Allowable solutions

  • The group welcomed the Allowable Solutions consultation, which it believes provides a good basis on which to take forward an agreement on the guiding principles for an Allowable Solutions framework. However they were extremely concerned about the implied timescales to get a scheme operational. 
  • This element has therefore been re-graded from RED - CRITICAL to RED/AMBER overall. However the group were clear that they believed the Policy aspect to be AMBER, but the Timing issue to be RED, requiring urgent and decisive action. This is explained below.
  • Given that policy decisions may not be concluded until early 2014 at best, the legislative requirements for establishing Allowable Solutions arrangements in Building Regulations, the need to establish any national fund and verification arrangements and to generate liquidity in funding mechanisms, the group were very concerned that it may not be possible to have a fully operational Allowable Solutions regime in place from 2016. 
  • Urgent action is required to provide a critical path analysis showing the realistic implementation timeline for Allowable Solutions, which should show both government and industry actions, including for any required legislative changes. It should also take into account any likely delays due to purdah around the general election in May 2015. 
  • In terms of the overarching policy framework for Allowable Solutions, the group believed that the most important single policy decision will be to determine the price cap. Early announcement on this and other aspects of the framework will give some certainty to developer and industry future planning and would help towards re-grading this aspect towards GREEN on the RAG scale. 
  • The preference for a national policy framework for Allowable Solutions stated in the Consultation, together with the potential implications of the Housing Standards Review, may help to curtail Local Authorities creating their own bespoke Carbon Funds. This addresses the group's previous concerns over the proliferation of varying local methodologies for Allowable Solutions mechanisms.

Timeline Status: