It has caused a hell of a fuss. In October last year, the government released a consultation on its proposed changes to parts L and F of the building regulations, which are intended to impose more stringent rules on energy efficiency in advance of the Future Homes Standard coming into force in 2025. The problem is that they don’t.
That, at least, is the view of a growing body of architects, engineers and other built environment professionals who believe that far from making new homes more environmentally friendly, the changes would in fact represent a retrograde step. With the consultation due to end on Friday 7 February, why exactly has the consultation got so many people hot under the collar?
Leap forward needed
A review of the proposed regulations by The London Energy Transformation Initiative (LETI) concluded they would not set the building sector on the trajectory required to tackle the climate crisis. Indeed, the organisation, an independent and voluntary group of experts, considers that the proposed standards are “likely to result in a step backwards in a climate where we need a huge leap forward”.
Part L and Part F of the Building Regulations contain requirements relating to the conservation of fuel and power, as well as guidance on building ventilation. Together, they will form an important part of the Future Homes Standard, which will be the first genuinely ambitious green building standard for residential construction since the Code for Sustainable Homes was scrapped in 2015.
Given that the government has pledged to build hundreds of thousands homes a year in the 2020s and has committed in legislation to ensuring the UK is net zero in terms of greenhouse gas emissions by 2050, it is vitally important that it gets such regulations right.
“There appears to be no connection between the proposed changes to Part L and the need for an urgent response to climate change,” says Clare Murray, head of sustainability at Levitt Bernstein, which is a LETI member. “Two million homes are likely to be built between 2020 and 2025. If the required standard is not met when homes are first constructed, they will require retrofit before 2050, which is likely to be five times more expensive than building them properly in the first place.”
Joe Giddings of The Architects Climate Action Network (ACAN) also has serious concerns. “The changes that are proposed as part of the Government’s consultation on the Future Homes Standard are hugely disappointing and completely inadequate during a time of climate emergency,” he says. “Rather than driving us towards more energy efficient houses, the proposals do the opposite.”
Specifically, the proposed changes scrap the fabric energy efficiency standard, meaning new homes could revert to inadequate minimum standards of insulation that are rarely used today. “Instead, the proposed regulations rely too heavily on bolt on technology and the wider decarbonisation of the energy grid,” says Giddings. “As such, it appears that the proposed regulations may actually make new homes less energy efficient than homes built under the current regulations.”
Masking fabric condition
Murray agrees. “Fabric performance is likely to get worse – a home in 2020 could be less insulated than a home under 2013 building regulations,” she says. “The use of an energy efficient heating system has the ability to mask fabric performance. Carbon and primary energy factors disguise the energy efficiency of a home. The energy consumption of a home can be high but carbon emissions low. This leads to inefficient homes that appear to be performing well.”
What all of this means is that buildings built under the 2020 regulations could well be less efficient than those built under the 2013 regulations, something that is both unhelpful and unnecessary. “New buildings using the 2020 regulations are likely to be less sustainable than those built under the 2013 version,” says Murray. “Buildings will appear to emit less carbon despite the fact they could be more energy intensive.”
What’s more, the proposed changes to the building regulations do nothing to take account of the embodied carbon in building materials, which was already a deficiency. Given that concrete alone accounts for between 8% and 10% of global carbon emissions, that is a real problem. “If we are to build [hundreds of thousands of] homes a year up to 2030, then embodied carbon needs to be considered,” says Giddings.
Murray adds: “Embodied carbon hasn’t historically been included in Part L. However, we would like the measurement of it to be phased in starting with larger developments first. This would pave the way for requiring embodied carbon reductions in future.”
Then there is the fact that the government is proposing to remove the power of local authorities to set higher energy efficiency standards in their areas, something that Giddings says “appears to be a nod to the big housebuilders”. He adds: “This will [hold] back a huge number of local authorities that are leading our response to the climate emergency and is a puzzling move.”
In terms of the way forward, Murray says that buildings should have to measure energy intensity – a measure related to use per sq m per year – as well as overall emissions. This would enable both designers and occupants to consider energy efficiency in isolation from the source of electricity. Moreover, she says that building regulations should be used to point developers and their designers towards existing examples of how materials and technology can be combined to produce highly efficient buildings.
“We already know how to design and build zero carbon buildings, says Murray. “It is all about making the energy demand of our buildings as low as possible before applying technologies. We should be learning lessons from projects such as Goldsmith Street, the recent RIBA Stirling Prize winner. Our building regulations should be pointing us in this direction instead of trying to give us a small step up from bad.”
Both LETI and ACAN have produced advice on how industry professionals can lobby government to improve building regulations in order to better tackle the climate crisis. LETI initiator Clara Bagenal George says that it is vital that the industry does all it can to address the consultation’s shortcomings. “The proposed regulations could be seen as taking a step backwards rather than a step forwards,” she says.
“This is extremely worrying in the context of the climate emergency. I strongly believe that we will not meet our climate change targets if the proposed 2020 regulations do not take a leap forward. It is really important that as many people as possible take part in the consultation to send a strong message to our government that their current proposals are unacceptable.”