The government has announced its intention to review Part L of the Building Regulations. This was first included in the Clean Growth Strategy in October 2017, subject to the outcome of the Independent Review of Building Regulations and Fire Safety, which reported in May 2018. Beyond this statement of intent, however, it has not formally announced such a review and what its scope will be.
The ambition and resources that will be put into this Part L review are currently unknown, especially as the government already faces pressing demands for regulatory reform post-Grenfell.
Action to reduce carbon emissions from the built environment is, nonetheless, urgently needed – as highlighted in this summer’s report by the Committee on Climate Change1 – and, now, most starkly in the new report by the International Panel on Climate Change.2
CIBSE believes the current approach in Building Regulations Part L does not deliver sufficient reductions in carbon emissions in practice. This is partly because calculations under Part L only cover regulated emissions (with unregulated emissions often a very significant part of the total actual emissions), and are not necessarily a representation of actual occupation and operational conditions. We, therefore, recommend an overall review of the requirements and methodology.
We would like the upcoming review of Building Regulations to be as well informed and effective as possible
In addition, we believe there is a need to improve the treatment of overheating risk and indoor air quality in Building Regulations. As covered previously,3 both are inadequately dealt with in current Building Regulations and Approved Documents, with overheating addressed only through a simplistic static assessment and air quality addressed only through ventilation, without criteria for overall resulting indoor air quality and no consideration of outdoor pollution.
We would like the upcoming review of Building Regulations to be as well informed and effective as possible. So we have been consulting with members and the wider industry on changes they would like to see, and the speed with which these should be implemented. This will inform a CIBSE position paper on recommendations for government that we intend to circulate to BEIS and the Ministry of Housing, Communities and Local Government. We will also look to engage with the Committee for Climate Change on these issues, with a view to both the short- and longer-term agendas.
We have already gathered views from previous consultation exercises, a recent workshop with members and the wider industry, and a feedback session in association with the London Energy Transformation Initiative (LETI). Our position paper will be published shortly at www.cibse.org/news-and-policy/policy
Please get in touch if you would like to be involved in the next stage, when we will be developing a more detailed response to the government consultation, once published.
The feedback we are looking for includes:
- Parts L and F, and all the associated guidance, including the Approved Documents and compliance guides for new buildings and works to existing buildings.
- As well as changes, what you think currently works well and should be retained in Building Regulations Parts L and F.
- Overall approach, as well as more detailed points that, in accumulation, could lead to non-negligible improvements.
- How the methodology may have been interpreted and incorporated – or not –within approved software, if you feel this has a significant detrimental outcome on performance, or delivers perverse outcomes.
All consultations we engage with can be found here.
- CCC 2018 Progress Report, June 2018.
- IPCC, 1.5oC report, October 2018.
- See, for example, CIBSE’s response to the Environmental Audit Committee enquiry on heatwaves, and to Defra’s Clean Air Strategy consultation.
Julie Godefroy is technical manager at CIBSE.