Local Planning Authorities have had a confusing time on what to out in development plans about decarbonising buildings stock and energy to buildings.
A useful summary of the many zig zags is the UK Green Building Council New Homes Policy Playbook
We had the Planning and Building Act legalising setting standards in advance of the Building regs, a deregulation order removing it but no regs implementing the order and a consultation as part of the Future Homes standard on whether to introduce the order.
Hence LPAS have been confused, introducing policies, then withdrawing them or adding notes to ther websites that they no longer apply.
At last some clarity. The Government has published a lengthy document on the Future Homes Standard.
Responding to a consultation on the Future Homes Standard, the government has set out plans to radically improve the energy performance of new homes, with all homes to be highly energy efficient, with low carbon heating and be zero carbon ready by 2025.
These homes are expected to produce 75-80% lower carbon emissions compared to current levels. To ensure industry is ready to meet the new standards by 2025, new homes will be expected to produce 31% lower carbon emissions from 2021.
lets look at the phasing in.
First is an interim uplift in Part M standards.
Subject to the outcome of the second Part L consultation published alongside this response document, our aim is now for the interim Part L(Conservation of fuel and power), Part F (Ventilation) and Overheating
Regulations outlined in both consultations, with associated guidance, to be
regulated for in late 2021, coming into effect in 2022.…a typical semi-detached home built to the 2021 version of Part L will emit 31% less CO2 than one built to current standards – and will act as a first step towards the Future Homes Standard.
In terms of interim measures by local planning authorities.
We recognise that there is a need to provide local authorities with a renewed understanding of the role that Government expects local plans to play in creating a greener built environment; and to provide developers with the confidence that they need to invest in the skills and supply chains needed to deliver new homes from 2021 onwards. To provide some certainty in the immediate term, the Government will not amend the Planning and Energy Act 2008, which means that local planning authorities will retain powers to set local energy efficiency standards for new homes. (para 2.40)
… as we move to ever higher levels of energy efficiency standards for new homes with the 2021 Part L uplift and Future Homes Standard,it is less likely that local authorities will need to set local energy efficiency standards in order to achieve our shared net zero goal. (para 2.41)
In terms of the roadmap to the Future Homes Standard
In their most recent annual progress report to Parliament, the Committee for Climate Change recommended that the Government commits to a robust definition of the Future Homes Standard, which is legislated for well ahead of 2025.10
Through consultation we received similar feedback from stakeholders, many of whom requested an early consultation on the technical detail of the standard and aclearer pathway to full implementation.
• We have listened to these calls for a swifter and more certain pathway. Our
work on a full technical specification for the Future Homes Standard has been
accelerated and we will consult on this in 2023.
• We intend to introduce the necessary legislation in 2024, ahead of full
implementation of the Future Homes Standard in 2025.
A draft future homes standard is included. Note this is somewhat stricter in home insultation than the previous zero carbon standard and low carbon heating (i.e. no gas biolers) are insisted upon.
Now how are LPAS to respond. The new approach is somewhat different than the zero carbon homes plan. The Phasing out of Natural Gas will mean there is less ‘Gap’ (residualn and unregulated emissions) to be filled – requiring approprate solutions (such as tree planting) for example. However the means of filling the low carbon hearing gap (heat pumps, zero carbon district heating etc.) is left open.
Looking at the proposed phasing in terms of planning policy we have
- Now to 2022 (introduction of interim part L)
- 2022 to 2025
- 2025 – Introduction of Future Homes Standard
Only a few weeks ago the UKGBC reccomended LPAS to chance it with the following policy.
A 31% reduction on the Dwelling Emission Rate (DER) against the Target Emission Rate
(TER) based on the 2013 Edition of the 2010 Building Regulations (Part L). A fabric first
approach shall be prioritised, ensuring that at a minimum the thermal performance of
the whole envelope exceeds that of the notional specification by 5%.
The energy use intensity for new homes should be reported on a kWh/m2/year gross
internal area (GIA) basis.
This is the standard already flagged up and which almost all housebuilders have already adjusted to. It is entirely reasonable to apply it between now and when revised Part L comes into force.
LPAs could also apply a stricter standard from 2022 to 2025, 50% reduction is reasonable, 75% will kick in after 2025.
I would strongly recommend that LPAs define the baseline as per the above there are many ways this is defined some throwing in total emissions and unregulated appliances. This is confusing and in terms of building fabric many SAP calculators will struggle. To deal with low energy heating and residual, unregulated and total emissions it is much better to have a separate policy (as the UKGBC recommends) to deal with this, a combination of large site based technology and contributions to carbon offsetting. This will avoid having to have complex SPGs which deal wit matters in duplicative and conflicting ways to the building regulations.
As a streaching target the UKGBC recommend
An energy use intensity (EUI) target of <70 kWh/m2/year operational energy use in GIA excluding renewable energy contribution shall be met. This target includes both regulated and unregulated energy consumption. New build homes shall deliver ultra-high levels of energy efficiency consistent with a space heat demand of 15-20kWh/m2 /year. Designers shall evaluate the operational energy use using realistic information on the intended use, occupancy, and operation of the building to minimise any performance gap. They shall demonstrate this through compliance with the above targets using a design for performance methodology such as Passivhaus PHPP or CIBSE TM54 Operational Energy
And in terms of residual emmissions
Where it is clearly demonstrated that net zero carbon cannot be fully achieved through
on-site measures, all developments shall be required to make a financial contribution
to the LPA’s carbon tax fund equal to the residual regulated emissions at a rate of
£X/tCO2 over 30 years.
Alternatively, developments can make up the shortfall off-site by funding a carbon
reduction or removal project directly, provided the LPA has approved this approach.
They also include a Merton rule type policy for 40% renewable, but i doubt this is necessary or sensible. 30% of ultra low emissions development might output far less carbon than 40% of a high carbon development. It is much better to set carbon targets and encourage maximisation of renewable potential than set arbitrary % targets.
Lets hope the UKGBC update their guide to deal with the new government announcements ASAP.
Decisions, Decisions, Decisions 