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Response to the Future Homes Standard consultation

A row of newly built houses. They are reflected in a lake in the foreground.
28 March 2024

The FHS is a plan to upgrade how new homes are built, making them emit less carbon. They’re the standards which are supposed to take us to net zero emissions.

Yesterday, we responded to the Future Homes Standard (FHS) and Home Energy Model (HEM) consultations  suggesting crucial changes for reducing emissions and combating climate change.

The FHS is a plan to upgrade how new homes are built, making them emit less carbon. They’re the standards which are supposed to take us to net zero emissions.

Here are some notable positives:

These changes might seem technical, but they represent essential steps towards a more sustainable future for our homes and our planet. But..

Within the Future Home Standard, the government has selected the lowest energy efficiency standard of the available options and rooftop solar panels will not be mandatory in new homes.

Translation? Until electricity from the grid is fully decarbonised, new buildings will keep adding to climate change. It’s as if we have all the time in the world, where-as the science shows we’re in desperate trouble, with reputable climate scientists describing recent climate records as “gobsmackingly bananas”.

There’s a couple of further follow on implications which aren’t that obvious.  

Cleaning up grid electricity

Firstly, the UK decarbonisation strategy hinges on electrifying everything (heating and transport). Together with replacing our ageing fleet of fossil fuel power stations, our demand for electricity is likely to quadruple by 2050, all of which needs to come from emission free sources.

Setting lower energy efficiency standards means that we’ll have to generate more renewable energy, and not requiring rooftop solar panel on new builds means more dependence on solar farms and onshore wind, which the government doesn’t seem that keen on either!  

At CSE, we work with citizens and community groups day in, day out, and in almost every conversation people ask why all new homes don’t have solar panels?   They’re cheap and getting cheaper, they save occupiers money and it’s more expensive to fit them separately later. It’s an obvious no brainer.

It all makes the decarbonisation of grid electricity harder, and that’s what’s needed to make the homes built to the new standard zero carbon.

Balancing renewable electricity supply with electricity demand

Secondly, just as crucial as making sure we have enough renewable energy capacity overall is making sure it’s available when and where we need it most to meet our needs effectively. The wind doesn’t blow and the sun doesn’t shine all the time.. meanwhile our energy demands fluctuate wildly, and supply and demand need to match exactly to avoid the lights going out.  

This is what leads to justly unpopular outcomes of paying wind farm owners to turn turbines off when there’s too much renewable energy (cost expected to rise to £2-4 billion per year around 2030) and paying for dirty fossil fuel generation to come on stream, when there’s not enough.

A true Future Homes Standard would help with this problem. Very well insulated homes which retain their heat will have lower peak demands.  With very energy efficient homes, it would be possible to turn their heating off or up for an hour or two (when electricity is most expensive) without residents getting cold. If you could do that with a million air source heat pumps (a little over 3 years’ worth of proposed housing growth), you’d have 6Gw of energy flexibility on tap.

So, its galling that the consultation doesn’t make this link, and to see just a few days ago, the government announce the likely construction of a whopping 22 – 28 GW of new gas power stations, that bill payers will be paying to keep on standby to keep the lights on.  

Setting aside the hole they drive through our carbon reduction commitments, what’s the likely cost of that on people’s bills?  Could the need for further gas generation be lessened by designing new homes to optimal standards.

Reinforcing the grid

Finally, in parallel with this consultation, there’s a huge need to reinforce the transmission and distribution grids, which will be costly (£60bn investment needed by 2030), controversial and slow, but necessary to de-carbonise grid electricity. 

If new homes are built to limit their energy demand, and to generate energy on site, we can reduce the need to transmit electricity around the country.

The consideration of costs also seems pretty selective too, considering the capital costs to developers, but not the ongoing energy costs for occupants, the energy system costs the standards would give rise to, or the potential to avoid higher system costs through higher standards.

It’s all the more galling that parts of the building industry (LETI and the UK Green Building Council) have already developed standards which capture these insights, and the leading planning authorities have adopted planning policies based on them, only for other authorities to be expressly discouraged from using them!

So along with many other commentators, CSE would push government to:

  1. bank the good bits of the proposed changes, and consult on more advanced standards, building on what LETI and UKGBC have already done and
  2. for the bits of government thinking about how to decarbonise grid electricity, balance and reinforce the grid, to consider how the standards we set for new buildings might help.

Read our full consultation response

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