Consultation update: Clean Air Strategy, London Plan, EPCs, SAP, Building Regulations

This month, CIBSE’s Julie Godefroy outlines key consultations on carbon and air quality policies

Recent submissions

Clean Air Strategy, Defra

Defra recently consulted on its draft Clean Air Strategy, after the High Court ruled it must do more to tackle air pollution. The strategy clearly tries to address growing public concerns, repeatedly stating Secretary of State Michael Gove’s ambition for the UK to show world leadership.

It is more comprehensive than previous plans, which had a narrow focus on NOx emissions from vehicles, and includes measures CIBSE had recommended,1 such as a better use of smoke control areas and a commitment to tackle carbon emissions and air quality jointly. We can expect future changes to biomass policies, for example, including emissions limits and revised Renewable Heat Incentive rules.

However, we have strong concerns that: 

  • The strategy does not commit to targets in line with World Health Organization (WHO) guidelines. This is rather weak if the government wants to be ‘world-leading in protecting our health’.
  • There needs to be strong monitoring and enforcement. Centrally, the government should be held to account post-Brexit, as it has been by the European Court of Justice.1 There must be adequate resources for local authorities to implement and enforce policies.
  •  There is currently no comprehensive regulatory framework on indoor air quality, and guidelines in Building Regulations Approved Document F are poorly implemented. This should be reviewed.
  • A broader approach is needed, favouring solutions that address pollution at source and offer health, wellbeing and environmental benefits, including better planning to promote cycling and walking and cut transport needs, and incorporation of green infrastructure. The government should support research and development into driving  behaviour change in consumers, and how urban form, trees and vegetation influence air pollution.

London Plan

A revised draft London Plan has been published, following a consultation earlier this year. Some of our recommendations have been incorporated: more recognition of green infrastructure in relation to the urban heat island effect, flood risk and sustainable drainage, and a clearer commitment to long-term air quality targets (see Clara Bagenal George’s article on carbon policies in January’s CIBSE Journal).

However, it is unclear how ambitions for green infrastructure and outdoor spaces, which are crucial for our health and wellbeing in urban areas, will stand against plans for increasing high-density development. Disappointingly, there is little monitoring of environmental objectives, which could jeopardise their delivery in practice.

Current consultations

Energy Performance Certificates (EPCs)

The government is asking for feedback on how EPCs could better drive carbon reduction in new and existing buildings. If you think the current regime and methodology could be improved, this is a big opportunity to respond.

Standard assessment procedure (SAP) version 10

BRE has published a revised version of SAP, not yet for official use in Building Regulations and EPCs. The proposed changes – including making the Criterion 3 solar gains test more robust overall, and halving the carbon factor for grid electricity to reflect actual values – are significant and something CIBSE has been advocating. While not a consultation, comments can be sent to BRE.

Building Regulations

The government is expected to publish a consultation on Part L this winter. Ahead of this, CIBSE would like to hear about changes you would like to see, whether small methodology points or wholesale changes to the energy and carbon savings approach.

We are also interested in your views on how this may be an opportunity to review Part F and better address overheating risk and indoor air quality.

Visit our website to see consultations we engage with.


1 See our response on Environmental Principles and Governance, Tuning in to take notice, CIBSE Journal, August 2018.