Future Buildings Standard by 2025 or zero carbon now?

The Government claims that agreeing the proposals in the Future Buildings Standard (for England only) consultation  (ending 13 April 2021) would provide a pathway to highly efficient non-domestic buildings which are zero carbon ready, better for the environment and fit for the future. At https://www.gov.uk/government/consultations/the-future-buildings-standard and responding online at

  https://www.smartsurvey.co.uk/s/FutureBuildingsStandard/

The Government’s preferred option is to increase the standards in Part L of the Building Regulations in readiness for the proposed introduction of the Future Buildings Standard from 2025.   Given that the building sector is not having to wait for any technological innovations to achieve net zero or negative carbon there is no excuse and no evidence id provided to delay the raising of standards in 2021 or 2020 at the latest.  A systems analysis indicates that the demand for electricity in transport and manufacturing requires the demand from the buildings sector to be minimised as soon as is possible.

It  is difficult to know what to make of the statement, "We are committed to moving at pace and will implement higher energy efficiency standards to the fastest achievable timeline, Our ambition is for the Future Buildings Standard to be implemented in 2025."? The consultation invites the response that this would be too late, adding to the legacy of buildings needing upgrading.  

The consultation says that many responses to the Future Homes Standard "...raised issues and concerns regarding the energy efficiency of buildings which went beyond the scope of our consultation proposals and the existing Building Regulations. These topics included: embodied carbon; Modern Methods of Construction; suggestions for how we can further address the performance gap of new buildings." Impatience is wearing thin waiting for the Government to address some of the broader and more fundamental questions around how all new buildings are designed and constructed to be fit for a zero carbon future. With a prompt from the Climate Change Committee there is a hint that using more timber in construction will sort the problem of construction carbon, avoiding the issue of sustainable sources, the substantial scale of carbon emitted in constructing services and infrastructure, and the 'building beautiful' agenda where there will be votes in bricks and mortar.

The consultation asks for views on alternatives, Option 1 aimed at a 22%improvement based on services and Option2 (27%) based on fabric. The only assumption to be made on why these are not combined into an improvement equivalent to net zero or negative carbon is the cost. To economise on the energy efficiency of buildings in a climate emergency is the epitome of a 'false economy'. The claim that the proposal is the highest standard for each element which is still cost-effective using a simple measure of payback for investment over the life of the product or work (ie 7 years) is applying a measure that ignores the infinite costs of climate collapse.

The references to 'world leading' are meaningless unless the Carbon Budgets set by the CC are being met. And even then, carbon neutrality by 2050 probably means 3degrees of warming without negative carbon technologies setting course from over 450 parts of carbon per million back to 300ppm.

Saying that improving the energy efficiency of the existing housing stock will be the subject of other government consultations draws attention to the latest 'green deal' already showing signs of failure and scratching the surface of the 25m plus dwellings needing deep energy refitting.

 A specific example of misdirection is 6.6.7 saying that, "Although Option 1 would support a smooth transition to the Future Homes Standard by increasing the skills of people building fabric elements of homes, it may also make it less appealing for some developers to install heat pumps under Part L 2021. This is because the difference between the costs of installing heat pumps and the notional building specification, which has a gas boiler and solar panels, will be reduced. However, a home built under this specification with a heat pump will still have a lower capital cost than one built with a gas boiler and solar panels, at £3134 and £4847 respectively." The Future Buildings Standard, representing a significant level of interference and regulation is evidence that the Government understands that carbon reductions from buildings will not be delivered by the private development industry by applying current measures of profitability.  In these circumstances the Government should be persuaded to take the logical step of ensuring that these regulations are consistent with net zero or negative emissions. 

You could read all 183 pages and comment on the U value of roof lights measured horizontally or at an angle, or take the opportunity to remind the Government that there is an emergency now not in 2025 and that early carbon emission reductions matter most.  Given that the building sector is the easiest to de-carbonise with no technological innovations necessary, all new buildings should be carbon negative in construction (eg timber and lime) and solar positive in operation (ie thermal and PV panels). It is also important to pressure you local council to take these more effective measures.