
The industry consultation on the Code for Sustainable Homes closed in
March 2006 and the outcome of this consultation is now awaited.
Dimplex, through its membership of TEHVA (The Electric Heating and
Ventilation Association), a trade association within BEAMA, responded to
the Code for Sustainable Homes consultation. This stated in summary:
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The Code for Sustainable Homes is welcomed, but this must be in
context with what is deemed to be sustainable during the stated
building lifetime of 60 years. Current legislation is pushing
housebuilders towards gas, which we believe is fundamentally
unsustainable in the long term because:
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Affordability
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The real cost of ownership for gas systems, when taking into
account annual safety checks, on-going maintenance and system
lifetime can be credibly demonstrated to be much lower for
electric systems
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Uncertainty over future gas prices, given that these will increase
dramatically in the medium to long term as we move towards imports
of upto 80% of gas supplies
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Carbon
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The Energy Review signals the Governments intention for lower carbon
centralized plant, contributed to from a combination of
renewables, nuclear and / or carbon sequestration.
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The knock on effect will be reduced carbon intensity figures for
electric heating and hot water systems, which by their nature are
inherently 'renewables ready'.
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It is highly questionable that buildings with low heat demand (in
the region of 1-2kW), whether a gas system and its operational
efficiency will provide efficiency benefits over well controlled
and responsive electric systems
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The carbon intensity figures for electricity should be aligned
with those used in SAP 2005 (EcoHomes currently uses a figure some
23% higher)
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Dimplex disagree that the coverage of six essential elements and other
optional elements is correct.
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Although it is right that the base level for energy efficiency
should be set at 2006 Part L levels and that there should be
incremental steps to improve the efficiency of the fabric of the
building, it is critical that back-stop u-values for fabric
measures be defined to ensure that fabric measures are not traded
against the energy performance of the services.
This is
critical point as the services will be replaced during the
lifespan of the building, as may its use, but the fabric will
determine its long term sustainable footprint.
Click
here to download a copy of the BEAMA consultation response.
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