The GHA believes that the proposed changes to Building regulations for 2020 in anticipation of the Future Homes Standard implementation in 2025 are inadequate and fail to address the current and pressing issue of the climate emergency.

There are nine key issues that we think are important in any consultation response:

Part L

1

Fabric Energy efficiency standards should be supported in regulation - the proposed removal, if implemented without appropriate backstops, is likely to lead to worse fabric performance (than Part L 2013) with unintended consequences.

(Q3.c, Q22, Q23)

2

Homes should be built to a minimum fabric energy efficiency standard, such as Passivhaus Low Energy Buildings or equivalent standards as early as possible.

(Q3.c, Q5.c, Q6.d, Q11, Q12.a, Q13.b, Q21, Q49, Q50, Q57, Q59, Q61, Q62)

3

Homes should be modelled for overheating risk using 2050 Prometheus weather data.

(Q26, Q30)

4

Incentives should be available (both in Planning and fiscal terms) in order to encourage early adoption of higher standards.

5

Measurement, verification and disclosure of annual energy use and renewable energy     generation to be reported using a kWh/m2.year metric with indicative targets set out to 2030.

(Q7.c, Q10.b, Q16, Q21)

Part F

6

Better enforcement via Building Control (or equivalent) of verification, performance and compliance, e.g. for adequate ventilation flow rates.

(Q47, Q49, Q50, Q51, Q52, Q53, Q57)

7

Better source control of pollutants.

(Q35, Q36, Q37)

Parts F and L

8

Local Authorities should NOT be prevented from setting enhanced targets/ standards.

(Q4.d)

9

There should be incentives for anyone adopting an enhanced Quality Assurance scheme, such as Passivhaus, BEPIT or APP, that can be shown to reduce the performance gap in new homes.

Next steps

The 'Future Homes Standard: changes to Part L and Part F of the Building Regulations for new dwellings' consultation closes at 11:45pm on Friday 7th February 2020.

Find out more at: https://www.gov.uk/government/consultations/the-future-homes-standard-changes-to-part-l-and-part-f-of-the-building-regulations-for-new-dwellings.

How to respond:

Online: https://www.surveymonkey.co.uk/r/TQW8GQ9.

Email: FutureHomesStandardConsultation@communities.gov.uk.

Post: Future Homes Standard Consultation, 2SW, Fry Building, 2 Marsham Street, London, SW1P 4DF.

References:

  1. Building Performance – Joint Position Statement, Building Performance Network - https://building-performance.network/advocacy/building-performance-joint-position-statement.
  2. Net Zero Operational Carbon 1-pager, LETI - https://www.leti.london/one-pager.
Future Homes/Part L & F Consultation – GHA Response

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