Andrew Mellor explains how to future-proof schemes in a fast-moving regulatory landscape
The Future Homes Standard was launched in the spring statement earlier this year. It proposed that from 2025 all new homes will incorporate world-leading energy-efficiency levels of performance, incorporating low-carbon heating systems, and that new homes from 2025 will not be able to connect to the gas network.
The government has now published a consultation document entitled The Future Homes Standard: 2019 consultation on changes to Part L (conservation of fuel and power) and Part F (ventilation) of the Building Regulations for new dwellings.
The document sets out the plans for reaching the 2025 standards with changes to Building Regulations in 2020 and 2025. The 2020 changes will be a partial step towards the planned 2025 standard whereby new dwelling energy performance will achieve a 75-80% reduction in carbon emissions over that required by the current Approved Document L1A 2013.
Revised Approved Documents L and F will be issued in the spring of 2020. These will be in the new format used by recent issues of other Approved Documents and will likely come into formal use during autumn 2020.
The proposed changes to the performance requirements of new homes in Approved Document L are the most onerous. The consultation proposes two options:
1) a 20% reduction in CO2 emissions over 2013 requirements, achieved through very high fabric levels of energy efficiency; triple glazing, gas-fired boiler and waste-water heat recovery (a cost uplift of £2,500 per house);
2) a 31% reduction in CO2 emissions over 2013 requirements, achieved through high fabric levels of energy efficiency; double glazing, gas-fired boiler, waste-water heat recovery, technologies such as photovoltaics (a cost uplift of £4,850 per house).
The Building Regulations landscape is changing quickly
The government’s preference is for option 2. But will this mean that in the future such homes will need to be retrofitted with triple-glazed windows and an electric heating system? The latter seems certain with the drive for heating and hot water being by non-fossil fuel-derived energy. In fact, the consultation document proposes that the low-temperature heating distribution systems installed from 2020 need to enable homes to allow for the installation of low-carbon heating systems such as heat pumps. This effectively means bigger radiators compensating for lower surface temperatures, unless underfloor heating is considered. This may not be such a major issue, as new homes being delivered under current Building Regulations already seem to have too many radiators, many of which are never likely to be used.
The 2025 Future Homes Standard will require triple glazing, very good fabric standards and low-carbon heat technologies to achieve the proposed 75-80% emissions reduction. Local authorities will no longer be able to set in policy energy requirements beyond that in Building Regulations.
Planned transitional arrangements will prevent developers submitting a Building Regulations application, then making a start on the first house and completing the whole development to the lesser requirements of the Approved Document L current at the time of the application. Instead, a period of time will be set during which certain homes can be started under the Approved Document current at the time of the Building Regulations application. All later homes would then have to meet the current requirements.
In addition, the consultation proposes that an as-built compliance report is produced by the energy assessor, which includes full details of the installed insulation and energy system products as well as U-value and Psi values and thermal bridging details. Photographic evidence of the installations will have to be provided to Building Control and the residents. There is of course some overlap here with the likely outcome of the Hackitt process and the forthcoming Building for a Safer Future legislation in relation to digital record.
With these proposed changes and the ones related to ventilation, overheating mitigation, fire safety, electric vehicle charging and high-risk residential building approval process, the Building Regulations landscape is changing quickly and the changes will need to be considered holistically to minimise technical, financial and operational impacts on the construction of new homes.
Andrew Mellor leads the development consultancy team at PRP. The practice has been advising MHCLG and conducting research around policy and building regulations.