Part L consultation about to close – but could it be a step back?

The consultation on the Future Homes Standard, which includes energy usage and efficiency under Part L of the Building Regulations, is due to close on 7 February 2020. As the deadline nears, one group of architects and engineers is arguing that proposed changes risk making homes in England less energy efficient rather than more.

We covered the policies influencing the proposed changes to Part L in more detail prior to the launch of the consultation last year. Now the London Energy Transformation Initiative (LETI), a voluntary group of more than 1,000 architects and engineers, is calling for changes to how building energy use and consumption is assessed.

Removing the Fabric Energy Efficiency Standard

The Future Homes Standard will be introduced in 2025 and will be implemented through the Building Regulations. It will set the national minimum energy performance requirement for all new homes in England when introduced.

The consultation document proposes removing the Fabric Energy Efficiency Standard (FEES), introduced as a revision to Part L in 2013, because proposed new metrics in the form of primary energy and householder affordability rating “will result in a set of standards which are complex and difficult to understand.”

Crucially, the FEES target is not influenced by building services, for example heating systems, fixed lighting or ventilation strategy.

In place of FEES, the consultation document sets out proposed minimum standards for fabric performance, with a range of U-values for elements such as external walls, party walls, roof, floor, windows and doors. Unlike FEES, better fabric performance could be “offset” by low-carbon energy provision.

In its report, LETI argues that although the proposed range of minimum U-values improves on Part L 2013, the removal of the FEES target could lead to new homes being specified with the minimum U-values and low-carbon technologies, such as air source heating, to pass a carbon target. LETI argues that it would be possible for a home with Part L minimum U-values to pass Building Regulations in 2020 that would have failed in 2013.

LETI is also concerned that a proposed emphasis on the overall carbon footprint of a home will allow it to appear more energy efficient, simply because the grid that supplies it is itself being decarbonised. In theory, a home could show it produced lower carbon emissions than before, even if its design and specification did not change. LETI’s fear is that this, too, could “mask” a home’s energy performance.

Removing local authorities’ ability to set minimum energy efficiency standards

Another proposal that LETI opposes is to restrict local authorities from setting their own higher energy efficiency standards for new homes. This ability was introduced via the Planning and Energy Act 2008 and while the consultation paper admits the move has been “very useful” in delivering more energy efficient homes, it also “may have let to confusion and uncertainty” for planning authorities and homebuilders.

LETI argues that the new proposal would be a backward step at a time when nearly two-thirds of local authorities in the UK have declared a climate emergency, with many introducing more stringent energy standards for new homes built in their area.

Final chance to have your say

With climate change high on the world agenda and the UN Climate Change Conference taking place in Glasgow this year, the spotlight will remain on the UK construction sector and what role it can play in reducing overall carbon emissions.

The proposed changes to Part L (and ventilation matters under Part F) in the current consultation will go a long way to creating the Future Homes Standard and its introduction in 2025.

House builders and other stakeholders now only have until February 7 to have their say.

 

Please Note: Every care was taken to ensure the information in this article was correct at the time of publication. Any written guidance provided does not replace the reader’s professional judgement and any construction project should comply with the relevant Building Regulations or applicable technical standards. However, for the most up to date LABC Warranty technical guidance please refer to your Risk Management Surveyor and the latest version of the LABC Warranty technical manual.

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