
VOICES | HYWEL DAVIES Taking stock As CIBSE Journal enters its 11th year, an unprecedented level of activity in legislation and policy is affecting building services engineers in the UK and worldwide. Hywel Davies looks at what is happening E verybody welcomes certainty but there is not a lot of it about. And that is nothing to do with the UKs future relationship with Europe. Last year, CIBSE responded to 29 consultations and Select Committee enquiries, as well as engaging with the Independent Review of Building Regulations and Fire Safety. A great deal of policy activity in areas relevant to CIBSE members is also under way at the moment, as we move from consultation and debate to implementation on several fronts. While some of it is specific to England, or even to London, much has wider relevance. Many of the issues are relevant to the devolved administrations, while fire safety, reducing carbon emissions, zero carbon buildings and indoor air quality have global resonance. In England, several parts of the Building Regulations are under review. The Implementation Plan1 issued in December, in response to the Independent Review, committed government to a full technical review ofPart B. It proposes possible changes ona number of technical issues, going well beyond the activity to clarify the current Guidance that has been under way for some time. This process has already started, with a call for evidence2 published in December alongside the Implementation Plan. This is in addition to the changes to Regulation 7, banning combustible materials from external walls of residential buildings more than 18m high, introduced in December.3 The Society of Faade Engineering4 is already busy developing guidance for its members on the detailed implications of the new rules, but it is clear that the design of faades for high-rise residential buildings will have to change. Also in the response to the Independent Review is a commitment to update Parts L and F (governing energy use and ventilation respectively). The same paragraph5 commits to a review of Part M (access) to complement work already being done in the wake of a report6 from theEqualities Select Committee on the issue of accessibletoilets. It also talks of a workplan for dealing with other technical requirements, such as Part P (electrical safety), in the new year. We will not be short of things to do on Building Regulations. The review of Parts L and F will also address overheating risk. CIBSE has some clear goals for the review: we need a clear trajectory for improving Building Regulations over time so that all new buildings achieve net-zero carbon by 2030, with milestones for interim stages. The next edition of Part L must drive significant further improvement in the target carbon dioxide emission rate. Beyond that, we need to see a move towards regulation of real carbon emissions in use, with genuine incentives for those who are willing to lead the way in measuring and reporting this. What would Part L compliance based on actual performance rather than design intentions, sometimes unfulfilled look like? This approach would also be more in line with the greater emphasis on whole-life performance of buildings set out in Building a Safer Future. To help drive innovation and investment, we should allow local authorities to set requirements that are more challenging than the Building Regulations, while remaining realistic. In relation to Part F, we would like to see a focus on achieving indoor air quality and not just ventilation rates. There are advantages to performance or outcome-based regulations, but they need to define the appropriate outcomes. For too long we have focused on air movement at the expense of air quality. It is not just Building Regulations that are addressing the quest for clean air; it has been a significant concern in London for some time, especially in relation to particulates from diesel engines. The Clean Air Strategy, published in January, acknowledges the need to address many of the concerns that CIBSE raised in the consultation last year, but ducks the call to adopt World Health Organization (WHO) limits on pollutant levels. If we dont listen to theWHO,then who do we listen to? For more on this topic, see page16. It is unfortunate that, with heightened awareness of pollution in city centres, schools and offices, we still ignore the problems of pollutants in industrial workplaces. Occupational lung disease is one of three We need a move towards regulation of real carbon emissions in use, with incentives for those willing to lead the way DR HYWEL DAVIES is technical director at CIBSE www.cibse.org 14 February 2019 www.cibsejournal.com CIBSE Feb19 pp14-15 Hywel Davies.indd 14 25/01/2019 16:13