The Future Buildings Standard Consultation Response, Energist UK Ltd

Section A: Non-Domestic Buildings

2) The Future Buildings Standard

Question 1: Our aim is that buildings constructed to the Future Buildings Standard will be capable of becoming carbon neutral over time as the electricity grid and heat networks decarbonise. Do you agree that the outline of the Future Buildings Standard in this chapter meets this aim?

a) Yes
b) No

a) Yes. The move away from fossil fuels towards electric heating systems aligns with the continued decarbonisation of the national grid and enables continued decarbonisation of development post-occupancy, towards carbon neutrality.

Question 2: We believe that developers will typically deploy heat pumps and heat networks to deliver the low carbon heating requirement of the Future Buildings Standard where practical. What are your views on this and in what circumstances should other low carbon technologies, such as direct electric heating or hydrogen, be used?

As much as practicably possible, the requirements of the building regulations should be technology agnostic and allow for the development of alternative low carbon fuel sources in the future. Alternative heating systems should be permitted provided they meet carbon and energy targets, especially where the use of heat pump systems may not be appropriate.  The industry will need clarity and certainty on future building standards to adapt to the use of heat pump systems in place of existing solutions.

Question 3: Do you agree that some non-domestic building types are more suitable for low carbon heating and hot water, and that some non-domestic building types are more challenging?

Yes. Targets should allow for multiple technologies to be utilised dependant on building usage, with flexibility within the defined methodology. Large warehouse or industrial buildings will be more suited to point or spot heating systems. Buildings with high demand for instantaneous heat may not be as well suited to low temperature heating systems and alternative solutions should be permissible.

Question 4: Do you agree with the allocation of building types to space and water heating demand types, as presented in Table 2.1 of this consultation document?

a) Yes
b) No

a) Yes, it is a sensible approach to split into these three building types based on space heating and hot water demand.

Question 5: We would like to introduce the Future Buildings Standard for all buildings as quickly as possible. When do you think the Future Buildings Standard should introduce low carbon space heating for buildings with Type 1 or Type 2 demand (buildings that have space heating demand more suitable for heat pumps)?
a) 2025 – our proposed date
b) Another date (please specify)

a) 2025. Updates to AD L and the introduction of FBS should align with the dates for the proposed Future Homes Standards. Having one date removes confusion over regulation changes – especially concerning mixed use developments.

Question 6: We would like to introduce the Future Buildings Standard for all buildings as quickly as possible. When do you think the Future Buildings Standard should introduce low carbon space heating for buildings with Type 3 demand (buildings that have space heating demand less suitable for heat pumps)?
a) 2025
b) Another date

a) Regulatory updates should be released at the same time across all building types, however the target should be achievable through alternative means, in recognition that low carbon heating options may be limited for Type 3 buildings.

Question 7: We would like to introduce the Future Buildings Standard for all buildings as quickly as possible. When do you think the Future Buildings Standard should introduce low carbon water heating for buildings with Type 1 or Type 3 demand (buildings that have water heating demand more suitable for point-of-use heaters or heat
pumps)?
a) 2025 – our proposed date
b) Another date (please specify)

a) Regulatory updates should be released at the same time across all building types, however the target should be achievable through alternative means, in recognition that low carbon heating options may be limited for Type 3 buildings.

Question 8: We would like to introduce the Future Buildings Standard for all buildings as quickly as possible. When do you think the Future Buildings Standard should introduce low carbon water heating for buildings with Type 2 demand (buildings that have water heating demand less suitable for point-of-use heaters or heat pumps)?
a) 2025
b) Another date (please specify)

a) Regulatory updates should be released at the same time across all building types, however the target should managed in such a way to allow compliance through alternative means where direct electric heating systems are appropriate for a development. Certainty around the introduction of new performance standards provides time for the supply chain to ready itself.

3) Interim uplift to Part L standards for non-domestic buildings

Question 9: We would welcome any further suggestions, beyond those provided in this consultation, for improving the modelling process; Part L and Part F compliance; and the actual energy performance of non-domestic buildings. Please provide related evidence.

To provide consistency across the industry the modelling tools used to demonstrate Building Regulations compliance should also be sufficient to estimate the energy demand of a building in use. This will require the continual evolution of modelling tools to close the gap between compliance assessed energy demand and in use energy demand.

Question 10: What level of uplift to the energy efficiency standards for nondomestic buildings in the Building Regulations should be introduced in 2021?
a) Option 1 – average 22% CO2 reduction
b) Option 2 – average 27% CO2 reduction (this is the Government’s preferred option)
c) No change
d) Other level of uplift (please specify)

b) 27%. AD L targets are overdue an uplift and regulation drives innovation and uptake. We note that continual decarbonisation of the electricity grid will enable lower targets to be delivered, especially in buildings with high electrical demand.

Question 11: Do you agree with the way that we are proposing to apply primary energy as the principal performance metric?
a) Yes
b) No

a) Yes – a primary energy metric ensures that high efficiency systems are utilised or offsetting measures in place to reduce the energy impact of the chosen fuel source. We would note that the terminology of primary or secondary is irrelevant as compliance with both is required to deliver on AD L standards.

Question 12: Do you agree with using CO2 as the secondary performance metric?
a) Yes
b) No

a) Yes. We would note that the terminology of primary or secondary is irrelevant as compliance with both is required to deliver on AD L standards. The TER is a familiar metric and well understood. It needs to be retained to drive carbon reduction in the construction industry.

Question 13: Do you agree with the approach to calculating CO2 and primary energy factors, referred to in paragraph 3.5.7 of this consultation document?
a) Yes
b) No

a) Yes – the same values should be used in both SAP and SBEM methodology to ensure consistency.

Question 14: Do you agree with the proposals for natural gas being assigned as the heating fuel for any fuels with a worse CO2 emission factor than natural gas?
a) Yes
b) No

a) Yes – this is a sensible approach to discourage carbon intensive fuels and allow a transition over time away from natural gas.

Question 15: Do you agree with our proposal of using a hybrid electric/heat pump heating system in the notional building when electricity is specified as a heating fuel?
a) Yes
b) No

a) Yes – however the efficiency of this notional system should not be set so high as to make direct electric heating an unviable compliance solution

Question 16: Do you agree with the proposal for the treatment of domestic hot water in the notional building?
a) Yes
b) No

a) Yes. This will encourage the use of instantaneous hot water supplies in low use buildings, preventing energy losses from storage.

Question 17: Do you agree with the proposal for connecting to an existing heat network, as presented in the draft NCM modelling guide?
a) Yes
b) No, they give too much of an advantage to heat networks
c) No, they do not give enough of an advantage to heat
networks
d) No, I disagree for another reason

a) Yes.

Question 18: Do you agree with the proposal for connecting to a new heat network, as presented in the draft NCM modelling guide?
a) Yes
b) No, they give too much of an advantage to heat networks
c) No, they do not give enough of an advantage to heat
networks
d) No, I disagree for another reason

a) Yes

Question 19: Do you agree with the proposed changes to the National Calculation Methodology Modelling Guide and activity database?
a) Yes
b) Yes, but additional changes should be made
c) No

a) Yes – it is important to revise these activities to ensure they reflect our current understanding of how we use buildings, a key element in reducing the performance gap.

Question 20: We would welcome any further suggestions for revising the outputs from SBEM, which would enable easier checking by building control on building completion. Please provide related evidence.

The BRUKL report should follow a similar format to the proposed BREL report for SAP. The current BRUKL does not provide enough detail and is unclear. The report should clearly reference:

• All fabric elements within the building and their performance against limiting U values
• A clear description on the type of space heating and DHW systems, fuel used and efficiency.
• A description of each ventilation system used in the building, along with efficiency and performance against minimum standards
• A description of lighting system system used in the building, along with efficiency and performance against minimum standards
• Any renewable energy technology

The above should be listed under these categories with reference to which rooms they are applicable to.

Question 21: Do you agree with the proposals for limiting heat gains in non-domestic buildings?
a) Yes
b) No, they go too far
c) No, they do not go far enough
d) No, I disagree for another reason

a) Yes. Passive design measures should be encouraged to reduce cooling demand. The measures proposed are appropriate.

Question 22: Do you agree with the proposed minimum standards for fabric performance in new non-domestic buildings as presented in Table 3.2 of this consultation document?
a) Yes
b) No, the standards go too far
c) No, the standards do not go far enough
d) No, I disagree for another reason

a) Yes

Question 23: Do you agree with the proposed minimum standards for fabric performance of new thermal elements in existing non-domestic buildings as presented in Table 3.3 of this consultation document?
a) Yes
b) No, the standards go too far
c) No, the standards do not go far enough
d) No, I disagree for another reason

a) Yes – standards should be aligned to the U value requirements for new builds.

Question 24: Do you agree with the draft guidance in paragraph 4.15 of the draft Approved Document L, volume 2: buildings other than dwellings on reducing unwanted air infiltration when carrying out work to existing non-domestic buildings?
a) Yes
b) No

a) Yes

Question 25: Do you agree that the limiting U-value for rooflights in new and existing non-domestic buildings should be based on a rooflight in a horizontal position, as detailed in paragraph 4.4 of draft Approved Document L, volume 2: buildings other than dwellings?
a) Yes
b) No

a) Yes

Question 26: Do you agree that we should adopt the latest version of BR 443 for calculating U-values in new and existing non-domestic buildings, as detailed in paragraph 4.1 of draft Approved Document L, volume 2: buildings other than dwellings?
a) Yes
b) No

a) Yes

Question 27: Do you agree with the newly proposed minimum efficiencies for natural gas, oil and LPG boiler and domestic hot water system installations in new non-domestic buildings in Section 6 of draft Approved Document L, volume 2: buildings other than dwellings?
a) Yes
b) No, the standards go too far
c) No, the standards do not go far enough

a) Yes

Question 28: Do you agree with the proposed set of standards for air distribution systems for new non-domestic buildings in Section 6 of draft Approved Document L, volume 2: buildings other than dwellings?
a) Yes
b) No, the standards go too far
c) No, the standards do not go far enough
If you answered no (b or c), please explain your reasoning.

a) Yes

Question 29: Do you agree with the proposals for self-regulating devices for new non-domestic buildings, as set out in Sections 5 and 6 of draft Approved Document L, volume 2: buildings other than dwellings?
a) Yes
b) No

a) Yes

Question 30: Do you agree with the minimum efficacy proposals for lighting in new non-domestic buildings in Section 6 of draft Approved Document L, volume 2: buildings other than dwellings?
a) Yes
b) No, the standards go too far
c) No, the standards do not go far enough

a) Yes

Question 31: Do you agree with the proposals for cooling in new non-domestic buildings in Section 6 of draft Approved Document L, volume 2: buildings other than dwellings?
a) Yes
b) No, the standards go too far
c) No, the standards do not go far enough

a) Yes

Question 32: Do you agree with the proposals to require building automation and control systems in new non-domestic buildings, when such buildings have a heating or air-conditioning system over 290kW?
a) Yes
b) No, a different trigger point should be used
c) No, I do not agree that building automation and control systems should be required in new buildings
d) No, I disagree for another reason

a) Yes

Question 33: Do you agree with the technical specification for new building automation and control systems as EN 15232, Class A?
a) Yes
b) No, the requirements go too far
c) No, the requirements do not go far enough

a) Yes

Question 34: Do you agree with the proposals for improving the commissioning guidance for new non-domestic buildings in Section 8 and 9 of draft Approved Document L, volume 2: buildings other than dwellings?
a) Yes
b) No, the standards go too far
c) No, the standards do not go far enough
d) No, I disagree for another reason

a) Yes

Question 35: Do you agree with the proposals for requirements relating to the assessment of overall energy performance of building services installations and providing information to building owners for new non-domestic buildings given in sections 8 and 9 of Approved Document L, volume 2: buildings other than dwellings?
a) Yes
b) No

b) No. TM54 analysis is detailed and relies heavily on input from the end tenant to understand building usage, installed services and how these will interact. Especially with reference to shell and core development, this information will not be available to the developer and providing such analysis would be meaningless in its accuracy. In addition, a TM54 analysis will assess unregulated energy consumption which is not something the developer will have an influence on, being outside of the remit of the Building Regulations. We would also raise concerns around the capacity of the industry to provide this analysis if it became a regulatory requirement.

Question 36: Do you agree with the guidance proposals for adequate sizing and controls of building services systems in new non-domestic buildings, as detailed in Sections 5 and 6 of draft Approved Document L, volume 2: buildings other than dwellings?
a) Yes
b) No, I do not agree with providing guidance on this
c) No, the guidance should be improved

a) Yes

Question 37: Do you agree with the proposal that wet space heating systems in new buildings should be designed to operate with a flow temperature of 55°C or lower?
a) Yes, through a minimum standard set in paragraph 5.9 of the Approved Document L, volume 2: buildings other than dwellings
b) Yes, through carbon and primary energy credit in SBEM
c) Yes, by another means
d) No, the temperature should be below 55°C
e) No, this standard should not be applied to all new buildings
f) No, I disagree for another reason

b) Yes. This is a sensible step to futureproof buildings to use lower-temperature heating systems, but consideration should be given to allow design flexibility where the provision of a LT heating system is not viable, provided carbon and energy compliance are still met.

Question 38: Do you agree with the proposals to clarify, rationalise and simplify the guidance for building services in new non-domestic buildings, and to incorporate the standards of the Non-Domestic Building Services guidance into the main body of the Approved Document L, volume 2: buildings other than dwellings?
a) Yes
b) No

a) Yes

Question 39: Do you agree with the proposals to simplify the requirements in the Building Regulations for the consideration of high-efficiency alternative systems in new non-domestic buildings?
a) Yes
b) No
If you answered no, please explain your reasoning.

a) Yes. This process has always been a tick-box exercise. Carbon and energy performance targets will drive the consideration of these technologies anyway, without the need for a specific Building Regulations requirement to demonstrate their consideration.

Question 40: Do you agree with the efficiency proposals for replacement fixed building services in existing non-domestic buildings as detailed in paragraphs 5.4 to 5.7 of draft Approved Document L, volume 2: buildings other than dwellings?
a) Yes
b) No

a) Yes

Question 41: Do you agree with the newly proposed minimum efficiencies for natural gas, oil and LPG boiler and domestic hot water system installations in existing non-domestic buildings in Section 6 of draft Approved Document L, volume 2: buildings other than
dwellings?
a) Yes
b) No, the standards go too far
c) No, the standards do not go far enough

a) Yes

Question 42: Should minimum boiler efficiency standards in existing nondomestic buildings still benefit from relaxations through the use of heating efficiency credits?
a) Yes, boiler installations should continue to benefit from heating efficiency credits
b) No, boiler installations should no longer benefit from heating efficiency credits (the Government’s proposal)

a) Yes, boiler installations should continue to benefit from heating efficiency credits

Question 43: Do you agree with the proposed set of standards for air distribution systems for existing non-domestic buildings in Section 6 of draft Approved Document L, volume 2: buildings other than dwellings?
a) Yes
b) No, the standards go too far
c) No, the standards do not go far enough

a) Yes

Question 44: Do you agree with our proposed approach and guidance to mandating self-regulating controls in existing non-domestic buildings, including technical and functional feasibility, as detailed in Sections 5 and 6 of draft Approved Document L, volume 2: buildings other than dwellings?
a) Yes
b) No

a) Yes

Question 45: Do you agree with the minimum efficacy proposals for lighting in existing non-domestic buildings in Section 6 of draft Approved Document L, volume 2: buildings other than dwellings?
a) Yes
b) No, the standards go too far
c) No, the standards do not go far enough

a) Yes

Question 46: Do you agree with the proposals for cooling in existing nondomestic buildings in Section 6 of draft Approved Document L, volume 2: buildings other than dwellings?
a) Yes
b) No, the standards go too far
c) No, the standards do not go far enough

a) Yes

Question 47: Do you agree with the proposals that when Building Automation and Control System is installed in an existing non-domestic building with a heating or air-conditioning system over 290 kW, it should meet the same minimum standards as new non-domestic buildings?
a) Yes
b) No, a different trigger point should be used
c) No, a different standard should be used
d) No, for another reason

a) Yes

Question 48: Do you agree with the proposals for requirements relating to the assessment of overall energy performance of building services installations and providing information to building owners for existing non-domestic buildings?
a) Yes
b) No, I do not agree with providing this guidance
c) No, the guidance should be improved

a) Yes

Question 49: Do you agree with the guidance proposals for adequate sizing and controls of building services systems in existing non-domestic buildings, as detailed in Sections 5 and 6 of draft Approved Document L, volume 2: buildings other than dwellings?
a) Yes
b) No, do not agree with providing this guidance
c) No, the guidance should be improved

a) Yes

Question 50: Do you agree with the proposal that when whole wet space heating systems (i.e. boiler and radiators) are replaced in existing nondomestic buildings the replacement system should be designed to operate with a flow temperature of 55°C or lower?
a) Yes, through a minimum standard set in paragraph 5.9 of Approved Document L, volume 2: buildings other than
dwellings
b) Yes, through carbon and primary energy credit in SBEM
c) Yes, by another means
d) No, the temperature should be below 55°C
e) No, this standard should not be applied to all existing buildings
f) No, I disagree for another reason

b) Yes. This is a sensible step to futureproof buildings to use lower-temperature heating systems, but consideration should be given to allow design flexibility where the provision of a LT heating system is not viable, provided carbon and energy compliance are still met.

Question 51: Do you agree with the proposals to restructure the guidance for building services in existing non-domestic buildings, and to incorporate the standards of the Non-Domestic Building Services guidance into the main body of the Approved Document L, volume 2: buildings other than dwellings?
a) Yes
b) No

a) Yes

Question 52: Do you agree the Government should continue to provide guidance for minimum building services efficiencies in existing non-domestic buildings, if the standard does not go significantly further than the Ecodesign regulations?
a) Yes
b) No, the Ecodesign regulations are sufficient
c) No

a) Yes

Question 53: Do you agree with the changes made to simplify, rationalise and clarify the guidance, and the updates to external references in Appendix E and Appendix F, in Approved Document L, volume 2: buildings other than dwellings, as outlined in paragraph 3.12.1 of the consultation document?
a) Yes
b) Yes, but not with the changes to the supplementary guidance
c) Yes, but not with the external references
d) No

a) Yes

Question 54: Do you agree that the measures in Tables D.1 and D.2 of Appendix D of Approved Document L, volume 2: buildings other than dwellings are likely to be technically, functionally and economically feasible under normal circumstances?
a) Yes
b) No

a) Yes

Question 55: Do you agree with the proposals for relaxation factors for modular and portable buildings, as detailed in Tables 2.2 and 2.3 of draft Approved Document L, volume 2: buildings other than dwellings?
a) Yes
b) No, the requirements go too far
c) No, the requirements do not go far enough

a) Yes

Question 56: Do you think that the Pulse methodology should be an approved means of demonstrating airtightness for non-domestic buildings?
a) Yes
b) No

a) Yes. The current draft AD L does not define the maximum appropriate building size for this testing method. This omission should be addressed.

Question 57: Do you agree that we should adopt an independent approved airtightness testing methodology such as the CIBSE draft methodology for non-domestic buildings?
a) Yes, and the CIBSE methodology is appropriate
b) Yes, but with a methodology other than CIBSE
c) No, an independent approved airtightness methodology shouldn’t be adopted.

a) Yes

Question 58: Do you agree with the proposal for guidance on the calibration of devices that carry out airtightness testing in new and existing nondomestic buildings?
a) Yes
b) No

a) Yes

Question 59: Do you agree with the proposed approach to energy sub-metering, as detailed in Section 5 of draft Approved Document L, volume 2: buildings other than dwellings?
a) Yes
b) No

a) Yes

Question 60: Do you agree with the proposed approach to energy forecasting, as detailed in paragraph 9.4 of draft Approved Document L, volume 2: buildings other than dwellings?
a) Yes
b) No, I do not agree with the proposed approach
c) No, energy forecasting should not form part of the Building Regulations

b) Energy forecasting should be based on compliance tools, not an additional assessment tool.

Question 61: Do you agree with the proposals for transitional arrangements for buildings other than dwellings?
a) Yes
b) No

a) Yes. This matches the requirements for residential development.

4) Interim Uplift to Part F standards for non-domestic buildings

Question 62: Do you agree with the proposed guidance in Section 1 and Section 2 of Approved Document F, volume 2: buildings other than dwellings on minimising the ingress of external pollutants and on the proper installation of ventilation systems in non-domestic buildings?
a) Yes
b) No

a) Yes. It is sensible to split AD F in two to cover non-residential buildings separately.

Question 63: Do you agree with the proposed guidance for reducing noise nuisance for ventilation systems in non-domestic buildings?
a) Yes
b) No

a) Yes

Question 64: Do you agree with the additional guidance provided in paragraphs 1.18 to 1.26 of the draft Approved Document F, volume 2: buildings other than dwellings on the installation of ventilation systems?
a) Yes
b) No

a) Yes

Question 65: Do you agree that the guidance in Appendix B of the draft Approved Document F, volume 2: buildings other than dwellings provides an appropriate basis for setting minimum ventilation standards?
a) Yes
b) No

a) Yes

Question 66: Do you agree with the list of industry guidance presented in Section 1 of draft Approved Document F, volume 2: buildings other than dwellings?
a) Yes
b) Yes, but additional guidance should be provided
c) No

a) Yes

Question 67: Do you agree with the list of references to industry guidance presented in Appendix C and Appendix D in the draft Approved Document F, volume 2: buildings other than dwellings?
a) Yes
b) No, the Government should amend the list of references
c) No, for another reason
If you answered no (b or c), please explain your reasoning and provide alternative suggestions.

c) No, the increased list of documents included in Appendix D adds an unrequired level of complexity. If any of the referred to documents contain relevant information it should be added to the latest approved document to avoid cross referencing documents.

Question 68: Do you agree with the proposals to simplify, rationalise and clarify the Approved Document guidance in Approved Document F, volume 2: buildings other than dwellings as outlined in paragraph 4.3.7 of the consultation document?
a) Yes
b) No

a) Yes. The Approved Document should focus less on design advice and be more targeted on meeting requirements of building regulations.

Question 69: Do you agree that purge ventilation in offices should be designed to provide at least four air changes per hour?
a) Yes
b) No, this standard goes too far
c) No, this standard does not go far enough
If you answered no (b or c), please explain your reasoning and provide alternative suggestions.

a) Yes

Question 70: Do you agree with the guidance for the ventilation of car parks and offices, as detailed in Section 1 of Approved Document F, volume 2: buildings other than dwellings?
a) Yes
b) Yes, but some improvements can be made
c) No, the guidance should be significantly changed

a) Yes

Question 71: Do you agree with the proposals in Section 3 of draft Approved Document F, volume 2: buildings other than dwellings, when replacing an existing window with no background ventilators?
a) Yes
b) No, the standards do not go far enough
c) No, the standards go too far

a) Yes

Question 72: Do you agree with the proposal to provide a completed commissioning sheet to the building owner and associated guidance in Section 4 of draft Approved Document F, volume 2: buildings other than dwellings?
a) Yes
b) No

a) Yes

Question 73: Do you agree with requiring increased capacity of 50% within new ventilation systems in offices shown in paragraph 1.38 of the draft Approved Document F, volume 2: buildings other than dwellings?
a) Yes
b) Yes, but with qualifications
c) No, the standard is too high
d) No, the standard is too low
e) No, I disagree for another reason
If you answered b, c, d or e, please explain your reasoning.

a) Yes

Question 74: Do you agree with the proposed standards for provision of outdoor air for offices, shown in paragraphs 1.35 to 1.36 of draft Approved Document F, volume 2: buildings other than dwellings?
a) Yes
b) Yes, but with qualifications
c) No

a) Yes

Question 75: Do you agree that extract ventilation in bathrooms, WCs, and other sanitary accommodation should be capable of operating in a continuous mode if necessary?
a) Yes
b) No

a) Yes

Question 76: Do you agree with the proposal for indoor air quality monitoring in offices as outlined in paragraphs 1.39 to 1.41 of draft Approved Document F, volume 2: buildings other than dwellings?
a) Yes
b) Yes, but with qualifications
c) No

a) Yes

Question 77: If applicable, please provide any suggestions for guidance for indoor air quality monitoring (e.g. CO2 monitoring) in nondomestic buildings.

N/A

Question 78: Do you agree with the proposals for systems that recirculate air as outlined in paragraph 1.46 of draft Approved Document F, volume 2: buildings other than dwellings?
a) Yes
b) No

a) Yes

Question 79: Do you agree with the proposed minimum ventilation standard in occupiable rooms in all types of non-domestic buildings where singing, loud speech or aerobic exercise may take place, where low temperature and low humidity environments may exist, or where members of the public may gather in large groups? These
are outlined in paragraphs 1.27 and 1.28 of draft Approved Document F, volume 2: buildings other than dwellings.
a) Yes
b) Yes, with qualifications
c) No

a) Yes

Question 80: Do you think the mitigating measures to protect against infection via aerosols would be suitable for any non-domestic buildings other than those stated in the Approved Document guidance?
a) Yes
b) No

a) Yes

Section B: Domestic Buildings
5) Standards for overheating in new residential buildings in 2021

Question 81: How should the Government address the overheating risk?
a) Through a new requirement in the Building Regulations and an Approved Document, as proposed in this consultation
b) Through Parts L and F of the Building Regulations
c) Through government guidance
d) I have an alternative approach
e) It isn’t an issue that needs addressing

a) A new Approved Document highlights the importance of overheating risk mitigation, and demonstrates a commitment to addressing this issue in a consistent manner across the country.

Question 82: Do you agree with the buildings that are in scope of this new part of the Building Regulations?
a) Yes
b) Yes, but they should be expanded to include more building types and/or existing buildings
c) No, they should be reduced to only include flats and houses
d) No, I disagree for another reason

b) Yes, but it is unclear if buildings such as new build hostels or hotels are included. These are building types where ‘people sleep on the premises’ and can include long-term residents, but are traditionally assessed as non-residential for the purposes of AD L. It is also not clear if the requirement for residential (institutional) buildings applies to the building as a whole, or only areas which are used for sleeping on the premises.

Question 83: Do you agree that the division of England based on overheating risk detailed in paragraph 5.6.3 of this consultation document is correct?
a) Yes
b) No, there should be one area
c) No, there should be more areas

c) Consideration should be given to assess whether other urban areas in the south of England should be identified and aligned with the design criteria for Greater London, especially considering that high density urban areas exist within the direct vicinity of London, and are subject to the same weather conditions. We would propose that two categories are retain, based on urban or non-urban and location defined by local climate.

Question 84: Do you agree with the categorisation of buildings into Group A and Group B as detailed in paragraph 5.6.5 of this consultation document?
a) Yes
b) No

a) Yes

Question 85: Do you agree with the simplified method as a means of compliance with the proposed new requirement to reduce overheating risk?
a) Yes
b) No, the method should be more sophisticated
c) No, the method is too easy to pass
d) No, for another reason

b) No, the method should be more sophisticated as it will still result in dwellings being constructed which will have a risk of overheating in specific rooms (rooms in roof for example). The differentiation on shading requirements between Greater London and the rest of the UK is too simple. However, we note that the methodology itself is not particularly accessible and will need robust compliance tools to assist developers in designing to these criteria.

Question 86: Do you agree with the maximum glazing area and shading standards for limiting solar gains in the simplified method as detailed in paragraphs 1.6 to 1.9 of the draft Overheating Approved Document?
a) Yes
b) No

b) No. Some level of shading requirement should also be applied to the rest of England under the simplified method (see answer 83). This should be triggered by the glazing ratio value.

Question 87: Do you agree with the approach to removing excess heat in the simplified method as detailed in paragraphs 1.10 to 1.13 of the draft Overheating Approved Document?
a) Yes
b) No

a) Yes, this allows for flexibility to purge heat build up through alternative means, such as louvres or mechanical purge.

Question 88: Do you think that adequate levels of daylight will be provided and that homes will be acceptable to purchasers while meeting these proposed standards?
a) Yes
b) No

a) Yes. Design flexibility in AD [X] through dynamic thermal analysis allows for more heavier-glazed designs in exchange for mitigation measures, so the guidance is not imposing strict design limits.

Question 89: Do you agree with offering dynamic thermal analysis as a means of compliance with the proposed new requirement to reduce overheating risk?
a) Yes, as described in the draft Overheating Approved Document
b) Yes, but not as described in the draft Overheating Approved Document
c) No

b) This methodology is widely recognised and implemented in the construction industry. It offers a more bespoke and robust approach than the Simplified Model. However, we would suggest that an alignment exercise between TM59 and AD [X] is undertaken to ensure a single consistent standard is used within the industry.

Question 90: Please detail any information you have about the likelihood of occupants opening doors and windows at night in unoccupied rooms.

No comment.

Question 91: Do you agree with the proposed acceptable strategies for shading and the removal of excess heat, when following the dynamic thermal analysis method, as found in Section 2 of the draft Overheating Approved Document?
a) Yes, I agree with both sets of acceptable strategies
b) Yes, but with amendments to the acceptable shading strategies
c) Yes, but with amendments to the acceptable strategies to remove excess heat
d) Yes, but with amendments to both sets of acceptable strategies
e) No, I do not agree with the acceptable strategies

a) Yes

Question 92: Do you agree that the overheating standard should not account for the effect of curtains, blinds and tree cover?
a) Yes, curtains, blinds and tree cover should be excluded
b) Yes, but only curtains and blinds should be excluded
c) Yes, but only tree cover should be excluded
d) No, none of these should be excluded
If you answered b, c or d, please explain your reasoning.

c) The provision of blinds and curtains should be an allowance solution, if provided by the developer as part of the base build and this can be evidenced and enforced. The homeowner should be made aware that the overheating strategy for their home is dependant on blinds being retained. Tree cover shouldn’t be allowed for, given it is not a permanent feature (can be removed, die, be cut back etc)

Question 93: Do you agree that the building should be constructed to meet the overheating requirement without the need for mechanical cooling?
a) Yes
b) No

b) No. While we agree that passive design measures are key to reducing the risk of overheating, we feel the use of mechanical cooling should not be disallowed and should be available for use as a last resort scenario, inline with current planning policy requirements and to recognise that in certain scenarios mechanical cooling is entirely appropriate, providing overall energy and carbon compliance targets are met.

Question 94: Do you agree with limiting noise in new residential buildings when the overheating strategy is in use, and the proposed guidance in Section 3 of the draft Overheating Approved Document?
a) Yes
b) Yes, but with amendments to the guidance
c) No, I do not agree with limiting noise when the overheating strategy is in use

b) Yes, but with amendments to the guidance. Current proposal suggests noise assessment is required unless the planning authority confirm there are no noise concerns. The wording should be changed so that noise assessment is mandatory where the planning authority specifically confirms there is a noise concern, and voluntary in all other cases.

Question 95: Do you agree with minimising the ingress of external pollutants when the overheating strategy is in use, and that the external pollutants guidance in Approved Document F, volume 1: dwellings should be followed where practicable?
a) Yes
b) Yes, but with amendments to the guidance
c) No, I do not agree with minimising the ingress of external pollutants when the overheating strategy is in use

a) Yes

Question 96: Do you agree with the proposals on security in Section 3 of the draft Overheating Approved Document in new residential buildings?
a) Yes
b) No

a) Yes

Question 97: Do you agree with the protection from falling guidance proposed in Section 3 of the draft Overheating Approved Document?
a) Yes
b) No

a) Yes. AD K should be updated to reference the additional requirements of AD ‘X’ to ensure there is no confusion or conflict over requirements. AD K should then take precedence over AD X, or at least provide clarity on any divergence in standards.

Question 98: Do you agree with the guidance on protection from entrapment proposed in Section 3 of the draft Overheating Approved Document?
a) Yes
b) No

a) Yes

Question 99: Are there any further issues which affect usability that should be included in the Overheating Approved Document?
a) Yes
b) No

b) No

Question 100: Do you agree with the proposed requirement to provide information on the overheating strategy to the building owner?
a) Yes, I agree with the requirement, the list provided and that this should be within a Home User Guide
b) Yes, I agree with the requirement, but think that the list provided should be changed or that this should not be
provided within a Home User Guide
c) No, I do not agree with providing information

a) Non-technical details based on the AD ‘X’ assessment and mitigation measures should be included in the Home User Guide, but full overheating analysis should not be provided as this is highly technical and can be misinterpreted.

Question 101: How do you see this new Building Regulation interacting with policies in local plans?

AD ‘X’ will create a national standard for overheating targets. Planning authorities which currently request overheating mitigation should be encouraged to fall in line with AD ‘X’ instead of setting separate targets locally. There is a potential for planning policy to clash with AD X requirements specifically with regards to GLA planning policy, which does currently allow for mechanical cooling. We strongly recommend there is alignment between the requirements of the Building Regulations and local planning policy on this topic.

Question 102: Do you agree that this guidance on limiting the effects of heat gains in summer, in both Approved Document L guidance for new dwellings and SAP Appendix P, can be removed?
a) Yes
b) No

a) Yes

Question 103: Should the transitional arrangements that apply to the overheating requirements align with the proposed transitional arrangements for Part L and F 2021 for new dwellings, as described in paragraph 5.10.2 of this consultation document?
a) Yes
b) No

a) Yes. It is important for AD L, AD F and AD ‘X’ to be treated as a single update to Building Regulations. The three documents should share the same launch date and follow the same transitional arrangements. This provides clarity and help to remove confusion on larger development about which regulations apply at a given time.

Part L standards for domestic buildings in 2021

Question 104: Do you agree with the proposed minimum fabric standards for existing domestic buildings set out in Table 6.1 of this consultation document?
a) Yes
b) No

a) Yes. This aligns to the model design for the carbon and primary energy assessment and will drive fabric performance. We recognise this will result increased wall build up, but feel reducing energy demand is key to reducing the carbon impact of new development.

Question 105: Do you agree with the draft guidance in section 4 of the draft Approved Document L, volume 1: dwellings on reducing unwanted air infiltration when carrying out work to existing homes?
a) Yes
b) No

a) Yes

Question 106: Do you agree that we should control the primary energy and fabric energy efficiency of new extensions to existing homes when using the SAP method of compliance?
a) Yes
b) No

a) Yes – as well as retaining the Emission Rate

Question 107: Do you agree that the limiting U-value for rooflights in existing domestic buildings should be based on a rooflight in a horizontal position, as detailed in Section 4 of draft Approved Document L, volume 1: dwellings?
a) Yes
b) No

a) Yes

Question 108: Do you agree that we should adopt the latest version of BR 443 for calculating U-values in existing domestic buildings, as detailed in Section 4 of draft Approved Document L, volume 1: dwellings?
a) Yes
b) No

a) Yes

Question 109: Do you agree with the proposed minimum fabric standards set out in Table 6.2 of this consultation document, and Sections 4 and 11 of draft Approved Document L, volume 1: dwellings?
a) Yes
b) No

a) Yes. Condensation analysis should be mandated where an existing element is being upgraded to ensure compliance with the interstitial and surface condensation risks as referred to under AD C.

Question 110: What level of FEES should be used for Part L 2021?
a) Option 1, full fabric specification
b) Option 2, fabric specification x1.15
c) Neither, it should be higher
d) Neither, it should be lower

b) TFEE was introduced to ensure fabric standards were not relaxed where low carbon heating systems are used, whilst providing design flexibility to deliver compliance. We do not consider Option 1 to provide an acceptable level of design flexibility. We note that the fabric elements of Table 6.3 are improved over the current notional building, meaning the like-for-like improvement would exceed a 15% uplift.

Question 111: Do you agree that we have adequately covered matters which are currently in the Domestic Building Services Compliance Guide in draft Approved Document L, volume 1: dwellings for existing homes?
a) Yes
b) No

a) Yes

Question 112: Do you agree with the proposed minimum standards for building services in existing homes, as detailed in Sections 5 and 6 of draft Approved Document L, volume 1: dwellings?
a) Yes
b) No, the standards go too far
c) No, the standards do not go far enough

a) Yes

Question 113: Do you agree with the proposals for replacement fixed building services in existing homes, as detailed in Section 5 of draft Approved Document L, volume 1: dwellings?
a) Yes
b) No

b) No. We do not see how compliance with this proposal is going to be monitored. It is likely that specialist advice will need to be sought to calculate the system efficiency against the primary energy and emission factors.

Question 114: Do you agree with our proposed approach to mandating self regulating controls in existing domestic buildings, including technical and economic feasibility, as detailed in Sections 5 and 6 of draft Approved Document L, volume 1: dwellings?
a) Yes
b) No

a) Yes

Question 115: Do you agree with the proposed specifications for building automation and control systems installed in a new or existing home, as detailed in Section 6 of draft Approved Document L, volume 1: dwellings?
a) Yes
b) No

a) Yes

Question 116: Do you agree with the proposals for extending commissioning requirements to Building  Automation and Control Systems and on-site electricity generation systems, as detailed in Sections 8 and 9 of draft Approved Document L, volume 1: dwellings?
a) Yes
b) No

a) Yes

Question 117: Do you agree with the proposals for requirements relating to the assessment of overall energy performance of building services installations and providing information to homeowners, as detailed in Sections 8 and 9 of draft Approved Document L, volume 1: dwellings?
a) Yes
b) No, I do not agree with providing this guidance
c) No, the guidance should be improved

a) Yes. Section 9.8 should mandate a new EPC is required when a new heating system is installed that is expected to significantly alter the energy performance of the dwelling

Question 118: Do you agree that water softening and water treatment guidance should be removed from formal guidance?
a) Yes
b) No

a) Yes

Question 119: Do you agree with the guidance proposals for adequate sizing and controls of building services systems in domestic buildings, as detailed in Sections 5 and 6 of draft Approved Document L, volume 1: dwellings?
a) Yes
b) No, I do not agree with providing this guidance
c) No, the guidance should be improved

a) Yes

Question 120: Do you agree with the guidance proposals on sizing a system to run at 55°C when a whole heating system is replaced, as detailed in Section 5 of draft Approved Document L, volume 1: dwellings?
a) Yes
b) No, I do not agree with providing this guidance
c) No, the guidance should be improved

a) Yes

Question 121: Do you agree with the proposed changes to the supplementary guidance and the external references in Appendix D and Appendix E, in the draft Approved Document L, volume 1: dwellings as outlined in paragraph 6.8.2.?
a) Yes
b) Yes, but not with the changes to the supplementary guidance
c) Yes, but not with the external references
d) No

a) Yes

Question 122: Do you agree with the proposal for guidance on the calibration of devices that carry out airtightness testing in new and existing domestic buildings?
a) Yes
b) No

a) Yes. A system should be in place to ensure this guidance continues to be relevant and accurate.

Part F standards

Question 123: Do you agree that we have adequately covered matters for existing dwellings which are currently in the Domestic Ventilation Compliance Guide in draft Approved Document F, volume 1:
dwellings?
a) Yes
b) No

a) Yes

Question 124: Do you agree with the proposed changes to supplementary guidance and the external references used in Appendix E and Appendix F, for existing domestic buildings from the draft Approved Document F, volume 1: dwellings?
a) Yes
b) Yes, but not with the changes to the supplementary guidance
c) Yes, but not with the external references
d) No

a) Yes

Question 125: Do you agree with the proposal to align the guidance and standards for work to existing homes to that outlined in Chapter 4 of the Government Response to the Future Homes Standard consultation?
a) Yes
b) No

a) Yes

Question 126: Do you agree with the proposed guidance for installing energy efficiency measures in existing homes, as detailed in Section 3 of draft Approved Document F, volume 1: dwellings.
a) Yes
b) No

a) Yes

Question 127: Do you agree with the content of the proposed checklist for ventilation provision detailed in Appendix D of draft Approved Document F, volume 1: dwellings?
a) Yes
b) No

a) Yes

Question 128: Do you agree with the guidance in Section 3 of draft Approved Document F, volume 1: dwellings when replacing an existing window with no background ventilators?
a) Yes
b) No, the standards go too far
c) No, the standards do not go far enough

a) Yes

Question 129: Do you agree with the proposals in paragraphs 3.29 to 3.31 of draft Approved Document F, volume 1: dwellings in 7.4.11 of this consultation document on work to existing kitchens or bathrooms?
a) Yes
b) No, the standards go too far
c) No, the standards do not go far enough

a) Yes

Question 130: Do you agree with the proposal to provide a completed commissioning sheet to the homeowner, as detailed in Section 4 of draft Approved Document F volume 1: dwellings?
a) Yes
b) No

a) Yes

Impact and Equalities Assessment

Question 131: Please provide any feedback you have on the impact assessment here, including the assumptions made and the assessment of the potential costs and benefits of the proposed options we have made.

No comment

Question 132: Please provide any feedback you have on the potential impact of the proposals outlined in this consultation document on persons who have a protected characteristic. Please provide evidence to support your comments.

No comment