Download Consultation Response
The Communities and Local Government consultation on Parts L and F of the Building Regulations closed on 17 September 2009. Thanks to all CIBSE members and industry colleagues that contributed to the discussion forum, attended events and helped to put the consultation response together. We will keep you updated via the CIBSE Journal, e-brief and website.
The key points in the CIBSE response were:
- We expressed serious disappointment that consequential improvements were not covered to any extent in the consultation despite a government commitment to this
- We warned that carbon emission targets were unlikely to be achieved unless government takes compliance and enforcement seriously
- We welcomed a proposal to require a design stage CO2emission rate calculation to be provided to the building control body (BCB) with the deposit of plans, in addition to a final as-built calculation and that a commissioning plan should be made available with the deposit of plans
- We called for transparency of the SBEM Code to enable it to be more understandable and not the ‘black box' it is at present
- We welcomed that government had addressed the issue that buildings designed with air-conditioning were more likely to get a ‘pass' in SBEM than naturally ventilated buildings but suggested that replacing overheating calculation and replacing it with a calculation that measures the solar gain resulted in a danger that 2010 compliant buildings may overheat and later require an AC retro-fit. CIBSE suggested that the solar gain calculation proposed be adopted for air-conditioned buildings and the previous overheating calculation (1% over 28°C and 5% over 25°C criteria) be reinstated for un-conditioned buildings.
- We expressed concern that the ‘special considerations' that will replace exemptions for historic buildings and buildings with low energy use were not set out
- We welcomed the suggestion of an industry steering group on compliance provided it had a remit to make a difference and offered to provide the secretariat for such a group
- We supported proposals that calculation tools should report energy demand, the setting of energy demand limits in amendments to Part L beyond 2010 and the need to learn more about peak demand
- We made extensive comments on natural ventilation, CHP, lighting and school buildings thanks to input from the CIBSE specialist interest groups in those areas and the Society of Light and Lighting.
- We pointed out the difficulties with MHVR and air-tightness particularly with user behaviour in dwellings
- We called for future editions of Part L to allow consideration of connection to district heating and locally produced energy from renewable sources
- We expressed concern over the increasing complexity of the regulations and the resulting increasing difficulty to ensure compliance. We called for certification schemes for Part L compliance
- We supported the inclusion of lifts and security and feature lighting in future editions of Part L from 2013 onward