19 Jun 2012

Is Thorium a Super Fuel?

Yesterday, I pitched up at Cambridge University's Engineering Dept to hear thorium evangelist Rick Martin talking about his new book, Super Fuel, subtitled Thorium, the Green Energy Source for the Future.

For those of you not familiar with the buzz about thorium, it's an alternative to using uranium as a fuel for nuclear reactors. It's abundant, it's much easier to manage and the waste and proliferation issues are greatly reduced (though not eliminated). I could go on, but you'd do better to look at the book.

What's just as interesting to me is that thorium has evangelists. Evangelists like Apple used to have evangelists? Yes, not so very different. But why would anyone evangelise nuclear power? Well, just as Apple was once a David pitching itself against Microsoft's Goliath, so thorium is very much a minnow when pitched against mainstream nuclear power. It's not just the fuel, it's how you use it and the buzz is all around liquid fluoride thorium reactors, known in thorium circles as Lifters, which don't need pressurising and have in-built passive protection against meltdowns.

This is not new technology. A Lifter was built and run for a while at the Oak Ridge Labs in the USA in the 1970s by Alvin Weinberg, the godfather of the thorium brigade. It worked fine but it got closed down because the USA decided that uranium reactors suited them better (at least in part because they could be used to produce enriched uranium for bombs). Since then very little has happened until very recently; the Chinese are now building a couple of lifters, and India is also starting to use thorium though as a solid fuel, not a liquid.

In the West, it's mostly down to the evangelists, notably Kirk Sorensen in the USA - you can watch his TED talk here:it's only 10 minutes and, boy, does he sound like Steve Jobs. Rick Martin seems to be his John the Baptist, not as technical but just as keen. Sorenson's and Martin's enthusiasm is infectious because, due to them, we know have our very own British evangelist, Bryony Worthington, who just happens to have a seat in the House of Lords. Worthington started out as an anti-nuclear campaigner at Friends of the Earth but re-assessed her views after coming into contact with Kirk Sorensen and finding out about thorium. There is also a Weinberg Foundation dedicated to spreading the thorium message.

I'm afraid I'm a sucker for all this. I don't know enough about nuclear physics to judge whether thorium is quite as wonderful as the evangelists make out, but there is such a buzz about it that it's hard not to get excited about the possibilities, especially as I feel so bleak about so many of the other options facing us. Hell, thorium even has its own skeptic, Arjun Makhjani, who makes nit-picking points about why it might not be such a great idea. You can hear him debate with Rick Martin here. Somehow, having a tame skeptic makes it all the more believable.

Martin made the telling point that nuclear R&D pretty much ground to a halt after Weinberg was sacked from his job by Nixon in 1973. Then, after the Three Mile Island accident in 1979, it all just froze up. Nuclear power went right out of fashion and no young grad student worth their salt ever considered dedicating their life to nuclear research. Renewables were just so much more fashionable. But now it's changed. Martin said the current situation reminds him of Silicon Valley c 1980 when there was IBM who were everything in computing and all these little start-ups with very different visions of what might happen.

This tacitly acknowledges that thorium lifters are not the only nuclear game changers in town and that there are other vision of where we could go with nuclear slowly gathering momentum, notably the travelling wave reactors which are being backed by Bill Gates. There are other designs too - known generically as 4th Generation Reactors. And let's not ignore the €10 billion being spent on the experimental Iter fusion reactor in France.

After decades in a semi-moribund state, nuclear research has once again come alive, promising solutions to many of the age-old issues that have dogged the industry. But to date it's only thorium and its lifters that seems to get evangelists excited. It's hard to know quite why this is but I feel that in large part it's because of the back story of how the initial research was shelved and forgotten and how it's been unearthed by an unlikely, non-establishment hero. There is a touch of the fairy tale here, a touch of magic. Nuclear power badly needed re-branding and Kirk Sorensen may just be the man to do it.

13 Jun 2012

Is there anything good in the Green Deal?

Yesterday, I went to a meeting in London put on by SPAB (Society for the Protection of Ancient Buildings) called to update people about their research into energy efficiency measures used in older properties. SPAB have become remarkably active in this field recently and there were nine presentations, each on different projects.

At the very heart of this research is a central fear that adding piles of insulation into old buildings (or indeed new ones) may cause havoc with the moisture levels in the fabric and may end up causing more harm than good. All across the country, researchers are beavering away measuring temperatures, U values, airtightness, relative humidity levels, rainfall, trying to work out what happens to homes both before and after treatment. What emerged was how little we really know about the behaviour of buildings, and how little research has been done.

The establishment view is summarised by two standards, BR 443 which deals with heat loss and sits behind the SAP calculations and BS 5250 which deals with condensation risk. In theory, if your wall assembly (or roof or floor) meets BR 443 and passes the BS 5250 test, then all is hunky dory. But in real life, most of the researchers were saying that neither standard really cuts the mustard and that the moisture modelling suggested by BS5250 is so simplistic that it's a veritable danger.

Which begs the question, what should replace it? Much was made of the more complex, dynamic WUFI model, though some pointed out that not everyone agrees that WUFI is the answer. Surely the Germans would know the answer? Maybe, but Neil May made the interesting point that he had reviewed much of the German language literature and wasn't convinced that their understanding was much better than ours. It seems that moisture behaviour in wall and roof assemblies remains poorly understood and therefore unpredictable.

So what's this all got to do with the Green Deal? Actually, it's pretty central because here we have a government policy which is designed to bounce us into both internal and external wall insulation in older properties, precisely the sort of measures which SPAB are highlighting may cause future problems. The Green Deal wasn't the purpose of this meeting, which was arranged months ago, but nevertheless the Green Deal did rather dominate proceedings and several interesting things came to light. To their credit, DECC (the government department behind the Green Deal) provided two spokepoeple, Nicola O'Connor and Steven Daniels, who explained some of the logic behind the recent publications, but they shot off pretty soon after their presentation and weren't around to hear the deluge of disquiet that followed.

One issue that kept emerging was the initial survey. There are, apparently, 45 measures which might be eligible for Green Deal finance, but which of these are suitable in any given household depend on the survey assessment by a professional who, it emerged, is going to be paid the princely sum of around £30 for undertaking this work. How much time is that going to buy? 10 minutes, if you are lucky. And will the advice be any good? More likely, it will be sales advice with commission for any number of supposedly Clean Tech businesses. "Will the survey be independent?" rang out the question from the floor. "We can't insist on this, but it will be impartial," replied DECC. "Hmmm", went the audience. A good independent survey, it was pointed out, like the ones Parity Projects undertake, is more likely to cost around £300-£500. Are "ordinary people" going to be happy to fork out an amount like this for a proper survey which might tell them to do nothing?

Then there is the warranty/guarantee. Apparently, there is to be some such scheme in place for Green Deal work, but exactly how it might work is hard to fathom. 25 years was mentioned, but can any building work be guaranteed for 25 years? This seems fanciful. And the loan is to be attached to the utility bills of the house, rather than the person who negotiated it, so if the house is subsequently sold, the loan goes with it.

Can you imagine what a sales boost this will be? "Oh, by the way, you have to pay £500 a year extra on your fuel bills until 2030 for all that insulation we stuck on the bedroom walls, and that air source heat pump which is in the garage but which we don't use very much."

More to the point, can you imagine big finance houses wanting to lend money on these terms? Combine the risk of an-as-yet unknown borrower with a warranty for work undertaken by others and just what would the interest rate be? That's a key point, and one that remains to be addressed. But if it can't beat a bank loan, or peer-to-peer lender Zopa, then what's the point bothering?

All in all, not a good word was to be heard for the Green Deal. I was almost beginning to feel sorry for it by the end of the day. Almost, but not quite.

18 May 2012

Should we re-nationalise the utility companies?

I've done the conservatory tax to death. On its own, it's perhaps not the biggest of stories and doesn't rate more than a footnote in the annals of the political machinations of the Coalition. But the problem is that it's not on its own. It's symptomatic of a whole raft of fudged decisions and misunderstanding which are beginning to taste of a deep rooted crisis in our energy policies.

On the plus side, we have in force a Climate Change Act which commits us to an 80% reduction in carbon emissions by 2050. We are, apparently, just about the only country to have done this. But as far as the plus side goes, that's just about it. I quite fail to see exactly who will be held responsible for us failing to meet this "legally binding target." But, despite this conundrum, it does at least show that the government of the day understands the nature of the problem facing us with climate change and carbon emissions.

But the big problem is how do we get from A to Z. How do we bring about an 80% reduction in carbon emissions by 2050? This is where the roadmaps come in. They offer the opportunity to map out a strategy to power society in a less carbon-intensive way.

Now you can take two approaches to energy roadmaps. You can meticulously map out scenarios for every form of energy use you can think of from cooking to commuting, pointing out just where improvements can and cannot be made. Or you can take a broad brush approach and just reduce the amounts of carbon we are allowed to burn each year and let society organise itself as best it can. Having been studying several of the micro-management roadmaps over the past year or so, I have come to the conclusion that the latter approach is preferable. The basic problem that cannot be addressed by the white-box, micro-approach is that we have no idea how much energy we will have in 2050, nor what price it will be, and without this information we can't begin to make sense of what we should be doing in the lead up to 2050.

A good example of this is the issue of the Green Deal and the retrofitting of insulation to our existing housing stock. Technically, we can do it to any standard, from simply filling up existing cavities, to undertaking radical Passivhaus-style retrofits. The difference in cost is maybe a few hundred pounds per house for the former, or a sum equivalent to rebuilding the entire house from scratch for the latter. Or, indeed, we could head somewhere in between these two extremes. But without knowing the cost of low-carbon energy in 2050, we can't make an informed decision about which way to go.

So we end up with a miasma of polices that sound like they are pointing generally in the right direction, but which in reality no one has a clue about. The Green Deal is a perfect example of this. Under it, you'll be able to borrow money for home energy improvements and you will be able to pay them off by adding the repayments onto your future energy bills. The idea — the Golden Rule, no less — is that your future fuel savings will more than compensate for the cost of the repayments added onto your fuel bills.

But there will be no guarantees about the cost of energy in the future, nor about whether the work carried out on your house will actually deliver the savings promised. The Green Deal pretends to be a hard-headed business decision, but it's no such thing, because the outcome is so tenuous.

Or take nuclear power. It's future is also in doubt and the underlying issue is surprisingly similar. Whilst businesses can calculate how much it will cost to bring a new power station on stream, they can't count on there being a sensible return because no one will guarantee them a price for the electricity they will produce. To do so is said to be anti-competitive, to be rigging the market or, as some green groups claim, to represent a subsidy. So the one form of baseload low carbon power that we know is technically feasible is unable to make any progress in the current environment, not because of people's dread fear of there being another Fukushima but because governments won't provide any guarantee that the product will be sellable.

No wonder all the energy companies are having second thoughts about new nukes. It's a bit like building a new hospital or school under a PFI scheme but without any forward contract indicating that the government would ever pay for it. Energy is seen differently: it's not a social good, like health or education, but a marketable product which we have to buy.

Or at least until people can no longer afford to pay for it. In fact, we have a new category of distress, fuel poverty, as if this is different to food poverty or clothing poverty, or just plain poverty.

And here we stumble upon the very crux of the problem. Much of the ongoing discussion about the Green Deal (and all the other energy subsidies that are flying around at the moment) centres on whether they are regressive, in effect transfers of money from the poor to the rich. It tends to be the rich that do things like do up houses and fit solar panels and to date much of this work has been paid for by hidden taxes loaded onto our fuel bills. Actually, there isn't much of a discussion to be had here because the answer is clear cut — yes, they are regressive, at least in the way they have been formulated to date.

Somehow the idea has taken root that the changes to our energy-burning habits must be funded from our existing energy consumption (i.e. our utility bills), a prime example of a hypothecated tax, and a prime example of why hypothecated taxes are not such a good idea. No one insists that the money raised from motoring taxes should all be spent on roads, or even that National Insurance should all be spent on pensions. So just why has the idea taken root that subsidies for low carbon energy or energy efficiency measures must come from our burning of high carbon energy? If these goals are socially desirable (which they are), then it's plain wrong to load them onto utility bills at a time when utility bills are already very high. People can see the connection, and the hoped-for improvements very quickly become unpopular.

In essence, energy policy is now trapped somewhere between the old Thatcherite dream of it being a privatised commodity and the new reality of it becoming a social good, like the NHS or the education system. Left to the market, it will continue to burn oil and gas, and exploit shale gas and tar sands and whatever else is around to keep the fires burning. But it will simultaneously be pumping CO2 into the atmosphere at an alarming rate, as if there is no tomorrow. Capital intensive projects like nukes and offshore windfarms and housing retrofits will be be ignored because the financial outcomes are too unpredictable, and just raising taxes on fossil fuels to pay for capital intensive low-carbon projects is becoming self-defeating.


Which begs the question, is it time to remove the utility companies from the market and make them, temporarily at least, more like the NHS? It seems politically completely off the radar, but it would enable the big infrastructure decisions to be made with long term planning in mind. If coupled with a guarantee to keep people warm through the winter (isn't that a social good to rank alongside the work of the NHS?) and to engineer a switchover to low-carbon power by 2050 at a price which wouldn't cripple the economy, then it makes sense. At least it makes more sense than allowing the current market failure to continue unabated.

After 2050, the utility companies could once again be sold off with a proviso that they could never again make money by burning fossil fuels. We did it for the banks. Arguably, this is more important.

20 Apr 2012

Conservatory Tax: what happens next?

The press story about the Conservatory Tax seems to have died down. It was perhaps a ten day wonder and it appears to be game set and match to the Daily Mail. There may be a few further rumbles along the way, but the way press fever works in this country there is a good chance that none of the Sunday's will run with it and by this time next week everyone will have forgotten about it and will be focussing on something new.

But just before we all forget it, I'd like to make a few further comments, and add a few pointers.

• The heart of the issue was to do with a consultation exercise on Part L of the building regs, essentially whether or not to include a requirement for consequential improvements (CI) for those improving and/or extending their homes.

• It had precious little to do with conservatories (which are rarely classed as extensions), nor was it to do with tax, but the Mail chose to christen the whole episode the Green Conservatory Tax. The name has stuck, which adds to the irony if nothing else.

• It was also only indirectly related to the Green Deal, which is essentially a financing option for those wanting to undertake green improvements. But not many people understood the differences between Part L's CI and the Green Deal. As far as Mail readers were concerned, they were both green and therefore both bound to be expensive.

• The case for CI stands on its own. It doesn't need the Green Deal to help pay for it, anymore than complying with any other aspect of building regs requires special financing. But the consultation muddies the water by suggesting that CI might be paid for by using the Green Deal. This, to my mind, was a mistake, because it is ceding the high ground of building reg compliance and intimating that CI was too bitter a pill to swallow without some sugar coating.

• It also ties CI to the Green Deal. What if the Green Deal ends? That would lead to us having an unenforceable building reg. By the way, lovely summary of Green Deal here on Casey's blog.

• The CI triggers were muddy. Having to undertake CI when your boiler has just blown up and needs replacing is not a good policy. It gets up my nose, so can't fault the Daily Mail for highlighting it. An own goal. There should be some simple to understand, justifiable CI trigger. I would suggest that if you are increasing the heated are of the house, then you have to undertake CI. A stricter one would be that the overall heat loss performance of the house shouldn't be any different before and after your extension is built. Now that would be hard sell.

• The element of compulsion in CI remains thorny, although it's not quite as novel as people initially imagine. There are lots of examples of the building regs compelling people to undertake work they might not care to do, and sometimes this goes on inside the existing house rather than being confined to new works (think loft conversions meeting fire regs).

• One possible alternative might be to offer trade-offs. For instance: you can build your extension to 2016 standards (might cost you are extra £2,000, with much wider walls) or you can build it to 2010 standards and spend £2,000 on CI inside the existing house.

• Another option might be to make greater use of Energy Performance Certificates and say that, if you want to extend, you must upgrade the overall energy performance of the house, say from E to C. EPCs are in theory a great tool to use to upgrade the housing stock, but they are hardly being used at all: in fact they are widely derided for being pointless.

• Finally, it's worth saying that all these policy instruments (and that includes Part L in its entirety, Green Deal, EPCs, FITs, RHI, you name it) are substitutes for a simple effective carbon tax. As long as we embrace piecemeal solutions to the fundamental problem of weaning ourselves off fossil fuels, we are likely to end up with flawed policy levers which get people very excited (both for and against) but are never going to achieve their goals.

18 Apr 2012

Conservatory Tax: Day 10, the plot thickens

The Conservatory Tax story broke on Easter Monday in the Daily Mail. That's 10 days ago. If you need to catch up, check out the last three blog posts on this site. By the weekend, both the Mail and the Telegraph were full of rumours of a "large Tory revolt" against Part L's consequential improvement proposals. No one was directly quoted.

Then on Monday 16 April, exactly one week after the initial story, the Telegraph and the Mail publish news that consequential improvements have been scrapped as a result of a "massive Tory backlash", and the next day the Mail prints a more revealing story that David Cameron himself thinks the whole idea was bonkers.

Drill deeper an it appears something very strange is going on here. This is a change of policy, no doubt about it. On Feb 7, Andrew Stunnell, the Lib Dem minister in charge of building regulations, made a speech at the BRE stating that consequential improvements were definitely going to happen. Stunnell said: "It's the grand old Duke of York of building regulations policy... but this time we're going to do it." This refers to the fact that twice before consequential improvements have been mooted in consultation, but never made it passed the finishing post into the published Part L.

But it now appears that Stunnell has been humiliated. "Cameron's spokesman", quoted in the Mail, says "This is a bonkers proposal and the Prime Minister frankly doesn’t understand how it got into the consultation document in the first place." Had he not thought to ask Stunnell? Does he really not have a clue what his ministers are up to? How embarrassing for both Cameron and Stunnell.

Cameron's source continues: "He is not going to allow a situation where someone who wants to do a bit of home improvement is forced to pay another 10 per cent on top."

Is this really a source close to Mr Cameron? Or Cameron himself hiding behind journalistic etiquette? Whoever uttered these words, it sounds like some bloke leaning over the bar at the Dog & Duck having a rant. Like "I only wanted to knock the two rooms into one. Bloody building inspector insisted I put a beam in between: cost an arm and a leg." Or "The sod made us put fire doors on the bedrooms when we did the loft. It was that or sprinklers. Jeezzus, I'm not made of money."

Then the source let's out "We’re all for going green but this is a ridiculous idea, innit." OK. I added the "innit", but you can almost hear it anyway. This is now apparently how government policy is being formulated. We are talking building regulations here, not Abu Qatada.

The old fashioned way of determining building regs went thus. Committees beaver away for months, civil servants draft and redraft documents, consultations get launched, reviews are undertaken and, yes, lobbying goes on behind the scenes. This is how every building regulation we have ever made has been shaped (till now).

Then you have the new way. The Daily Mail blows up a scare story out of almost nothing and 8 days later you have a source close to Mr Cameron spiking the carefully laid proposals, in a interview that's not even an interview. No official word on the change in policy has appeared anywhere on government websites or dispatches. It's all been conducted through the Mail.

And, stranger still, rather than congratulating the Prime Minister on "seeing sense", the Mail then goes and lambasts him for making another U-turn. In the very same article. U turn No 9; time taken to complete U-turn = one week.

It really does make you wonder who the hell is running this country. Is the Mail's agenda to attack any piece of environmental legislation they can uncover, or is it simply to humiliate the Prime Minister. Or both? Not only do they make Cameron sound like a half-wit, but they then go and slap him about for being a half-wit.

There are dozens of things Cameron could have said which wouldn't have pushed him into a corner like this. Such as "We are aware some of the proposals are controversial but it's only a consultation exercise and we will be looking closely how best to press ahead in the coming months." OK, this sounds a bit boring and staid, but it's got to be a bit better than "it's bonkers" and "I've no idea how this came about." That is just so pathetic it's embarrassing.

Something went on between Whitehall and Kensington High Street, home of the Daily Mail, but we outside the Westminster bubble are not party to it. There is more than a whiff of authenticity about it all because Downing St has come out and said they still support the Green Deal: if they supported Part L's consequential improvements as well, they would have said so, but instead there has been a stony silence.

What really pisses me off is that this is all happening in the midst of the Leveson enquiry which has a brief to look at the relationship between press and politicians. Here we have a prime example of the press interfering with due political process. They have barged in, demanded a forum with a menu of half-baked, ill-conceived criticisms, ridden roughshod over all other consultees, and have seen the government cave into their demands in the space of a week.

There could of course be more to this story. Far from being the instigator, the Mail may have been acting on behalf of disaffected Tories looking for a way to overturn these "unpopular proposals." But adding a level of conspiracy to the proceedings only makes matters worse. Either way, the verdict is damning. This is no way to run a railroad.

Finally, a lovely piece in the Guardian about what's been happening in Uttlesford DC for the past five years, where consequential improvements via planning permissions have been hailed a great success by the Tory-led council. And Uttlesford is not alone. I know of at least one other council, Forest of Dean, where similar schemes have been running and I suspect there may be more.

Consequential improvements are nothing new nor scary. You could argue that they underpin the entire edifice that is the building regulations, by making people go that extra mile to get things right. If you want to build a roof, brace it properly so it doesn't collapse. If you want a toilet, make sure it's vented so it doesn't smell. If you are putting in stairs, make sure people can get up and down them safely. And if you are making major alterations to your house, make sure you can afford to heat it. Just why is there a "massive Tory revolt"?

17 Apr 2012

The Case for Consequential Improvements

From the debate so far, you'd think that consequential improvements were designed purely and simply to get up the noses of aspirational, squeezed-middle, Daily Mail reading home improvers. They weren't. There is a good case for them and it's not being heard.

At the heart of the matter is the question of energy saving and the law of diminishing returns. It states that the first inch of so of insulation saves a mass of energy, but each subsequent inch saves less than the one before. This is expressed in mathematical terms in U value calculations which show that if you want to halve the heat loss, you have to double the amount of insulation.

It's relatively easy to halve the heat loss of an existing wall with no insulation in it. Adding around 50mm of insulation will reduce the U value from around 1.2 to around 0.6 (that's half). It's much more demanding to halve the heat loss in an extension which is being built to modern standards: getting a wall from a U value of, say, 0.3 down to 0.15 would involve widening the cavity from around 80mm to nearly 200mm, and forking out for 120mm extra insulation. There are other details to consider here as well, but for simplicities sake, I'll ignore them.

In doing this, your extension may have halved its energy loss but it's done it from a much lower starting point. The total energy saved in the new extension will be far less than you might save in the existing house where you've only had to add 50mm of insulation. You've also, incidentally, lost a significant floor area from your extension as the walls have to be so much wider to cope with all that insulation.

The financial calculations are even more compelling. Adding 120mm of extra insulation onto a 30m2 extension is complex and relatively expensive: it could easily add a couple of thousand onto build costs. Cavity wall insulation on an existing house usually costs between £300 and £500. The cavity wall insulation will result in far more energy being saved, and have a far greater effect on fuel bills. Like an order of magnitude.

Financially, it's a no brainer. It makes sense to insist that the existing house is upgraded rather than pouring money into building an ultra-low-energy extension.

There is more. Any energy saving you might hope to get in the newly-built extension will be mostly lost via the existing house, meaning that the expensively constructed low-energy extension will probably not save any appreciable amount of energy at all. And the whole house now risks being uncomfortable to live in, neither fish nor fowl. It would be like wearing a coat where the left side is made of a thin cotton and the right side of thick sheepskin. What a crazy design? Who would choose such a coat? Who would choose to live in such a house?

Like it or not, consequential improvements make sense, at least when the house is being extended. If it was to really have teeth, Part L would be insisting that anyone extending the heated floor area of an existing house should ensure that the overall heat loss of the new should be no more than the old. Now that would be draconian (but it would also make a lot of sense).

As it stands, the suggestions for improvements as set out in the Part L consultation are very watered down so that only four actions are required:
• cavity wall insulation (only if you've got an unfilled cavity)
• extra loft insulation (big deal)
• cylinder lagging (again, it's a nothing job, and over half the country doesn't even have a cylinder, they use a combi)
• draft proofing

It's very hard to see this lot costing £10,000 for anyone, unless you happen to own a huge country house. It's hard to see it costing much more than a grand on most homes. With or without the Green Deal, it's not going to be very expensive to install these and it makes sense it terms of overall comfort, if nothing else.

Up till now, Part L has tried to maintain some sort of parity of standards between new build and extensions, but it's reached the point when the two are about to separate because (as discussed) it makes little sense to build extensions to new build standards if the existing house is a drafty old pile. What should Part L do for extensions? Should it insist that they continue to ape new build standards (cost maybe £2,000 per extension, energy saving negligible) or should it branch out and insist that the equivalent money is spent in the existing house? The answer is obvious: consequential improvements are logical, sensible and justifiable.

200,000 extensions a year represents a huge floor area, comparable with the floor area arriving via newly built homes each year. Are we just going to give up on trying to get these homes fit for the 21st century? High energy bills are not going to go away anytime soon and Part L is one of the very few tools at the government's disposal to protect people from them. Ditch consequential improvements and you leave a gaping hole in energy policy.

As a footnote, I do think it was a mistake to add replacement windows and boilers as triggers for consequential improvements. I wonder whether they were placed in the consultation as a negotiating ploy, so that something could be conceded before the final version of Part L was published. If so, it has backfired badly. The principle of consequential improvements should be simple to grasp: if you chose to extend the heated envelope, you must improve the energy performance of the existing house. Adding window and boiler replacement as triggers muddied the simplicity of this golden rule.