It’s nearly three years since the introduction of Building Regulations Part L 2010, and in March 2012 the proposals for the 2013 iteration for the Conservation of Fuel and Power Regulations, Part L 2013, landed on our desks.
Although we are still awaiting final publication of the 2013 version, the three year gap between iterations highlights the expediency with which the Department for Communities and Local Government is treating the impending introduction of zero-carbon homes in 2016 and non-domestic buildings in 2019, confirmed by the government in the 2013 Budget.
There are a significant number of objections to such a rapid update – that not enough evidence has been gathered from the 2010 version of the regulations to make changes, and that stricter regulations will act as a barrier to growth at a time of precarious national finances.
However, UK climate targets are not negotiable on the basis of financial activity, or lack thereof. And the emergence of the green economy has shown that even in harsh fiscal climates, it is possible to create opportunities for business. Our buildings are still responsible for sizable CO2 emissions and everyone in the industry knows progress needs to be made to pave the way to the zero carbon deadline.
The proposed new-build CO2 reduction targets over the 2010 objective of 8 per cent for homes and 20 per cent for non-domestic buildings are a notable departure from the previously stated aim of a 25 per cent cut in emissions for both building types. Certainly, the wide gulf between the two targets is interesting.
The consultation document says non-domestic buildings will now be expected to employ renewables to hit the emissions target.
Not so for dwellings. It seems the government is keen not to be seen to be hindering house building, and perhaps the house builders have been more vocal in their lobbying than their non-domestic cousins, resulting in the government’s 2010 spending review commitment to reduce the burden on the house building industry.
Elsewhere, things are a little simpler. The minimum backstop U-values for non-domestic building fabric are unchanged, although designers may have to go beyond these values to hit the new CO2 targets.
The minimum system efficiencies recommended in the Non-Domestic Building Services Compliance Guide have been tightened. For instance, for most air conditioning systems, the minimum ESEER is being increased from 2.5 to 2.7. Likewise, the maximum SFPs have all been incrementally reduced by 0.1 – 0.3 W/l/s, depending on the system.
Again, however, it may be necessary to exceed these minimum efficiencies to comply with the new CO2 targets.
The body set up to establish how homes will meet the zero carbon challenge, the Zero Carbon Hub, has said emissions targets set though Part L should reflect the ‘as built’ performance.
This recognises that there is a performance gap between the predicted emissions and those that occur in practice. While the consultation document sets out proposals to assist in reducing this gap for homes, there are no parallel proposals for non-domestic buildings, despite the fact that there is also a considerable performance gap for non-domestic buildings.
In order to further study and close this gap, large amounts of in-use data are required. This would have been readily available if the government had managed to outline a programme for the introduction of display energy certificates for non-domestic buildings in the recent Energy Act.
The lack of a programme and associated data highlights what a missed opportunity that was.
The final piece of the zero carbon puzzle is allowable solutions. These will essentially take the form of payments to fund projects aimed at reducing emissions off-site, hence offsetting the residual emissions from developments. It is very difficult to determine if the steps being made to reduce emissions on site will be cost-effective compared with allowable solutions when the industry does not yet know what the costs of allowable solutions are likely to be.
Although consultation on this was promised before parliament’s summer recess, it would be of far more use to read now, in tandem with the proposed changes to Part L.
For existing buildings, the main area of focus of the proposals was the integration of the Green Deal with consequential improvements to the energy efficiency of homes, while other works are being undertaken.
This was labelled the ‘conservatory tax’ and in December 2012 communities secretary Eric Pickles announced that this plan would be scrapped following Conservative Party opposition, although existing consequential improvements requirements will remain.
The U-value targets for replaced, extended or renovated thermal elements have also been subject to revision.
In general, the proposals outlined for Part L 2013 are pragmatic and well thought through. Emissions cuts implemented since 2002 essentially mean that even buildings only built to the regulatory minimum will still be low carbon.
We have had nearly six years to get used to the idea of zero carbon buildings. Although the policies are starting to take shape, we need more data on buildings in-use by introducing DECs and information on allowable solutions before we have a good idea of how much more work is required to hit the zero carbon target.
Dan Jestico is head of research and development at Hilson Moran