VOICES | JULIE GODEFROY One step closer? Government proposals for improving energy efciency in buildings show signs of ambition, but regulations need modications, says Julie Godefroy G overnment has recently published several consultations on the energy and carbon performance of buildings (see news and page 22): For new homes, proposals for Building Regulations, Approved Document L and SAP. By late 2019/early 2020, we also expect proposals covering non-domestic buildings, existing homes, and a new overheating standard Proposals for improving the energy efficiency of businesses, possibly requiring Energy Performance Certificate ratings of C by 2030. Additionally, government is expected to consult in 2020 on mandating operational ratings for commercial buildings. New homes We have concerns about the proposal to prevent local authorities from adopting higher standards Government has committed to introduce by 2025 a Future Homes Standard, for new-build homes to be future-proofed with low carbon heating and world leading levels of energy efficiency; no new homes built with gas (or other fossil fuel) heating. Government proposes this would represent a 75-80% improvement on Part L 2013 carbon emissions levels. The stated aim of Part L 2020 is to be a meaningful and achievable stepping stone towards this. Proposals include: Two options for the overall uplift to carbon DR JULIE GODEFROY is technical manager at CIBSE performance in 2020: a 20% improvement, based on very high fabric performance or the governments preferred option a 31% improvement based on more minor fabric improvements and the installation of low carbon heating or renewable systems Upgrading minimum energy efciency standards for fabric and services The introduction of a primary energy target, in line with Consultation Closing date for contributions to the CIBSE response Amendments to the planning system for electricity storage 29 November 2019 Proposals for the minimum energy efciency standard for non-domestic private rented sector 6 December 2019 The Future Homes Standard: Changes to Part L and Part F of the Building Regulations for new dwellings 10 December 2019 Changes to the Standard Assessment Procedure (SAP) 10 December 2019 Changes to the approved methodology for testing buildings for air leakage 10 January 2020 Draft revision of CIBSE TM23 Testing buildings for air leakage 10 January 2020 Upcoming consultation deadlines the Energy Performance of Buildings Directive, which would work alongside the carbon target. The fabric energy efficiency target would be removed Tightening as-built and information requirements, including testing every home for airtightness, and more accurate as-built energy calculations Future-proong homes to low carbon heating, with space heating temperatures limited to 55oC A new heating affordability criterion: government is seeking suggestions Aligning carbon factors with reality and removing fuel factors, which distort the assessment. While we welcome the stated aims, the following points need to be reviewed: AD-L 2020 should deliver a 31% improvement and include the best possible fabric to future-proof homes, reduce demand, and limit the costs of low-carbon heating Regulations need to shift towards total operational energy performance, rather than as-built regulated emissions only see our briefing at bit.ly/CJNov19Zero Government proposes to consult on the Future Homes Standard implementation in 2024. This is much too late. It should be available earlier, to allow market leaders to adopt it and develop expertise and supply chains. Similarly, while we acknowledge the desire to streamline standards, we have serious concerns about the proposal to prevent local authorities from adopting standards higher than Building Regulations. In places such as London, local authorities should be allowed to lead the way and adopt the Future Homes Standard, subject to viability testing. This would significantly help the rest of the market when the standard is mandated from 2025. Please send contributions to technical@cibse.org Views on these areas would be particularly useful: Proposed upgrades to fabric and services efficiency SAP methodology and characteristics of the notional building Is the proposal for 55oC heating systems sufficient to future-proof for low carbon heat? Should other measures be considered for example, storage space? The notional building, set at the same shape as the proposed building, does not encourage consideration of building form to reduce demand. The fabric energy efficiency rating at least went some way towards this how effective are the new proposals replacing this? 24 November 2019 www.cibsejournal.com CIBSE Nov19 pp24 Julie Godefroy.indd 24 25/10/2019 14:43