The government has made numerous announcements in the past two years about its intended direction on energy, carbon and the environment. Many of these have been framed by the Clean Growth Strategy and by Theresa May’s Grand Challenge to ‘at least halve the energy usage of new buildings by 2030’, and ‘halve the costs of reaching the standard in existing buildings’.
There are some glaring omissions in the Clean Growth Strategy: it is silent on fracking, the expansion of Heathrow, and the government’s moratorium on onshore wind in England, even though all of these are important parts of the national infrastructure and environmental landscape, with potentially significant negative impacts.
There is, however, a lot that CIBSE welcomes and which is aligned with advice from the National Infrastructure Commission and the Committee on Climate Change, including: the very existence of a strategy, which can help long-term decisions, innovation and investment; the continued commitment to carbon reductions; and the attention to energy efficiency and retrofit.
We need to see leadership from public building occupiers. It is a very poor signal that the NAO occupies a building with a G-rated DEC
Unfortunately, more than a year later, there has been little progress. Some delay is understandable when the Ministry of Housing, Communities and Local Government is working on regulatory reform in response to the Grenfell tragedy, and government is grappling with Brexit. However, there were stark reminders last year of the urgent need to reduce carbon emissions dramatically (‘Time to act’, CIBSE Journal, November 2018). CIBSE highlighted concerns in response to the recent parliamentary inquiry on energy efficiency, and here are some examples.
The first implementation phase of the minimum energy efficiency standards (MEES) came into force last year, requiring private rented properties to have an Energy Performance Certificate (EPC) rating of E or above. Unfortunately, government has ruled that residential landlords need not spend more than £3,500 to achieve this, even if this may result in tackling only about half of the F- and G-rated properties. It’s difficult to reconcile this with the government’s ambition for fuel poverty to be reduced and for most homes to be EPC-C by 2030.
Retrofitting existing building stock is particularly challenging, and we need to maximise opportunities from ‘trigger points’, such as sales, new leases, and works requiring building regulations and/or planning approval. MEES should ensure that as many properties as possible are upgraded. There should also be a clear trajectory of progressive tightening, so that landlords who wish to are encouraged to go further than the minimum E rating, thereby reducing their need for further expensive and disruptive works in the future.
EPCs and DECs
The register of EPCs and Display Energy Certificates (DECs) for public buildings is still an under-used resource, because its publicly available data is often of poor quality and not regularly updated. As a result, it does not raise public awareness. Nor does it act as a driver for occupiers of public buildings, or help professionals analyse building performance data to turn it into useful information, such as benchmarks or trends in the best buildings. Improving the quality and functionality of the register is a low-cost measure that would be of significant value to industry, government and academia.
In parallel, we need to see leadership by public building occupiers, demonstrating a responsible use of energy resources and of our money. It is a very poor signal, for example, that the National Audit Office occupies a building with a G-rated DEC.
Sustainable targets in planning
Finally, years after the 2015 Housing Standards Review – and despite the Localism Act – there is still great uncertainty and confusion about whether local authorities (except the Greater London Authority, which has greater powers) can set energy, carbon and sustainability targets beyond national standards in their planning requirements. We understand that improvements over Part L equivalent to the (now defunct) Code for Sustainable Homes Level 4 are allowed, but government has not confirmed this widely or unambiguously. Even this constrains local authorities who wish and are able to require higher standards towards zero carbon – and it does not cover other sustainability issues, such as green infrastructure. This really should be sorted as soon as possible, to let local authorities show leadership.
Building Regulations Part L and F
As mentioned in previous columns, CIBSE has produced a position paper with recommendations for changes to Building Regulations Part L and F, covering energy, carbon, air quality and overheating (bit.ly/CJFeb19JG). Since then, government has confirmed that the upcoming review will indeed cover overheating and air quality, as well as energy and carbon. We very much welcome this, and government is expected to consult later this year.
The Department for Environment, Food and Rural Affairs has published a number of important documents in recent weeks:
■ Clean Air Strategy: The revised document still fails to propose air-quality objectives aligned with the World Health Organization, as we recommended. However, it shows significant improvements in acknowledging the need for more attention to indoor air quality and to prevention through the planning system, both of which we have advocated.
■ The Environment Bill sets the framework for environmental regulations and enforcement post-Brexit, and it proposes to enshrine the 25-year Environment Plan in statute. It also comes with a draft monitoring framework of environmental indicators. This is encouraging, and we will give a more detailed update in next month’s Journal.
■ Monitoring framework for the 25-year Environment Plan: While we haven’t looked at the detail yet, the creation of indicators to monitor and report on environmental conditions is very encouraging in itself.
We will comment on these in next month’s Journal.
■ Heat Networks – Code of Practice for the UK. Revised edition. Closing date for responses is 10 February.
■ Decarbonising heating: Overview of current evidence. Closing date for contributions to a CIBSE response is 12 February.
■ All the consultations with which we engage can be found at cibse.org/news-and-policy/consultations