Building regulations need to go further and faster
CSE and TCPA’s joint response to the Government’s consultation on The Future Homes Standard
7 February 2020
CSE and the Town and Country Planning Association (TCPA) have today submitted a joint response to the Government's consultation on The Future Homes Standard, which covers changes to Part L and Part F of the Building Regulations for new dwellings.
We would like to encourage all Local Authorities and interested stakeholders who have yet to submit a response to this consultation to do so today.
The consultation, found here, will be open until 11.45pm on 7 February.
Our joint response challenges the Government’s proposed gradualist approach to setting building standards on energy efficiency. The consultation falls well short of creating the fundamental changes now needed to address the challenge presented by the climate crisis, and to make up for time lost by the Government’s decision to cancel the Code for Sustainable Homes in 2015.
Building Regulations should act as a policy floor, not a ceiling
In particular, both the TCPA and CSE are extremely concerned about the proposals being tabled which would remove the power of local planning authorities to set standards above basic building regulations.
We are aware of 32 authorities with adopted zero carbon policies and at least 16 more in the process of developing zero carbon planning policies. Many of these local authorities have demonstrated that it is already economically and technically viable for developers to achieve larger carbon savings than those being proposed in this consultation for 2020.
We therefore consider that removing powers from local planning authorities to set higher standards, represents a retrograde step and will seriously inhibit the UK’s ability to meet climate change targets. With fast moving innovation in energy and construction technologies and much greater ambition by local communities to take action on climate change, it is essential that local authorities retain flexibility to set local policy standards. It is also worth noting the majority of planning policy innovation on renewable energy systems and building standards has been set by local government.
Shifting the focus to operational performance?
Although we appreciate the inclusion of suggested measures to improve as-built performance through Building Regulations, we consider that the proposals do not go far enough.
Many studies have shown that there can be a significant difference between modelled and operational performance and, if homes are to have a lower impact on the environment and be affordable to heat, then it is essential that this gap be properly addressed.
We would strongly encourage the government to consider alternative approaches to promote high standards in operational performance.
Maintaining fabric performance
Finally, we are concerned by the suggested removal of the Fabric Energy Efficiency Standard (FEES). In our view, good fabric performance is a necessity and should always be the very first step in reducing carbon emissions.
More energy efficient dwellings place a lower burden on energy supply, are less likely to require extensive retrofit to meet higher standards in the future, and are more effective than the alternative technology-based options at keeping down consumer energy bills in the long term.
It is therefore very worrying that modelling carried out by the London Energy Transformation Initiative (LETI) suggests that under the new regulations it would be possible to construct a new home that is less well insulated in 2020 than under Building Regulations 2013. The knock-on effect would be a likely increase in fuel poverty as people are left heating their homes with expensive direct electrical heating.
Rachel Coxcoon, Director of CSE’s Climate Emergency Programme, says that “the consultation appears to serve only to protect volume housebuilders from the hassle of having to adapt their standard plans and instead build the kinds of houses local authorities want them to deliver to tackle the climate emergency and provide comfortable, liveable homes that are affordable to run.
By scrapping the Code for Sustainable Homes in 2015, government took the pressure off the housebuilding industry at a time when it had already largely adapted to the scheme. This consultation purports to move the situation back onto the right track, but all the evidence shows it is far too little, too late.
Local Authorities are already leading the way on this agenda; removing their ability to set locally ambitious targets for better housing undermines local democracy, community wellbeing and the fight against climate change”.