FEES: Too easy, too hard, about right?

Dyfrig Hughes

No promises, but the wait for the finalised SAP 2009 and Part L should be over soon! The finalised documents are expected by 1 April, leaving 6 months for Accreditation schemes to get their SAP software updated and ready for a 4 October launch. The imminent election is not expected to scupper this, as long as the civil servants get it out in time.

Already published is the government consultation on the Fabric Energy Efficiency Standard (FEES). This is the bottom bit of the Zero Carbon 'triangle', made up of three layers: (1) Energy efficiency, (2) On site energy and connected heat, and (3) Allowable solutions. This consultation also covers the Code for Sustainable Homes within which the FEES is proposed to replace the Heat Loss Parameter as the measure for ENE2. For a full explanation of this, click here. (This is an excerpt from a recent technical bulletin, sent to all On Construction Domestic Energy Assessors registered with the NHER Accreditation Scheme.)

NES ran a couple of interactive workshops at Ecobuild last week on the topic of the FEES, in partnership with the Zero Carbon Hub. This featured our recently released version of NHER SAP 2009 Preview which now also outputs the FEES, in addition to the Code for Sustainable Homes ENE1 and ENE2. The workshops included a fascinating description by the Hub of how the FEES was arrived at, and impassioned debates about the logic adopted.

Dyfrig Hughes, technical managerThe FEES sets a target in kwh/m2/year of 39 for mid terraced/semi-detached houses and flats and a target for detached dwellings of 46 as of the 2016 Building Regulations. Interim targets will come in 2013. Many of the NHER OCDEAs present were arguing that the FEES target was too easy to meet and was leaving far too much of the zero carbon target to non fabric measures. The Hub argued that it was not right to require that developers meet more of the zero carbon target by fabric measures alone; that should be left to their discretion. There is, they claim, a phase change in the difficulty of installing high levels of insulation if one goes above the minimum standards required by the proposed FEES. The OCDEAs were arguing that renewables were too easy to remove and that there is nothing wrong with requiring things via the Building Regulations – that is the whole point of them!

Many in the audience expressed the view that the FEES was pathetic compared to the requirements of the Passivhaus standard, which sets a maximum target of 15 kwh/m2/yr. Interestingly, the Hub pointed out that the FEES adopts a different way of measuring kwh/m2/yr. The Passivhaus standard includes the contribution from mechanical ventilation with heat recovery to reducing energy demand. By contrast the FEES excludes 'anything that moves' If you correct the Passivhaus standard for mechanical ventilation, they say that the 15 kwh/m2/yr increases to 25 kwh/m2/yr; a lot closer to the FEES target, but still a long way to go. What do you think about the FEES target? Too easy, too hard, about right?

Responses to the consultation have to be in by 24 March 2010; it will be interesting to see what emerges. But first we have the delights of Part L 2010!

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As international consultants we see the passivehaus standard spreading out throughout main land Europe. UK have chosen to develop a more comprehensive systems like BREEAM etc. which in our view should be adapted in other EU countries. We fear a new standard with different targets will split the overall idea and force companies to adapt products (cost implications) instead of creating more uniform methods.
The targets set in FEES might be realist compared to UK building culture - but is it enough?


FEES is another poor and wholly unecessary compromise. I self-built the UK's 1st certified Passivhaus (with JPW Construction). After this last winter in our house I simply cannot understand the resistance and confusion in the UK. 25 kWh/(m²yr) without an MVHR is a silly comparison. In the northern European climate the MVHR is integral to Passivhaus. It's not a problem it's a bonus. Come on you UK housbuilders, large and small, what the heck are you afraid of? Stop making excuses. You CAN make money with Passivhaus, especially with the economies of scale available to you.