Part L suggestion

> **NOTES** > Our proposed Yes/No answers for each question are highlighted orange. Where supporting text is required, you can click the orange boxes to cycle through preset texts. > > Please use the answers below to populate and submit the official Part L 2020 consultation [online response form](https://www.surveymonkey.co.uk/r/TQW8GQ9). > > **Please reword responses slightly if you have time**—your response will have more impact—duplicates responses are considered for qualitative analyses but are removed for quantitative analysis. > Blue boxes give more information and context where useful. ## Chapter 2 The Future Homes Standard ### Q1 Do you agree with our expectation that a home built to the Future Homes Standard should produce 75-80% less CO2 emissions than one built to current requirements? 1. Yes 1. No – 75-80% is too high a reduction in CO2 1. *No – 75-80% is too low a reduction in CO2* ###### rand-q1 ### Q2 We think heat pumps and heat networks should typically be used to deliver the low carbon heating requirement of the Future Homes Standard. What are your views on this and in what circumstances should other low carbon technologies, such as direct electric heating, be used? > (feel free to leave blank) ### Q3 Do you agree that the fabric package for Option 1 (Future Homes Fabric) set out in Chapter 3 and Table 4 of the impact assessment provides a reasonable basis for the fabric performance of the Future Homes Standard? 1. Yes 1. No – the fabric standard is too demanding 1. *No – the fabric standard is not demanding enough* ###### rand-q3 ### Q4 When, if at all, should the government commence the amendment to the Planning and Energy Act 2008 to restrict local planning authorities from setting higher energy efficiency standard for dwellings? 1. In 2020 alongside the introduction of any option to uplift the energy efficiency standards of Part L 1. In 2020 but only in the event of the introduction of a 31% uplift (option 2) to the energy efficiency standards of Part L 1. In 2025 alongside the introduction of the Future Homes Standard 1. *The government should not commence the amendment to the Planning and Energy Act* ### Q5 Do you agree with the proposed timings presented in Figure 2.1 (displayed in Chapter 2) showing the Roadmap to the Future Homes Standard? 1. Yes 1. No – the timings are too ambitious 1. *No – the timings are not ambitious enough* ## Chapter 3 Part L Standards for New Homes in 2020 ### Q6 What level of uplift to the energy efficiency standards in the Building Regulations should be introduced in 2020? 1. No change 1. Option 1 – 20% CO2 reduction 1. Option 2 – 31% CO2 reduction (the government’s preferred option) 1. *Other* Please explain your reasoning. ###### rand-q6 ### Q7 Do you agree with using primary energy as the principal performance metric? 1. Yes – primary energy should be the principal performance metric 1. No – CO2 should remain the principal performance metric 1. *No – another measure should be the principal performance metric Metrics such as Energy Use Intensity (EUI) in KWh/m2/yr should be used, that can be confirmed in-use by metered data.* ###### rand-q7 ### Q8 Do you agree with using CO2 as the secondary performance metric? 1. Yes 1. *No* ### Q9 Do you agree with the proposal to set a minimum target to ensure that homes are affordable to run? 1. *Yes* 1. No ### Q10 Should the minimum target used to ensure that homes are affordable to run be a minimum Energy Efficiency Rating? 1. Yes 1. *No* ###### rand-q10 ### Q11 Do you agree with the minimum fabric standards proposed in table 3.1? 1. Yes 1. *No – should be more insulating* 1. No – should be less insulating ### Q12 Do you think that the minimum fabric standards should be set in the Building Regulations or in the Approved Document (as is the current case)? 1. In the Building Regulations 1. *In the Approved Document* ### Q13 In the context of the proposed move to a primary energy metric and improved minimum fabric standards, do you agree with the proposal to remove the fabric energy efficiency target? 1. Yes 1. *No* ### Q14 Do you agree that the limiting U-value for roof-lights should be based on a roof-light in a horizontal position? 1. *Yes* 1. No ### Q15 Do you agree that we should adopt the latest version of BR 443? 1. *Yes* 1. No ### Q16 Do you agree with the proposal of removing the fuel factors to aid the transition from high-carbon fossil fuels? 1. *Yes* 1. No ### Q17 Do you agree with the proposed changes to minimum building services efficiencies and controls set out in table 3.2? 1. Yes 1. No – proposed standard goes too far 1. *No – proposed standard does not go far enough* ### Q18 Do you agree with the proposal that heating systems in new dwellings should be designed to operate with a flow temperature of 55°C? 1. Yes 1. No – the temperature should be below 55°C 1. No – dwellings should not be designed to operate with a low flow temperature 1. *No – I disagree for another reason* ### Q19 How should we encourage new dwellings to be designed to operate with a flow temperature of 55°C? 1. *By setting a minimum standard* 1. Through the target primary energy and target emission rate (i.e. through the notional building) 1. Other ### Q20 Do you agree with the proposals to simplify the requirements in the Building Regulations for the consideration of high-efficiency alternative systems? 1. *Yes* 1. No ### Q21 Do you agree with the proposal to adopt the latest Standard Assessment Procedure, SAP 10? 1. Yes 1. *No* ###### rand-q21 ### Q22 Do you agree with the proposal to update the source of fuel prices to BEIS Domestic energy price indices for SAP 10.2? 1. *Yes* 1. No ### Q23 Do you agree with the method in Briefing Note – Derivation and use of Primary Energy factors in SAP for calculating primary energy and CO2 emissions factors? 1. Yes 1. *No* ### Q24 Do you agree with the removal of government Approved Construction Details from Approved Document L? 1. Yes 1. *No* ### Q25 Do you agree with the proposal to introduce the technology factors for heat networks, as presented in the draft Approved Document? 1. Yes 1. *No, they give too much of an advantage to heat networks* 1. No, they do not give enough of advantage to heat networks 1. No, I disagree for another reason ###### rand-q25 ### Q26 Do you agree with the removal of the supplementary guidance from Approved Document L, as outlined in paragraph 3.59 of the consultation document? 1. Yes 1. *No* ### Q27 Do you agree with the external references used in the draft Approved Document L, Appendix C and Appendix D? 1. *Yes* 1. No ### Q28 Do you agree with incorporating the Compliance Guides into the Approved Documents? 1. Yes 1. *No* ### Q29 Do you agree that we have adequately covered matters which are currently in the Domestic Building Services Compliance Guide in the new draft Approved Document L for new dwellings? 1. Yes 1. *No* ### Q30 Do you agree that we have adequately covered matters which are currently in the Domestic Ventilation Compliance Guide in the new draft Approved Document F for new dwellings? 1. Yes 1. *No* ### Q31 Do you agree with the proposals for restructuring the Approved Document guidance? 1. Yes 1. *No* ### Q32 Do you agree with our proposed approach to mandating self-regulating devices in new dwellings? 1. Yes 1. *No* ### Q33 Are there circumstances in which installing self-regulating devices in new dwellings would not be technically or economically feasible? 1. *Yes* 1. No ### Q34 Do you agree with proposed guidance on providing information about building automation and control systems for new dwellings? 1. *Yes* 1. No ## Chapter 4 Part F Changes > LEAVE BLANK ## Chapter 5 Airtightness > LEAVE BLANK ## Chapter 6 Compliance, Performance and Providing Information ### Q57 Do you agree with the introduction of guidance for Build Quality in the Approved Document becoming part of the reasonable provision for compliance with the minimum standards of Part L? 1. *Yes* 1. No ### Q58 Do you have any comments on the Build Quality guidance in Annex C? ###### rand-q58 ### Q59 Do you agree with the introduction of the standardised compliance report, the Building Regulations England Part L (BREL) report, as presented in Annex D? 1. *Yes* 1. No there is no need for a standardised compliance report 1. No – I agree there should be a standardised compliance report but do not agree with the draft in Annex D ### Q60 Do you agree with the introduction of photographic evidence as a requirement for producing the as-built energy assessment for new dwellings? 1. *Yes* 1. No ### Q61 Do you agree with the proposal to require the signed standardised compliance report (BREL) and the supporting photographic evidence to be provided to Building Control? 1. *Yes* 1. No ### Q62 Do you agree with the proposal to provide homeowner with the signed standardised compliance report (BREL) and photographic evidence? 1. *Yes* 1. No ### Q63 Do you agree with the proposal to specify the version of Part L that the home is built to on the EPC? 1. *Yes* 1. No ### Q64 Do you agree Approved Document L should provide a set format for a home user guide in order to inform homeowners how to efficiently operate their dwelling? 1. *Yes* 1. No ## Chapter 7 Transitional Arrangements ### Q65 Do you agree that the transitional arrangements for the energy efficiency changes in 2020 should not apply to individual buildings where work has not started within a reasonable period – resulting in those buildings having to be built to the new energy efficiency standard? 1. *Yes – where building work has commenced on an individual building within a reasonable period, the transitional arrangements should apply to that building, but not to the buildings on which building work has not commenced* 2. No – the transitional arrangements should continue to apply to all building work on a development, irrespective of whether or not building work has commenced on individual buildings If yes, please suggest a suitable length of time for the reasonable period in which building work should have started If no, please explain your reasoning and provide evidence to support this. ### Q66 Do you foresee any issues that may arise from the proposed 2020 transitional arrangements outlined in this consultation? 1. Yes 2. *No* ### Q67 What is your view on the possible transitional arrangements regarding changes to be made in 2025? ###### rand-q67 ## Chapter 8 Feedback on the Impact Assessment > LEAVE BLANK --- ## THANK YOU—All done! > **Please reword responses slightly if you have time**—your response will have more impact—duplicates responses are considered for qualitative analyses but are removed for quantitative analysis.

Question,Answer,Reasoning 1,c,It is important that the Future Homes Standard is based on operational performance. Ie this could be metered kWh/m²/yr targets 1,c,"The metrics need to change in order to achieve the carbon savings that we need to meet our climate change targets. We should stop talking in terms of percentage reductions as these introduce avoidable complexity and do not clearly indicate performance relative to net zero carbon and compliance needs to be based on how a building performs in use. The Future Homes Standard must be based on the energy a building consumes in operation measured at the meter rather than a percentage reduction over a notional building model). " 1,c,"The Future Homes Standard compliance must be based on operational performance based on (metered) kWh/m²/yr targets (e.g. domestic display energy certificate(DEC)). Percentage reductions are confusing, 100% reduction does not mean zero carbon." 1,c,"The only way to improve the energy performance of new residential buildings to to base compliance on metered energy usage once the building is complete." 1,c,"Carbon is important, but it hides and confuses how the building is performing, it is therefore important that the Future Homes Standard is based on 'Energy' and it must be based on how the building performs in use, rather than an energy model." 1,c,"No- We need to move away from the carbon metric, and a percentage reduction from a notional building, this only confuses things." 1,c,"Even if building achieve 100% carbon emission reductions - this does not mean that they will zero carbon, and may still need retrofit. The method needs to change. The future homes standard needs to be based on energy use, measured at the meter. As a first step, the 2020 regulations must mandate public energy use disclosure." 1,c,"In 2025 (Future Homes Standard) compliance should be based on operational performance based on (metered) kWh/m²/yr targets (e.g. domestic display energy certificate(DEC)). As a stepping stone, we propose that in 2020 the energy consumption of all new homes should be disclosed (in a format that supports data protection) to understand energy consumption as a driver for improving operational performance. 75-80% carbon emission reductions based on an NCM model are meaningless." 1,c,"The current method is flawed and needed to change. It is important that new buildings are built to impose a minimal load on the national grid and thereby help the UK to achieve net zero carbon emissions. We must stop talking in terms of percentage reductions as these introduce avoidable complexity and do not clearly indicate performance relative to net zero carbon. Compliance needs to be based on how a building performs in operation." 3,c,"A well-insulated building fabric is not promoted due to the loss of the fabric energy efficiency standard (FEES). Worryingly new homes could be less efficient in 2020 than under Building Regulations 2013. FEES should be kept and improved upon." 3,c,"FEES has been withdrawn from the Future Homes Standard 2020, this means that new homes could be less efficient in 2020 than under Building Regulations 2013. FEES must be re- introduced, and the standard improved." 3,c,"FEES must not be removed from the regulations, it must be kept in the regulations and improved upon. " 3,c,"The proposed 2020 Part L could result in new homes that are less insulated then current regulations. This is not acceptable. FEES must remain" 3,c,"Why had FEES been withdrawn? this is a step backwards, the proposed regulation does not protect building fabric" 3,c,"The more we can insulate our homes the less energy they will use for heating. FEES needs to be kept and improved upon" 3,c,"To meet zero carbon home will need a space heating demand of 15 kwh/m2 or less (measured in-use not based on the SAP model). The proposed regs do not meet this." 3,c,"We should not be designing and building homes that will need retrofitting in the future, this is a waste of time and money. A well-insulated and efficient building represents our greatest chance of meeting our climate commitments in new homes. The proposed regulations do not go far enough." 6,d,"50-60% is more representative of a target that is technically feasible and financially viable. Although it is important to note that an absolute energy consumption target is more useful than a percentage carbon target." 6,d,"These options do not go far enough on fabric efficiency. We should not be designing and building homes in 2020 that will need retrofitting with additional insulation in the future. A well-insulated building represents our greatest chance of meeting our climate commitments in new homes. The Future Homes Standard 2020 does not promote a well-insulated building fabric. Under the new regulations new homes could be less insulated in 2020 than under Building Regulations 2013. Fabric should always be the first step in reducing carbon emissions, with technology reducing the remaining emissions. The proposals of 20% and 31% reductions do not push fabric, comfort and well-being hard enough. Under Part L 2013 there is a Fabric Energy Efficiency Standard (FEES) metric which helps prevent homes being designed with a fabric worse than the ‘notional’ building. While the ‘notional’ fabric specification has been improved marginally in the Future Homes 2020 consultation, the FEES target has been scrapped. This means that homes can be designed using the ‘minimum’ building fabric u-values as long as the building passes the carbon and primary energy targets. Where an energy efficient heating system (such as an air source heat pump) is specified the building is able to pass these targets with a poor building fabric. This is a loophole that overrides the need to have a well-insulated fabric. Testing carried out using the consultation iSAP tool has demonstrated that the same terrace house that would have failed Part L 2013, due to poor fabric, would pass the carbon and primary energy targets under Part L 2020: #### A home can pass Option 1 with a 48% CO2 reduction (with a primary energy pass) using the following fabric standards and a heat pump (this would have failed Part L 2013 FEES): - Wall - 0.26 - Roof - 0.16 - Floor - 0.18 - Window/door - 1.6 - Air perm - 5 - Thermal bridging - Default - MVHR --- #### A home can pass Option 2 with a 41% CO2 reduction (with a primary energy pass) using the following fabric standards and a heat pump (this would have also failed Part L 2013 FEES): - Wall - 0.21 - Roof - 0.14 - Floor - 0.16 - Window/door - 1.4 - Air perm - 3 - Thermal bridging - Default - MVHR These results significantly exceed the 20% and 31% reductions proposed without any effort to improve fabric specification or use the notional fabric values. Not only does the loss of FEES allow the specification of poor fabric, but the introduction of updated carbon factors masks the problem further. The 31% carbon reduction target is not a sufficient step forward. We want to see homes expected to make at least a 50% reduction in carbon emissions, ideally 60%. The update in carbon factors is supported, however, the target carbon emission reductions should be re-aligned with this in mind. An identical home that had a 3% reduction in carbon emissions under 2013 regulations could now have a 75% reduction in carbon emissions under the 2020 regulations. The proposed option 1 - 20% reduction and option 2 – 31% reduction in the consultation does not take this into account. The London Plan already requires a 35% reduction in CO2 and a 10% reduction in CO2 through fabric alone. Both options are a significant step backwards from this. It is important to note that rather than a carbon emission reduction target we advocate an absolute energy consumption target. " 6,d,"This is far to low. The carbon emissions of the grid have fallen, this means if you just switch to a heat pump you can get 60-70% carbon emission reductions, with a poor fabric that will need to undergo retrofit in the next 30 years. We should not be building buidlings that need to be retrofited." 6,d,"The part L method is not fit for purpose and the % carbon emissions metrics is not relevant used in SAP bares no corolation to energy performance (and thus carbon emissions in-use). An absolute energy consumption target (based on in-use performace) is much more relevant than the proposed method. But if we are for the short term to stick to the current method 60% reductions would be a more reprasentatvive target." 6,d,"London has had a 35% carbon emission reduction target for years. The targets need to be at least 50%" 6,d,"Fabric should always be the first step in reducing carbon emissions, with technology reducing the remaining emissions. The proposals of 20% and 31% reductions do not push fabric, comfort and well-being hard enough. Under Part L 2013 there is a Fabric Energy Efficiency Standard (FEES) metric which helps prevent homes being designed with a fabric worse than the ‘notional’ building. While the ‘notional’ fabric specification has been improved marginally in the Future Homes 2020 consultation, the FEES target has been scrapped. This means that homes can be designed using the ‘minimum’ building fabric u-values as long as the building passes the carbon and primary energy targets." 6,d,"31% is not enough, and does not set the industry on the right trajectory. 55-65% is technically feasible and financially viable. It is important to note that the method needs to change- and be based on in-use energy performance- like a DEC." 7,c,"A metric based on the total energy use (regulated and unregulated) of the dwelling which can be verified by measurements by the dwelling’s energy meter(s) should be used. A good example is Energy Use Intensity (EUI) in KWh/m2/yr " 7,c,Carbon and primary energy are both not directly related to how a building performs. A metric based on the total energy use (regulated and unregulated) of the dwelling which can be verified using an energy meter such as Energy Use Intensity (EUI) in KWh/m2/yr should be used. 7,c,"Metrics such as Energy Use Intensity (EUI) in KWh/m2/yr should be used, that can be confirmed in-use by metered data." 7,c,"While we understand that there is an EU directive to use a primary energy metric, we believe that disclosure of performance metrics such as Energy Use Intensity (EUI) in KWh/m2/yr should be used in addition to better connect design with the actual building performance that consumers experience." 7,c,It is really important that regulation can be confirmed using in-use metered data. This means that the primary metric needed to change to an absolute energy metric - such as KWh/m2/yr" 7,c,"Carbon and primary energy both hide how the building is performing. The metric needs to be kwh/m2 that can be verified in use. It is important to note that SAP cannot be used to predict energy use." 7,c,"Using carbon and primary energy is confusing, especially when used in the form of a percentage reduction target. An Absolute energy use target must be used- such as KWh/m2/yr" 10,b,"An EPC rating is a very poor predictor of energy consumption and therefore energy bills. A significant adjustment factor would need to be included if this was used - to protect residents from unexpected high energy bills." 10,b,"It is not acceptable to assume that a home with a good EPC rating will have low energy bills." 10,b,"EPC bares little coloration to energy use, therefore it is very important that the SAP model is not used to predict energy bills" 10,b,"Not if the minimum Energy Efficiency Rating is based on SAP, as this is not a predictive energy consumption tool, and is not related to how much energy is used in the home once it has been built" 21,b,"There are mainly flaws in the SAP methodology which have not been addressed. These flaws currently prevent homes genuinely achieving net zero carbon and do not support the shift to operational energy measurement, verification and reduction. This includes: - The use of a notional building to determine a percentage reduction in carbon over a semi-fictional baseline building. - The use of a gas boiler as the system in the baseline/notional case - this over inflates the carbon reductions of a heat pump. If the aim is to move away from fossil fuels to a heat pump based system, then the baseline should also use a similar system to avoid the reductions appearing greater than in reality. - SAP does not take into account the efficiency nuances of systems such as mechanical ventilation with heat recovery (MVHR). The further an MVHR is placed from a building façade, the longer the ductwork becomes. This significantly reduces the efficiency of the MVHR. This is not taken into account in SAP. - SAP over rewards large areas of glazing on the south facades. While there is benefit to receiving free heat, this is counterproductive to reducing overheating in homes. The benefit of heat gain directly competes with the need to reduce glazing area to mitigate overheating." 21,b,"The SAP methodology is not fit for purpose anymore - zero carbon can not be achieved with SAP" 21,b,"There are so many problems with SAP, this method currently prevents homes genuinely achieving net zero carbon. Firstly the % improvement over notional is confusing. - and this doesn’t incentive designers for good form factor. It hugely underestimates heating demand, this means that is does not properly incentives a high performing fabric." 21,b,"SAP method is out of date and not aligned with meeting our climate change targets." 21,b,"SAP is not fit for purpose, it does not predict energy consumption. 100% carbon emission reductions does not mean zero carbon." 25,b,"Heat networks should not be regarded as a preferred option by default. Heat networks are often more expensive and have higher capital costs and distribution losses not present in communal or individual heating systems." 25,b,"Heat networks are a way of delivering low carbon heat, but should not be preferred by default." 25,b,"Hot water should not be generated using fossil fuels for new homes thus technology factors should not be used." 25,b,"The reason given in the consultation for introducing technology factors is to allow heat networks to decarbonise in the future by transitioning from gas CHP to electrical heat pumps. We do not object to the transition of heat network plant to low carbon solutions in the future. If this is the case then mechanisms must be put in place to ensure decarbonisation is achieved as intended and that loop holes are not provided for more fossil fuel plant, such as gas CHPs in the meantime." 58,,No 58,,No further comment 58,,Nothing to add 67,,Consultation should begin as early as possible on proposed 2025 regulations to allow for a smoother transition. This would allow sites to be built to new standards sooner as per the transitional arrangements. 67,,The earlier the consultation on 2025 regulation can start the better! 67,,Building that would come before the finalisation of 2025 regulation would strongly benefit from a knowdledge of the Future Homes aim then. 67,,"By 2030 all new homes will need to be zero carbon, this means that at the very latest compliance based on in-use energy performance needs to be brought in in 2025. In order for the industry to learn and build knowledge on how buildings need to designed and constructed to meet the required targets. Thus consultation should begin as early as possible, and pointers towards what the 2025 regulation will be, should be published as soon as possible." 67,,"The industry needs to have time to ready its self for the change that we need to make to meet zero carbon, therefore consultation should begin as early as possible on proposed 2025 regulations to allow for a smoother transition." 67,,"(leave blank)"