In 2025, the final uplift of the Future Homes and Buildings Standards will come into force, setting new requirements for energy efficiency and heating for both new homes and non-domestic buildings.
The UK government has said these standards will align with efforts to meet net zero by 2050, help lower energy bills for consumers and improve air quality. However, the government’s proposed changes to Part L and F of the Building Regulations, which inform the standards, lack ambition.
Our response echoes our previous calls for a stronger and bolder approach on metrics, fabric, post occupancy evaluation (POE) and embodied carbon regulation and was informed by in-depth feedback from RIBA expert members working in small and large practices across the country.
Making measurement count
The best way to cut bills and carbon emissions is to reduce energy use – to do this, we must improve the energy efficiency of our buildings. The first step is making sure we are using the most appropriate metrics. Our response, echoing previous RIBA calls, urges the government to use operational energy as the principal metric for measuring energy efficiency, and stop using primary energy.
Operational energy, which is measured in energy use intensity (EUI), is already well evidenced in standards such as Passivhaus. Its use would also align with the UK Net Zero Carbon Buildings Standard – a major cross-industry initiative, which will bring together net zero carbon requirements for all major building types.
Raising fabric standards
RIBA has long advocated for fabric efficiency, building form and envelope being primary considerations when designing a building. We believe no home built under the Future Homes Standard should add to the retrofit burden because of poor fabric efficiency.
The marginal cost of improving fabric efficiency is low, whereas retrofitting fabric efficiency measures is more expensive than raising fabric standards at the point of construction. It is disappointing to see that the government’s proposed fabric standards go no further than the existing minimum building fabric set out in the 2021 uplift to Part L.
Our response explains why we should not rely on low carbon heating technology alone to decarbonise the built environment. Improving fabric efficiency must be the priority, as part of a patchwork of solutions.
Closing the performance gap
As a sector, we have a poor understanding of the true performance of our homes and buildings, and how they impact users and the environment. RIBA has been making the case for the wider adoption of POE to help to tackle this. POE offers a process for obtaining feedback on a building’s performance in use after it has been built and occupied – giving an insight into how buildings are performing compared to their design intention.
Positively, the consultation acknowledged the need for measurement of the real-world performance of new homes. However, government proposals for voluntary post-occupancy performance testing do not go as far as is needed. We’re calling on the government to accelerate the adoption of POE, making it mandatory for new homes.
A missed opportunity on embodied carbon
Disappointingly, embodied carbon was considered out of scope for this consultation - a missed opportunity. With operational energy use making up only a portion of the carbon emitted across a building's entire lifecycle, failing to get a grip on the vast amounts of carbon embodied in the material used to produce, operate, and maintain buildings will hold us back from our net zero ambitions. Overlooking embodied carbon regulation now would be a costly mistake for our future.
In 2022, the government set out that it would consult on the approach and interventions to mainstream the measurement and reduction of embodied carbon in the built environment - but we are still waiting. We continue to ask the government to bring this promised consultation forward as soon as possible.
What next?
The government will now consider the responses to the Future Homes and Buildings Standard. In the meantime, we continue to reiterate our key positions to Ministers, MPs and civil servants, urging them to measure operational energy, publish the promised consultation on embodied carbon and advocate for the adoption of mandatory POE in new homes. If our homes and buildings are to stand the test of time, we must act now.
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