Elmhurst issues final response to key Future Buildings Standard Consultation
Elmhurst has issued its final response to the Government’s Future Buildings Standard consultation, which covers proposals for energy and ventilation standards to be implemented from 2021 for non-domestic buildings as well as new and existing homes.
| You can read Elmhurst’s Final consultation response here. |
The Future Buildings Standard consultation follows the Future Homes Standard consultation which was released in October 2019, and covered proposals for future energy standards in new build homes. Both consultations are linked and together establish a roadmap towards creating homes and buildings that are fit for the future, a built environment with lower carbon emissions and homes which are adapted to the overheating risks caused by a warming climate.
The Future Buildings Standard consultation document was split into two sections.
Section A: New and existing non-domestic buildings
This section included a proposal to set an interim uplift to Part L and F standards in 2021, and also established a roadmap for the implementation of a new Future Building Standards in 2025. The primary aim of this new Future Buildings Standard is to ensure that non-domestic buildings undertake a transition to using low-carbon heat sources for heating and hot water.
Key messages from Elmhurst’s Response:
We support the government’s preferred option to uplift the energy efficiency standards for non-domestic buildings in the Building Regulations. This calls for a 27% reduction in carbon emissions on average per building, as part of an interim uplift in 2021. We also advocate for a whole building approach to be used in pursuit of this uplift and to also utilise the National Calculation Methodology in providing a full energy assessment of a building
Elmhurst believes that an additional step change should be included in 2023, in between the 2021 Interim uplift to Part L and the 2025 Future Buildings Standard. This will allow us to discover and review whether the changes implemented in 2021 are being met and that the technology is present and being utilised to ensure a smooth transition to the 2025 standards.
Future proofing buildings is sensible but unintended consequences should always be considered.
With the movement towards ongoing new technologies as a solution to the complex non-domestic building stock, we must ensure SBEM is able to account for them with regular reviews and updates.
All building regulations Part L2 checks (BRUKL reports) should be completed by accredited, qualified and competent Non-Domestic Energy Assessors.
All building regulations Part L2 checks (BRUKL reports) should be completed by accredited, qualified and competent Non-Domestic Energy Assessors.
Section B: New and existing domestic buildings.
Like Section A, this section also included a proposal for a 2021 uplift of Part L and Part F standards for homes. Aspects of this section build on the previous Future Homes Standard consultation due to the fact that it addresses level at which the Fabric Energy Efficiency Standard metric should be set., some standards for building services as well as guidance on the calibration of devices used for airtightness testing. The consultation also proposes the introduction of overheating standards for new residential buildings (some non-domestic buildings also fall within this scope).
Key messages from Elmhurst’s Response.
Elmhurst supports the improvement of energy efficiency measures for new thermal elements in existing dwellings. However, the Government should go further in its energy efficiency standards for retained thermal elements in existing dwellings
Separate energy efficiency requirements should be introduced for new conservatories even when thermally separated from the home.
Future proofing homes for low carbon heating is sensible but unintended consequences should be considered. For example, oversized radiators needed for low temperature systems may be positioned poorly, and the increased body of water may impact on the responsiveness of the system.
The retained Fabric Energy Efficiency Standard for new homes should be based on the Part L 2021 notional building with no additional adjustment to the target.
Ventilation systems should be designed by a competent person and then independently inspected and tested before building regulations sign off.
We support a new Building Regulation to mitigate overheating in new homes, but believe the compliance procedures should remain in Part L.
The assessment of overheating risk should still have an initial indication from SAP assessments produced by accredited OCDEAs. This should then guide stakeholders to more detailed assessment methods where required.
Any individual assessing overheating risk using the detailed method must be required to be part of a competent persons scheme.
Summary
Elmhurst’s Technical and Operations Director, Stuart Fairlie, comments: “It is fantastic to see that, in spite of the pandemic, the government are still keen to make buildings fit for the future, and this consultation provides a vital next step in this process. The government has indicated that the results of the consultation will appear in legislation in December 2021 for adoption in the summer of 2022, so we hope that it won’t be too long until we see the direction that government are taking with this”.
To read the consultation, click here.
To read Elmhurst’s final consultation response, click here.