Mark Oliver, MD at H+H, looks at the long term implications of Part L 2013 and how it will affect the zero carbon target.
Back in August the Government finally made an announcement about the long awaited changes to Part L of the building regulations. The announcement did not afford us with an in-depth account of the changes but rather pointed the industry in the correct direction and forced us to wait a bit longer for the publishing of the revised Approved Document L.
Part L deals with the conservation of fuel and power and was last revised in 2010. Under the revisions new homes will have to be six per cent more efficient with regards to carbon emissions, while non-domestic buildings will have to deliver a nine per cent improvement on current regulations. A notable change from previous Part Ls is the emphasis placed upon the fabric of the building with the introduction of a fabric energy efficiency target (FEES). The new rules are set to come into effect in April 2014 and according to the announcement from the communities and local government department it will result in a saving of 6.4 million tonnes of CO2 per annum. There are no changes planned for extensions to existing homes.
I welcome the announcement because it provides assurance for the construction industry. I am particularly enthused by the focus on fabric as this is an issue I have spoken about for a long time, including in this magazine because of the impact it has on the merchants.
There has been much talk about the delay to the changes and the idea that they have been somewhat watered down. The original plan was that Part L 2013 would become law in April 2013 following the usual period of consultation. We are now expecting it to be published imminently and that it will become law in April 2014, a year later than planned, although it will still be known as Part L 2013 (we think). The original expectation, in line with Level 4 of the Code for Sustainable Homes, was a 25 per cent improvement in energy efficiency. This 25 per cent became 8 per cent and now 6 per cent more carbon (rather than energy) efficient. So, if the Approved Documents are published as planned in October, the new set of regulations will effectively put us a year behind in terms of working towards the 2016 target of building zero carbon homes, meaning it is now more likely to be 2017.
This delay may not be such a big deal because the UK’s 2016 target is in fact a self-imposed target set by a previous Minister for Housing and Planning in December 2006. The logic was that all new homes needed to be zero carbon by 2016, in order to meet the commitment to reduce the whole country’s carbon emissions by sixty per cent by 2050. However, since 2006 we have had the deepest and longest recession in a century and witnessed the lowest level of peacetime house building in one hundred years. In addition to this, new European legislation has been passed that states 2020 should be the target date for new homes to be near zero carbon. There is strong logic that suggests we should collectively be working towards 2020 in line with European legislation.
There is also the issue of what is ‘zero carbon’. Since Yvette Cooper’s 2006 announcement, the definition has changed several times. Homes built after 2016 regulations come in aren’t going to be zero carbon, but they will be very low-energy homes. Each new home built will also include the cost of subsidy, known as “allowable solutions” to upgrade existing homes.
Combining the two factors of time delay and change in definition, it would make sense to me to simply align ourselves to the European Union’s Energy Performance of Buildings Directive and adopt both the dates and the definition of this directive. Rather than focussing on ‘zero carbon’ the European legislation focuses on ‘nearly-zero-energy’ meaning a building that has a very high energy performance.
Given the ever prevalent issue of the country’s economic situation and the need to encourage more home building, should we be taking such an aggressive approach to the interpretation of the European directive? The 2016 target was set in prosperous times and there is no denying that it does cost the economy when regulations are changed and made harsher; it becomes more expensive to build. The Coalition Government aimed to be the greenest government ever but at the recent Conservative party conference George Osborne’s mantra was “saving the planet shouldn’t cost the earth”.
Money spent making a new home more energy efficient has less impact on CO2 emissions than upgrading a Victorian home to current building regulations, which is where the logic of the allowable solutions comes from. There are twenty-five million homes to be upgraded with less than 25 million minutes between now and 2050.
Moving forward, it is obvious that the fabric of the building will grow in importance when it comes to building regulations and merchants. Whether a merchant is independent or part of a national chain, it needs to be in a position to capitalise on this as opposed to losing sales to specialist suppliers of systems such as air source heat pumps and bio-mass boilers.
When building with masonry and the focus is firmly on a fabric-first approach, aircrete is the most popular material in the market. It affords buildings greater thermal efficiency due to the millions of tiny non-interconnecting cells that make up the structure of the blocks and this helps in bringing down the U-values.
As a company H+H will be working with our merchant partners to help them with their construction details guides. Along with other leading suppliers, we are working to produce a 2013 part L guide for the independent merchant and small builder that simplifies and condenses the housing building regulations. With the new Part L for homes being based on an ‘elemental approach’, this should help SMEs in the start point of their house designs, although there is a lot of in-built flexibility.
Part L 2013 will not be the building regulations change that puts the UK within touching distance of our current 2016 target but that is not what matters. What matters overall is that as a country we do not become fixated on zero carbon homes, when in fact we should be taking a broader view of the problem and focusing on our usage of energy and trying to limit this as much as possible, through focusing on the actual building rather than putting the onus on the home owners. After all, if you start with the fabric of the building, ensuring that as much thermal insulation as is practically possible is built in at the outset, because once it is built, it is there for the 150 year life of the building and residents cannot easily affect its efficiency.