21st February, 2020
The Future Homes Standards The FES Group’s Response.
The summary of The FES Group’s response to The Future Homes Consultation.
Report by Paul Bainbridge, Associate Technical Director. For and on behalf of The FES Group.
The FES Group were pleased to be given the opportunity to provide comments on the proposed changes to Part L 2020 via the Government’s consultation document released in October 2019. The FES Group has provided full and honest answers to all questions we feel are applicable to our area of expertise and our aim was to provide the Government with a balanced view from both our clients and the desires for a zero carbon future.
The FES Group acknowledge the Government’s plan to have the approved document ready for spring 2020 with implementation of the regulations in autumn 2020.
Part L 2020 Standards for New Homes in 2020
The consultation put forward two options; option 1 being a 20% reduction in CO² emissions and option 2 being a 31% reduction over CO² emissions. It was acknowledged within the document that these options would increase build costs but would reduce running costs for the end user and that this would be the first step towards a desired 70-80% reduction by 2025.
The FES Group agree with the above intentions, however, at this time the cSAP software and the preferred method of compliance does not back up the above claims. The FES Group has found on average option 2, being the Government’s preferred option, is in fact a 50% reduction over Part L 2013. The FES Group have also found that it is clear the Government’s intention is in electric as a main heating fuel, ASHP’s being the primary choice. This will result in both increased build costs (to be expected) but also an increase in running costs. The latter is simply due to the fact that the base cost of electric in its pence per kwh is significantly higher than that of gas. This is an issue that lies outside the construction industry and while The FES Group recognises that a decarbonised grid is an adequate zero carbon fuel its cost to the end user must reflect this, otherwise adoption by the industry and the general public is going to be extremely difficult.
It is our recommendation to implement option 1, a 20% reduction over Part L 2013. However, this is on the provision that the regulations will have an intermediate update between 2020 and 2025, for example 2023. It is our belief a 20% increase in 2020, a 25/30% increase in 2023 and a 30/40% increase in 2025 will provide the industry with a staggered introduction to the new technologies, building techniques and other changes needed to hit the final Future Homes Standard in 2025. This will also allow for regular updates to the SAP methodology, fuel costs and carbon factors all of which are demonstrated as needing regular updates by the now significantly outdated SAP2012 methodology.
The consultation has proposed the use of 4 performance metrics over the previous 3 metrics currently used in SAP2012. This includes the removal of the Fabric Energy Efficiency metric and the introduction of two new metrics. The Dwelling Primary Energy Rate and the homeowner affordability rating.
The FES Group welcome this, considering the changes and improvements being made to the fabric u-values limiting factors and the lower DER needed in compliance finally coupled with the removal of fuel factors for LPG or oil the DFEE metric is pretty much null and void. While its introduction in the SAP2012 methodology served a purpose, (to prevent poor performance in fabric to be supplemented by renewables) the issue is circumvented by the level of performance needed under SAP10.
The FES Group are encouraged by the reduction in the limiting fabric u-values. These are a significant step without being extreme and still allow for a varied approach to design. We are also pleased to see the introduction of the Dwelling Primary Energy rate. The FES Group are familiar with the performance of a dwelling’s energy having assessed its reduction within our Energy Statements for the past few years. We are familiar with the difference between energy reduction and carbon reduction and welcome a clear distinction between the two measures to aid in industry education.
Finally, The FES Group encourage the removal of fuel factors. This is to provide each calculation and fuel type with a level playing field. We do however discourage the proposal to introduce a technology factor for district heating. This works against the level playing field philosophy we think is paramount to giving accurate information to the industry and the general public.
The consultations suggest the removal of the SAP appendix K Accredited Construction Details PSI values for use in thermal bridging calculations. While we acknowledge that these details are significantly outdated we would have liked an updated set to provide an easier alternative to calculated details or using defaults.
We do however highly encourage the proposal to update u-value calculations to the latest version of BR443.
Our final point is in support of the proposal to amend the Planning & Energy Act 2008 to restrict local authorities from setting higher energy efficiency standards than the regulations. The FES Group support this idea as the current system is confusing and inconsistent. Considering the steps being made within the regulations both in 2020 and going forward we would advise that a uniformed approach is going to be best adopted by the industry.
Part F Changes
Whilst The FES Group does not specialise in Part F, we do support the introduction of a completed commissioning checklist in accordance with the proforma given in Appendix C of Approved Document F, Volume 1. However, we would advise that these proformas are completed by a suitably qualified persons and that an appropriate accreditation and auditing scheme was introduced to give credibility to the commissioning checklist and to ensure the systems are working correctly.
The changes put forward in the consultation document with relation to air tightness testing include a change in the methodology to be written by CIBSE, a mandatory requirement to undertake air testing on a plot by plot basis, and a drop in the maximum allowable air test to an 8.00m³/m².h plus the introduction of an alternative air testing method in the Pulse Air Testing Methodology.
The FES Group strongly recommend the proposal to have the air testing methodology written by an independent body. We are in agreement with the draft methodology prepared and welcome a document that addresses the theory of air testing as well as its practical application. We also note that the existing TSL1 document is outdated and we welcome an even stance to the accreditation bodies in place to enforce the regulations.
The FES Group are also in agreement with the proposal to undertake plot by plot air testing. The current averaging system does not work as intended and is often misunderstood by both design teams and building control officers and does not guarantee the performance of a dwellings final EPC.
Individual air testing will ensure confidence in the performance of a dwelling’s fabric and accuracy of the EPC produced.
The FES Group agree with the proposed drop in the maximum air pressure test to 8.00m³/m².h which is in line with the improvements made to the limiting u-values in Part L. A consistent improvement across the whole building is welcomed.
The FES Group are also pleased to see the proposed introduction of the Pulse Air Testing unit. While the unit differs from the blower door method we are encouraged to see that new methods and technologies are being explored and that options will be available to the type or method of tests undertaken on site.
The consultation also put forward a couple of changes to the way air pressure test results are input and calculated within SAP, including a cap on the benefit naturally ventilated dwellings gain below 3.00m³/m².h and an automatic rounding up of As Built Air Test results by 0.5m³/m².h
Unfortunately, The FES Group does not agree with either of these proposals. We believe that dwellings should be prevented from achieving an air pressure test of 3.00 m³/m².h or being designed with one via a compliance fail. Only allowing air pressure test of 3.00 m³/m².h or below where mechanical ventilation is provided as simply capping the benefit given does not prevent the issues of over airtight dwellings.
We also disagree with the proposal to round up air pressure test result by 0.50m3/m2.h in the As Built SAP and have in fact proposed that the rounding should be done to 0.10m3/m2.h It seems strange to us that a dwelling with an air test of 4.65m3/m2.h would show a 5.00m3/m2.h on the As Built SAP and EPC. This will also create confusion for developers, homeowners, building control assessors and EPC auditors.
Compliance, Performance and Providing Information
The consultation proposes the introduction of the BREL report and the requirement to provide building control and the homeowner with a signed copy upon completion of the Post Construction stage which is signed by both the assessor and the developer.
The FES Group are in full support of this proposal, the BREL document shares similarities with our own SAP specification which we have used as a similar As Built Confirmation document for a number of years and welcome its transparency in clearly identifying all aspects of the dwellings fabric and services. The document also forms an excellent and clear check for building control allowing for easier identification of differences between what was designed and what was built.
It was also proposed that photographic evidence should be provided of the dwelling during construction showing insulation installed and thermal bridging junctions across the building to be provided to the end user upon completion of the dwelling.
Whilst The FES Group understand a desire for such photographs, at this time we do not believe the idea has been sufficiently considered for implementation into the 2020 regulations. A number a significant questions need to be answered and further clarification of what photos will be needed and who can take these photos. We do however believe that this discussion could be completed in time for implementation in 2025 and as a result welcome further consideration of this in the future.
The FES Group also support the proposal to include the version of part L that the EPC was assessed against. This is to provide clear information to homeowners on the performance of their dwellings and how they compare. We also suggest that an indication of compliance pass or fail should be shown for On Construction lodgements.
Finally, the consultation proposes a change to the transitional arrangements to restrict the length of time a dwelling can be built to previous editions of the regulations.
While The FES Group welcome this change and agree that we should not be building dwellings now to regulations set in 2005 or even before, this change needs to be clear to prevent issues on existing developments.
We do not believe new transitional arrangements should be applied to developments registered to Part L 2013 or earlier as this would create a number of issues in the industry. Such a change to the goal posts needs to be clearly stated as being from Part L 2020 onwards, otherwise it could be unreasonable.
The FES Group believe that 9-12 months is adequate time to plan, assess, design and cost a development on a plot by plot basis to allow for a change in regulations where development time spans between editions of the regulations. As a result dwellings built within 1 year of the 2020 regulation ending will need to be upgraded to the latest edition of Part L.
We also believe that by the introduction of the Future Homes Standard in 2025, this 1 year transitional arrangement can apply to Part L 2013 and before. Giving these developments 5/6 years to prepare for such as change is reasonable.
We eagerly await the Government’s response to the consultation and welcome the publication of the Approved Documents L & F 2020 in spring alongside the introduction of SAP10.2
Take the first steps towards the Future Homes Standard with The FES Group
The FES Group are working hard to minimise the potential disruption and cost implications of these proposed changes on behalf of our clients and we will continue to provide analysis on this important consultation over the coming months.
For any immediate questions and advice, you can contact our technical team.