The route to Zero Carbon – Part 2 (The 2013 step change)
On the route to Zero Carbon, what is proposed or likely to happen for the 2013 waypoint?
Previously I talked about where we’ve come from and where the goal posts are (currently anyway). The following covers the consultation proposals and situation for English regulations Part L 2013 proposals, I’ll cover Welsh Part L 2013 Proposals and Scottish Building Standards Section 6 proposals for 2013/2014 in separate posts as each part of the UK is considering differing target proposals. Northern Ireland regulations (2012) only just changed last year to the same level as England and Wales 2010, so their next step will presumably not be until 2015/2016 or so.
English Building Regulations Part L 2013 proposals
Due to Government’s commitments to ‘one in, one out’ and to reduce the burden on builders as well as exempting micro businesses from new regulations until April 2014, they are committed to finding an ‘out’ to balance the new regulations impact. It was stated that if they couldn’t balance the two, then proposals would be cut. For CO2 targets, two options were considered, but as the budget balancing was based on the first option, the second option is presumably fairly unlikely to go through. the two options are:
- An 8% aggregate improvement (approximately a dwelling constructed to Full FEES target, with efficient services and is the Governments preferred option).
- A 26% aggregate improvement (approximately a half way point between Part L 2010 and 2016 on-site carbon compliance levels).
In my opinion, the second option would have been a much more meaningful step. The Carbon compliance level proposed for 2016 represents a 52% improvement over current levels (worth bearing in mind when considering where we’re aiming for – Zero Carbon).
In addition to the 2013 CO2 target, it was also proposed to introduce a regulatory energy target based on Fabric Energy Efficiency Standard (FEES). FEES is an energy demand limit in kWh/m²/year covering space heating and cooling. Two options were considered for the FEES Target:
- Full FEES: 39 kWh/m²/yr. for apartments and mid-terrace and 46 kWh/m²/yr. for end-terrace, semi-detached and detached. The standard proposed by Zero Carbon Hub for zero carbon homes. This level represents at least a meaningful step forward for fabric of the building. Combined with the 26% aggregate target for CO2, this would be a good stepping point towards the proposed 2016 carbon compliance level.
- Interim FEES: 43 and 53 kWh/m²/yr. Less demanding than full FEES, providing greater flexibility in meeting the proposed 8% improvement carbon target.
Interim FEES target would only have a lifespan of this 3 year period of building regulations before presumably being replaced by a more demanding standard, which doesn’t really seem like much of a worthwhile step forward. There are some worked examples on the Zero Carbon Hub website from February 2012, of how to comply with the proposed fabric standards.
FEES is a useful tool to ensure that new dwellings are constructed to ensure a good standard of building fabric, reducing heating demand and therefore emissions and fuel cost.
Hopefully the idea of adding this as a metric required to be met by new dwellings will go through – I’m a little worried that this one will get lobbied against and dropped due to negative publicity as seems to have happened with consequential improvements. The Welsh consultation proposals considered the additional metric too complicated for regular builders, so instead proposed a tighter fabric specification requirement within the proposals.
Other changes consulted on included:
- Elemental backstops were proposed to be retained and tightened (the level at which these are set would depend on the chosen target FEES Level)
- Fuel Factors (these serve to raise the TER for some non-gas heating types, making it easier for them to pass). The proposals were for either leaving them at 2010 levels, reduced levels or removal of the fuel factor entirely (Carbon compliance task groups recommended solution by 2016).
- The introduction of the FEE based fabric standard would reduce the ‘heat pump loop hole’ for Part L 2013, but not necessarily for future carbon targets, hence the long term suggestion to remove artificial support for higher emission heating fuels. Removal of the fuel factor entirely is unlikely this time around due to the additional cost burden.
- As-designed vs. As-built performance – a recognition in Part L 2013 of a potential performance gap between design and as-built.
More work is ongoing to look into this issue, with the Zero Carbon Hub tasked by Government to explore the issues involved. There is a lot of argument as to how far towards zero carbon to move in the next interim step. Some argue for no changes, stating that more dwellings need to be built to 2010 levels before stepping forwards to the next target and that business cannot absorb the costs of further improvements in targets in the current economic climate. Others argue that we should push further towards 2016 targets now and consider ‘allowable solutions’ requirements for the 2016 change. The negative stance is perhaps understandable in light of the current difficult market, but it is also extremely short-sighted, and will make the task of meeting the zero carbon standard within the proposed timescales all the harder.
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