The Ministry of Housing, Communities and Local Government (MHCLG) has this week published its response to the 2019 consultation on Part L and F and the Future Homes Standard.
The consultation deadline is 13th April 2021.
The Future Homes Standard and Future Buildings Standard are due to be implemented from 2025.
MHCLG’s intent is that these standards set out a pathway towards creating homes and buildings that are fit for the future, and a built environment with lower carbon emissions and homes adapted to the overheating risks caused by a warming climate.
MHCLG expect that homes built to the Future Homes Standard will have carbon dioxide emissions 75-80% lower than those built to current Building Regulations standards, which means they will be fit for the future, with low carbon heating and very high fabric standards. The Future Buildings Standard consultation builds on the Future Homes Standard by setting out energy and ventilation standards for non-domestic buildings, existing homes and to mitigate against overheating in residential buildings.
The interim 2021 Part L uplift to energy efficiency requirements will act as a stepping stone towards the full Future Homes Standard and Future Buildings Standards. For new homes, MHCLG expect it to result in a meaningful and achievable 31% carbon emissions saving compared to the current standard.
This two-stage approach (2021 uplift, and 2025 Future Homes / Building Standard) is intended to support industry to prepare and position itself to build to the full standard: ensuring that a sufficient supply of low carbon heating and an appropriately-skilled workforce is in place; and that our housing supply commitments can still be met.
Initial CIBSE response
We have carried out an initial review of the proposals for new dwellings, i.e. Part L & F 2021 and the Future Homes Standard.
CIBSE had expressed strong concerns about the previous proposals, and we are pleased to see some positive changes in line with our 2020 recommendations, of which:
- Retaining the right for Local Authorities to set energy and carbon standards that go beyond Building Regulations. This recognises the leadership role played by many Local Authorities and communities across the country, allows more carbon savings, earlier, ultimately supporting development in the rest of the market.
- Retaining a fabric efficiency standard to promote a fabric first approach.
- Accelerating the development of the Future Homes Standard, now due for draft publication in 2023. This will give confidence to supply chains and encourage early adoption by market leaders and local authorities.
- Omitting the proposed technology factors which would have excessively supported district heating networks by allowing heating emissions to be 45% higher. This will provide a fairer assessment of their carbon impact against other low carbon heating options.
However, we still have concerns about a number of proposals, including:
- The draft FHS specification proposes an airtightness of 5 m3/hr/m2 at 50Pa and natural ventilation. This is quite far from "world-class" levels of energy efficiency. Supply chains must develop so MVHR is well designed and installed, to deliver energy savings and good indoor air quality. This should be encouraged with a draft FHS specification showing best practice airtightness and MVHR.
- Compliance targets are still proposed to be set by comparison with a notional dwelling. This means little in real life, prevents verification in use, and does not drive passive design. We recommend moving to simpler, more effective and trackable targets such as Energy Use Intensity and/or carbon emissions /m2/yr.
- Apart from fabric efficiency, the metrics are kept as primary energy and carbon emissions. Both are dependent on the wider system (including varying conversion factors) and mean little to consumers. They do not facilitate tracking of progress over time, comparisons between buildings, and creating a closer link with real life performance. We recommend energy use instead of primary energy.
- Measures are proposed to address the performance gap, and this is welcome, but these stop at Practical Completion: there is still no indication from MHCLG of measures to address actual in-use operational performance. These must be looked at, possibly through another regulatory instrument than Building Regulations, for example as part of the wider regulatory regime created in response to the Hackitt Review.
We are going through the proposals for overheating, and for Part L, F and the Future Building Standard, and will provide an initial analysis of these shortly.
You can read our consultation response on the 2019 proposals for new dwellings. We will be testing new proposals against this, as well as the latest evidence and advice, including the Climate Change Committee’s 6th Carbon Budget, released in December 2020.
Following on from our work on the 2019 consultation, we will produce responses to these hugely important consultations. We are very keen to work on this with our members, industry, and other organisations, so please get in touch at [email protected] if you would like to be involved and support our work.