Primary concerns: how the revised EPBD will impact SAP and SBEM

The latest revisions to the Energy Performance of Buildings Directive have now been published. Hywel Davies considers the implications and possible consequences for energy-related regulations for buildings in the UK

The revised Energy Performance of Buildings Directive (EPBD) was published in the Official Journal of the European Union1 on 18 June 2018. Unlike the 2010 recast, which was a completely new text, we now have a series of amendments to the recast text, making it a little harder to digest. Some significant changes are clear, however. They will also trigger a chain of further consequences for the regulation of buildings in the UK.

The amended EPBD (Annex 1, new section 1) requires the energy performance of a building to: be expressed by a numeric indicator of primary energy use in kWh/(m2.y) for the purpose of both energy performance certification and compliance with minimum energy performance requirements. The methodology applied for the determination of the energy performance of a building shall be transparent and open to innovation.

The consequence of this change is that the national calculation methodology (NCM) and the SAP and SBEM tools will need to be reviewed. We will also need to consider how the NCM is affected by a further requirement in the revised Annex, which is that ‘Member States shall describe their national calculation methodology following the national annexes of the overarching standards, namely ISO 52000-1, 52003-1, 52010-1, 52016-1, and 52018-1’.

EU directives apply to the UK because it is still an EU member state

We are due to be building ‘nearly zero-energy buildings from January 2021’,2 so we will also need to define what meets that requirement.

The existing directive already requires member states (and we are still one) to review their current energy standards every five years.

Having last reviewed Part L in England, and its equivalent in Wales, in 2013 – with reviews of Part F in Northern Ireland and Section 6 in Scotland at a similar time – we now need to review them anew. This offers a significant opportunity to address known areas of concern with the current guidance and requirements, as well as to review the NCM.

The Clean Growth Strategy and the associated Grand Challenge, announced last month, commit us to this, too. They also commit us to reduce the use of high-emission fuels off the gas grid, so we need to encourage greater use of low carbon technology there, and the future-proofing of new off-gas grid buildings so they can be moved onto lower carbon systems. And that is not all. With a rapidly decarbonising grid, there are calls to reconsider the role of fuel factors and the carbon emissions factors used in Part L that should not be ignored.

There are increasing reports, and expert witness appointments, in relation to overheating of new dwellings and other buildings, with implications for cooling energy and, therefore, a knock-on impact on the NCM. If cooling to mitigate overheating becomes typical, the revised Annex will require it to be included in the NCM. We need to think again about how we address overheating in Part L.

Finally, various studies consider the impact of (and compliance with) current airtightness provisions. The Association of Noise Consultants is developing guidance to address the increasing challenge of delivering acoustic and thermal comfort together effectively.

We must seize the chance to review the regulation of energy and comfort in buildings

While they are termed ‘comfort’ issues, there is growing evidence that buildings – especially homes – that overheat, are poorly ventilated or are unduly noisy (or even very quiet) are creating yet another latent drain on our overstretched health services. So they are health and welfare issues, and fall within the scope of the Building Regulations. We should now take a systematic and holistic look at these aspects of the regulations in the Part L review. We may also need to look at Parts F and E.

The Grenfell tragedy has caused the most intense scrutiny of how we regulate and manage the operation of buildings since the Ronan Point explosion 50 years ago.3 Dame Judith Hackitt’s assessment ‘that the whole system of regulation… is not fit for purpose’, has triggered a major programme of work, details of which the government has promised to announce in the autumn.

I am certain this will result in the greatest change to our system of Building Regulations in at least a generation. We must seize the chance to review the regulation of energy and comfort in buildings alongside that, to ensure that what we build and refurbish is both safe and healthy to live in.


  1. ‘Directive 2018/884 amending the Energy Efficiency Directive (EED) and Energy Performance of Buildings Directive (EPBD)’, which can be found in all EU official languages at
  2. Building Regulations 2012, Regulation 25B requires this from 1 January 2021.
  3. On 16 May 1968, a gas explosion in the kitchen of an 18th-floor flat resulted in the collapse of the south-east corner of Ronan Point, a 22-storey east London tower block, causing four deaths and 17 injuries. The subsequent inquiry led to a significant review of Building Regulations and the treatment of progressive collapse.

Hywel Davies is technical director at CIBSE