Part L & F Consultations
02 Oct 2019
After years of anticipation surrounding new building regulations, our inbox was hit with a flurry of consultations last night.
The Government has finally published plans for a new version of Approved Document L (for energy efficiency), a new AD F (for ventilation), and confirmed a new regulatory standard for managing summer overheating is on the cards.
These documents currently apply to new-build homes in England, but we’re expecting further publications in the coming months to pick up on Welsh standards, non-domestic development and existing buildings.
We’re still digesting the content and will be releasing a series of articles over the coming months to keep you informed and help you prepare for the coming changes.
To whet your appetite, here are some points that distracted us from Bake Off last night:
It’s a Consultation
Firstly, it’s important to remember there will be no changes until October 2020 at the earliest. The consultations are currently open for public debate and may change before they go live. If you want to have your say about any of these points, head to the MHCLG website before February 7th (https://www.gov.uk/government/consultations/the-future-homes-standard-changes-to-part-l-and-part-f-of-the-building-regulations-for-new-dwellings).
The usual timescale of transitional arrangements is under the spotlight. They want to replace the current 12 months grace period with a stricter system. If construction has started on a specific house or building, the older regulations apply. If you haven’t started on work on that dwelling or building after the grace period has expired, the new AD L applies, irrespective of when the Building Notice was submitted. This new approach could mean we have sites under the same planning consent and Building Notice being constructed to different Approved Documents.
The Target Emission Rate
As you may expect the Emission Rate is being lowered. The Government is pushing for a 31% reduction in CO2 over current standard, but they’ve also published a lighter version to give an option of 20% instead.
Primary Energy and Affordability Targets
The new Part L could have three mandatory targets. The Target Emission Rate stays but the Target Fabric Energy Efficiency would be replaced with the Target Primary Energy Rating. This would measure the total energy demand of a building, rather than just heat demand, based on the natural energy content of the fuels used in the dwelling. A new target could also be introduced to set an ‘affordability’ goal – this might be based on EPC ratings (similar to MEES regulations).
No relaxation for fossil fuel heating systems
One of the proposed changes to AD L sits nicely with the Government’s announcement earlier this year that it wants to ban heating systems using the most carbon intensive fuels. The current Target Emission Rate is relaxed for dwellings that use LPG or oil heating systems – this is to help developments which are off the gas grid. The new Part L gives no such leeway. This isn’t a straight-out ban but will make it far more difficult to comply with Part L when using an oil heating system.
Limiting the powers of LPAs
Could Local Planning Authorities be stopped from imposing additional emission targets over Part L? The Government is considering making changes to the Energy Act (2008) to prevent councils from going above-and-beyond the CO2 requirements of Building Regulations. London is leading the way in this field by setting zero carbon targets on new development. There’s no mention whether this change to the rules would stop authorities from requesting carbon offset payments as an alternative.
Air testing every dwelling
Under the proposals, Air Leakage Testing will become mandatory on every new dwelling, instead of having the option of sample testing. And the maximum allowable target will be dropped from 10 to 8. As Built documents and Energy Performance Certificates won’t be issued until the Air Leakage report is completed, Developers will be expected to submit failed air test reports as part of the final pack of papers filed with Building Control to show they’ve made last minute improvements.
Electric heating systems
BRE has released a new version of SAP (10.1) to work alongside these proposals. Anyone who’s worked with SAP10 emission factors as part of their planning submission will have seen first-hand how a decarbonised electricity network can impact their specification. SAP10.1 goes even further. Electricity is now considered to be less carbon intensive than gas. In theory this means a house with electric heating will fly through the emission target, but will panel heaters comply with the new energy and affordability targets? Heat pump technology will be a definite winner under these proposals.
Managing summer overheating
There have been rumours for some time about creating a new section of Building Regulations to manage internal temperatures (aka overheating). This appears to be moving forward, but details are still under review. One option is to use the basic assessment within SAP to check high-risk dwellings, which would then trigger a more detailed review using thermal dynamic modelling.
The Part F proposals suggest whole house ventilation and windows with opening restrictions should be made mandatory on homes in low air quality areas. This is the first time air quality and pollution has been considered within Building Regulations, whereas historically air quality standards have been set as part of the planning process.
At an initial glance these proposals are going to bring significant changes to the way we construct new buildings. The industry is being driven towards improved fabric standards, low temperature heating systems, less reliance of fossil fuels and more consideration to overheating risks.
We will be providing further analysis on these documents in the coming weeks, as well as updates on parts of the proposals which are still to be confirmed.