Future Homes Standard Consultation Response

We need a clear, strong, industry-backed proposal for a better Future Homes Standard.

In response to the government consultation on the Future Homes standard and the Home Energy Model; Bioregional and Good Homes Alliance, alongside other expert, industry-leading organisations including LETI and the UK Green Building Council have sent a letter to DLUHC and DESNZ, with evidenced proposals for a better standard.

Neither of the Future Homes Standard consultation options go far enough in addressing the urgent need for change to meet our climate commitments, or the healthy homes with low bills that we need.  250 prominent industry organisations joined us in signing our letter in response. The letter is an opportunity to advocate for positive change with one strong, clear proposal.

The links to the consultations can be seen here: https://www.gov.uk/government/consultations/the-future-homes-and-buildings-standards-2023-consultation. We have encouraged organisations to submit their own responses. The deadline for responses is Wednesday 27th March 2024.

The Town and Country Planning Assocation has issued a a joint letter to the Secretary of State regarding the 13 December Written Ministerial Statement. Find out more here: https://www.tcpa.org.uk/joint-letter-to-the-secretary-of-state-regarding-the-13-december-written-ministerial-statement/

 

The Rt Hon Michael Gove MP

Secretary of State for Levelling Up, Housing, and Communities

2 Marsham Street, London SW1P 4DF

Cc: The Rt Hon. Claire Coutinho MP,  Secretary of State for Energy Security and Net Zero

Wednesday 27th March 2024

Dear Secretary of State,

Re: Future Homes and Building Standard (FHS) and Home Energy Model (HEM) consultations

As leading businesses and organisations involved in delivering new homes and buildings to high sustainability standards, we are writing with our view on the FHS and HEM consultations. We would like to meet you to discuss the consultations and are available to provide further information in addition to our organisational responses.

We support the following elements of the proposals which should be implemented without delay. We welcome the end of fossil fuel heating and commitment to electric heating. We support integrated on-site renewables for new homes, and the extension of energy efficiency measures for dwellings created under material change of use. We welcome the proposed HEM as a replacement for SAP.

However, this is not a definitive Future Homes Standard, but rather a positive step towards it. Many of us involved in the development of the Future Homes Hub’s (FHH) five contender specifications[i] (CSP) are disappointed that the two weakest options are being consulted upon. We request a further iteration of the Standard be developed to ensure new buildings are of a higher specification by 2028. In this letter we set out immediate concerns to be addressed and outline why further development of the FHS is needed.

We have immediate concerns to be addressed in the 2025 regulations:

  1. We strongly disagree with the Option 2 notional specifications. Omitting photovoltaics (PV) and lowering building fabric standards will lead to an additional £600-£700 per year on energy bills for residents of new homes compared to the current Part L 2021 and Option 1 respectively[ii]. The public sector equality duty ensures Government does not introduce standards which unduly affect those on lower incomes or with protected characteristics. A lower fabric standard would increase the pressure new homes place on the electricity grid at a time when the electrification of heat, transport, and industry means demand for electricity is expected to grow fourfold by 2050.[iii] All new homes should have integrated PV as standard to maximise available renewable energy, especially as the cost of installation continues to plummet[iv].
  2. We strongly disagree with the choice of Primary Energy over Delivered Energy. We see no evidence provided to justify this choice, with 76% of respondents to the previous FHS consultation[v] opposing Primary Energy as a metric. The Climate Change Committee (CCC) supported Delivered Energy for domestic Energy Performance Certificates (EPCs) [vi]. The HEM consultation discusses the use of Delivered Energy and a different metric for the FHS creates Government inconsistency and confusion. Delivered Energy should become the key metric in this Standard.
  3. We support voluntary post occupancy performance testing, but enhanced testing of buildings post-completion, or “As built” should be mandatory. The proposal to ensure transparency on actual performance – acknowledged by Government as a key outcome for EPC reform following the 2021 consultation – is urgent. We support the introduction of performance testing, but a wholly voluntary approach will not provide the necessary protection from sub-standard build quality causing increased energy bills.[vii] In order to ensure a home’s as-built thermal performance is as designed, mandatory performance testing needs to included using simple, low-cost, enhanced post-completion testing, such as short duration whole-house heat loss tests[viii]. In addition, more accurate post occupancy testing should be voluntary but incentivised.

There is a need to improve on the proposals for a higher standard which delivers on the FHS aims. The Written Ministerial Statement of 13 December 2023 seeks greater consistency between national and local energy efficiency.  This could be addressed by Local Authorities, sector professionals and DLUHC co-developing and converging on a common definition of higher levels of performance during the course of 2024, based on the recommendations set out below , and could be used from 2025 onwards. This higher standard can then be used to inform the next iteration of building regulations by 2028. This needs to be signalled now by the Government, to avoid any negative impact on housing supply, as it will then be factored into land prices.

  1. Regulate embodied carbon in new buildings. Embodied carbon makes up 20%[ix] of UK built environment emissions and declarations of whole life carbon are already required for large building projects. Policies to measure and limit embodied carbon and apply circular economy approaches within the construction sector are urgent and should be included in FHS.
  2. Improve fabric standards for U values and air tightness. Alignment with current good practice can improve comfort and achieve a level of thermal resilience and stability to permit sufficient flexibility for grid peak load management.[x] The FHH CSP4 has just 25% of the home heating demand compared to FHS Option 1.
  3. Improve new home ventilation systems. Research is urgently needed to determine if trickle vents with intermittent extract fans and with decentralised mechanical ventilation (dMEV) deliver the indoor air quality and comfort required[xi]. The limited evidence that exists suggest high instances of poor air quality, particularly in bedrooms[xii]. Should the research indicate poor air quality, and comfort, in use the FHS should mandate systems such as mechanical ventilation with heat recovery (MVHR) to deliver good air quality, reduce condensation and mould, and recirculate heat (as addressed in the FHH CSP3, 4, and 5).
  4. Reduce electricity generation investment required. Improvements to building fabric and ventilation outlined above have been calculated to save circa £22.6 billion in electricity generation investment over 20 years compared to Option 1, and would result in a £190/year reduction in bills for occupants.

Higher standards will not limit housing supply. The FHS consultation stated concern that higher standards will increase costs and complexity for housebuilders and limit housing supply. Recent Government studies [xiii] [xiv] did not find higher standards to be a constraint on housing supply. The additional cost of CSP4, for a one-off 200 home site, compared to Option 1, was £13.8K[xv] per plot and will be considerably less when delivered at scale. This cost will be absorbed through adjustments to land values, as with previous regulation changes, not increasing householder costs and not limiting housing supply. Homes built to higher standards have shown to be feasible and viable at a local authority level across England, having passed tests of Local Plan inspection[xvi] [xvii] [xviii] [xix].

Collaborating for better standards that really work. Lessons from the 2021 FHS pilots, and existing homes built to higher standards, should inform a future homes standard. We collectively bring knowledge and experience of building to higher standards, and offer practical justification for achievable standards which benefit industry and residents in line with net zero goals. We urge you to collaborate with us to develop the standard further.

References

[i] https://irp.cdn-website.com/bdbb2d99/files/uploaded/Ready+for+Zero+-+Evidence+to+inform+the+2025+Future+Homes+Standard+-Task+Group+Report+FINAL-+280223-+MID+RES.pdf

[ii] https://www.gov.uk/government/consultations/the-future-homes-and-buildings-standards-2023-consultation/the-future-homes-and-buildings-standards-2023-consultation#performance-requirements-for-new-buildings

[iii] https://committees.parliament.uk/writtenevidence/115773/pdf/

[iv] www.mcc-berlin.net/en/news/information/information-detail/article/plummeting-prices-for-solar-power-and-storage-make-global-climate-transition-cheaper-than-expected.html#:~:text=MCC%2Dled%20study%20on%20the%20effect%20of%20technology%20and%20product%20in

[v]https://assets.publishing.service.gov.uk/media/60114c6c8fa8f565494239a7/Government_response_to_Future_Homes_Standard_consultation.pdf

[vi] https://www.theccc.org.uk/publication/letter-reform-of-domestic-epc-rating-metrics-to-patrick-harvie-msp/

[vii]

[viii] https://irp.cdn-website.com/bdbb2d99/files/uploaded/BPE%20Guide%20-18.10.23.pdf

[ix] https://ukgbc.org/our-work/topics/advancing-net-zero/embodied-carbon/

[x] https://www.gov.uk/government/publications/building-for-2050

[xi] https://www.heatspaceandlight.com/hygiene-ventilation-designed-homes-offices/

[xii] https://www.paulheatrecovery.co.uk/wp-content/uploads/2020/03/Final-report-dMEV.pdf

[xiii] https://assets.publishing.service.gov.uk/media/5bd6eb3940f0b6051e77b6a6/Letwin_review_web_version.pdf

[xiv] https://commonslibrary.parliament.uk/research-briefings/cbp-7671/

[xv] https://irp.cdn-website.com/bdbb2d99/files/uploaded/Ready+for+Zero+-+Evidence+to+inform+the+2025+Future+Homes+Standard+-Task+Group+Report+FINAL-+280223-+MID+RES.pdf

[xvi] https://www.cornwall.gov.uk/media/fkzp45mv/eb042-20200359-climate-emergency-dpd-technical-evidence-base-rev-g.pdf

[xvii] https://www.cornwall.gov.uk/media/vtigrrk3/sd06-ce-dpd-viability-report-nov-2021.pdf

[xviii] https://www.n-kesteven.gov.uk/sites/default/files/2023-03/INF002a%20Central%20Lincs%20Whole%20Plan%20Viability%202021.pdf

[xix] https://beta.bathnes.gov.uk/sites/default/files/2021-08/B%26NES%20LPPU%20Viability%20Study.pdf

Signatories for the letter are now closed. You can still sign up to show your support by completing the form below.

Signatories

Developers

CALA homes developer
Elsworth projects developer
Fore-FINAL2
Greencore
KIN
LOKI-Logo_2024
Places for London
Xera

Local Authorities

Camden council LA
Central lincs
Chelmsford city council
Cherwell
East Suffolk LA
Essex
Forest of Dean
Greater Cambridge Shared Planning
Rother district council LA
Southampton city council
Warwick DC
West oxfordshire district council
Winchester City Council

Housing Associations

Forest clt
Hastoe
Peabody
SNG_Primary-Logo_Master_BK-RGB.ai-1 (002)

Non profits/NGO’s/charities

ACAN_Logo_Black
AECB
Architects declare
ASBP_LogoIdea_1_Bodoni_Orange
Association of Directors of Environment Economy Planning & Transport (ADEPT) non prof
BHESCo
Bioabundance Community Interest Company non profit
British Blind and Shutter Association
Bucks Climate Action Alliance non profit
Cambridge retrofit hub
Canopy Housing
Chartered institute of architectural technologists
CIAT_Short form Logos_Colour_RGB
Climatr action risborough
Coaction
CPRE Oxfordshire Charity
CSE-logo
ECOAction
EDGE
GreenBristol
Greening steyning
Heating Bildeston
Hegerley Wood Trust non prof
Highgate Society
Home Energy Action Lab
IEMA
IMA logo master
Insulated render and cladding association non prof
Interior Design Declares non profit
IOM3
Isle of Wight mission zero hub
Marloe Energy Group non profit
New London Architetcure
NW3 Community Land Trust
Planet2030
Quality of Life Foundation
Rebel Farmer
Rights communtity action
Rose Hill
SBUK-logo
Sustainable Development Foundation non profit
Sustainable Haringey
Sustainable Wantage non profit
Talking-Tree-logo
tcpa
transition-bath-logo
UK100-LOGO-no-backgund-2
Water Mill non prof
Wiltshire climate alliance non prof
Winchester Action on the Climate Crisis (WinACC)
Zero Carbon Haddenham charity

Architects and designers

A D Practice ltd architecture
Absolute project management
ADP
ahmm
Allies and Morrison
Andrew Catto
Andrew Hughes Architects
Architecta_Logo_exploration_v2-08-1
Architects in Practice
Architype
Atelier habitat
AWW-Standard-Logo-Slate
BDP_logo_RED_CMYK
Belsize
Berzins Architects architecture
Bird Architecture
Bloom logo_long
Chapter 2 Architects
Charlie_Luxton_Design_
Crow-Architecture_Heavier-27
Cullinan Studio
Curl la tourelle
CZWG
DvJ Design
ECD
ECE
Eco Design Consultants Architecture
Feilden Clegg Bradley Studios architecture
GDS-Logo-M_Block-Black-46
Grace Choi Architecture
Greenfield
GUNN
Habitat architects
Hawkins Brown
Haysom Ward Miller
Henley Halebrown architects
HKS Architects
Hopkins Architects
HTA Design
Jestico + Whiles Architecture
Juliet-Bidgood
Kast Architects
Levitt Bernstein
Love Architecture
LTS
Material works
Materialise Interiors
MawsonKerr
MEPK
Miltiadou
Morris+Company
Niche design
Nicola Holden
North architects
Paper igloo
Phillips 2
Pollard Thomas Edwards
Prewett Bizley
Rees Pryer
rivington street studio
Sheppard Robson
Simpsonhaugh
Solent Arch-Wordmark-LBG
Studio Bark
Studio gather architecture
Studio Partington
Studio Perrin Architecture
Tasou (2)
TP Bennett Architecture
Transition by Design
Trewin design
VHH
Vincent + Gorbing
Waugh Thistleton
White Arkitekter Architecture
WilkinsonEyre
Will Saxby
WonKy architecture
Working title architects
WWA_Logo_2021_Orange-on-White
yapp1

Consultants and engineering

Abba Energy architecture
Allan Molyneux
Architectural Physics
Arup
Beyond Carbon Associates
Build-Energy-update-JPG
Carnego
Civic Engineers
Clifford
Climate guide ltd
ColdProof
Construction Carbon
Delta Q
DvJ Design
Ecolytic
Edgars
Elemental solutions
ERS Consultants Ltd
Etude
Futureground_Stacked
GeoEnergey Design Engineering
Green Peaches
Greengage
Humble bee logo - print
InklingLogo_large
Introba
IOE_white
KJM Ltd consultant
KLH Sustainability consultant
Lamorbey
Linktreat
Marberg
MF_LOGO_FINAL
Murton co
NDM Heath
Net positive solutions
Net zero advisory
Nordic physics
Nuplanet
Page-Park-BLK-Logo
Planet 20 0 Ltd consultant
Polaris Passivhaus Consult + Construct Limited consultant
Pope consulting
QODA
Rapungi
Riverway consultant
RTR_01
Smart energy services
SquareGain-logo
SSB Consultant
Stroma consultant
Sustainability By Design consultant
TTG-logo_TTG-1
Urdal
USUS
Verte Ltd
Vertigo
Warm_Logo
Will Saxby
XCO2-Logo_Grey_Transparent-Background

Contractors

Carbon-Rewind-contractor
Cast interiors
EcoVert
Melius
Silen-Construction_Logo
Wilmott dixon

Building product manufacturers/suppliers

cropped-HAUS_Logo-1
ECOLOGIC slips
Etopia Logos
Hemsec product
Internorm_Windows-Doors.indd
Lowfield
siga
Smartlouvre
Trust electric heating
Zimbl

Academic

Building meaningful futures academic
Fuel Poverty Research Network
High Performing Homes
LEEDS BECKETT

Finance

Ecology finance

Software and technology

Sero

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