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Are the proposed changes to the Approved Documents (Part L and Part F) a failure to act responsibly?

December, 2019|

As a business this year we have responded to the consultation process for changes to the Approved Documents because it felt important to do so in the light of UK’s Parliament’s declaration of a climate emergency. Below I have tweaked our letter to Future Homes Standard Consultation. If you agree with it, perhaps 2019 might be first year you also put words to your thoughts and formally respond. Hattie Harman of the AJ magazine noted in a recent tweet how few architects have responded so far

We operate a commercially successful business that provides a timber frame Passivhaus construction system. Our system has been used on multiple domestic schemes to achieve an operational heat demand (under 15kWh/m2 year) that is 80% less than current new build housing to the minimal standards of our building regulations (86kWh/m2 year).

The options presented in the Future Homes Standard consultation proposes a 20% or 31% reduction in emissions (Option 1 or Option 2), compared with current targets set by Part L & Part F 2013. It is our understanding that these options have been designed to provide a step change to achieve net zero emissions homes by 2030/2050. However these new standards could in fact be applied and result in fabric efficiency less than that allowable under the current regulations.

Our work demonstrates that it is possible to achieve net zero emissions homes today. These low energy buildings enable effective use of low carbon heat generation, due to this reduced heat demand. This in turn puts less pressure on the energy network and so expands the growth potential for such technologies.

The Committee for Climate Change and the RIBA 2030 Climate Challenge both now recommend a domestic space heat demand by 2025/2030 that relies on limiting fabric parameters to 40-60% better than Part L1A 2013. The Future Homes Standard does not seem to be correlated with the CCC and RIBA recommendations at all.

The building regulations standards that are set for 2020 will influence UK construction for the next 5-10 years, due to the typical procurement cycle. The IPCC and UN have stated that the next 10 years are critical in limiting catastrophic increases in average global temperatures. We therefore believe the proposals do not go far enough. Further preventing councils from setting targets better that Part L & F will slow the growth of low carbon construction industries, which seems completely counterproductive to the ultimate aim of achieving net zero emissions homes and a ‘green’ economy.

In summary, we do not believe either Option 1 or Option 2 go far enough towards net zero emissions housing. Our business demonstrates such housing can be market ready now, and we see no reason why the building regulations should not be updated to reflect this.

If you also have a business that operates beyond the current minimal standards of the building regulations, then perhaps consider adding your voice to the pressure on government and a very poorly performing sector in terms of environmental responsibility. We have ten years to hit the recommended targets of the UK Climate Change Committee and this is a short window for a whole industry to change. We should be all pressing down on our accelerator pedals not slowing up at the next junction.

Jae Cotterell 

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Buildoffsite Property Assurance Scheme (BOPAS) was developed to address these concerns and perceived risks associated with innovative construction. BOPAS is recognised by the principal mortgage lenders as providing the necessary assurance underpinned by a warranty provision, that the property will be readily mortgageable for at least 60 years.