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Last-ditch bid to get government to rethink ‘unambitious’ Part L changes

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Climate change activists are urging architects to reject government proposals to change regulations on the energy efficiency of new homes, which they say are a ‘step backwards’

Ayone wishing to respond has only a few hours left to submit responses to the consultation on the amendments to Part L and Part F of the Building Regulations for new homes before the deadline at 11.45pm tonight (7 February).

Yesterday climate change protesters demonstrated outside the Ministry of Housing, Communities and Local Government (MHCLG) against the ‘unambitious’ new Part L, which covers conservation of fuel and power in the home, and Part F, which relates to ventilation.

According to the government, the regulatory changes form part of its strategy to create a Future Homes Standard by 2025, aimed at encouraging low-carbon heating and creating ‘world-leading levels of energy efficiency’.

The alterations to the Regs are seen as a milestone towards the government’s target of achieving net zero emissions by 2050.

However, campaigners say the proposed new standards fall woefully short, adding that the Future Homes Standard did not consider the embodied carbon of buildings. There are concerns, too, about a move to strip forward-thinking local authorities of their powers to set higher energy efficiency standards.

Sofie Pelsmakers, assistant professor in Sustainable Architecture and Housing Design at Finland’s Tampere University and author of The Environmental Design Pocketbook, said: ’The UK government abolished The Code for Sustainable Homes and the Zero Carbon definition half a decade ago, but it has failed to replace them.

‘The existing standards were supposed to be the stepping stone to better, more sustainable buildings and homes by 2020, yet a policy and regulatory vacuum of ambition means that the government is allowing homes to be built that are not fit for purpose today, let alone tomorrow.’

She added: ‘This means that not only have buildings been designed and built to outdated standards, locking in their mediocre performance and associated climatic impacts for decades to come, but the current proposal is barely crawling forward from those outdated standards. Instead of the gigantic leap forward that is so needed for the British people, our global neighbours and climate, the current proposals confirm that the UK has lost its ambition and leadership in this area.’

The new approach will not meet the Intergovernmental Panel on Climate Change’s timetable

A review of the proposed changes to Part L and F by The London Energy Transformation Initiative (LETI) suggest that the new approach will not meet the Intergovernmental Panel on Climate Change’s timetable. To limit global warming to 1.5 degrees C, the IPCC has given a deadline of 2030 to cut emissions by 45 per cent from 2010 levels.

LETI analysis suggests that to hit our targets by 2030 all new buildings will need to operate at annual net zero carbon emissions, which means that by 2025 100 per cent of all new buildings must be designed to have net zero carbon emissions.

Clara Bagenal George, initiator of LETI, claimed the proposals for Part L were ‘likely to result in a step backwards’, when what the climate emergency demands is ‘a huge leap forward’. She is calling for a ‘strong consultation response’ from built environment professionals to make the government think again.

The government consultation sets out possible two options for energy efficiency: option one would deliver a 20 per cent cut in carbon emissions due to improvements in insulation, such as triple glazing; option two calls for a 31 per cent reduction in carbon emissions by installing equipment such as photovoltaic panels together with higher insulation standards, though not as high as in the first option – employing, for instance double, rather than triple glazing.

Despite the higher building costs, the government says that option two is its preferred route, due to its higher reductions in carbon emissions and positive impact on supply chains.

Under the Future Homes Standard, an average new-built home will have a 75-80 per cent reduction in carbon emissions compared with one built to current energy efficiency requirements, the government says. This will largely be delivered through ‘very high fabric standards and a low-carbon heating system’, the consultation document says. As an example a new home might have a heat pump, triple glazing and standards for walls, floors and roofs that significantly limit heat loss.

But the Architects Climate Action Network (ACAN), which is also calling on the profession to challenge the changes, disputes the way that carbon values have been measured under the proposals.

In a letter to Housing Secretary Robert Jenrick, signed by dozens of architects, ACAN criticised the way carbon emissions are calculated under the proposals, saying: ‘The use of carbon factors as proposed in this consultation is a step backwards and will disguise poor fabric efficiency through over-reliance on a decarbonised grid. Under the proposed regulations, new homes may end up using more energy than those built to 2013 regulations.’

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Dsc 0151

Source: Sam Turner

Extinction Rebellion and members of ACAN mounted a demonstration yesterday outside the offices of the MHCLG. They highlighted another key ACAN objection – that councils will be prevented from being stricter than the building regulations.

The government says this is to prevent housebuilders from facing extortionate costs and problems due to a lack of uniformity in supply chains. Campaigners respond that with 65 per cent of councils declaring a climate emergency last year it amounts to a diktat preventing them from taking the necessary action.

A fourth point raised by ACAN is that the Future Homes Standard needs to take into account embodied carbon. Emissions associated with a building’s use only make up a proportion of its total carbon footprint, with the emissions associated with materials, construction and refurbishments – embodied carbon – making up a greater share, the campaigners argue.

Sam Turner, one of the core co-ordinators at ACAN, said the action envisaged by the government was not ambitious enough and would take until 2025 to implement properly. He pointed out that LETI had come up with a proposal that could be implemented now. ACAN are urging architects to respond and to attach the LETI evidence, he said.

In relation to councils setting higher standards, the consultation document says: ‘We appreciate both uplift options increase the costs for home builders and so we propose to remove the ability of local planning authorities to set higher energy efficiency standards than those in the Building Regulations.

’This has led to disparate energy efficiency standards across the country and can create inefficiencies in supply chains, labour and potentially quality of outcomes. Removing this ability will create certainty and consistency.’

Turner, an architect at Webb Yates, described the government’s rationale as ‘ridiculuous’.

‘Making councils go by the lowest common denominator and the least ambitious target is pathetic,’ he said. ‘To say you don’t want to have variety across the country is ridiculous, as there are different varieties of local plans in every area.’

The consultation relates to new domestic buildings. Further consultations are expected on existing homes and new and existing non-domestic buildings.

The changes have been greeted with dismay by some local authorities. Councillor Richard Livingstone, Southwark Council cabinet member for Environment, Transport and the Climate Emergency, said that 80 per cent of carbon emissions in the borough came from buildings. ‘We know we have to look at the building standards and we’re looking at stronger controls. That the government is trying to stymie this is outrageous. They are handcuffing us as local authorities to stop us doing any better.’

He rejected the idea that developers would be deterred from building homes due to tougher standards.

He told the government to think again following the consultation. He said: ‘As a bare minimum we want them not to hamper local government.’

An MHCLG spokesperson said: ‘We are determined to make sure houses built now and in the future are greener than ever before. Our proposed Future Homes Standard will require all new homes built from 2025 to have 80 per cent fewer carbon emissions – that’s real action to protect our environment and tackle climate change.’

The new Part L and Part F rules are likely to be published in early to mid-2020, and to come into force in mid to late-2020. The government has committed to introduce the Future Homes Standard by 2025.

Responses to the consultation questions should be submitted by online survey  or emailed to FutureHomesStandardConsultation@communities.gov.uk  by 11.45pm tonight.

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