Part L of the Building Regulations, which covers energy performance in buildings, is currently out for consultation before coming into law later this year. After reviewing the consultation documents, we believe they do not go far enough, or fast enough to meet the climate emergency facing us.
The original method of calculating emissions for Part L compliance was never intended as a tool to reach zero carbon; in fact, it was designed to allow comparison between dwellings in disparate parts of the UK, papering over potential differences in weather or operation. It is concerning that there has been no update to the calculation methodology – as we have shown, greenhouse gas emission factors vary over the course of even one day in response to the grid supply and demand.
The removal of the Fabric Energy Efficiency Standard (FEES) is likely to actually result in more carbon emissions from our future buildings, not less. If anything, the notional fabric U-values should be improved, along with air tightness. With the removal of FEES, homes could be built with less insulation than required by the current regulations. This represents a step backwards.
The carbon reduction target set out in the proposals do not move us close enough to net zero carbon, and the proposed regulations would remove the power from local authorities to set more ambitious targets.
The consultation closes on 7 February 2020. This is our moment, for each of us to add our voice and comment on these proposals. The changes to Part L will materially affect the framework in which all residential buildings in England and Wales will be assessed in the coming years, and have a lasting impact on the UK’s ability to reach net zero carbon.
During the last consultation in 2013, there were only a few hundred responses. Because 85 of the industry responses used the same text, the review panel counted them as just one response. We must each speak individually this time, so use our thoughts above, or the guidance provided by the London Energy Transformation Initiative, but please enter the text yourself, in your own words.
We at Atelier Ten will be submitting a response as a company, and many of our employees have already submitted individual responses. Join us, send in your thoughts on the consultation, highlighting your concerns with the new proposals. Only if enough of us speak up will we be able to make our voice heard and effect some real, meaningful change.