This post is by Philip Box, public affairs and policy officer at the UK Green Building Council
On 19 January, the government published its long awaited response to the 2019-20 consultation on changes to building regulations in England, and initial plans for the Future Homes Standard.
Having consistently pointed towards this standard as the linchpin of its plans to decarbonise new build housing in recent months, not least in the recent planning white paper, the pressure was on the government for this announcement to deliver.
Ultimately, there are several reasons to be cheerful about what has emerged in the government’s response, but there are at least a couple of reasons to be disappointed.
The Future Homes Standard won’t be implemented before 2025
First, the less good news. After the government mysteriously removed a sentence indicating that the Future Homes Standard would be moved forward to 2023 from the prime minister’s ten point plan for a green industrial revolution, minutes after it was published, there were understandably rumours that this would be included in the consultation response.
Sadly, this was not the case. Instead, it is only the consultation on the full standard that will be moved forward to 2023. This is, at least, somewhat positive, as it will allow the market time to develop both the associated expertise and supply chains for reaching net zero. This is particularly important with regards to scaling-up heat decarbonisation, as the consultation suggested a preeminent role for heat pumps in future homes, which matches the prime minister’s goal for 600,000 heat pumps a year by 2028.
In the meantime, the more ambitious option for an interim 31 per cent reduction in CO2 through Building Regulations, compared to current standards, will be enacted. Again, this is positive, given that the uplift in the target provides a vital stepping stone towards reaching the aims of the full Future Homes Standard, which will aim for CO2 emissions 75-80 per cent lower than current Building Regulations achieve.
However, overall, the decision not to bring the Future Homes Standard forward is disappointing, especially given the government’s commitment to speed up housebuilding through planning.
Local authorities can still set their own energy efficiency standards
Not surprisingly, the proposed planning reforms will also have substantial implications for local authority standards. Significant concerns were raised during the consultation period over plans to remove the powers of local authorities to set local energy efficiency standards above the national minimum. Several leading authorities, including the mayors of London, the West Midlands and Greater Manchester, signed a letter calling for these plans to be reconsidered.
With many local authorities having already set net zero targets for earlier than 2050, the ability to go further than national regulations will be crucial. UKGBC’s recent Interactive Policy Map and New Build Policy Playbook both highlight those local authorities who have already set more ambitious local standards.
In response, the government confirmed that, for the moment at least, local authorities would still be able to set higher energy efficiency standards. However, in the context of the impending planning reforms, it left the issue open for later resolution. All eyes will now be on the response to the Planning White Paper.
The Fabric Energy Efficiency Standard stays
The consultation response also confirmed that the Fabric Energy Efficiency Standard (FEES) will no longer be scrapped, and that the government will consult on going further, having acknowledged the ‘fabric first’ approach is sound.
This represents a significant win as, in the absence of FEES, the 31 per cent emissions improvement could be delivered through the installation of low or zero carbon technologies on sub-optimal, inefficient building fabric, leading to avoidable grid demand.
Whilst this is certainly a step in the right direction, maintaining the FEES standard alone does not address some of the wider issues around whether building regulations can genuinely deliver net zero. The consultation response acknowledged the need to tackle the performance gap, ie the difference between designed and actual performance in use, and whole life carbon, the emissions over a building’s lifecycle, but suggested measures to address these were outside the scope of the current consultation.
There is still much work to be done to ensure both the Future Home Standard and building regulations live up to their presentation as “world leading”, not least in moving towards a system focused on in use building performance. Likewise, it is important that progress on a local level is not impeded by measures that will hamper ambitious local authorities from going further.
More consultations are on the way, so whilst this is clearly not the end of the road to zero carbon homes, it is a step in the right direction.
