It is less than two years since the introduction of Building Regulations Part L 2010 and we have recently seen the consultation for the next iteration of the Conservation of Fuel and Power regulations, Part L 2013, land on our desks with an almighty 300-page thud.
The three-year gap between successive iterations highlights the expediency with which the Department for Communities and Local Government (DCLG) is treating the impending introduction of zero carbon homes in 2016 and non-domestic buildings in 2019. There are a significant number of voices against such a rapid update which say that not enough evidence has been gathered from the 2010 version of the regulations to make changes and that stricter regulations will act as a barrier to growth at a time of precarious national finances.
However, UK climate targets are non-negotiable on the basis of financial activity or lack thereof. And the emergence of the green economy has shown that even in harsh fiscal climates, it is possible to create opportunities for business. Our buildings are still responsible for sizable CO2 emissions and everyone in the industry knows that progress needs to be made to pave the way to the zero carbon deadline.
The proposed newbuild CO2 reduction targets over the 2010 objective of 8% for homes and 20% for non-domestic buildings are a notable departure from the previously stated aim of a 25% cut in emissions for both building types. Certainly the wide gulf between the two targets is interesting. The consultation document states that non-domestic buildings will now be expected to employ renewables to hit the emissions target. Not so for dwellings. It seems apparent that government is keen not to be seen to be hindering house building, and perhaps the house builders have been more vocal in their lobbying than their non-domestic cousins, resulting in the Government’s 2010 spending review commitment to reduce the burden on the house building industry.
If Part L 2013 results in additional costs for builders, savings will have to be made in other policy areas to compensate. But is this saving up pain for later? After all, in 2016 homes will have to hit the zero carbon target in whatever form that may take.
The introduction of an absolute fabric energy efficiency standard (FEES) to drive energy efficient built form and fabric has the potential to aid designers in trying to hit the domestic CO2 targets. The proposed standards will be tough to meet but with a bit of learning and guidance, the industry should be able to cope. If the consultation goes so far as to adopt the stricter of the proposed FEES levels, it is probable that this will do the majority of the work in meeting the new CO2 target, leaving less CO2 to be mitigated through building systems and renewables. The ‘fabric first’ approach is one that has been advocated by many in the industry, building sustainability in from the outset of a project and avoiding accusations of ‘greenwash’ or ‘green bling’ from the use of large amounts of expensive renewables to mitigate CO2.
The proposal for FEES and targeted levels of emissions for homes from 2016 were both well researched recommendations made by the Zero Carbon Hub, a body dedicated to devising how homes will meet the zero carbon target. It is a shame a similar organisation has not been established to tackle the far more complex issue of how non-domestic buildings will meet the zero carbon goal.
The Zero Carbon Hub states that the 2016 zero carbon targets should reflect the ‘as built’ performance, recognising that there is a gap between the predicted emissions and those that occur in practice. This has been confirmed by on-site measurements conducted by the Good Homes Alliance and Leeds Metropolitan University. It has been suggested that the performance gap xan be addressed through the use of a voluntary Publicly Available Specification (PAS) to improve construction standards and to penalise dwelling emissions which do not adopt the PAS. If it is to gain widespread industry adoption, the PAS will need to be simple and effective. If not, designers will be more likely to accept the emissions calculation penalty. The PAS has only been proposed for dwellings. The consultation document acknowledges that there are no parallel proposals for non-domestic buildings, yet the fact remains that there is a considerable performance gap. In order to further study and close this gap, large amounts of in-use data are required. This would have been readily available if the government had managed to outline a programme for the roll-out of Display Energy Certificates for non-domestic buildings in the recent Energy Act. As such, the lack of a programme and associated data highlights what a missed opportunity that was.
The final piece of the zero carbon puzzle is Allowable Solutions. These will essentially take the form of payments to fund projects aimed at reducing emissions off-site, hence offsetting the residual emissions from developments. It is very difficult to determine if the steps being made to reduce emissions on site will be cost effective compared with Allowable Solutions when the industry does not yet know what the costs of Allowable Solutions are likely to be. Consultation on this was promised for spring 2012 and it would be of use to read now, in tandem with the proposed changes to Part L.
For existing buildings, the proposals’ main area of focus is the integration of the Green Deal with consequential improvements to better building efficiency whilst other works are undertaken. Consequential improvements will now apply to all building types, regardless of size. Regardless of what the perceived flaws are with the Green Deal, the alignment of policy from two separate government departments makes a great deal of sense and represents some rare joined up thinking.
Questions remain over how widely the Green Deal will be adopted and also over how well domestic consequential improvements will be enforced by local authority building control departments. This is especially true for the proposed consequential improvements for minor works such as replacing boilers or windows, where building control officers do not attend the site. As with previous iterations of Part L, consequential improvement works have to be technically, economically and functionally feasible. This, some may argue, offers a loophole for people to wriggle out of completing additional works. Again, it will be interesting to see how these are adopted and policed for the domestic market.
The proposals outlined for Part L 2013 are pragmatic and well thought through. Emissions cuts implemented since 2002 essentially mean that even buildings that are only built to the regulatory minimum will still be low carbon buildings. We have had nearly five years to get used to the idea of zero carbon buildings and although the policies are starting to take shape, we need more data on buildings in-use by rolling out DECs and information on Allowable Solutions before we have a good idea of how much more work is required to hit the zero carbon target.
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