 2008

    Sullivan Report:

    I would agree with the importance the Austrian delegate placed on the subsidies which stimulate the voluntary uptake and ensure speedy progress with passive houses. That our government believes in coercion rather than effective persuasion is a tragedy.

    However, some of your other thoughts mystify me.

    We have progressed from coal fires with huge amounts of heat escaping up the chimney stacks, to coal-fired boilers, to gas- or oil-fired boilers, and to condensing boilers. Gravity systems have changed to pumped systems. Random ventilation through gaps was replaced by ventilation slots at the top of windows. Kitchens and bathrooms now have mechanical ventilation which ventilates the warm air to the outside.

    Whole-house heat-recovery ventilation is an improvement on this, as it uses the heat of the outgoing air to indirectly warm the incoming air. As we are using mechanical ventilation anyway, we might as well use an efficient system.

    What are "PassivHaus living habits"? As I understand it, the occupants switch their ventilation system off and open their windows in good weather, just like the rest of us (unless they are hayfever sufferers or asthmatics, and therefore greatly helped by filtered air).

    As and when somebody has successfully demonstrated a totally reliable and affordable whole-house heat-recovery ventilation system which is entirely passive, i.e. relying on convection, we will no doubt all adopt it gladly. Until then, however, the whole-house heat-recovery ventilation system is the very best which is economically feasible for us.

    Now there's a challenge for you!

  4. Technically, MVHR is an improvement on trickle vents and extractor fans. But it may not turn out to be so in practice, especially in a country where people are used to sleeping with their windows open. It needs maintenance to work effectively and, whilst it can and does work effectively in offices and hotels, that doesn't mean it will transpose seamlessly into individual homes. Indoor air quality becomes dependent on mechanical ventilation system: I can't be alone in having doubts as to whether that's really a great idea.

    I think that at the very least, compulsory MVHR should be tested on a few thousand homes for three or four years before it gets rolled out across the nation. But such is the speed with which we are adopting the Code for Sustainable Homes that it's unlikely that this will happen.

  5. AnonymousJune 04, 2008

    "MVHR should be tested on a few thousand homes for three or four years' to see how it performs":

    Will some seven or eight thousand passive houses across Europe satisfy you, from cool northern to warm southern areas ? That seems quite a large – and seemingly successful – trial. And it is reported that some of the owners sleep with open windows too!

    Or, if you look at it slightly differently:

    Provide people with an energy-efficient home. If they do not feel like using the heat-exchange facilities, and prefer to pay for increased energy consumption, then that is their loss. The resulting extra CO2 pollution, however, is a loss for all of us.

    At least, when the house is sold, the next owner can enjoy both the comfort and the low energy bills which the original passive house offers.

    Aren't these fair reasons for implementing decent standards ?

  6. Most of the current PassivHaus dwellers are self-selected, so they don't make a fair trial for MVHR, which is the point that the Austrian delegate was making. You are assuming that MVHR is an "improvement" on what exists now, but to get any benefit from it at all, you have to learn to live with it. Which means maintaining it correctly and also not opening windows when its running. If you don't do this, then there is an energy penalty from double ventilating. So it's not a question of fit and forget.

    So questions remain about MVHR on a mass scale. Does it really make a difference? Could it actually make things worse? Are there any better options? Don't you think it would be wise to find out before we make it obligatory?

  7. AnonymousJune 04, 2008

    Unfortunately it seems to be our tradition that improved building standards are only achieved through regulation. Incentives for improved voluntary standards have worked elsewhere, but here they have been sadly missing. Lack of leadership from the government, and reluctance by the construction sector are all factors.

    Time has run out for us, and improved energy standards are probably now only achievable by the traditional mandatory route. The passive house standard is the best realistic building option and so it has become the chosen level.

    As I said earlier, cost-effective and reliable passive ventilation would be good and could be part of the passive house, but unfortunately none is yet available and the world cannot wait ... hence my challenge to you!

    "Double ventilating/heating":

    If you leave your window open in winter, you pay more for your heating, whether this is by means of a boiler or a heat-recovery ventilation unit.

    If you ventilate your home by opening windows in summer, would you leave your boiler or your heat-recovery ventilation unit switched on? Surely not!

    Deciding to switch the central heating boiler off is no different to switching the heat-recovery ventilation unit off when you don't need them.

    "Fit and forget":

    Boilers need regular maintenance, and kitchen extractor fans need filters - no different to heat-recovery ventilation units.

    In view of the health benefits (re asthma and hayfever), and the financial and CO2 savings, I can't wait to see one installed in my home. I suspect the world can't afford to wait either to reduce the CO2 pollution.

  8. You are obviously sold on the idea that MVHR is a winner. And for many people, it will be. But for everyone? I am just not as sure as you. I've met one or two people who have fitted it and really not liked it, especially the noise of the fans at night. And they were ones who had chosen to fit MVHR. I suspect that a mass roll out will have unintended consequences and that it would make a lot of sense to employ a more cautious approach.

  9. AnonymousJune 05, 2008

    Putting the energy issue to one side, I agree with concern about noise levels; not only ventilation units, but appliances in general.

    Although I have chosen appliances on the basis of low energy use and low noise levels wherever possible, I still dislike the sound of the 'low-noise' fridge, freezer and boiler in the kitchen. In my view that noise is a design fault, and it is not surprising that boilers are often housed in an attached garages where possible, and that appliances in utility rooms are popular.

    Not having these options, I parked my appliances in home-made cupboards with noise-absorbent linings, though obviously I still had to leave gaps for ventilation where necessary.

    In Europe, I understand, boilers and heat-exchange ventilation units are often placed in cellars or walk-in-larder-type cupboards. The ventilation ducts include a length of silencer duct before the outlets. Are these things perhaps missing in the homes of the one or two people you have met? Or are the ducts undersized?

    Be that as it may, you may be interested that efforts are being made to persuade the manufacturers of heat-exchange ventilation units to upgrade their sound insulation, to avoid the expense of a special cupboard or similar.