BEAMA has given a mixed reaction to the overdue release of the Building Regulations Part L guidance documents. Although frustrated at the delay and lack of ambition of the regulations, industry can now progress with a clearer plan towards April 2014 and beyond. In several areas, the guides reflect constructive discussion between DCLG and industry, and BEAMA will maintain its regular engagement with Government to press for continuous improvement in building energy efficiency.
BEAMA welcomes the minimum Fabric Energy Efficiency standard as a good step forward that helps to establish a ‘fabric first’ approach. Conversely, the 6% overall improvement on domestic standards from 2010 regulations is weaker than the plans announced at consultation stage and is a disappointment. This will not only slow the progress of improving energy performance, but also risks harming industry confidence.
Moreover, this calls the proposals of the Housing Standards Review into question. The plans to drop the Code for Sustainable Homes combined with only a 6% uplift in new-build standards will leave developers without any recognised, truly progressive target that could incentivise construction of high efficiency homes. Consequently, BEAMA believes the Code ENE1 and the Planning and Energy Act should be retained.
Furthermore, to ensure the intended benefits of the regulations and guides are achieved in practice, they need to be adequately enforced. This is particularly true for Regulations 27 and 27A, which require accurate design specifications to ensure a close match between designed and achieved performance. If designs are not seen through, and measures are added or changed during development, building performance is at risk.
Despite these reservations BEAMA is encouraged by several positive provisions. The flexible and performance-based regulations give options for compliance, helping to make requirements achievable. The retention of the fuel factor and steps toward future proofing for electrification of heat are also welcome.
Evidence of Government listening to industry is shown in the improved clarity of heating controls guidance, and promotion in the Compliance Guide for the first time of heating system filters.