Elmhurst issues response to Welsh Part L and F Review
On 19th December 2019 the Welsh Government published its Building Regulations Part L and F Review consultation which proposed, amongst other things, an 80% reduction in carbon emissions from new dwellings by 2025.
This was accompanied by a proposed interim step in 2020 which established two options: a reduction of either 37% or 56% in carbon emissions. The deadline for responding to the Consultation is Thursday 12th March 2020.
Elmhurst widely communicated its inital thoughts about the consultation and quickly summarised the proposals that it made upon its release back in December 2019. Elmhurst then embarked on a tour of training events to ensure that energy and housing professionals fully understood the proposed changes made by Welsh Government. The Welsh Building Regulations Part L and F review mirrors many of the proposals estbalished within MHCLG's (England's) Future Homes Standards, however, there does remain some key differences. These include the proposed uplift to energy efficiency standards in 2020, which aims to push carbon reduction further, the use of MVHR in the notional dwelling, and also the minimum fabric standards. Following feedback from members Elmhurst is delighted to publish our formal response to the consultation.
Overview of Elmhurst's repsonse
1. Part L 2025 should reduce carbon emissions by 80% for new dwellings by 2025.
2. With the long term goal now clearly established, there should be two regulatory changes planned in 2020 (update to SAP 10 and a 37% reduction in carbon) and 2025 (update to SAP 12 and an 80% reduction). In addition, there should be an intermediate change to SAP 11 in 2023 which can include an update on carbon intensity values and changes to accept new and innovative technology.
3. The ‘triple lock’ of primary energy, carbon and cost metrics offer a balanced assessment of energy efficiency in homes. However we would recommend that a Fabric Energy Efficiency Standard be introduced to ensure a fabric first approach.
4. Although MVHR will undoubtedly have an important role in low energy homes in the future, we agree with concerns over their use at this time due to the appeared lack of enforcement of Part F.
5. The uplift to minimum back stop values for both fabric and services are acceptable. We applaud Welsh Government for going further than other regions in regards to the fabric standards.
6. Build costs may be reduced by reducing the space heating demand to 15 kWh/m2/yr however the focus on space heating demand only could result in other unintended consequences for homes.
7. The Energy Performance Certificate should be used to communicate the three, equally important, metrics of primary energy, cost and carbon. This essential document should also be used to identify the version of the building regulations against which compliance has been assessed and identify any issues, such as where air tightness levels and ventilation strategies may be incompatible.
8. Cost should be expressed in terms of a minimum EPC rating, and we propose B from 2020 and A by 2025 with incentives such as lower rates of stamp duty be given to early adopters.
9. All “requirements” should be specified in the legislation itself and the approved documents should only ever be guidance to achieving compliance. Items of best practice should be omitted and left to trade bodies and competent persons schemes to produce.
10. SAP must be maintained as close to the truth as possible. Corrupting fuel factors, which have been used as an aid to transition from high fossil fuel, should be removed
11. Elmhurst believes that actual carbon values, rather than optimistic predictions, should be used in SAP and revised with the proposed updates in 2020, 2023 and 2025.
12. Future proofing homes is sensible but unintended consequences should be considered. For example, oversized radiators needed for low temperature systems may be positioned poorly, and the increased body of water may impact on the responsiveness of the system.
13. All relevant documentation produced in the design and build phase, including the new Building Regulation Wales Part L report (BRWL), EPCs, evidence and photographs should be made available to the regulatory bodies, the customer and all future owners of the building through a property “log book”.
14. Ventilation systems should be designed by a competent person and then independently inspected and tested before building regulations sign off.
15. The proposed BRWL report is a good method of demonstrating compliance at the ‘design’ and ‘as built’ stages but these must always be produced by an accredited On-Construction Energy Assessor (OCDEA). Building Control must see evidence of design compliance before building commences.
16. Obtaining evidence of compliance, including photos, will reduce the performance gap. Photos should be captured independently of the building owner but not necessarily by the OCDEA. Responsibility for compliance must remain with the builder.
17. All new homes should be subject to an airtightness test.
18. Pulse should be introduced as an alternative method of testing buildings, even those below 1.5 m3/m2/hr.
19. Transition periods for new regulations should be limited to 12 months from the date the legislation becomes effective and, from that date, any new home that as presented for Building Regulations sign off must comply with the new regulations.
Elmhurst’s On Construction Support Team Leader, Jason Hewins, said “We applaud the Welsh Government for setting an ambitious target for energy efficiency in new homes for the next five years. As always we have spoken to our members in order to create our consultation response and would encourage all members to respond themselves before it closes on 12th March. The Consultation documents can be found here. As always we will keep all members informed of any future developments from Welsh Government.”
Consultation Information: https://gov.wales/building-regulations-part-l-review-0