A number of important consultations have been published recently, to which CIBSE will respond.
The proposed revised National Planning Policy Framework aims to speed up housing and infrastructure delivery, with a stronger presumption in favour of development and more consistency across local authorities – including a proposal to limit their ability to set energy efficiency requirements above Building Regulations. This could also limit local authorities’ ability in other areas, such as embodied carbon.
CIBSE strongly disagrees with the proposal. Local authorities have been setting ambitious standards without impeding development, as evidenced in the LETI response1, to which CIBSE has contributed. Local authorities should retain the ability to set ambitious standards to support energy efficiency and carbon reductions. This can be subject to viability tests on local plans and individual applications (as currently). The government could set a framework for higher standards, as it has for water efficiency through Part G.
The consultation also seeks to respond to the huge expected growth in data centres2, with proposals on energy-intensive development and co-located renewable energy projects.
The consultation on the Home Energy Model (HEM) and associated Energy Performance Certificate (EPC) reforms focuses on existing dwellings. HEM will replace SAP as a more sophisticated modelling methodology and the consultation proposes a modular approach to HEM inputs, depending on available data.
The consultation focuses on replacing the current main EPC ‘energy efficiency’ rating and secondary carbon-based rating with four new metrics: fabric performance, heating system, smart readiness and energy costs. This could have a significant impact on stock assessments and retrofit investment priorities.
As expressed over the years3, CIBSE supports the introduction of separate metrics, rather than seeking a single metric covering multiple issues. It also supports having a dedicated metric on fabric performance, but recommends one that can be compared with actual measured performance.
A smart-readiness metric is the most innovative proposal. There is no well-established approach to assessing and rating ‘smart readiness’, which can encompass a number of technologies and outcomes. Options were explored in initiatives such as the UK Net Zero Carbon Buildings Standard, but with insufficient consensus and supporting data, the approach has been to start data collection on several parameters to inform future metrics and objectives.
The proposed Heat Network Technical Assurance Scheme (HNTAS) will support statutory regulation of heat networks by setting technical specifications covering system design, construction, commissioning and operation, alongside governance arrangements for compliance monitoring and certification. It defines requirements for energy centres, hydraulic design, metering, controls and customer-interface systems.
While the proposed standard sets performance requirements in some areas, it does not set overall energy efficiency or carbon performance requirements. Instead, it focuses on the engineering parameters supporting performance and allowing its verification. Requirements for overall performance outcomes are expected to be delivered through other means.
CIBSE has expressed concerns about how heat zoning would deliver low carbon heat networks4 and welcomes views on the HNTAS proposals.
About the author
Dr Julie Godefroy is CIBSE’s head of net zero
References:
1 LETI Consultations bit.ly/CJLETICo
2 Future energy scenarios: Pathways to net zero, Neso, November 2025 bit.ly/CJFES25
3 Reforms to the energy performance of buildings regime, CIBSE Response, 2025 bit.ly/CJEBPCo25
4 Heat network zoning consultation, CIBSE response 2024 bit.ly/CJHNZCons