Mind the Regulatory Gap!

Energy Efficiency: Building towards Net Zero The House of Commons Business, Energy and Industrial Strategy Committee has recently published a report on Energy Efficiency. Chapter 6 of the report deals specifically with new build properties. The report states that “When already faced with the challenge of upgrading the energy performance of the entire housing stock, it is nonsensical to be continuously making the problem worse by allowing new homes to be built that will also need to be retrofitted. “ The report notes that the prohibitive cost of retrofitting means that in all likelihood these necessary improvement to meet current standards will never occur and dwelling’s will remain inefficient for another generation. The report also identified that “despite receiving billions in taxpayer funds” housebuilders were still inevitably making “profit margins and shareholder returns the overriding priority”; noting that upgrading energy efficiency standards will not be a priority for house builders until there is a commercial case to do so and a level playing field for all developers. Building Regulation Performance Gap The report identified a performance gap between design stage compliance with Building Regulations and actual ‘As Built’ performance. Currently there is no requirement (apart from air testing) for developers to demonstrate that a dwelling actually performs as designed. According to the report the performance gap on fabric heat loss alone has been found to in some cases be more than double the design value. The report committee heard that there are actually potentially larger carbon savings in closing the performance gap than in making standards more onerous. The report furthermore noted that as homes move away from gas-fired boiler and are built with low carbon heat (e.g. Air Source Heat Pumps), if the fabric efficiency of the home under-performs, the impact on consumer bills will be greater than it is now. The cost per unit of energy through low carbon heating technologies is expected to be higher than gas. Energy Evaluation Services Comment EES agrees with the findings of the report and looks forward to early measures been taken to fix the gap between ‘design’ and ‘as built’. EES agrees that House-Builder should supply the information used in SAP calculations to the purchaser so that some form checks could be carried out if performance was questioned. It would also provide an incentive to developers to meet the standards they have published. The recommendation of incentivising post completion testing by house-builders is also considered an essential step forward in order to improve the energy efficiency of dwellings and reduce ‘the gap’.

Electric Cars or Electric Heating … Can the UK have both?

Background The UK government has provided the clearest indications that they are intending to accelerate the programme to reduce the country’s dependence on finite fossil fuels with their associated higher carbon emissions. A report by the Committee on Climate Change (CCC) says that from 2025 at the latest, no new homes should be connected to the gas grid – and should be constructed with super efficient houses and flats heated using low-carbon energy instead. The assumption being that new houses will primarily be heated by renewably sourced electricity until other more innovative sources (including hydrogen) or more widely available. The Big Question The big question is however, will there be sufficient electricity generated to meet the increased combined demands for cars and domestic heating. Even back in 2017 the National Grid identified that electric cars would fuel a huge demand for power, with peak electricity demand predicted to be more than the capacity of the planned Hinckley Point C nuclear power station by 2030. This prediction was based upon the assumption that plug-in cars and vans could reach 9m by 2030 up from 90,000. With the projected further increase in electricity demand to meet UK residential heating usage, the question remains will there be sufficient electricity generated to meet these combined increased demands.! Even if the thorny question of providing the infrastructure for charging electric cars has been solved, It is apparently still not evident that the UK’s National Grid would have the capacity in its system to support a nation full of EVs. It is also certainly not clear that there would be sufficient supply to meet the simultaneous demand for charging of cars overnight at the same time every evening, just when domestic heating requirements were being ramped up. Any Answers? Ofgem has sought to answer some of these questions and have made its own proposals to encourage flexible charging by providing incentives for customers to charge their electric vehicles at the right times (i.e. outside peak demand times on the grid). Their proposals would also help to keep energy costs down for all consumers as technology would allow stored electricity from electric vehicle batteries to be sent back onto the grid when it is needed. Contact EES consultants for advice on sustainable design of dwellings. Why not join the debate.

Changes to MK Planning Energy Policy

The new Plan:MK2016 – 2031 (adopted March 2019) introduced a new Sustainable Construction & Renewable Energy Policy. It is envisaged that this type of policy is likely to become more widespread as Planning Authorities seek to drive development towards zero carbon. The new policy replaces the previous Local Plan Policy D4 which introduced sustainable construction requirements that pre-empted higher national energy standards in buildings. Policy SC1 Sustainable Construction confirms that development proposals will be required to demonstrate how they have implemented various requirements including the following: Materials & Waste Reduction Energy & Climate Change Water Usage Retrofitting Materials & Waste Reduction The policy encourages the reuse and recycling of land and materials where possible. It looks to encourage the incorporation of green roofs to improve water management and provide space for biodiversity. The policy encourages developers to consider the lifecycle of any proposals including how they can be adapted to meet changes in social and economic needs. Energy & Climate Policy SC1 encourages the implementation of the energy hierarchy for new developments. It also encourages schemes to consider energy storage and demand management to support local and national energy security priorities. SC1 also requires developments of 11 or more dwellings and non-residential developments with a floor space of 1000 sq.m or more to submit an Energy & Sustainability Statement to demonstrate how the proposals would meet the following requirements: Achieve a 19% carbon reduction improvement upon the requirements set within Building Regulations Approved Document Part L 2013. Provide on-site renewable energy generation, or connection to a renewable or low carbon community energy scheme, that contributes to a further 20% reduction in the residual carbon emission. Make financial contributions to the Council’s carbon offset fund. For dwellings calculate Indoor Air Quality and Overheating Risk performance. Implement a recognised quality regime that ensures the ‘as built’ performance meets design. Establish a recognised monitoring regime to allow the assessment of energy use, indoor air quality, and overheating risk. Water Usage Policy SC1 also establishes that new dwellings will have to limit water consumption to 110 litres/person/day and wherever possible incorporate water reuse and recycling and where viable implement rainwater harvesting. Retrofitting Under the new Policy, proposals which would result in considerable improvements to the energy efficiency, carbon emissions and/or general suitability, condition and longevity of existing buildings will also be supported. For further advice check the consultancy service that EES can provide for developers.

Is this goodbye & farewell to the radiator?

The government has given a firm indication that it wishes gas-fired boilers to be phased out by 2025 as shown in the  CCC Infographic. The Committee on Climate Change recognises that decarbonising and adapting the UK’s housing stock is critical for meeting legally-binding emissions targets by 2050. The CCC reports states that the Government needs to take action in five areas NOW. This includes: Enforcing standards, ensuring compliance with those standards and closing the ‘performance gap’. Delivering a step-change in construction skills, Retrofitting existing homes so they are low-carbon and resilient to a changing climate. Ensuring new homes are low-carbon, energy efficient and climate resilient  Addressing urgent funding needs. The report stated that ‘no new homes should be connected to the gas grid by 2025. This could mean the end of radiators and gas hobs as we know them. CIBSE published a post last year 2018 which after discounting Hydrogen sought to identify other possible alternatives. Biomass (woodchip or pellet) has long been heralded as a low carbon alternative to gas, but as the post pointed out, there is just not the resource to meet the demand on a large scale in the UK. District heating systems are becoming increasingly popular. The Bristol Heat Network is an example of such developments. District heating systems using heat from waste incineration plants, is one way of getting away from using fossil fuels. Heat Pumps (Air Source or Ground Source) are perceived as a possible alternative to gas-fired boilers but come with a significant cost penalty to the developer. They also work most efficiently with low temperature emitters (e.g. under floor heating) and could not deliver the temperatures required for standard radiators. So is this goodbye and farewell to the humble radiator? For more information on how we can advise and assist in improving energy performance of dwellings, just drop us a line. Contact Us  

Making Best Use of Energy Statements

Background Many Local Authorities require Energy Statements as part of a planning application and have specific policies relating to sustainability, energy efficiency or Carbon. Typical requirements are that the developer should present a statement outlining how they intend to achieve a percentage of renewable energy or how a scheme is likely to meet current Building Regulations. These energy requirements may also state that proposals should maximise energy efficiency and conservation through: orientation, layout and design of buildings, use of natural light and solar gain, and taking full advantage of opportunities to use renewable or alternative energy sources. Some policies  may also require proposals to demonstrate how trees and vegetation have been used to achieve visual acoustic, energy saving, wildlife and other environmental benefits. Increasingly Local Authorities are encouraging developers to link energy statements up front with Building Regulations Part L and to adopt a Fabric First approach in order to lower energy demand above and beyond the requirements of current Regulations before deciding on the most appropriate renewable energy technology. Design Issues This up front approach although laudable is not without its issues for the developer. The scheme design may be at a preliminary stage and detailed specification associated with fabric, glazing heating and ventilation etc. may not yet have been considered. Indeed the scheme as proposed may not ever be built and as a result the ‘developer’ may see the energy statement as an unnecessary planning ‘tick box’ exercise. On occasions the architect/designer involved during the planning process may not be retained for the build out when it does occur. The resulting Energy Statement included with the application may therefore be based upon notional, target or generic specifications and apart from comprising the general size of the development may not bear much relevance to the finalised scheme. Alternatively in the absence of detailed specification the Energy Consultant may be left to propose a possible design solution that demonstrates compliance with Part L Things to Consider: In our view an Energy Statement is the ideal point at which to review all sustainability options including risks and opportunities and therefore it could and should provide far more than just a validation tick box. Given that achieving compliance with Part L is not always as straight forward as it used to be. Many a developer has discovered to their cost that their scheme does not comply with Part L just at the point when the roof is about to be built. When requesting an Energy Statement it is recommended that the developer should consider the following: Is the Statement considered simply a validation exercise to get through planning. Will the scheme proposal referenced in the Statement as it stands ever be built? Is it considered important that the scheme provides a viable, sustainable, comfortable solution for future occupants? If the scheme referenced in the energy statement was to be built as it is proposed would it actually meet Part L? Are there any energy features referenced in the Statement that would need to be considered early on in order to provide any benefit. Are there specific BREEAM/HQM requirements in place for the scheme that need to be considered as early as possible. We recommend a chat with our sustainability team at EES in advance to ensure that  the Energy Statement requested provides the specific requirement of the Planning Authority and other concerned parties.  

1 Million New Homes?

Background Last year the Government hit its target of building 200,000 homes each year in England, putting it on track to fulfil the promise it made two years ago to build one million homes by 2020.  With this ambition however, comes increasing pressure on finite resources including energy & water. It also increases pressure on waste handling, roads and drainage. Sustainable designs attempt to join the circle of providing the requirements for dwelling without impacting on the environment for future generations. Standards Most developers will be aware of such schemes as Code for Sustainable Homes (CfSH) or Home Quality Mark (HQM) or BREEAM that establish a framework of standards for ensuring residential schemes achieve a certain level of sustainability. The standards include targets for: Energy & CO2 emissions Water Usage Materials (including sourcing) Surface Water drainage Water Management Daylighting / Sunlight provision Noise reduction / sound insulation In terms of energy efficiency / CO2 the standards refer to current Building Regulations Part L encouraging developers to go beyond minimum compliance. Additional credits are provided for schemes that incorporate some form of renewable or Low Carbon technology into their proposals. This may include the use of: Photovoltaics (PV)/Solar Hot Water Heat Pumps CHP Biomass Wind Turbines Heat Recovery In terms of water usage targets are set for reducing the consumption of potable water through the use of efficient fittings, appliance and the installation of water recycling systems. Higher grades of compliance are set at <80 litres / person per day compared to more typical <120 l/p/day. Energy Evaluation Services Consultancy EES have sustainability consultants with experience in sustainable design and certification.Our team can assist designers in achieving sustainable targets including energy/CO2 and water efficiency. We can provide Sustainability/Energy Statements for planning applications. We can also assist in providing SAP calculations & EPCs / Part L certification and production of the development of thermals models if required.