Energy Saving Trust responded to the Future Buildings Standard consultation.
The proposals represent a positive step towards improving the performance of new buildings in England.
We particularly welcome the focus on low carbon heat, the step towards more resilient buildings (with the proposed introduction of a new requirement on overheating in homes and the decision to review Part L [energy and carbon] and Part F [ventilation] together and the reinstatement of the Fabric Energy Efficiency Standard (FEES) for new homes.
While a positive step forward, there is scope to be more ambitious. This would require a clearer focus on the end-goal and a change from the established approach. Part L (energy, and carbon), the underlying methodology and its modelling/compliance tools were not designed with net zero in mind and are too narrow in scope.
Our key recommendations here are:
1. Ambition aligned to net zero
The last update to the energy and carbon part of the building regulations was in 2013. Given both this and our net zero ambitions, the proposed 22% or 27% improvement from 2022 does not seem ambitious enough. London has been successfully applying a 35% reduction since 2016 for large non-domestic buildings since 2016 and will operate a ‘net zero carbon’ policy from 2021. We recommend either a higher target overall or different targets for the types of building (offices, hotels etc.) based on ability to improve.
2. Energy not CO2 should be the focus
‘Future-fit’ buildings are ones in which energy use has been minimised from the outset. Prioritising relative metrics like primary energy and carbon dioxide (CO2) focuses on impact now rather than lifetime impact. This can mask high energy requirements which could be a drain on tomorrow’s grid.
3. Building regulation scope should expand to include all future energy use
The building regulations control only part of the energy use in buildings – those from heating, lighting and cooling, which are built into the building. In non-domestic buildings, ‘unregulated’ sources can be double those from ‘regulated’ sources. We can’t manage what we can’t measure so we need new forecasting tools and targets to reflect this. When we can ‘see’ this ‘hidden’ energy in advance, building design can minimise it from the outset.
4. We need ‘very good’ – not ‘improved’
The ‘notional building’ approach requires builders to deliver a percentage improvement on equivalent buildings. This delivers buildings that are ‘better’ but potentially still not ‘good enough’. A new approach based on maximum energy demand (kWh/m2/yr.) for both total energy and space, heating and cooling would encourage designers to innovate and design out the need for energy in their buildings from the outset.
5. ‘As-built energy performance must reflect design (‘performance gap’)
We welcome the steps made here but more is needed. A stronger focus on compliance, mitigation where there is a shortfall and Post Occupation Evaluations would support this. Prioritising operational energy as the key metric/target (our recommendation 2) would allow prospective buyers and tenants to compare buildings and drive a market for buildings that reflect their design credentials (as with the Australian NABERs scheme).
6. Low carbon heating should be required as soon as it is cost-effective and affordable
The consultation sets out types of buildings where is it already feasible and affordable to install low carbon space and/or water heating (such as heat pumps). We recommend low carbon heating is installed in these buildings from 2022 (when the 2021 uplift applies) with fossil fuel use phased out in new buildings from 2025.
7. Energy hierarchy approach
The proposed approach will allow gas heating and solar PV to be substituted for low carbon heating such as heat pumps. This locks-in fossil fuel usage and higher emissions for the 15-year lifetime of the boiler. We support an alternative ‘energy hierarchy’ approach in which all steps are taken to reduce demand first then heating is supplied, low carbon where feasible, and only then are lower carbon technologies (such as PV) applied to offset residual emissions.