Previous post:

Next post:

Part L 2010 consultation – CIBSE/Sponge debate

by Mel Starrs on September 9, 2009

in Events & Conferences, Part L

In the first of this series of posts, I set the background to the Part L 2010 consultation. In this post I am going to look at the issues which were raised at the recent Sponge/CIBSE consultation event , which I attended on 20 August.

Hywel Davies presented 7 issues which were of concern to CIBSE:

Part F – Ventilation. With the increasing demand for more airtight buildings, especially dwellings, the requirement for ventilation is being reviewed, the compliance guide contains installation requirements for natural and mechanically vented systems as well as an installation and commissioning checklist that should be completed as part of the installation handover and signed and approved by a person “qualified” to do so. For more information see volume 3 of the consultation

I will admit I haven’t had time to fully come to grips with Part F. The points made by Hywel were that there will be a drive towards more mech vent in homes. Whilst in principle this is not a problem, he raised some concerns regarding installation, commissioning, operating properly and maintaining correctly.

I have to concur with Hywel on this one – hand on heart – when was the last time each of you cleaned the filter/grille on your bathroom extract fan – especially anyone in rented property?

Hywel also had concerns with fuel poverty and affordable housing – there is already evidence of unauthorised interventions in the sector with regards to fans in the past.

Again, I have to concur – I had first hand experience of this in Bucks County Council in the late 90’s with whole house mech vent systems in council housing – was perceived to be a cost and so many were ‘imaginatively’ disabled.

Process energy. The proposed approved documents clarify that energy efficiency requirements apply not just to spaces providing human thermal comfort, but also to any building space where energy is used to condition the indoor climate but can the energy efficiency measures be easily applied to buildings where heating and cooling is used during a ‘process’? To read the relevant section of ADL2A start at page 111 of volume 2

 

 This relates to consultation Question 69: Do you agree that Part L should set standards for buildings which use energy to condition spaces that contain processes, such as computer rooms and cold stores?

Server rooms – this was a hot topic of debate on the night. Should server rooms be covered by Part L or not? As they cover process rather than comfort, one school of thought (which I would agree with) thought not, others thought they ought to be.

Part L deals with the building and fixed services. Computer server rooms consist of often changing equipment, with loads varying to meet the demands of the occupants and as such should not be treated as fixed services.

Processes such as computer rooms will be covered by CRC (for many occupants) and any future carbon tax mechanisms. As such, they should not be included in Part L (although they should indeed be incentivised to be as efficient as possible). Building Regs should stick to what they were designed for and not used as a mechanism for regulating things outside the scope of buildings.

Micro vs macro. The proposals focus on compliance for individual buildings but should there be more to promote district heating solutions? For more information see page 356 of volume 2 (non-domestic) and page 267 (domestic)

Tension between Building Regs and Planning requirements – micro vs macro. There is a gap between community/district and building solutions – again, this is something which should be anticipated for, but not led by Building Regs. i.e. do their best to avoid penalising community heating as a solution. There were a few points raised about biomass – an increasing import industry not really giving fuel security, and also pollution issues

Compliance. A theme of the consultation is closing the gap between ‘design performance’ and ‘real performance’. Some of the proposals are the Accredited Construction Details scheme, wider use of Competent Person schemes, design stage BER/TER calcs and production of a commissioning plan by the designer. What are the causes of this performance gap and are these proposals therefore what is needed to close this gap? For more information read chapter 2 of volume 1 (page 19)

The solar overheating sections of Approved Document L2A set out glazing criteria that have to be met for side lit and top lit spaces. Are the criteria reasonable? For more information see page 131 of volume 2 onwards.

The 2006 regs referred to CIBSE (which we know is subjective at best), 2010 puts in more guidance – is it sensible?

Consequential Improvements. The government has ‘ducked’ out of addressing this issue explicitly in the consultation. There are many low cost improvements that could be made to a building’s energy performance and this is a particular recommendation that CIBSE and other organizations would like to make to the CLG.

We will also be looking at the ‘future thinking’ section where CLG is asking for thoughts on Part L and what might be incorporated after 2010.

Point was made that there is a dearth of research for 2013 and 2016

 

Other points made during the night were surrounding the fuel factors which are still skewed towards electricity. Again, rather than ‘mask’ the high carbon in the Building Regs, if BEAMA, Creda etc want to protect the electrical heating industry, they should do so in a mechanism OUTSIDE the Building Regs – subsidise at installation/source – not muddy the compliance calculations.

 

There was also some degree of discontent with SBEM, with calls for it to be scrapped as it is anything but ‘simple’. A DSM approach or a return to elemental method were proposed!

Next week, I’ll mop up any loose ends and collate some conclusions. Any comments?

  • Iain Fraser

    Hi Mel, thanks for the summary, I wanted to attend the event but was out of town at the time.

    Anyway my thoughts:

    Ventilation – I used to think that wholescale, wholehouse ventilation would be stricken with user problems, e.g. tenants with sticky-tape. And while I still think there will be problems introducing this for new and existing dwellings I think it’s the route we must take. I see it as another step in the evolution of domestic buildings, see indoor WCs and central heating as past precedents.

    Micro vs macro – Allowable solutions and community energy funds should be the mechanisms to balance Building Regs and create fairness for proposed developments across the UK. I see Merton-type rules becoming obsolete as Part L becomes tougher – by 2013-2019.

    SBEM, DSM and Elemental Methods – Interesting, flexibility and freedom given to design teams post Part L 2002 is a hallmark of the Approved Document. Moving away from this to standardised design solutions would be easier for the industry and may stifle innovation. Is this a price worth paying? I think Sweden went down this route with their Regs. One would like to think that this was assessed to inform Part L 2002…

  • Iain Fraser

    Hi Mel, thanks for the summary, I wanted to attend the event but was out of town at the time.

    Anyway my thoughts:

    Ventilation – I used to think that wholescale, wholehouse ventilation would be stricken with user problems, e.g. tenants with sticky-tape. And while I still think there will be problems introducing this for new and existing dwellings I think it’s the route we must take. I see it as another step in the evolution of domestic buildings, see indoor WCs and central heating as past precedents.

    Micro vs macro – Allowable solutions and community energy funds should be the mechanisms to balance Building Regs and create fairness for proposed developments across the UK. I see Merton-type rules becoming obsolete as Part L becomes tougher – by 2013-2019.

    SBEM, DSM and Elemental Methods – Interesting, flexibility and freedom given to design teams post Part L 2002 is a hallmark of the Approved Document. Moving away from this to standardised design solutions would be easier for the industry and may stifle innovation. Is this a price worth paying? I think Sweden went down this route with their Regs. One would like to think that this was assessed to inform Part L 2002…