It’s been just over a month since the English Part L was updated, and our Technical Department has been busy working through the first assessments under the 2012 methodology. But this change in Regs has thrown up a conflict on sites where planners are asking for Code for Sustainable Homes (CSH) compliance, leaving designers in a drawing-board no-man’s land.
It’s because Part L now requires tighter targets than the CSH 2009 rulebook: Section ENE1 of the Code awards credits based on the improvement shown between the Dwelling Emission Rate and the 2009 Target Emission Rate – the bigger the reduction, the more credits you receive. Section ENE2 of the Code awards credits based on the Fabric Energy Efficiency Score (FEES) – the better the fabric of the dwelling, the more credits you can claim. This score is calculated using SAP 2009.
If you are building to the older version of Part L, this doesn't cause any problems… SAP 2009 and the Code will happily work side by side. But if you've been asked to meet Part L 2013, the calculators in the Code simply aren't compatible with SAP, making it impossible to calculate the amount of credits available. And with ENE credits being heavily weighted, and ENE1 being a mandatory target, you can’t proceed with the Code passed this hurdle. So the bottom line as things currently stand: a new residential development which has been registered under Part L 2013 cannot be assessed under the Code for Sustainable Homes.
We have spoken with one of our accreditation bodies (the people who sit above us and make sure SAP reports and CSH reports are completed accurately) about workarounds, but the official line is that if a Part L 2013 site is required to meet a level of the Code, we need to hang fire until further guidance is released.
It is not an option to complete a SAP using 2012 methodology, and then reverting the data back into 2009 methodology for the purposes of making it compatible with the current Code guidance. The Building Research Establishment (BRE) is in charge of writing updates to the Code guidance, and we understand a ‘patch’ is currently being written which will create a way that credits can be awarded based on a SAP 2012 calculation.
There is no date for when this update will be released. This is likely to be the last revision to the Code as we know it. The guidance is set to be phased out in early 2015, as new rules will mean planning departments are more limited about requesting regional variations to policies. A streamlined, voluntary version of the Code may be considered in the future (similar to Section 7 in Scotland) but nothing is set in stone. As soon as we receive word of the Code / SAP 2012 patch, we’ll produce a full list of changes, and how ENE1 and ENE2 credits can be achieved using the newest version of Part L.
Register for your guide to Part L in England here.