Written evidence submitted by Active Building Centre Research Programme (DHH0108)



1.              Policy impact

2.              Priorities and timelines

3.              Technology mix

4.              Barriers to scale

5.              A fair transition

6.              Impact of environmental levies

7.              Incentives and regulations

8.              Household engagement

9.              Responsibilities and governance



The Active Building Centre Research Programme (ABC-RP) is a collaborative programme encompassing 10 of the UK’s leading Academic Institutions developing innovative tools and technologies that will ensure buildings of all scales contribute to a reduction in carbon emissions and a more sustainable built environment.

We are working across a broad range of technologies and research themes to demonstrate and evidence the net-zero emissions benefits that buildings offer at building and community scales.

Core technology and research themes encompass:

        Thermal storage

        Predictive building controls

        IoT and monitoring platforms

        Building energy modelling

        Power network modelling

        Energy analytics and stock modelling

        Socio economic impacts

Our research programme is underpinned by the design and development of a suite of tools that enable the application of these themes in real world environments. Through our work, we are accelerating:

        A reduction in the carbon impact of the built environment

        Improvements in the quality of homes and workplaces

        Academic research into industrial applications 

        The UK’s trajectory towards net-zero

Further information on our programme, and active buildings, is available here – www.abc-rp.com, and from our partner organisation here - www.activebuildingcentre.com.

The responses and evidence provided in this document have been developed by experts from across our consortium and highlights three key themes:

  1. Data, from buildings and systems, is key to enabling a strategic and measurable approach
  2. A whole-system, whole-life approach will deliver the most impact and can be enabled by emerging methods from research communities
  3. The ‘Buildings and Heat Strategy’ must draw on UK research activities and act as the catalyst to accelerate their outcomes and impact if we are to achieve net-zero by 2050

We are submitting a response to this call for evidence as our research programme is delivering research outcomes that will enable the decarbonisation of the built environment.

As this consultation progresses, we would welcome the opportunity to provide expert witnesses with expertise in this area.

Active Building Centre Research Programme response

1.                Policy impact

What has been the impact of past and current policies for low carbon heat, and what lessons can be learnt, including examples from devolved administrations and international comparators?

To decarbonise the heating of buildings, a systematic approach should be taken across both new build and existing stock. This should take a whole house, holistic approach, significantly reducing energy demands and ensuring supplied energy is delivered with zero emissions as the UK’s capability to do so increases.

Policy impacts

Building fabric improvement has been addressed through successive tightening of Building Regulations, with the average SAP in England improving to 62 in 2016 from 45 in 1996. However, only 1.4% of new-build energy performance certificates in 2019 were in Band A. Further, poor design has not been discouraged in Building Regulations Part L, and neither do these regulations impose performance targets. So, although building performance has improved, the lack of firm performance targets and the use of minimum standards for buildings in past and current policies may have, in some cases, led to a ‘do the minimum’ approach. This has lessened the potential impact of policies on carbon reduction.

The Code for Sustainable Homes ended in 2014, and the key lesson learnt since its abolition is the value of a national standard for building performance. The code provided a transparent pathway which enabled the market to invest with confidence, leading to reductions in deployment costs. It also enabled impacts from policy changes to be measured and future decisions to be based on quantitative and qualitative evidence. There are several initiatives attempting to address this lack of a national standard and performance data, most recently within the Optimised Retrofit Programme launched in November 2020 by Welsh Government.

Additionally, there is currently no clear definition of what is meant by ‘net-zero carbon homes’ within UK regulations.  For clarity and purpose, the government should provide such a definition and align building performance targets. The Future Homes Standard is the ideal vehicle for this. The definition needs to accommodate new-build and retrofit requirements for the decarbonisation of the UK’s built environment and should also target future technological innovations. 

Our academic partners at the University of Bath have expanded on the need for a clear definition of a net-zero carbon or active building in their white paper 'Buildings as Energy Infrastructure, not Passive Consumers,' available here.

International comparators

The UK has a temperate climate so comparison with northern European markets, especially parts of Germany, France, the Netherlands, Belgium, and Denmark, are most appropriate. For example, in regard to U-values, England has adopted a significantly different approach to these markets; the values for the fabric thermal transmittance are entirely voluntary. The limits on the individual fabric elements are only statutory guidance yet act as a limitation to the design flexibility. By only providing voluntary guidance, the impact of this policy on low carbon heat has been limited. 

Devolved comparators

In the UK, ambition is growing at devolved, sub-national and local scales to create ‘low carbon economies’ or ‘local energy marketplaces’ (c.f. Welsh Government 2019; Local Energy Oxford 2020). These take the approach of localised, multifaceted decarbonisation of buildings and infrastructure, heat, and other energy vectors, and are sometimes viewed as solutions to energy vulnerabilities. They are also seen as beneficial to the development of sustainable low carbon local economies. 

By way of example, The Foundational Economy is an approach taken by the Welsh Government to ensure public sector investments improve the economy in Wales by developing the growth of vital services and skills.

The recently launched Optimised Retrofit Programme is one such initiative designed to help deliver decarbonisation throughout the Welsh economy. This is a strong example of using public investment to leverage greater private sector investment to trial new decarbonisation approaches across all areas of the home, not just heat.

Beyond decarbonisation, the programme is being used as a tool to fuel the green recovery post-Covid and support growth in a long-term, economically, socially, and environmentally sustainable fashion.



2.                Priorities and timelines

What key policies, priorities and timelines should be included in the Government’s forthcoming ‘Buildings and Heat Strategy’ to ensure that the UK is on track to deliver net-zero? What are the most urgent decisions and actions that need to be taken over the course of this Parliament (by 2024)?

To achieve net-zero by 2050, the UK Government must begin technological deployment immediately with low regret, high-TRL options.

All net-zero carbon scenarios see a major role for heat pumps and fabric improvements which can and must be deployed as soon as possible. Although these technologies are not new, their deployment in the diverse UK building stock is, resulting in two challenges:

        A performance gap, which for heat pumps can be significant and if not tackled during deployment will have cost and infrastructure implications

        Unintended consequences from inappropriate specifications or other implementation issues which can ruin people’s lives. This is particularly important when considering the social housing sector where such consequences would impact disproportionately on the fuel or cash poor

The UK must put into place a major programme of deployment orientated research and innovation that tackles these two issues. This should be a long-term collaboration between industry and academia with clearly defined goals and a shared vision. The programme should be supported by long-term policy predictability which will encourage SMEs and large corporates alike to invest in the new skills, and capabilities required to deliver at a national scale.

Related to the above point, the UK needs to establish local manufacturing capability for these international technologies. This should be incentivised to work in conjunction with a deployment programme focused on tailoring the technologies to a UK context. 

To aid policy predictability, national, open source data infrastructures to capture building and sub-system performance should be established as a priority. This will make policy decisions more transparent, enable their success to be measured, and future decisions to be based on quantitative and qualitative evidence.

Again, we point to the Welsh Government’s approach to the Optimised Retrofit Programme as an example. A relatively small investment is being made to test the best approach to decarbonising homes at a meaningful scale. The programme is underpinned using open standards and performance data capture to enable analysis of the effective approaches from across the scheme which can then be scaled. 

3.                Technology mix

Which technologies are the most viable to deliver the decarbonisation of heating, and what would be the most appropriate mix of technologies across the UK?

Viable technologies

The success of any technology in decarbonising heat is predicated on having access to low or net-zero carbon energy vectors (either electricity or hydrogen or both) and needs to be underpinned by a reduction in demand. There is a growing consensus that electricity will be low-carbon or even net-negative by the mid-2030s, due to the wider focus on decarbonising the electrical generation mix.

The range of currently viable technologies for the delivery of low-carbon heat are well known. Heat-pumps of various types (ground source, air-source, hybrid) and resistive electric heaters can be deployed at scale and have been shown to increase the flexibility in building energy consumption by at least 40%. Deployment should be at building level and through energy centres at a community and city scale.

Imperial College London, a member of the ABC-RP consortium, has recently published a white paper which provides more detail on ‘The role of active buildings in the transition to a net-zero energy systems’ available here.

The use of hydrogen gas boilers at a building level, or at a larger scale within an energy centre, is conceptually like the delivery of heat through electricity as the energy vector; both are viable and deployable forms of technology. 

While hydrogen is a useful energy store, there are many challenges to its deployment domestically. While the biggest may be cost, the infrastructure requirements underpinning this are significant; it is estimated that the pipes carrying the hydrogen would need to carry  approximately 3.3 times more flow than at present.

Reduction in demand on the property side of the meter is the other half of achieving decarbonised heat. This is best achieved primarily through targeted fabric improvements across the existing UK building stock. Heating and hot water systems will also require significant improvement in performance to respond to peak grid pressures and times of high levels of carbon in the grid-supplied energy mix. Real-time consumption monitoring will help optimise building performance, as well as more intelligent control mechanisms. Coupled with active technologies, buildings will be able to perform more efficiently for both occupant comfort and energy consumption, supporting a significant reduction in demand.

To maximise the benefits of an electricity-powered supply system, storage technologies should be implemented as widely as possible to provide more active technology capabilities. On-site battery and heat storage technologies are rapidly advancing in efficacy and capacity and falling in terms of cost (although batteries certainly have yet to achieve a high ROI). Both technologies can store energy either generated or supplied at times of low-carbon intensity to be used when grid-supplied energy is at a high-carbon intensity. Thermochemical heat storage technologies that are deployable at scale and low cost are emergent and currently at low TRL levels, so currently deployable options are water-based. Batteries are a proven technology and mix well with on-site renewable generation, however, cost implications are a barrier to wide deployment.

Electrical heat-pumps are beneficial in the amount of energy they require to operate; much lower than a resistive electrical heater or hydrogen gas boiler. However, as most customers currently meet space heating and hot-water demand using natural gas, these benefits are not seen by the consumer. This is because gas is much cheaper than electricity (see Q5), a factor that needs to be addressed to successfully decarbonise heat in homes. 

Based on the above points, electrically powered technologies supplemented with monitoring and control systems should be prioritised as they are currently the most technically and economically viable. Reducing the overall heating demand through fabric improvements will further support decarbonisation by reducing overall demand. Coordinated retrofitting existing building stock and increasing the standards of new-build properties should also be prioritised. 

Technology mix

The most appropriate mix of technologies across the UK will vary, ensuring the appropriate choices are made at a regional and local level. The variety of building stock across the UK means that not all properties, or consumers, would be suited to having heat-pumps, or resistive heating, or connection to a heat network. In some cases, this may be economically unviable; for example, the Trent Basin development is in close proximity to the local heat network, but it was cost prohibitive to connect the new homes. Instead, the developers looked to deploy a different mix of technologies that were more economical. 

It is clear that deployment of heat pumps, heat networks and hydrogen boilers needs to be significantly increased as part of the technology mix, but this must be done so in a coordinated manner aligned with fabric improvements, storage capacity, and tailored at a regional level. The critical factor being those technologies that are deployed are scalable, widely integrated, and grid-flexible, to enable future enhancements and capacity.



4.                Barriers to scale

What are the barriers to scaling up low carbon heating technologies? What is needed to overcome these barriers?

There are several barriers outlined throughout this response, the largest being demand reduction which, as mentioned on a number of occasions already, must be addressed through targeted fabric improvements to homes. Reducing demand is still the most efficient way to reduce carbon emissions and provides numerous systemic benefits from local job creation through to health and wellbeing improvements.

Advances in manufacturing offer the opportunity to radically reduce the cost of retrofitting buildings and scaleup deployment of low carbon technologies. At the same time, the availability of data on the performance of our building stock is improving as new methods of gathering and generating data accelerate in their performance and deployment.  Coordinating advanced analytics and manufacturing processes as part of the toolkit of low carbon heating technologies is vital to ensure we maximise these opportunities and avoid locking in the current high levels of consumption and the cascading impact of this consumption upon the energy system.

Beyond the core points outlined above, we would highlight the following contributory factors that are key barriers to scaling low carbon technologies.

Applied research

Further investment is required into the research and development of zero-carbon heating technologies. Critically this needs to be outcome focused, scalable (from component to system) and integrate economic and health and wellbeing factors. Specific areas of focus should include:

Occupant behaviour

New heating and hot water systems in buildings will create a new ‘shiftable’ load to decarbonise consumption, but occupants may resist shifting to low-carbon heating technologies over time due to what is known as ‘occupant fatigue.’ This fatigue may be from experience, for example a negative perception resulting from previous government-led house improvement initiatives, or just a lack of engagement with the need to decarbonise heat in homes. Building performance that does not deliver against the occupants’ expectations may also contribute to occupant fatigue and lessen the impact of the technological interventions (see Q8). An occupant-centred approach to delivery of these technologies must be adopted and it should be based on regular, open, and coherent communications.

Data availability

A clear view of the impact of previous and current standards on UK homes, which would enable targeted and appropriate retrofit improvements, is not available. This lack of data means that the exact scale of the retrofit challenge, and the particular interventions required for each property to decarbonise heat, cannot be known to any degree of accuracy. As discussed in Q2, national open source data infrastructures to capture building and sub-system performance are required to overcome this barrier. This will enable more targeted and cost-efficient investments in decarbonisation measures. If deployed as described in Q9, it could also be used to stimulate UK-based SMEs and mitigate government reliance on - and potential lock-in with - large, out-sourced service providers.

Gas prices

The current and future cost of natural (grid) gas is so low in the UK market that it will be difficult to convince on-gas properties to move off-gas. Until cost parity is reached with electricity, and until technologies such as heat pumps can attain coefficients of performance close enough to gas, it will be costly and inefficient to move off-gas. As discussed,in Q4, the lower rate of VAT on gas should be removed to mitigate this disincentivisation to move away from gas heating. 




5.                A fair transition

How can the costs of decarbonising heat be distributed fairly across consumers, taxpayers, business, and government, taking account of the fuel poor and communities affected by the transition?

The priority must be to insulate as many homes as possible through appropriate fabric improvements.  Home insulation is a modular, “shovel-ready” project that can easily be deployed quickly and on a large scale as part of a post-Covid recovery package. This would have a direct benefit to SMEs across the UK.

The first wave of projects should prioritise the fuel-poor, but there are enough badly insulated buildings in the UK to guarantee the need for many subsequent waves. This means that people who are retrained to install insulation can look forward to sustainable employment in more than one sense. The better insulated the home, the less heat it will require, and the cheaper it will be to provide it.

This programme should be making targeted interventions by employing scalable, digital, and non-intrusive building fabric diagnosis tools. In parallel to this, investment should be encouraged in solutions that automate building stock analysis, providing valuable data and enable targeted retrofit interventions.

The data collected through such tools should be fed into nation-level open source data infrastructures to ensure sustained and independent validation of building and sub-system performance. This in turn should be accessible to all, enabling informed decision-making around the options for decarbonisation of the home. 

The experience of the Green New Deal shows that complexity is the enemy of take-up, suggesting that grants (with means-testing) rather than loans should be used to kick-start the process. People who are fuel poor should not be required to pay unless they are asset rich.

The carbon anti-tax on gas (i.e., lower rate of VAT) should be removed; energy consumption tends to rise with income and so the scheme is regressive. Doing so will increase the incentive to insulate homes properly and move to lower-carbon heating. Gas will still have an artificial advantage over other heating sources until a carbon tax is added to its price (as for electricity).  It is likely to be necessary to raise benefits or use targeted support to offset the costs for low-income and other fuel-poor households; this reinforces the urgency for fabric improvements.

6.                Impact of environmental levies

What is the impact of the existing distribution of environmental levies across electricity, gas and fuel bills on drivers for switching to low carbon heating, and should this distribution be reviewed?

Throughout our responses to other question we have addressed a variety of government-led interventions based on the expertise of our consortium, however we are not currently undertaking research activities into environmental levies to the extent that would support this call for evidence.

7.                Incentives and regulations

What incentives and regulatory measures should be employed to encourage and ensure households take up low carbon heat, and how will these need to vary for different household types?

Experience with the PV FiT scheme shows that mass deployment can significantly reduce the costs of any low-carbon technology, although the prices paid by early adopters will be high. This suggests that some financial support is required; however, it is important to avoid the experience of PV schemes.  

People who could afford to spend several thousand pounds on a PV system were given an 8% return on their investment (or more once the Feed-in Tariff became misaligned with panel costs), well above the rates available from banks. The electricity consumers who funded these guaranteed returns were generally poorer than those who benefited from them. 

The key lesson is to base any subsidy on the most realistic input data available, and to update these frequently.  National open data infrastructures capturing building and sub-system performance would support validation of subsidy rates and aid a more strategic, evidence-based approach. Standard principles of public finance also argue that where a public good is being provided (such as the benefits of learning-by-doing in low-carbon heat) it should be funded from general taxation, rather than by distorting the price of an intermediate input; in other words, business energy users should not be disadvantaged by making them contribute to these costs.

Service models that encourage value and wider benefits, to both the consumers and wider energy systems, will play a vital role in decarbonisation and should therefore be incentivised. Robust, innovative DNO/iDNO business models should include mechanisms that reward reductions in consumption and flexibility, such flexibility being enabled by active buildings and technologies.

Consortium partner Imperial College Business School, discusses potential service models in detail in their white paper 'Can You Make Money from Active Buildings? Challenges facing business models’ available here. 


8.                Household engagement

What action is required to ensure that households are engaged, informed, supported and protected during the transition to low carbon heat, including measures to minimise disruption in homes and to maintain consumer choice?

In planning any actions to decarbonise heat in homes, it is vital to engage and support home occupants because:

        Homes hold intrinsic meanings, value, and expectations to many people 

        Homes are where many everyday practices are fulfilled, themselves informed by interconnected and relative social connections within the home, and with people, communities, and organisations outside of the home

        Homes support aspirations for occupants living well that can be taken for granted

In view of the above, interventions resulting from the decarbonisation of heat may change some of the ways in which homes are subjectively perceived, valued and lived in. This could have implications for residents’ aspirations and wider societal benefits.

Empirical research has identified several further influencing factors:

        New low carbon heat technologies may restrict consumer choice, affecting how and why heating regimes are carried out and to what effect

        Household decarbonisation has led to increased digitalisation of household energy services, raising concerns regarding data appropriation and privacy in addition to concerns for consumer digital skills and connectivity

        Decarbonisation of heat can require alteration of existing energy practices and behaviour, working against long-standing norms (i.e. to save energy, switch ‘off’ but ASHP should be ‘on’ continuously)

        Necessary material changes to building structures, fabrics and aesthetic can also affect the home’s atmosphere/people’s emotional connections to their homes

        There are different issues for homeowners compared to tenants in social housing or privately rented properties

        It may be challenging to convince people to move away from existing gas central heating without low carbon heating providing immediate benefits (e.g. making financial savings on energy expenditure, particularly for vulnerable consumers)

Recommended actions

Communication with households about potential challenges and opportunities should be clear, coherent, and easily accessible. These should be from a mix of sources, including at national, sub-national and localised scales. This should be supplemented with information highlighting actions and benefits at local scales, and the links between these actions and benefits and larger-scale ambitions and achievements should be transparent.

Longevity of new technologies, heating services or fabric improvements require flexibility, adapting to changes in people’s lives. This underpins previous points about the scalability of deployed technologies and their ability to accommodate future requirements, a feature inherent in active buildings and technologies.

Any improvements to properties must be monitored in the longer-term so that it is possible to provide sufficient support to households on their journey to net-zero. This is because of the generic uncertainties that exist in association with digitalisation and data sharing, altering building structures and fabrics, and installation/operation of new technologies and energy services. Such monitoring is being carried out as part of the Welsh Government’s Optimised Retrofit programme.

Importantly, measures that could lead to instances of lock-in to carbon heavy heating, specific vendors, or fuel poverty should be avoided. This is all the more important when considering the pathway to decarbonisation for those in, or at risk of fuel poverty.

Real-life demonstrations of residential decarbonised heat solutions should be used to support the households along the transition pathway. These would be most beneficial when showcasing localised, place-based pathways. The Trent Basin and Priory Hall Park projects are good examples of such a demonstration.

Overall, low carbon heating interventions must enable continuation of daily routines and fulfil people’s expectations of heating their home. This includes not only providing warmth or convenience, but allowing the carrying out of caring, socialising, and other daily functions not directly associated with ‘heat’.

Cardiff University, an ABC-RP consortium member, explore these topics in detail as part of their white paper ‘Active buildings in the changing policy landscape: conceptual challenges and social scientific perspectives’, available here. 



9.                Responsibilities and governance

Where should responsibility lie for the governance, coordination, and delivery of low carbon heating? What will these organisations need in order to deliver such responsibilities?

The UK government needs to enable a systematic, data-driven approach to delivering low carbon heating that provides predictability for all stakeholders. To do so, the ABC-RP recommends a cascading approach where the UK government acts as the overarching coordinator and enabler of place-based actions as follows:

1. Empower and enable

UK government to set carbon budgets and taxation that incentivises zero-carbon energy vectors. This should be supported by transparent policy roadmaps and stimulus funding that enables all stakeholders to invest in the future with confidence. This should be supplemented with national open source infrastructures to collect and share consistent and transparent building data, including building condition and performance, upon which decisions can be based.

2. Develop

Devolved governments should be empowered to accelerate decarbonisation by developing and coordinating place-based approaches most suited to regional socio-economic and topographical conditions.

Welsh Government has made significant progress in this respect, stimulating decarbonisation in specific markets such as social housing through the Well-Being of Future Generations Act (2015). This has created a significant opportunity for government, industry, and academia to collaborate and enhance innovative processes and cycles. 

To support this, a systematic, digital approach to stock modelling and condition surveying is required (as discussed in Q5). This capability should be scaled across the UK and feed into a national data infrastructure. Such capabilities will improve the analytics and targeting of decarbonisation interventions at devolved scale to enable performance validation of measures. 

3. Deliver

Local authorities (LAs) should be empowered to balance the risks of decarbonisation interventions through performance incentivisation and supplementary funding. This should be enabled by the development of a national open source infrastructure for building stock data, with LAs able access data on stock conditions and recommended interventions to support and prioritise their place-based investment decisions.

4. Catalyse

Registered Social Landlords (RSLs) should be encouraged, through devolved governments or LAs, to accelerate their own refurbishment and decarbonisation programmes. This should be target-orientated and incentivised to foster aspirational approaches rather than benchmarking to achieve the lowest required standard.

Fostering a place-based approach across the levels outlined above will also serve to benefit UK-based SMEs in the supply chain.

Underpinning this approach, and as highlighted throughout this response, is the requirement for national open source data infrastructures for building stock data that is universally available. This will aid transparency and an evidence-based approach that endures the journey to net-zero as a centrally convened and funded mechanism. It is clear that technical and carbon reduction processes will require rapid evolution and co-exist alongside decarbonisation processes.


December 2020