In December the Department for Levelling Up, Housing and Communities (DLUHC) published the outcome of the Future Buildings Standard consultation – the second stage of the two-part review on changes to the Building Regulations to help decarbonise our building stock. It followed the Future Homes Standard, which was consulted on in 2020.
What is the Future Buildings Standard?
The Future Buildings Standard is a policy document that sets out proposed changes to Part L (conservation of fuel and power) and Part F (ventilation) of the Building Regulations and introduces a new requirement to tackle the risk of overheating in new residential buildings. It focuses primarily on new non-domestic buildings, but also includes policy relating to existing non-domestic buildings and new and existing homes.
During the initial consultation period in April 2021, alongside providing our own response, we led a coalition of 20 built environment and climate action organisations and wrote to Jeremy Pocklington, Permanent Secretary at DLUHC, outlining significant concerns.
Both recent Future Homes Standard and Future Buildings Standard consultations have shaped the forthcoming 2021 ‘uplift’ to Parts L and F of the Building Regulations for both domestic and non-domestic buildings – but the full standards will be further consulted upon in 2023 and implemented in 2025.
What does the Future Buildings Standard require?
From 2021 new non-domestic buildings will be required to produce 27% less CO2 emissions when compared to current buildings – a positive start on our road to decarbonisation.
It also progresses plans for new performance metrics by setting a new primary energy target, CO2 emissions target and minimum standards for fabric and fixed building services.
But while we welcome the CO2 emissions target, and minimum standards for fabric and fixed building services, we (and 80% of those who responded to the relevant question in the consultation) do not believe that primary energy should be the principal performance metric. Instead, we call on the government to start regulating the amount of energy used by a building by measuring and setting operational energy targets.
Reassuringly, the government has “not yet determined the performance metrics for the Future Buildings Standard” and commits to “consider the ongoing suitability of these metrics” going forward; we will continue to engage with DLUHC and promote operational energy.
The Future Buildings Standard also introduces a new Approved Document – Part O – which aims to tackle overheating in new homes. While welcome, it’s important to remember this will only apply to new dwellings and seems to overlook the very same problems experienced by those living in existing homes or conversions. However, it’s good to see the government commit to undertaking further research into this area.
The standard also sets out the 2021 ‘uplift’ to the fabric energy efficiency standard for new homes. While some u-values could be more ambitious, overall, this is a positive move towards a fabric first approach. The 2021 uplift will come into effect on 15 June 2022 – which gives us six months to prepare. However, ‘transitional arrangements’ of 12 months will also apply.
One of our key asks back in April last year was to introduce and regulate embodied carbon targets and better assess building performance to close the performance gap. Unfortunately, these were not included in the consultation outcome.
It did however reveal that alongside their work on the Future Buildings and Future Homes Standards, DLUHC and the Department for Business, Energy and Industrial Strategy (BEIS) are developing a ‘Statement of Intent’ that will consider what more needs to be done by the government and industry to deliver net zero buildings by 2050. The statement promises to address both embodied carbon and the performance gap.
What happens next?
This year will be an important year for influencing the government on the technical development of the Future Homes and Buildings Standards proposals. And that’s what we will do, by highlighting our key policy positions: the importance of measuring actual energy performance through operational energy targets, setting embodied carbon targets and closing the performance gap through better predictive energy modelling, verification and comparison in use including post-occupancy evaluation.
Read more about the RIBA's climate action work.