New green standard for all new build homes – cutting carbon emissions for generations to come

A new green standard for new build homes will bring an environmental revolution to home building – tackling climate change while keeping household bills low.

With homes, both new and existing accounting for 20% of emissions, government committed in the 2019 Spring Statement to introducing the Future Homes Standard (FHS) in 2025 as part of the journey to meet the 2050 target to bring all its greenhouse gas emissions to net zero by 2050.  This target was set in law on 27 June 2019 and one of the most ambitious targets in the world.

On 1 October, the Future Homes Standard was unveiled by Ministry of Housing, Communities & Local Government (MHCLG).  It will see polluting fossil fuel heating systems such as gas boilers banned from new homes by 2025 and replaced with the latest generation of clean technology.  Using new technologies such as air source heat pumps and the latest generation of solar panels, developers will need to ensure they are doing their bit to tackle the threat of climate change, start to address home buyer dissatisfaction regarding falling house quality standards and allow homeowners to save on their energy bills as developments in the fabric of buildings, such as wall insulation and heating, help drive down the cost of keeping homes warm.

On the back of this, MHCLG have launched consultation* for stronger building regulations that will pave the way for the Future Homes Standard. Views are being sought on how changes to building regulations can drive down the carbon footprint of homes built after 2025.  This includes changes to the ventilation and efficiency requirements as well as the role of councils in getting the best energy standards from developers.

To help the industry reach a position where it can deliver in 2025, there is a proposed meaningful and achievable uplift to energy efficiency standards in 2020. The intention is to make new homes more energy efficient and to future-proof them in readiness for low carbon heating systems.  It is expected that an average home built to the FHS will have 75- 80% less carbon emissions than one built to current energy efficiency requirements (Approved Document L 2013).

The Future Homes Standard: Changes to Part L and Part F of the Building Regulations for new dwellings

Energy efficiency requirements for new homes are set by Part L (Conservation of Fuel and Power) and Part 6 of the Building Regulations.  The introduction of an uplift to Part L standards in 2020 would not only improve the energy efficiency of new homes but would also mean that home builders, installers and supply chains will be working to higher specifications in readiness for the introduction for a further uplift in 2025 to meet the Future Homes Standard.

It includes proposals for revising the Approved Documents for Part L and F to make them easier to navigate and to support efforts to simplify Approved Documents more generally. This includes incorporation of the technical requirements of the ‘Compliance Guides for Parts L and F into the Approved Documents’ and restructuring the suite of guidance for the energy efficiency of dwellings into a single document (Approved Document L volume 1: dwellings).

This consultation is the first stage of a two-part consultation about proposed changes to building regulations.

The initial consultation addresses:

  • Options to uplift standards for Part L of the Building Regulations in 2020; and changes to Part F
    • More stringent transitional arrangements for these standards to encourage quicker implementation
    • Draft outline specification for future consultation about the Future Homes Standard
    • Clarifying the role of planning authorities in setting energy efficiency standards.

The consultation sets out two options to uplift energy efficiency standards and requirements:

  • Option 1: 20% reduction in carbon emissions compared to the current standard for an average home – to be delivered by very high fabric standards (typically with triple glazing and minimal heat loss from walls, ceilings and roofs).
  • Option 2: 31% reduction in carbon emissions compared to the current standard which could be delivered based on the installation of carbon-saving technology such as photovoltaic (solar) panels and better fabric standards.

Government favours the latter target as it would result in lower household bills and consequentially have a much shorter payback period. It also delivers more carbon savings meaning the jump towards zero fossil fuels in 2025 will be easier to navigate and would help to prepare supply chains for heat pumps and increase the number of trained installers.  This would provide an early boost to the LZC (low and zero carbon) sector which will need a helping hand if it is to have any hope of meeting demand by 2025.

Both uplift options increase the costs for home builders, therefore it is proposed to remove the ability of local planning authorities to set higher energy efficiency standards than those in the Building Regulations.

This has long been a bugbear of the sector as it creates a postcode lottery of differing energy standards.

The consultation also includes the first steps towards improving the ‘as built’ performance of new homes.

The Part L consultation proposes that housebuilders provide photographic evidence in a bid to get around the problem – it is very hard to check insulation levels and other energy-saving measures once these are covered up.

A summary of the important text of the consultation relating to Building Regulations is detailed below.

Future Home Standards – Summary of proposed changes of the Building Regulations

Part L – Proposed changes to Part L and Part 6 of the Building Regulations

These are set out in Chapter 3 and include:

  • Changing the whole building minimum energy performance target, which involves;
  • Introducing primary energy as the principal performance metric, and continuing to use a CO2 as a secondary metric
  • Removing the fabric energy efficiency metric
  • Incorporating the latest evidence on primary energy and CO2 emissions of fuels, and removing fuel factors in the calculation for high-carbon fossil fuels and electricity
  • Introducing a householder affordability standard for new dwellings, so that new homes are affordable to heat
  • Taking a significant interim step towards the Future Homes Standard through;
  • Uplifting the minimum standard of whole building energy performance improving the minimum insulation standard
  • improving the minimum efficiencies of fixed building services
  • Future-proofing new dwellings to be ready for low carbon heating systems;
  • Improving compliance with Part L in order to improve as-built performance
  • Aligning the Part L standards for new dwellings with the 2018 revisions to the Energy Performance of Buildings Directive, where relevant
  • Adopting the most recent version of the government’s Standard Assessment Procedure for Energy Rating of Dwellings Version 10 (SAP10.1)
  • Simplifying the structure and content of guidance relating to Part L


Part F – Proposed changes to Part F of the Building Regulations

These are set out in Chapter 4 and include:

  • Simplifying the approach for determining the ventilation rate and system design requirements for a dwelling
  • Reviewing the way that ventilation systems are presented in the Approved Document to reflect common design practices
  • Bringing guidance designed to reduce the ingress of external air pollutants into the main body of the Approved Document, and reviewing its technical content
  • Making technical changes to guidance for ventilation systems in line with the latest evidence and understanding
  • Simplifying the structure and content of guidance relating to Part F Airtightness


Airtightness – Proposed changes to the airtightness requirements of Part L of the Building Regulations

These are set out in Chapter 5, including:

  • Reviewing the approved airtightness testing scheme methodology
  • Considering whether developers should test all individual homes on a development, and removing the option of sample-testing
  • Limiting incentives in the Standard Assessment Procedure (SAP) which encourage very airtight naturally ventilated dwellings
  • Reflecting the uncertainty of air permeability test results in SAP
  • Exploring the potential for alternative testing methods or alternative approaches to demonstrating compliance with guidance on airtightness


Improving Compliance and Building Performance – Proposals for providing information

These are set out in Chapter 6, including:

  • Providing guidance to improve build quality and reduce the performance gap
  • Developing a new style Part L compliance report
  • Improving accuracy of as-built energy models by proposing photographic evidence for new dwellings
  • Educating building occupiers on how to operate low-carbon homes by proposing home user guides for new dwellings


Transitional Arrangements – Proposed changes

These are set out in Chapter 7, including:

  • Proposals to introduce new transitional arrangements to encourage building homes to the latest Part L standards
  • Possible transitional arrangements for the 2025 Future Homes Standard


The proposals in consultation includes the scrapping of the loophole called transitional arrangements, meaning housebuilders could build all the homes on a development site to the regulations in force when they started work on the first house regardless of how long this would take.  Someone buying a new house on a site that had been developed over many years could unwittingly end up with a much less energy-efficient home than one built at the same time on another site, exacerbating home buyer dissatisfaction further. Transitional arrangements have prevented carbon reduction ambitions of the latest versions of Part L being successful.

 Small and medium sized building companies are often working on smaller developments, so they can be affected sooner by changes. The proposed new transitional arrangements may therefore be fairer to small businesses.

 Work to existing dwellings

As set out in the governments Clean Growth Strategy, it is the intent to consult on standards when work is carried out in existing dwellings, with a view to uplifting the standards where there are cost-effective, safe and practical opportunities to do so. To reduce the risks associated with energy efficiency works to existing buildings, for example, the associated impacts on airtightness which reduce the overall amount of fresh air entering the home.  It is proposed to introduce new guidance for Part F (Ventilation) to provide clarity on the expected ventilation standard when retrofit work is carried out.

New and existing non-domestic buildings

Also set out in the Clean Growth Strategy are plans for revising standards for buildings other than dwellings with consultation on making improvements to Building Regulations requirements for new and existing non-domestic buildings, including opportunities to promote low carbon and higher energy efficiency heating, ventilation and air conditioning systems in new buildings.

Overheating in new dwellings

In 2018 the Environmental Audit Committee (EAC) held an inquiry into heatwaves and their impact on the UK. Within the final report, the EAC recommended that the government should create a new regulation to stop buildings being built which are prone to overheating.  The government responded to this recommendation by committing to consult on a method for reducing overheating risk in new homes.  The consultation will address this commitment and include proposals to reduce the risk.

[The consultation will run until 10 January 2020.  It relates to Building Regulations for England only and is primarily aimed at: Property developers and builders, Property owners and occupiers, Construction industry professionals, Manufacturers and suppliers of construction materials, Environmental organisations, Local authorities and other building control bodies.  Specific elements may be of interest to members of the public.]

The proposals in consultation includes the scrapping of the loophole called transitional arrangements, meaning housebuilders could build all the homes on a development site to the regulations in force when they started work on the first house regardless of how long this would take.