Emergency response?

With increasing concern about the pace and scale of climate change, there are growing calls for radical changes to the energy efficiency requirements of building regulations. Hywel Davies considers the challenges of seeking deeper and faster emissions reductions

There is a widespread view that the changing climate demands more urgent action than ever, with many local authorities declaring ‘climate emergencies’. Many observers are calling for deep and radical cuts in the energy use and carbon emissions of buildings to start almost immediately, and the Committee on Climate Change is increasingly concerned about the slow rate of change.

In England, a major consultation on the future direction of energy efficiency requirements for new homes closed recently, and further consultation on proposals for new non-domestic buildings and refurbishment of existing buildings is awaited. Government’s response to parliamentary calls for regulations to address overheating is also keenly awaited.

This all seems obvious. The relationship between carbon dioxide concentrations in the atmosphere and global temperatures have been known since the work of Swedish chemist Svante Arrhenius in the late 19th century. His calculation of the warming effect of higher CO2 levels is remarkably close to the observed data collected from the late 1950s onwards.

Increased average temperatures and more frequent extreme weather events are occurring around the globe. It seems so simple to seek immediate and drastic improvements to the energy efficiency standards for new buildings. But, in reality, it is a more complex problem.

Carbon emissions from buildings are not the only concern for building regulators right now. Since the Grenfell Tower disaster, which claimed 72 lives and changed many more forever, it has become clear that far too many buildings in England are inappropriately clad, and that those buildings do not comply with Requirement B4 of the Building Regulations, which addresses external fire spread.


“A fundamental duty of government is to ensure the homes we build are safe, and that residents feel safe in them”

Tenants and leaseholders are living in buildings that do not provide acceptable levels of fire safety, while some freeholders wrangle over what they can, legally, be required to do.

Many of those who have leases find they cannot sell their property because of concerns about the external façade construction and the inability to either mortgage or insure the dwelling.

These people consider that the fire safety of those buildings is much more of an emergency than anything else right now. Putting an end to the lethargy, inaction or sheer evasion of responsibility of those wrangling building owners – and making these buildings safe to occupy – is, understandably, the top priority for building regulations ministers right now. This is reflected by the commitments in the Queen’s Speech to a Fire Safety Bill and a Building Safety Bill. The former will clarify legal responsibilities for the external walls of multi-occupied residential buildings under the Fire Safety Order.

Meanwhile, at least one leading housebuilder is urgently assessing its recently completed homes for their compliance with aspects of the regulations. A growing body of evidence over the past two decades shows that many homes do not deliver the levels of energy efficiency expected from their design. Current levels of compliance of new homes leaves significant scope for improvement.

Dame Judith Hackitt’s report provided numerous examples of the failings of the construction sector, and the evidence published by the public inquiry, as well as the Phase 1 report, make it clear that we not only have a performance gap, but also a quality gap in our sector.

She identified significant concerns around enforcement and compliance, issues that some have been flagging up for many years. Those quality concerns are also known to plague the energy performance of buildings in use.

The industry must address quality concerns with new homes, and deliver buildings that really meet the fire-safety requirements and all other parts of the regulations. There is an urgent need to improve those buildings known to need fire-safety improvements. These tasks are far from trivial.

This is the backdrop to the most recent consultation on changes to Part L of the building regulations. It gave options for more stringent emissions reductions, as well as a plan for developing a ‘Future Homes Standard’ to come into effect from 2025.

While changes to the fabric energy efficiency standard are unwelcome – and the proposed timeline to write the Future Homes Standard inadequate for delivering a robust, tested standard for use by 2025 – they do seek to improve standards further and remove current loopholes allowing developers to build to the 2010 requirements in 2020.

The idea that we can just add a further challenging set of energy efficiency targets to come into force this year does not reflect what is possible. The industry does not have the capacity to deliver this, and the regulatory system simply cannot deliver all these objectives at once.

A fundamental duty of government in a developed country is to ensure the homes we build are safe, and that residents feel safe in them. Nobody will want to live in a zero-emissions home if they don’t feel safe there.

We must make significant cuts in emissions from buildings, and quickly. This needs major changes to the way we design and build our homes, and the energy efficiency standards to which we build.

This is why we need to maintain safe, energy efficient fabric standards in 2020 and start to develop the energy efficiency standards for 2025 now – not next year. There is no more time to waste.

About the author
Dr Hywel Davies is technical director at CIBSE