CIBSE (Chartered Institution of Building Services Engineers) SBE0090
Written evidence from CIBSE (Chartered Institution of Building Services Engineers)
The respondent is The Chartered Institution of Building Services Engineers (CIBSE), the professional body which exists to ‘support the Science, Art and Practice of building services engineering, by providing our members and the public with first class information’.
CIBSE members design, install, operate, maintain and refurbish the systems in buildings.
CIBSE has over 20,000 members, about 15,000 in the UK. We publish best practice advice and guidance that is internationally recognised as authoritative. The CIBSE Knowledge Portal makes it available online as the leading systematic engineering resource for the building services sector.
Reasons for submitting a response
CIBSE’s charitable objects, defined by its Royal Charter, is ‘The promotion for the benefit of the public in general of the art, science and practice” of building services engineering, and “the advancement of education and research” and “the publication of the useful results of such research” in building services engineering. As such, CIBSE has been very active in the fields of energy efficiency, carbon reduction, resource efficiency and climate adaptation for several decades.
In 2019 to increase our action in the face of the climate emergency, we published our first Climate Action Plan (https://www.cibse.org/news-and-policy/policy/technical-themes/net-zero ), which identifies areas where we have an opportunity and a responsibility to act, from guidance and training, input to government and local policy, through to codes of professional conducts and our own actions:
§1 - While updates to building regulations have been consulted upon, they fall significantly short of what is required to ensure significant reductions in energy use and associated carbon emissions in practice. We do not detail this here as the inquiry’s focus is embodied carbon, but our recommendations are detailed in our recent response to the Future Building Standard consultation: https://www.cibse.org/News-and-Policy/Policy/Consultations/Closed-Consultations/Future-Buildings-Standard-Building-Regulations-Pa and we have included a summary in Appendix A. We stress this must be addressed and we would be very happy to discuss our concerns and recommendations with the EAC.
§2 – A significant opportunity to reduce embodied and operational carbon is in our approach to existing buildings and retrofit: the performance of existing buildings must be improved, and existing buildings should be adapted and re-used wherever possible, rather than demolished and replaced.
§3 -There is little progress and no firm commitment nor timescale for regulations to be introduced on embodied carbon. In parallel, some policy activities may have gone counter to this. These should be revised.
§4 - However, the past few years have seen significant progress which could pave the way to regulating embodied carbon, including:
This progress is evidenced in the growing consensus of professional bodies (including CIBSE) and other organisations calling for regulation of embodied carbon, most recently in the joint letter to the Secretary of State in response to the Future Building Standard consultation: https://www.cibse.org/news-and-policy/april-2021/cibse-joins-coalition-in-letter-to-government-over .
§5 – Much of this inquiry focuses on materials to reduce embodied carbon. However, this is only a very limited part of the required approach: the impact of materials must be considered in the round, with upfront embodied carbon considered alongside whole-life embodied carbon (e.g. durability), operational carbon, and functional requirements. Resource efficiency (“lean design”) and waste reduction must also be considered. This means that overall embodied carbon assessments are a more suitable approach than blunt tools such as banning materials or preferring some over others.
RESPONSE TO QUESTIONS
Q1 - To what extent have the Climate Change Committee’s recommendations on decarbonising the structural fabric of new homes been met?
§6 - To very little extent, if any.
§7 - The CCC’s first recommendation on that matter, in their 2019 Housing Fit for the Future report, was: “Develop new policies to support a substantial increase in the use of wood in construction. This will need to focus on overcoming a range of cultural, skills and financial barriers in the construction sector. “
§8 - There are some initiatives in devolved administrations e.g. of note, the manifesto of the newly elected Welsh government: “Build in the right way using materials with low levels of embodied carbon, such as timber, and specifically Welsh timber, creating a timber based industrial strategy that can develop and sustain the high value production and processing of Welsh wood. This will take us further in tackling fuel poverty, create sustainable jobs and provide research and training opportunities”. However, we are not aware of any UK-wide policy addressing the CCC recommendation.
§9 - In addition, a significant new piece of legislation has been the ban on combustible materials in external walls.
§10 - In the wake of the Grenfell Tower tragedy, government committed to “ban combustible cladding” from high-rise residential buildings. In the event the legislation had to be framed to ban combustible materials, with certain legally specified exceptions, from the whole of the external wall of buildings in scope.
§11 - Initially this applied to some 12,000 existing buildings and we currently build about 600 new high-rise residential buildings each year. Government has since consulted on lowering the height of buildings covered by the ban and may reduce it to 11m, which would bring some 75,000 – 80,000 buildings in scope, and potentially a further 2,000 – 3,000 new buildings each year.
§12 - In parallel, the insurance and professional indemnity markets have hardened very considerably against the use of combustible materials, including timber, significantly restricting what the industry is insured to design or to build (whether or not it is in external walls).
§13 - All of this heightens the need for policies that will promote the use of timber more widely where it is reasonable and safe to do so, to contribute to the UK’s carbon reduction targets.
§14 - Ensuring safety is of course a priority, but does not conflict with sustainability objectives: a building that burns is not sustainable. CIBSE understand the difficulty of taking more refined approaches, for example clearly to define “cladding” in law, or to take account of levels of combustibility and of specific configurations (where the combustible material is located, what it is surrounded by etc). A more nuanced system would, for safety to be assured, rely on competence of the whole design and supply chain. The Building Safety Bill and other initiatives, such as the industry-led Construction Industry Council Climate Action Plan, aim to address the issue of competence, among others. As the new building safety regime is put in place and takes effect, with resulting improvements in competence and enforcement, then the approach to timber in buildings should be revised in order to allow its safe application in new and existing buildings.
§15 - The CCC’s second recommendation on that matter was: “Undertake low-regrets action to support the assessment and benchmarking of whole-life carbon in buildings with a view to informing the future policy framework. “
§16 - The only evidence of government action on this recommendation is a statement in the January 2021 MHCLG response to the Future Homes Standard consultation: “We will carry out wider work to consider the future of energy efficient and low carbon buildings. This will examine some of the broader and more fundamental questions (…) such as the role of (…) low carbon materials, including timber, in delivering low carbon construction where these can be used safely.” This is rather vague and non-committal. We are not aware of more specific actions taken or planned by government, nor of the possible legislative instruments being looked at to take these actions (e.g. planning framework, building regulations, product standards?).
§17 - This lack of action on embodied carbon has been raised by a significant number of organisations, including CIBSE, in the recent joint letter in response to the Future Building Standard consultation, April 2021: https://www.cibse.org/news-and-policy/april-2021/cibse-joins-coalition-in-letter-to-government-over.
§18 - We would also point out that to achieve significant improvements in “decarbonising the structural fabric of new homes”, we will need not only to use lower-carbon materials, but, crucially, to apply resource efficiency i.e. use less material through lean design and reduced waste production. A key element of this is building shape, which influences the amount of envelope and super- and sub-structure, often by far the most significant elements of upfront embodied carbon in new buildings. The current approach to Building Regulations Part L (which addresses operational carbon) does NOT encourage efficient building shapes, as each building is assessed for compliance by comparison with a building of the same shape. CIBSE have been recommending for some time that the approach based on a notional building should be reviewed, to drive improvements in absolute (not relative) performance, and encouraged to take building form into account. This could have both operational and embodied carbon benefits.
§19 - In addition, a number of measures go counter to the CCC recommendation; in particular, the missed opportunities to promote retrofit, retaining and improving existing buildings – see questions 4 and 10.
Q2 - How can materials be employed to reduce the carbon impact of new buildings, including efficient heating and cooling, and which materials are most effective at reducing embodied carbon?
§20 – Some materials, especially timber, clearly offer opportunities to reduce embodied and whole-life carbon, and their use must be encouraged – see question 1. With regards to materials employed in building services, CIBSE TM56, 2014 and TM65, 2021 offer some guidance but attention on this topic is relatively recent so further advice is likely to emerge in the next few years, as understanding and data availability increase – see also Question 5.
§21 - However, materials selection must be part of a broader approach to whole life carbon and functional requirements. Blanket approaches to promote or avoid the use of particular materials are too blunt and may not have the desired effects, because materials influence the whole life carbon impact and performance of buildings in a number of ways:
§22 - In addition, while some materials may have a lower embodied carbon (e.g. by weight or area of application), they may for the same application need to be used in different quantities (e.g. thicker insulation for the same U-value). A simple comparison between materials is therefore not necessarily relevant without considering their “functional unit”.
§23 - As simple illustrations in the case of building services:
§24- As per Question 1, we would also note that resource efficiency should come before materials selection: as well as reducing construction waste, this must include “lean” design to use less material, before selecting the material. In addition, lean design is an area where there are opportunities to benefit both embodied and operational carbon e.g. reducing demand and avoiding over-sizing can reduce upfront embodied carbon by reducing plant size, and it can also reduce operational carbon by reducing annual consumption and improving efficiency.
§25 - Altogether, this means that considering materials alone is insufficient. System design and the selection of materials and products have to take a number of factors into account, often with the best solution determined on a project-by-project basis, using an overall embodied and operational carbon approach.
Q3 - What role can nature-based materials can play in achieving the Government’s net zero ambition?
§26 – A key opportunity is timber – see questions 1 and 2, and estimates by the CCC of contributions from timber construction (hand in hand with forestry and land management) to the UK’s net zero target.
§27 – Another opportunity is the use of natural insulation materials: in addition to embodied carbon benefits, this could have benefits such as improved air quality (lower emissions of volatile organic compounds) and, particularly, in retrofit applications, moisture breathability and compatibility with heritage conservation approaches. We have received feedback that these applications could be helped by relatively simple measures, such as wider availability of options available in regulatory compliance calculations (i.e. SAP and associated software), where materials in the available database tend to be dominated by large manufacturers of, usually, non-nature-based materials.
§28 – It is really important to realise that, in both the case of timber and natural insulation, their widespread application would require the widespread development of skills and competence to avoid unintended consequences, since their properties, particularly in relation to moisture movement, are different from what is now “typical” design and construction practice.
Q4 - What role can the planning system, permitted development and building regulations play in delivering a sustainable built environment? How can these policies incentivise developers to use low carbon materials and sustainable design?
§29 - Both the planning system and building regulations are fundamental in delivering a sustainable built environment, including:
§30- The planning system and building regulations must work together:
§31 – Specific recommendations on the planning system:
§32 – Specific recommendations on building regulations: Joint letter to the Secretary of State (see §17), and response to the Future Buildings Standard consultation (see §29), and response to the Future Homes Consultation summarised in Appendix C and available in full here: https://www.cibse.org/News-and-Policy/Policy/Consultations/Closed-Consultations/Changes-to-Part-L-and-Part-F-of-the-Building-Regul .
§33 - The Architect Climate Action Network recently produced a report with a number of recommendations on ways which embodied carbon could be accounted for in the legislative framework: https://www.architectscan.org/embodiedcarbon .
Q5 - What methods account for embodied carbon in buildings and how can this be consistently applied across the sector?
§34 – Recent years have seen significant convergence in methodologies, and most derive from the same European and British standards. The main one referred to in industry guidance and planning policy (e.g. London Plan) is the RICS professional statement, which CIBSE broadly support except for 2 points:
§35 - CIBSE has provided guidance on resource efficiency and reducing embodied carbon from building services for a number of years:
§36 - Lessons should be gathered from early adopters, including those driven by the new requirements in the London Plan. This could help refine the methodologies and guidance. It could also lead to product standards (e.g. if detailed assessment found systematic opportunities in certain products) and to the development of rules of thumb which could be used at early project stages or on small projects where full embodied carbon assessments are too onerous.
§37 – There is already training available on methodologies such as the RICS one, and CIBSE are currently developing training on the use of TM65. It is possible that more formal routes will be developed by industry to improve consistency in embodied carbon assessments e.g. 3rd party verification, certified assessors etc. This is more likely to happen if government send strong signals that embodied carbon will become regulated in the future.
Q6 - Should the embodied carbon impact of alternative building materials take into account the carbon cost of manufacture and delivery to site, enabling customers to assess the relative impact of imported versus domestically sourced materials?
§38 – Yes, as per standard methodologies. All materials and products should be compared on a like-for-like basis, including manufacture and transport impacts, whether or not it is abroad.
§39 - This will help address a gap in the UK’s carbon targets, which currently exclude emissions abroad related to UK consumption (we acknowledge that government recently committed to include shipping and aviation in their Nationally Determined Contributions and 2035 carbon reduction target; this is a first step, but it does not include manufacture, often far more significant in carbon terms).
Q7 - How well is green infrastructure being incorporated into building design and developments to achieve climate resilience and other benefits?
§40 – This is not done often enough and is often reliant on the ambition of local planning policies. CIBSE have highlighted this on a number of occasions. For example, the consultation on the NPPF and National Model Design Codes (see §31) mostly refers to green infrastructure as “green space”, ignoring the multiple functions and benefits that green infrastructure can deliver, such as overheating risk mitigation and air quality.
Q8 - How should we take into account the use of materials to minimise carbon footprint, such as use of water harvesting from the roof, grey water circulation, porous surfaces for hardstanding, energy generation systems such as solar panels?
§41 – As a general rule, these systems should be included in the embodied carbon assessment. However, once the assessment is used in decision making then (as for all other design decisions), functionality has to be taken into account i.e. what is the overall embodied and operational carbon impact of these systems compared to others which deliver the same function. For example, when looking at on-site generation (e.g. PV panels), the question is whether, compared to other forms of generating electricity, they have a lower embodied and operational impact. The grid will decarbonise and therefore the relative operational carbon benefits of PVs may reduce in the future, but energy will still be needed to be produced by a system or another, with associated embodied as well as operational carbon expenditure, so on-site PVs may still offer benefits overall.
§42 – An important associated question is which carbon factors should be used in these assessments: it is relatively straightforward for upfront embodied carbon (since this has been spent already), but relies on projections and assumptions for whole life impacts. Guidance from government to bring consistency would be very useful on this issue.
Q9 - How should re-use and refurbishment of buildings be balanced with new developments?
§43 – A key instrument is planning, at which stage these decisions are made – see Questions 4 and 10. Broadly speaking, we recommend the following approach:
§44 – More generally, while we acknowledge the overall need for more housing, and for housing that is affordable, there is also a need to think strategically about housing alongside transport links and jobs. Some areas of the country see significantly lower demand for housing (indeed, some have large numbers of under-occupied or empty homes). The pandemic has increased opportunities for jobs to be spread around the country thanks to the wide adoption of working-from-home. Furthermore, a proper national retrofit programme commensurate with our net zero target, as advocated by CIBSE and the Construction Leadership Council (https://www.constructionleadershipcouncil.co.uk/news/national-retrofit-strategy-consultative-document/ ), among others, and supported by a major investment in skills and focus on quality of work would create huge opportunities for job creation throughout the country. These two factors alone illustrate opportunities for the creation of new or improved homes away from high-demand areas such as London and the south-east, in areas where this would not necessarily need to be new build…
Q10 - What can the Government do to incentivise more repair, maintenance and retrofit of existing buildings?
§45 – We provided detailed recommendations to this question in our recent submission to the EAC inquiry on energy efficiency of existing homes (https://www.cibse.org/News-and-Policy/Policy/Consultations/Closed-Consultations/Energy-Efficiency-of-Existing-Homes ). Key points are summarised here, but we very much encourage the EAC to consider our more detailed recommendations in that submission and would welcome the opportunity to discuss them with the EAC.
§46 - Our key recommendations to deliver retrofit at scale, at speed, with the intended benefits and without unintended detrimental consequences are:
- Adopt a clear and visible retrofit strategy that is fully coordinated between government departments and linked to the heat decarbonisation strategy. It must have long- and short-term objectives to give confidence to supply chains to invest in development of skills, competence, business models and products. There must be efforts to increase awareness among homeowners, raise confidence in supply chains and potential benefits to justify the disruption and capital investment.
- Review the regulatory framework to cover all relevant opportunity points for retrofit and all sections of the market, including building regulations, planning, MEES and ECO, the planning system and new requirements at point of sale. The review must consider how to address actual in-use performance.
- This regulatory framework must fit into the new regulatory regime being developed under the Building Safety Bill to make sure that healthy and comfortable internal conditions and energy and carbon reduction are seen as key safety and performance requirements in their own right.
- Monitor progress and be prepared to introduce incentives, requirements and additional support if regulations and market-driven demand do not deliver sufficient progress.
- Adopt a whole-house approach to avoid carbon lock-ins and detrimental consequences and achieve more ambitious energy and carbon reductions.
- Introduce digital building passports, with a clear route to net zero carbon and a record of the works carried out that transfers from owner to owner.
- Learn from past reviews and make better use of existing schemes such as the PAS 2030/35 framework and Trustmark; adopt data gathering, monitoring and sharing throughout, and gather lessons to allow continuous improvements.
- Put in place a strategy to develop supply chains skills and competence. This could start with requirements on public projects and could form an integral part of the post-pandemic recovery plans.
- Carry out a review of energy pricing and financial incentives, to align with carbon, environmental and health objectives.
END OF MAIN SECTION
This response has been produced by Dr Julie Godefroy, Technical Manager at CIBSE. Do not hesitate to contact us for further information.
APPENDICES – SUPPORTING INFORMATION
APPENDIX A – RECOMMENDATIONS ON FUTURE BUILDING STANDARD - (EXECUTIVE SUMMARY FROM CIBSE RESPONSE TO CONSULTATION, APRIL 2021)
We welcome a number of aspects in the Future Homes Standard (FHS) response and the Future Buildings Standard (FBS) consultation, which we had called for in our response to the 2019-20 FHS consultation and other policy positions:
However, there are a number of proposed measures which cause concern and may cause unintended consequences, and some measures which CIBSE considers necessary that are omitted. These concerns and omissions are set out below along with our recommendations for inclusion in the 2021 and 2025 revisions:
Key points to address
CIBSE recommendations for 2021 revision
CIBSE recommendations for 2025 revision (i.e. Future Buildings / Homes Standard, but also including existing buildings / homes)
1 - Target setting and like-for-like-comparisons, to drive real reductions in energy use and heat decarbonisation
For non-domestic buildings the 2021 uplift currently proposes to vary the heating fuel in the notional building e.g. district heating or gas if this is in the actual building. This provides artificial support factors for particular systems e.g. district heating networks would be allowed several times the emissions from heating than heat pumps, and significantly more than even from gas boilers: this is not enough incentive to heat decarbonisation now and to build supply chains.
Buildings and heat options must be evaluated on a like-for-like basis:
The approach based on a notional building may have been appropriate when regulations sought relative improvements, but all opportunities need to be captured towards the net zero carbon target and there must be a clear way to assess and track progress. The notional building prevents like-for-like comparisons and does not drive optimisation of building form and orientation.
New buildings of the same type should be compared to the same target level of performance, an absolute target.
In addition, the outline FBS should from now on set a clear end data for new fossil fuel installations, as the outline FHS does. This will give a clear direction and incentive for supply chains to develop.
2 – Metrics that support energy efficiency and heat decarbonisation
The consultation proposes a dual metric system, introducing primary energy alongside carbon. Both these metrics mean little to consumers, especially primary energy. They rely on conversion factors which change over time, which does not facilitate tracking of progress over time, comparing buildings, nor creating a closer link with actual performance.
In addition, the consultation states that the benefit of using primary energy would be to drive reductions in electricity demand. However, our analysis shows that this is a flawed argument, as the primary energy factors for electricity completely follow its carbon factors: primary energy as a metric does not add any value.
Finally, and importantly, primary energy favours gas and other fossil fuels over electricity and therefore goes against heat decarbonisation.
We understand primary energy was introduced because the EPBD uses it, but Brexit provides an opportunity not to.
Instead of primary energy, energy use as metric alongside carbon emissions and fabric performance would better address the key goals of energy efficiency, carbon reduction, and consumer engagement.
Retain energy use as a metric alongside carbon emissions, and fabric performance. Review the need to introduce a metric or criteria to address demand management (e.g. peak demand and proportion that can be shifted).
3 - A commitment to actual performance, starting with disclosure
Actual in-use performance beyond Practical Completion must be addressed, for example as part of the wider regulatory regime created in response to the Hackitt Review. As a very minimum, this should start with disclosure of actual energy use (broken down into fuels where applicable).
In addition to this, we recommend reviewing the possibility to introduce further in-use evaluation, monitoring and evaluation to match performance criteria in Building Regulations and the Approved Documents e.g. ventilation rates. We expect this should be possible within the existing framework of the Building Act (Section 2 – Continuing Requirements) and Building Regulations; however, we are aware that the clause on Continuing Requirements is difficult to interpret, and we also recommend that this lack of clarity needs addressing.
We have commented in detail on the proposed new overheating risk “simplified method”, including the request for more information on the rationale and testing carried out. Regardless of the final method implemented, as it is a new regulatory requirement and a new un-tested method, we strongly recommend that MHCLG should put together a programme of monitoring to test its implementation and gather lessons for the next revision. We would also recommend that Building Control reserve the right to request in-use monitoring of temperature and possibly feedback from occupants. However good the new method ends up being, there will be lessons to gather and incorporate, and this must be factored in right now.
The data collected from the 2021 disclosure requirement should inform the FHS and FBS and the setting of absolute rather than relative targets (see point 1).
The overheating methodology should be modified in line with lessons gathered from the first phase of implementation, including in-use monitoring and feedback.
In-use monitoring and evaluation requirements should be in place to match Building Regulations performance requirements.
4 – Commissioning
New buildings will not be net zero carbon buildings unless they are commissioned. There needs to be greater focus on compliance with the commissioning requirements. It must become accepted that building control will expect to see and may make some checks on commissioning evidence then we will not achieve net zero. This may imply some training requirements for building control professionals, and it may require some procedures to support the greater focus, but without action it is not possible to claim that the changes to the regulations will achieve the intended carbon impacts.
Commissioning should very clearly include performance testing, and this could for example be linked to a penalty in as-built Part L calculations unless satisfactory results are provided to Building Control. This would benefit both energy efficiency and, for ventilation systems, air quality.
Continue as per 2021, and incorporate any lessons learnt.
Look to introduce digital returns of key information throughout the build process to simplify the cost of existing requirements and reduce the impact of additional information requirements. Such a system should be centralised and accessible to the Building Safety Regulator, allowing them to see easily where projects are not producing required information and therefore to target their compliance and enforcement efforts on topics where compliance is low, or on those parties not delivering, which in turn incentivises better compliance.
5 - Airtightness and ventilation
For dwellings, the notional building specification of 5 m3/hr/m2 at 50Pa together with natural ventilation does not set the right direction to prepare supply chains for airtight buildings and highly efficient ventilation (even if other systems remain allowed).
For non-domestic buildings, a limiting value of 8 m3/hr/m2 at 50Pa is too high.
Testing requirements and limit airtightness values must be introduced on existing buildings and existing dwellings, at least where substantial works are carried out. This will improve performance and build quality, and support better informed decisions on both energy efficiency and ventilation. See also point 7 on whole-building approach
The draft FHS specification proposes an airtightness of 5 m3/hr/m2 at 50Pa, and natural ventilation. This is quite far from the "world class" levels of energy efficiency intended for the FHS and is a remaining important opportunity for energy savings. The FHS specification should show best practice airtightness and MVHR (even if other systems remain allowed). This would encourage the development of supply chains now so that MVHR is well designed and installed, and delivers energy savings and good indoor air quality.
6 – A trajectory for the existing stock
For existing domestic and non-domestic buildings the consultation package only includes a 2021 revision, and it is a relatively modest one.
However, given the scale and performance of the existing building stock, it is clearly by far the biggest challenge to achieve net zero carbon buildings. Whilst this cannot be solved by Building Regulations alone, they are a key policy to drive some of the changes needed. It is therefore essential that work is done urgently to consider the role of Building Regulations in the decarbonisation of the existing building stock and to co-ordinate the various policies that influence the energy use of our building stock. The recent coronavirus response has highlighted the need to co-ordinate health requirements and energy requirements more closely, for example. It would be very helpful to see a clear and early indication that the challenge of existing buildings is a cross departmental policy issue and a cross disciplinary technical issue.
Government must commit to a 2025 upgrade and set out a programme of works to introduce upgraded requirements informed by evidence and supported by clear guidance on complex technical issues, such as dealing with traditional construction buildings, thermal bridging and moisture movement. This should incorporate lessons from recent exemplar retrofit projects, PAS 2035, past programmes such as Retrofit for the Future, and additional research if required. It should be on the same timescale as the development of the FHS/FBS.
Implement 2025 Future Homes & Buildings standard proposals for the existing stock
7 – A plan and a whole building approach for the existing stock
Two serious limitations in the current requirements for existing buildings are that they do not provide an end goal compatible with net zero, and they rely heavily on an elemental approach. This doesn’t sufficiently make the links between energy, overheating, air quality, and fabric, and it doesn’t prevent carbon lock-ins and unintended consequences. All works covered by Building Regulations must contribute to the huge challenge of putting buildings on track to net zero, while being healthy and comfortable.
The Part F requirement that ventilation should be “no worse” than before the works is highly inadequate, as many homes are not well ventilated. The works should be “net zero ready”, and a longer-term plan should be produced for the building, to reduce operational, embodied, and financial expenditure now and in the future. It is the approach promoted in PAS 2035, which regulations should build on.
Continue as per 2021, and incorporate any lessons learnt. Start a programme gradually phasing out fossil fuel replacement plant in existing buildings/dwellings.
8 - Calculation methodologies that are fit to Net Zero
There is little evidence that NCM drives improvements on non-domestic buildings. Space heating is known to be routinely under-estimated, clearly an issue for heat decarbonisation and the appraisal of options. Changes to NCM in 2021 should be more substantial changes than currently proposed, in particular on the calculation of energy use for heating.
MHCLG should also commit to a fundamental review of NCM to accompany the FBS, similar to that commissioned by BEIS for SAP/RdSAP 11.
Implement the conclusions of the fundamental review of SAP and NCM.
Competence, skills, and supply chains
Many of the topics and proposals detailed above will require significant skills updates and upgrades across the whole of the supply chain. They are not optional extras, they are essential to achieving the necessary successful outcomes from the measures detailed. Without a serious and sustained focus on skills over many years then significant aspects of the programme are in jeopardy from the outset. There are 2 particular areas where this is the case:
The outline Future Homes / Buildings Standard must clearly show what supply chains will be expected to deliver, so they can start preparing now, and the 2021 revision must represent a clear step towards 2025 requirements, to provide further incentives for supply chain development.
In addition, and recognising that this cannot be addressed by Building Regulations alone, MHCLG should work closely with BEIS to develop a buildings policy which covers safety, sustainability and skills. For a more detailed analysis please see the Royal Academy of Engineering paper “Beyond COVID-19: laying the foundations for a net zero recovery.
General comments on the consultation package
We acknowledge that a consultation seeking to tackle new and existing buildings, domestic and non-domestic, 2021 and 2025, and Parts L, F and overheating, was a significant challenge to produce, and we appreciate all the work which went into it. However, following our own analysis as well as the feedback we have received from several parties, we would like to raise concerns about some of the information provided which, together with the breadth of the consultation, may prevent MHCLG from gathering truly well-informed and thorough responses. The following items are of particular concern as they are significant topics for building performance, carbon emissions, and the health of occupants, and we are concerned about the quality of responses as a result. There may be others which we have not been able to spot:
APPENDIX B – RECOMMENDATIONS ON NPPF & DESIGN CODES (EXECUTIVE SUMMARY FROM CIBSE RESPONSE TO CONSULTATION, APRIL 2021)
CIBSE submitted a response to this consultation making the following suggestions:
APPENDIX C – RECOMMENDATIONS ON FUTURE HOMES STANDARD (EXECUTIVE SUMMARY FROM CIBSE RESPONSE TO CONSULTATION, FEBRUARY 2020)
As the consultation document itself states, “Despite progress reducing emissions from homes, we need to go much further. New homes being built now and in the next 5-10 years will still exist in 2050 and therefore we must ensure that the energy efficiency standards we set for them put us on track to meet the 2050 target.” This echoes the statement by Chris Stark, Chief Executive of the Committee on Climate Change that “The UK has achieved major changes in complex systems before, but not at the scale that the Committee on Climate Change has now recommended to reach net-zero in the UK.”1
The report specifically recommends, in relation to reducing energy demand in buildings, that BEIS and MHCLG: “Ensure that the implementation of the Hackitt Review addresses the energy efficiency performance gap on the evolution of and compliance with buildings standards and in the development of skills, standards, procedures and capacity within the building industry sector.”
We very much agree with the stated overall ambition described, but have strong concerns that the proposals set out are not sufficiently ambitious to deliver significant progress towards meeting the objectives of reducing carbon emissions, annual energy consumption and peak demand, and ensuring affordability to consumers. The proposals for Part L 2020 do not represent the required “meaningful and achievable step” towards zero carbon, and the timeline and content of the Future Homes Standard is not ambitious enough, nor does it begin to address real in-use energy performance and carbon emissions.
In summary, we recommend the following:
o Peak demand: this should at the very least be estimated and reported on; MCHLG could review this and consider the need to limit peak demand in the future if required, subject to how well buildings perform and the pressures on the electricity grid
o Embodied carbon: we recommend that from 2025, the embodied carbon of key building elements should be considered, so that data is gathered by MHCLG for the purpose of benchmarking and future standard setting, and to develop the expertise of the industry.
o Adaptation and resilience to climate change, including considerations of overheating, water consumption, flooding, and drainage.
We have a provided a substantial amount of supporting information to illustrate and justify our comments, and point at possible solutions. This is meant to be helpful. We would be very happy to discuss this with MHCLG and to review options for revised proposals and the development of the FHS.
We also look forward to the expected consultation on a new overheating standard, and on existing dwellings and non-domestic buildings. Existing buildings are the real challenge, hence why we must get it right with new buildings as soon as possible, to avoid adding to future challenges. Many points made in this response, including the overall methodology approach and the need for a move to operational performance requirements, are as relevant to these sectors and we would hope they can be taken into account in the development of those upcoming proposals too.
Our response has been informed by contributions from members and wider stakeholders, including impact assessments of the proposed changes. We want to stress the huge and unprecedented level of interest from industry, which reflects an undoubted appetite for more ambitious proposals and a meaningful step towards net zero carbon.
In very large part our response is consistent with that of other prominent built environment bodies, including the RIBA, Green Building Council, London Energy Transformation Initiative, and Greater London Authority. We are aware that the RTPI and CIEH also agree on the points relevant to their expertise.
1 Statement in the Foreword to “Shifting the Focus” – full reference Eyre, N and Killip, G. (eds). 2019. Shifting the focus: energy demand in a net-zero carbon UK. Centre for Research into Energy Demand Solutions. Oxford, UK. ISBN: 978-1-913299-00-2
2 For a research paper exploring residential operational ratings, see for example: Lomas K. J. et al, A domestic operational rating for UK homes: Concept, formulation and application, Energy & Buildings, 2019
3 BPN joint position statement on building performance , November 2019: https://building- performance.network/advocacy/building-performance-joint-position-statement
4 CIBSE Briefing Paper on route to net zero carbon buildings, August 2019 https://www.cibse.org/getmedia/bdaf4dee-5980- 4b58-871c-a24e88c010d4/CIBSE-Steps-to-net-zero-carbon-buildings.pdf.aspx
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 https://www.raeng.org.uk/publications/reports /beyond-covid-19-laying-the-foundations-for-a-net-z