2013 Part L revisions - A Modest Proposal

18/Jul/2011
Brian Scannell

Arguments over the 2013 revisions to Part L of the Building Regulations are heating up, but will they actually help or hinder progress towards homes that are easy to heat?

Debates around the right level of fabric standards and the relative merits of absolute or aggregate targets and related issues are absorbing lots of time and soaking up resources across the industry, including Government, housebuilders, manufacturers, software providers and consultants.  It can be a rather dispiriting exercise for everyone involved.

At the same time, the EPC being issued for newbuild homes show that the overwhelming majority of properties are still being built to the 2006 and even earlier standards.

This is all perfectly legal given the approved transition arrangements.  But it does mean that whilst the debate about the next regulations is underway, the last round of revisions have yet to have any impact on the ground.

And unless something changes, when the 2016 revisions to the Regulations come into force, we will again see transition arrangements.  That will mean that homes will continue to be built to the 2013, 2010 and probably still the 2006 and earlier Regulations well beyond 2016.

Does this really make sense?

Coincidentally, Salford University recently published a report reviewing the performance of low energy houses designed by the council and university and built more than 30 years ago[1].  What the report clearly demonstrates is that it has been possible to build homes that perform in practice better than the current and planned design standards.  According to the authors:

“Dwellings designed to the SALFORD house principles are expected to be able to meet the proposed 2016 near-zero Carbon Regulations at competitively low capital cost.”

Which rather left me wondering whether we’re focusing on the right changes to Part L to deliver low energy homes?

The fact is that we now have a pretty clear idea of what will be required for the 2016 Part L revisions.  So why not focus on getting those stands into use as quickly as possible? 

So my modest proposal is that Regulations be issued as soon as possible that simply say that from 1st April 2016 completion certificates will only be issued for dwellings constructed to the near-zero standard.

No messing about with intermediate standards.  No distraction from the drive to near-zero carbon.  And crucially, no requirement for transition arrangements that just serve to delay for years the actual adoption of standards.

Builders will have the benefit of almost five years to get their designs ready and get practical experience of building to the near-zero standard – without any of the distractions, complications and uncertainty of intervening changes to the standards.

With the standards for new dwellings clearly nailed down in this way.  The focus for Part L revisions could then become ensuring an effective implementation of consequential improvements.

It makes no sense at all to continue to allow emissions from existing buildings to increase as a result of extensions and conversions when cost-effective means of cutting existing emissions are being ignored.

In practice, the requirements of the EPBD recast must mean that consequential improvements have to become mandatory.  But implementing the requirement in an efficient and effective way requires careful thought and planning.

So yes, let’s see Part L revised sooner rather than later.  But rather than spending months debating intermediate standards, let’s get on with finalising the near-zero standard for 2016 and let’s implement it so that it comes into effect in practice in 2016 rather than years later. 

And if builders have concerns about the practicality of achieving a near-zero standard, there are more than 30 years of history to learn from and several years to develop the designs and practice the skills needed.  That would be something for NHER members to get enthused about. 

It’s just an idea, what do you think?

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[1]  See: Salford low energy house report

Comments

 

I fully believe in the generalised idea that the near-zero standard for 2016 should come into effect IN PRACTICE in 2016, rather than years later. Cost competitive solutions against conventional platforms already exist within the UK, that meet and exceed expectations.

However, if we are to skip over the intermediate 'learning standards/steps', we should also draw a line in the sand in regards to the minimum requirement prior to 2016, so the stock built between now and then do not reflect the lower requirement of being built to the 2006 and even earlier standards.

 

My 2p: Firstly, the fundamental energy standard for 2013 should be set at the FEES level (the first slice of the zero-carbon triangle, ie. a space heating demand of 39-46 kWh/m2/yr depending on built form). And that’s it! No need for an additional carbon standard, because it’s implicit. Let builders focus on achieving this pragmatic fabric standard without having to worry about other metrics initially, and in a couple of years they’ll be tremendously well-positioned to take the final step to 2016.

Secondly, give Passivhaus-compliant dwellings ‘deemed‐to-satisfy’ status in Part L1A 2013. There's widespread support for this suggestion within the industry. Tech Wkg Gp WG1 also put it in their report to BRAC. The job now is to convince Ministers to keep the suggestion in the Part L consultation (which is due towards the end of this year), and obviously to lobby people to respond positively to that section of the consultation in due course.

 

Good blog Brian.
There is a massive time lag between regs coming into force, and seeing any changes on building sites.
One of the best ways I can see in changing this, is for there to be much more communication between Govt and builders, so that builders will know exactly what is expected well in advance of the requirements.....and the biggest problem is the small private builder.
One of the best tools to help this happen is getting the SAP calcs done at design stage, as is required under 2010 regs, but as mentioned, builders are still getting their heads around 06 regs, and don't even think about a SAP until they think they've finished the build and just need to get it signed off....at which point the BCO asks for the EPC.
And thats before you even consider the difference between what is reported as happening for the SAP, and what actually happens on the building site. I would like to see some sort of reporting system where, as a build progresses, the BCO signs off a particular element having checked it on site, and a copy of this then forwarded to the SAP assessor, so that they can rely on the data being correct, rather than trusting a builder who says he has used x type of insulation, when in reality he has used y.

 

And as a further comment....I wonder if we need to look at moving away from terminology such as "zero carbon".
Much of the public, (and it seems to be increasing)don't buy into carbon savings, global warming, etc.
I think its now accepted that if anything is driving RDSAP EPCs and carrying out the recommendations, its £s not carbon. People want to reduce their bills.
That lesson should be applied to Part L and then maybe more builders will but into it. Many builders aren't bothered about "carbon emissions", but they would see the advantage of building a house that is cheap to run as that is what a lot of buyers are looking for. So the intention is right, but do we need to change the way the message is delivered.

 

Good article Brian -I fully agree with your proposals associated with publishing the 2016 requirements now and lets just get on with it rather than "chewing the cud over intermediate standards"! If developers fail to adapt over the next 4 years, they will only have themselves to blame if they can't get completion certificates issued in 2016.

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