Battling for controls

Approved Document Part L is set to grab everyone’s attention when the updated version is published later this year ahead of it becoming law in 2013. When you consider that one of the key elements within it is the planned integration of the Government championed Green Deal, it’s easy to see why it could cause such a stir.

The Green Deal looks certain to be tied into a new interpretation of consequential work when considered in terms of new extensions, changes to building services and changes to the use of space, e.g. the creation of additional office space areas.

There has always been a requirement that all consequential work must meet the latest level of energy regulations. But the definition of what is and isn’t consequential has long been open to wide interpretation on the back of a caveat that classed it as having to be both technically feasible and economic. At the consultation stage of Part L 2013 it was proposed that work would be considered economic if it could qualify for Green Deal financing and this is widely expected to be retained when the updated version is published. This should lead to more clarity and an increase in work being carried out on existing properties to improve their energy efficiency.

Reasonable payback

What this means in practical terms is that if an energy efficiency measure has a reasonable payback, building owners could fund it through the Green Deal – something that could be done with no upfront expenditure and no on-going cost above the current energy costs of running the building. The loan is simply paid through the electricity bill from the energy savings achieved by the added measure. Importantly, the loan would remain with the building rather than being attached to a particular owner.

Whether the Green Deal is a success depends a lot on it being achieved without huge regulation and administrative burden, and how an outstanding Green Deal loan is viewed when a building is sold or part of a building changes occupants or ownership.

One of my key concerns is that the energy calculation tool SBEM will be used to calculate whether an energy efficiency measure meets the payback criteria. In my opinion the SBEM model does not currently fully reflect the energy saving potential of certain measures, most importantly lighting controls. Should this weakness in the model remain it will result in lighting related improvements not being adopted and the significant savings they deliver being missed out on completely.

That said, the Green Deal’s inclusion of the majority of controls, including lighting control systems for commercial buildings, is extremely positive. This is especially true when considered alongside the proposed improvements to Part L 2013, which actively encourage the installation of greater levels of control for lighting in new commercial buildings and schemes. Furthermore, the availability of Green Deal funding for lighting controls and other measures in commercial buildings will potentially go a considerable way to tackling the upgrade of existing stock. All of which begs the question why has SBEM not been updated to better reflect the benefits available from installing lighting controls?

Viable alternative

Another issue is the ease with which the SBEM model can handle smaller commercial properties, which are much more like domestic properties in their construction. The use of SAP, the residential equivalent of SBEM, for such properties isn’t currently a viable alternative as it fails to cover lighting and other types of controls, despite the fact that, like in homes, lighting is the second largest user of energy in these types of buildings.

Part L and the Green Deal are seen by the Government as tools to achieve a minimum level of energy efficiency and to act as a catalyst to drive adoption of wider energy measures, but they are in danger of failing to deliver due to the fact that controls simply aren’t included within plans for the residential sector – a strange omission when you consider the prominent role they have been given within more general areas.

If the UK as a whole is going to come close to delivering the genuine zero carbon targets, both ‘as built’ and ‘in use’, that the Government is promoting then there needs to be an immediate review on how the inclusion of lighting controls is improved within both SAP and SBEM. Such a rethink would place commercial and residential buildings on a similar level and, most importantly, put the power to control energy use firmly in the hands of building owners. And I say with absolute confidence that this new found control would be popular across the board – especially when people realise the financial savings they can and do deliver.

I sincerely hope that the integration of the Green Deal into the final published 2012 update of Part L (especially in sections 2A and 2B) is not dropped as a result of its postponement for the commercial sector scheme.