Elemental

Had I realised the 17th was not tomorrow, but today, I might have been able to construct a more considered piece. For completeness, here are some further rambling thoughts on the Part L 2010 consultation. Issues I wanted to look into further but ran out of time on included overheating, and a better understanding of the numbers involved in L2A vs. L2B.

Not discussed at the Sponge event, but will be of interest to some will be the proposed approach of aggregating the percentage improvement over building types (for non-domestic), rather than a flat 25% improvement over the 2002 notional building. This means that averaged over the building stock, a 25% improvement will be made. Whilst I applaud the logic, the ‘black box’ aspect of applying these curves, plus questions over what happens if the predictions are wrong (i.e. the mix of building works changes dramatically over the period of time the curves are supposed to work) mean I am not entirely happy with this. I agree it’s probably more sensible than the flat approach for non-domestic stock, but are we approaching the problem correctly in the first instance?

Are the goalposts changing? Are we still comparing to 2002 notional building? Or was the 2002 notional building never the right building to compare against in the first place? The answers are, yes, no, probably not. Part L 2010 is an improvement on 2006, but an improvement to a less than ideal solution to begin with.

There are some who think that SBEM should never have been introduced and that a DSM approach (perhaps based on the open-source US DOE program Energy Plus, which was once the basis of IES) should have been employed as the only non-domestic solution from the outset. Are SBEM’s days numbered? I’m not sure – I haven’t managed to find out figures for numbers of buildings submitted using SBEM vs. DSM over the last 4 years (I feel a request for information under FOI coming on), but I personally am much happier using proprietary DSM software than SBEM, even if the building templates have largely been slim-lined and rationalised for 2010.

Ex-colleague Lynne, over at Hattie’s blog says:

In the Part L consultation, reinforced by the Zero Carbon Definition response from government, a clear emphasis on reducing demand through building fabric is made explicit in the guidance, although as yet the proposals are not prescriptive via U-values and the principle of design freedom is maintained.

As an architect, what is clear to me is that we need to gear our design development process to understand the impacts of what we draw from day one – in Part L and F terms, this means getting orientation, fenestration, construction typology and solar access right so that we are using the ‘basics’ to minimise demand as far as possible from the very outset.

Part L 2010 still gives designers some degree of discretion, rather than dictating a ‘cookie-cutter’ solution. Simplified and arbitrary targets (and yes, I am having a dig at Passivhaus here) devalue and marginalise design engineers. We cannot allow this to happen. Defending discretionary behaviour should be the rallying call of CIBSE, IStructE and others, improving the profession’s standing in the UK (which we cannot allow to be subjugated any further).

There was a puff piece some time back in the AJ, where the Tories rather jokingly wanted to abolish Building Regulations. Let’s not throw the baby out with the bathwater, but rather than tie ourselves in knots trying to meet arbitrarily set targets, let’s get back to first principles and remember what the intentions of the Regulations are:

• conservation of fuel and power
• predicting carbon emissions and ensuring they are less than a stated minimum

It is well within our ken to apply our minds to these riddles, retaining design freedom and without getting lost in a mire of red tape. Isn’t it?

admin Regulation consultation, 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?

admin Regulation building regs, consultation, Part L

So after a fun (?) summer of consultations, the final date for submission for the Part L and F consultation will soon be upon us: 17^th September. The consultation came out on 18 June, but with a massive 800 odd pages to wade through it has taken most of the summer to digest.

This series of posts will mainly concentrate on Part L2 for non-domestic buildings, so I won’t touch on the consequential improvements debate. Plenty has already been said on this here, here and here (that last link is where the ACE have threatened to sue the government – oh to be a  feisty lobbyist!). For those who are interested in Part L1, there is a good summary over on the NHER website (pdf). There is also a very good CIBSE micro-site available which covers L1 and L2. Comments could be added to the CIBSE response up until 4^th September, so too late now. However, it is worth checking out some of the questions and answers on the forum.

There is also a good powerpoint presentation from AECOM/BRE available here (216 slides, 8MB long but useful): www.aecom.com/media/5930.pdf

I shall start with some basics, to set the scene:

The Approved Document (AD) deals with the energy efficiency requirements in the Building Regulations 2000. Historically, the AD was only a method of compliance (not a regulation). This changed in the 2006 revisions to the Building Regulations (which I will touch on below).

It is worth reminding ourselves what Part L of Schedule 1 states:

Where does our carbon obsession come in then? There is only mention of energy and fuel in Part L? This tension between energy and carbon comes up again later, so pay attention.

There are currently two separate requirements to carry out CO₂ emission rate calculations. These are under (i) regulation 17C of the Building Regulations 2000 and (ii) Regulation 17E implementing Article 7 of the Energy Performance of Buildings Directive, requiring the provision of Energy Performance Certificates. It has been proposed that these two be simplified into one regulation but has not yet happened. The ‘master’ Building Regulations document is available here (pdf). The Schedule comes at the end. So our approved document ADL2A incorporates not just Part L, but regulations 17C and 17E. Confused yet?

The AD sets out 5 criteria. If it can be demonstrated that all five have been met, then the building is compliant. Of these, the first directly relates to a regulation (17C) and is therefore mandatory. The BER must be less than the TER and either SBEM or DSM must be used to demonstrate compliance. Criterion 2 through 5 remain guidance only. The 2010 revisions to 2006 are in italics below, deletions shown in strikeout:

Criterion 1: in accordance with regulation 17C, the calculated predicted CO2 emission rate for the building as constructed (the Building Emission Rate, BER), must not be greater than the Target CO2 Emission Rate (TER)

Criterion 2: the performance of the building fabric and the heating, hot water and fixed lighting systems should achieve reasonable overall standards of energy efficiency following the procedure be no worse than the design limits set out…

Criterion 3: Those parts of demonstrate that the building that are not provided with comfort cooling systems have has appropriate passive control measures to limit solar gains. The guidance given in…; and the aim is to counter excessive internal temperature rise in summer in accommodation that does not need air conditioning and where it is not therefore provided. The impact on CO2 emissions from mechanically cooled buildings is taken into account in the BER. the purpose is to limit solar gains to reasonable levels during the summer period, in order to reduce the need for or installed capacity of air conditioning systems.

Criterion 4: the performance of the building, as built, is consistent with the prediction made in the BER…Extra credits will be given in the TER/DER calculation where builders provide robust evidence of quality assured procedures in the design and construction phases

Criterion 5: the necessary provisions for enabling energy efficient operation of the building should be put in place.

The UK’s much touted zero carbon goal was actually set in the Budget in 2008:

an ambition for all new non-domestic buildings to be zero carbon from 2019 with consultation on the timeline and its feasibility and new public sector buildings from 2018

So now we know where all the regulations and goals come from, the next post will get on to the changes for 2010.

mel starrs Regulation consultation, EPBD, Part L

Spotted this article in BD last week which piqued my interest. I’ve been thinking long and hard what a change of government next May might mean to the industry.

The Conservative Party has trained its sights on Cabe as part of an expected crackdown on expensive government quangos if the party wins the next election.

In the midst of the worst recession for decades, shadow ministers Ed Vaizey and Grant Shapps this week raised questions over the future of the taxpayer-funded watchdog following leader David Cameron’s recent pledge to replace the current “spendaholic” government with a new government of thrift.

So how much spending are we talking about here? Off to the ERC Quango database and a few minutes later I had knocked up a graphic with the 2006 government funding inserted. Note that the LDA figures are taken from their annual report for 2006/7 and relate only to the DTI funding (they have contributions from others). Also, the HCA was still EP and HC back in 2006.

click image to enlarge

Whilst CABE spends considerably more than say SDC, it pales in comparison to English Heritage and the RDA’s. And by far the biggest slice of the pie is HCA. (I’m assuming the spending in education is actual delivery of education rather than building of schools).

I’m not sure whether CABE are safe or not, or if they should be. But it’s always worth putting a bit of context to a story when there’s no data given. Come on BD, you could have done that?

And why should the industry care? Take a look at the bodies above and tell me you haven’t been involved in at least one project where funding came from one of those pots over the past 10 years? So, crystal ball time. Without getting into party politics, anyone want to predict what the effects of a change at the top will be (especially for those of us (mid thirties and younger) who have never really worked under any other flavour of government)? Comments, as always, are open…

admin News, Regulation CABE, government, quango, SDC, spending, UK

Today I updated my CDM training, and learnt about the 2007 changes which came into effect 7 April 2007 (nearly 2 years ago). Not that much has changed from a designer point of view. The planning supervisor is now called a CDM co-ordinator. Other key changes for designers are:

If you need to brush up on your knowledge and are a designer (i.e. anyone who prepares or modifies a design OR arranges for or instructs any other person under their control to do so) then there is guidance here from CITB. A summary of duties is available here.

And if you are in any doubt as to if you are a designer? If you specify an outcome (pure performance spec, or as a client representative, for example), then probably not. If you specify HOW to achieve that outcome, then yes, you are a designer.

admin Regulation CDM2007, CITB, compliance, designer duties, HSE

Additional guidance has been published on the NCM FAQ’s page regarding how to deal with shared spaces within blocks of flats using iSBEM:

Each flat is a separate dwelling and must be assessed using SAP (the relevant guidance is in ADL1A). However, the common areas in the flats are not classified as dwellings. As stated in ADL1A paragraph 14, the appropriate approach to compliance depends on whether the common areas are heated or unheated. If they are heated, the guidance in ADL2 should be applied using SBEM. If they are unheated, reasonable provision would be to provide fabric elements that meet the fabric standards set out in paragraphs 33 to 36 of ADL1A. 

A new activity will be added to the activity database in a future version of iSBEM for these areas. For now, please select Building type ‘Hotel’ and activity ‘Circulation area (corridors and stairways)’. This activity has no DHW demand associated with it. It is still necessary to assign a DHW generator to these areas, this will not cause any problems in the project because the generator will not be used where there is no DHW demand. The default DHW generator should be used in this case, if gas is not available in the building, the DHW fuel should be changed to any fuel other than natural gas.

In related new, IES have announced that their SAP 2005 and SBEM packages have been approved by DCLG. Version 5.6.1 was released yesterday:

IES are the only provider that can now offer approved software for all of the possible CO2 calculation methods allowed under Part L:

·               SAP 2005 (L1A)
·               Dynamic Thermal Simulation (L2A)
·               SBEM (L2A)

admin Regulation calculation, dsm, ies, isbem, ncm, Part L, SAP, SBEM, simulation, Software

The general flavour of reaction seems to be to welcome the CSH, but with many calls to address existing housing stock.

Friends of the Earth agree that the Code should be mandatory – I think it will be by April 2008.

Places for People believe it should apply to all housing.  I would agree in principle, but more research needs to be done to see what exactly is feasible.  Trying to enforce unachievable targets is a worse sin than doing nothing at all in my book.

Green Building Press have a good summary of reactions, including CPA (Construction Products Association) who expressed disappointment that it does not provide greater recognition for manufacturers and suppliers who have developed sustainable building materials (something I commented on here).  It will be taken on board if EcoPoints are used, but a new document is due, BRE Green Guide 2006. The Guide is due for electronic publication in January 2007 and replaces the Green Guide to Specification. Good quotation from Micheal Ankers of CPA:

“Improving the existing housing stock by 1% each year would save more energy than making the entire housing new build, zero carbon.”

Treehugger, a US green blog has also picked up on the story.

RIBA’s president Jack Pringle has welcomed the news, and again reiterates the need to look at the existing housing stock:

“Action targeted at new homes can only be the start, and still more needs to be done. The Government’s manifesto proposed a Code for Sustainable Buildings and I hope to see further steps by the Government to tackle the energy performance of existing building stock. The RIBA has put its weight behind challenging carbon reduction targets which we believe are vital. Today has seen a fine step forward by the Government but further action is needed if we are to design our way out of climate change.”

admin Regulation Construction Products Association, CSH, embodied energy, EPBD, existing housing, Friends of the Earth, Jack Pringle, Micheal Ankers, Part L, RIBA, sustainable building materials

It’s been a long time coming (public consultation on the code was between 4 December 2005 and 6 March 2006) and it won’t be enforced until April 2007, but today the Code for Sustainable Homes (pdf, 28 pages) was published. Full technical guidance on how to comply will be issued in April.

Some reaction has already been issued, TCPA here (they comment on the fact that this applies to housing only at this stage), BBC here (they mention the proposal to bring water use into the Building Regulations), Building here (subscribers only), Guardian here (controversially – “The House Builders Association dismissed the plan as “gesture politics” that threatened to undermine the government plan to build tens of thousands of new homes in the south-east.”), BRE are more optimistic here, EST here.
As I predicted last week, the definition of zero carbon housing has been clarified as:

A zero carbon home is one with ‘zero net emissions of Carbon Dioxide (CO2) from all energy use in the home’. The definition encompasses all energy use in the home (including energy for cooking, TVs, computers and other appliances) rather than just those energy uses that are currently part of building regulations (space heating, hot water, ventilation and some lighting). It means that over a year there are no net carbon emissions resulting from the operation of the dwelling. This could be achieved either through steps taken at the individual dwelling level or through site wide strategies. So it will not be necessary for each dwelling to have its own microgeneration capacity where development level solutions would be more appropriate.

As expected, the Code builds upon EcoHomes, and from April 2007 CSH will replace EcoHomes for new housing in England. For those of us who are accredited EcoHomes assessors, we will be able to carry out CSH assessments. From the BRE website:

Compliance with the Code Assessment will consist of a two step process – an initial assessment at the design stage and final certification after construction as detailed below:

• Design Stage Review

• Based on design drawings, specifications and commitments
• Results in interim certificate of compliance

• Post Construction Review

• Based on the design stage review
• Confirmation of compliance including site records and visual inspection.

The rating system is from 1 star to 6 stars. The BRE think that a 3 star is equivalent to EcoHomes ‘Very Good’. The categories will look very familiar to anyone used to EcoHomes. The main changes from the old EcoHomes scheme are that minimum levels have been set for energy and water at each ’star’ level (theoretically, in EcoHomes if you do fantastically well in every other section, you could do badly in these two and still claim and ‘Excellent’ or ‘Very Good’ rating). The rest of the categories retain the flexibility EcoHomes had.
(click to enlarge)
My initial thoughts:

• I would have liked to have seen this code as mandatory. Until April 2008 it is voluntary only and after that it will be up to the results of the consultation. At least the voluntary period running concurrently with the consultation ought to speed the process up a little.
• I’m happy to see that PCR’s (post construction review) are mandatory
• The starting point for a 1 star building is a 10% improvement on Part LA 2006 – had the scheme been mandatory, this would surely have been set at the same level as Part L1A – so what does this mean for the future development of both CfSH and Part L1A, which will now become inextricably linked?
• Mention is made of the BRE Green Guide 2006 – I look forward to it’s publication. Ecopoints are mentioned as an aspiration for the future.
• Some of my favourite bugbears of current housing are there – space for home offices, cycling facilities, composting facilities and waste and recycling facilities – could this spell the end for the two-bed shoebox apartment blocks that are springing up all over Leeds? Developers may be forced to look beyond the bottom line, and start providing spaces which are livable in.
• It is not clear how the star system will relate to building labelling which will be brought in in response to EPBD. The vast majority of existing housing would fail to gain a 1 star rating? The star rating is said to ‘complement’ the proposed building labelling system.

What does the future hold? The timetable looks like this:

• April 2007 – further guidance issued and the code becomes voluntary
• June 2007 – EPBD building labelling becomes mandatory for all new houses
• April 2008 – CSH possibly becomes mandatory along with a change in Building Regs Part L1A (10% improvement on Part L1A 2006?)? Water use included in Building Regs?
• 2009 – EPBD building labelling becomes mandatory for all houses which are sold or leased
• 2010 – 25% improvement on Part L1A 2006
• 2013 – 44% improvement on Part L1A 2006
• 2016 – zero carbon housing

Looking into my crystal ball, it is highly probable that in the next review of Part L1A, CSH will become mandatory and the two run side by side. The consultation process for this has been announced today here. The consultation is an interesting read (pdf, 44 pages) but it will be April 2008 before anything from this is implemented. The pace of change is very frustrating.

Today’s publications are great news for new housing, but as many others have pointed out this accounts for only 1% of the housing stock in England. Once EPBD kicks in and sellers begin to realise that their houses are not competing with new build, pressure will begin to build for addressing the problems with the existing stock. Now that CSH is published, let’s turn our attention to the existing stock and really begin to make a difference.

admin Regulation BRE, CSH, EcoHomes, EPBD, existing housing, Part L, timetable

Gordon Brown announced his pre-budget report yesterday. The pertinent chapter for our industry is Chapter 7 (pdf, 26 pages). Driving home last night Radio 4 were asking the question ‘what is a zero carbon home?’. The reporter had even rang up DCLG for an answer – a spokesman said “one which was not a net recipient of electricity from the national grid” but it was clear that the reporters were still somewhat confused. We could wait for the Code for Sustainable Housing (due for publication next week, I believe) for the official definition but I believe what follows will be close.

The commonly cited definition of zero carbon development comes from the London Renewables document, ‘Towards Zero Carbon Developments‘ (pdf, 108 pages):

A zero carbon development is one that achieves zero net carbon emissions from energy use on site, on an annual basis.

A zero carbon house is one that approaches net carbon emissions from energy use in construction and on site over the useful life of the building

admin Regulation CSH, DCLG, embodied energy, Gordon Brown, London Renewables, transport energy, zero carbon

29 November 2006: PPS3:Housing was published, a precursor to the Sustainable Code for Housing, which we all await with bated breath.  No explicit mention of EcoHomes in the document, but does this look familiar (from paragraph 16)?

Matters to consider when assessing design quality include the extent to which the proposed development:

• Is easily accessible and well-connected to public transport and community facilities and services, and is well laid out so that all the space is used efficiently, is safe, accessible and user-friendly. 
• Provides, or enables good access to, community and green and open amenity and recreational space (including play space) as well as private outdoor space such as residential gardens, patios and balconies. 
• Is well integrated with, and complements, the neighbouring buildings and the local area more generally in terms of scale, density, layout and access. 
• Facilitates the efficient use of resources, during construction and in use, and seeks to adapt to and reduce the impact of, and on, climate change. 
• Takes a design-led approach to the provision of car-parking space, that is well-integrated with a high quality public realm and streets that are pedestrian, cycle and vehicle friendly. 
• Creates, or enhances, a distinctive character that relates well to the surroundings and supports a sense of local pride and civic identity. 
• Provides for the retention or re-establishment of the biodiversity within residential environments.

Fairly close to the principles of EcoHomes.  A statement regarding Code for Sustainable Housing is due in December, when we will find out what the fuure holds for the EcoHomes scheme.

admin Regulation CSH, Housing, PPS3