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Part L 2010 consultation – introduction

September 7th, 2009

So after a fun (?) summer of consultations, the final date for submission for the Part L and F consultation will soon be upon us: 17th 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 4th 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 BERExtra 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.

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Links for August 31st through September 3rd

September 4th, 2009

These are my links for August 31st through September 3rd:

  • BBC – Open Secrets: Comparing the energy efficiency of public buildings – In case anyone missed this (over 5000 properties get a G): "until a few days ago, if you wanted to compare all the buildings on the register, you had two somewhat time-consuming and tedious options: you could visit the 28,000-plus buildings, look for the doubtless prominently displayed certificate, and note down the details; or, if you had a means of finding out their reference numbers, you could enter them, one by one, into the database and retrieve the data.
    However, new regulations came into force a fortnight ago which now allow this material to be divulged.
    In response to my request under the Environmental Information Regulations, the Department of Communities and Local Government has sent me a large spreadsheet [MS Excel, 8.14Mb] listing all the properties on the register, their energy efficiency rating and their CO2 emissions, so that it is possible to analyse this to compare all the buildings on it."
  • E. O. Wilson Takes a Position – E. O. Wilson, one of the most distinguished and respected scientists in the world, has signed the position on economic growth developed by the Center for the Advancement of the Steady State Economy (CASSE). The position statement points out the conflict between economic growth and environmental protection and proposes a steady state economy as a desirable alternative. A steady state economy aims for stability in population and consumption of energy and materials — it is a truly green economy that meets people's needs without undermining the life-support systems of the planet.
  • Real Life LEED: SRI Values for Copper Roofing – Old vs. New – Credit interpretation rulings for SSc7.2 yielded no inquiries about materials that have a non-stable SRI value. Although this is simple conjecture, given the rapid deterioration in SRI for copper (non-compliant within a year, likely much sooner), I would suggest that this product is not in compliance with the intent of the credit which is to reduce heat islands. Clearly for the majority of the life of the copper roof will help foster heat island issues and not reduce them.
  • Some Buildings Not Living Up to Green Label – NYTimes.com – Actual energy performance in use will be flavour of 2010 on both sides of the Atlantic: "But in its own study last year of 121 new buildings certified through 2006, the Green Building Council found that more than half — 53 percent — did not qualify for the Energy Star label and 15 percent scored below 30 in that program, meaning they used more energy per square foot than at least 70 percent of comparable buildings in the existing national stock."

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Del.icio.us.ness

November 14th, 2008

What I’ve been reading about:

mel starrs News

My del.icio.us bookmarks for August 30th through September 1st

September 1st, 2008

These are my links for August 30th through September 1st:

  • Coal verses Nuclear (Jonathon Porritt) – I've not made much comment on George Monbiot's comments on nuclear – mainly because I agree with his qualifications. JP explains here why the green movement are in a kerfuffle about it by explaining: "a communicator as astute and clever as George should (and surely does) know the difference between a 'Yes … If' position and a 'No … Unless' position." JP's a "No…Unless" man…
  • Rod Sheard leads MBO at HOK Sport – Building – After a long period of consolidation and M&A are we due for increased fragmentation and MBO's? The current economic climate would suggest not, but HOK Sport are going for it…
  • Deadlines provide an opportunity – BSEE – Building Services and Environmental Engineer – BESCA's new accreditation scheme is the only one that certifies assessors to inspect both Level 1 (simple, packaged or VRV) and Level 2 (complex, central-cooled air or water) air-conditioning systems.
  • Mission Creep | Neil Williams » Blog Archive » How to be an interesting civil service blogger (and not get fired) – via Tom Watson, a guide to blogging if you're a civil servant. Private sector bloggers can learn from this too – a good summary of things as they stand.
  • CIBSE RESET tool (Excel spreadsheet download) – Further to TM38, this tool is intended to provide guidance to those responsible for the design, installation, commissioning, operation and maintenance of building services. It is not intended to be exhaustive or definitive and it will be necessary for users of the guidance given and results produced to exercise their own professional judgement when deciding whether to abide by or depart from it.

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My del.icio.us bookmarks for July 10th through July 11th

July 11th, 2008

These are my links for July 10th through July 11th:

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More on EPC’s for houses

April 19th, 2007

The Government wants go further to make it easier for homebuyers to access grants for energy efficiency measures, linking them to new EPCs.

Grants look to be worth about £100 – £300 for homes rated E, F or G. Current estimates for the cost of an EPC are £85 (which the seller, rather than the buyer pays). This price will probably vary in terms of location – rural areas will probably not be as well served as urban areas, with prices reflecting this.

EPC’s of E and lower are equivalent to a SAP rating of 54 or lower.

So will it be better to look for a house with a B rating (say SAP of 85) or an E rating of 54 and get the grant? The savings on energy bills of a B rating will amount to around £300/yr. Now it’s unclear what the grants would cover, but it’s unlikely they’ll cover the full capital cost of your improvements. The cost to bring a house up to 85 from 54 is likely to be much greater than £300.

It will be interesting to see if the market takes all this information and reflects it in prices.

For instance, Sellers A and B, on the same street, with the same access to schools etc, and for simplicity sake, the same shape of building. If seller A has an EPC with 85 on it, do they price their house taking into account the future savings the new buyer will make in relation to seller B’s house which has an EPC with 54 on it? Or do they try to recover the investment they have made in installing improvements? Or are they the marker by which seller B discounts against? Of course both sellers have to pay the same price for their certificate (assuming they are in a location with many assessors who are competing for business).

Any comments anyone?

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Getting ready for EPC’s

April 18th, 2007

The always excellent TheyWorkForYou has alerted me to these factoids:

Q: how much has been allocated to the Energy Performance Certificates scheme for (a) start-up costs and (b) 2007-08?

A:The Department has allocated some £1.96 million to start-up costs for the Energy Performance Certificates scheme. This money is required to put into place the necessary systems and calculation methodologies to support introduction of energy certificates and to develop guidance, qualifications and quality assurance frameworks for energy assessors. The allocations for 2007-08 are currently under consideration.

I assume this includes the upcoming public buildings, as well as housing.

Q : how many qualified (a) home inspectors and (b) domestic energy assessors there are on the (i) Buildings Research Establishment, (ii) Royal Institution of Chartered Surveyors and (iii) SAVA Government-accredited schemes?

A: As at 23 March there were 1,085 home inspector candidates who had successfully passed their exam. There were over 3,000 DEA candidates who were in or about to begin training, all of whom could qualify by June.

Accreditation schemes for domestic energy assessors are in the process of being approved by the Secretary of State, and will receive formal approval shortly. As no approval has yet been made details cannot be provided.

Still no formal approval!  Cutting it a bit tight, aren’t they?

Q: what funding her (Yvette Cooper) Department provides to government-accredited schemes to train (a) home inspectors and (b) domestic energy assessors?

A: No public funding has been provided to the commercial companies currently offering training courses to prospective home inspectors and domestic energy assessors.

The trainees themselves are responsible for payment of their own fees, but have access to the range of Government-backed schemes such as career development loans which are available to those wishing to upgrade their skills or undertake a new career.

Q: how many lenders offer a green mortgage in preparation for the introduction of energy performance estimates?

A: We are aware of four lending bodies who currently offer ‘green mortgage’ products, others have said they are interested in developing products. As the Chancellor stated in the Budget, the Government expect the introduction of Energy Performance Certificates and other initiatives to provide the potential for the market for ‘green’ financial products to develop further.

She hasn’t said who they are – anyone know?

Unrelated to EPC’s, but relevant to housing and obviously asked due to the impending merger of HC and EP:

Q: how much land is owned by (a) the Housing Corporation and (b) English Partnerships; and what estimate she (Yvette Cooper) has made of its value.

A: The Housing Corporation predominantly pursues its objectives through the provision of grant funding and does not currently own any land.

English Partnerships, the national regeneration agency, owns over 8,000 hectares of land being held for phased redevelopment and disposal, with an estimated market value of £1,838 million as at March 2006.

Nearly £2 billion of land in the coffers – good news for BREEAM and EcoHomes/Code for Sustainable Houses.  EP land requires a ‘Very Good’ certification as minimum or 3 star for CSH.

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More reaction to CSH (Code for Sustainable Homes)

December 14th, 2006

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.”

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Finally – The Code for Sustainable Homes is published

December 13th, 2006

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.
flexibility.jpg(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.

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Sustainable Construction in Practice

June 6th, 2006

Last week I attended an event organised by Construction News Conferences at 27 Sussex Place: ‘Sustainable Construction in Practice‘. Below are some notes and thoughts from the day, roughly in the order of the presentations. Some of the presentations were not available in paper on the day and when these are released on pdf I may add to this list.

One thing which did strike me about the event was the high proportion of women attendees – from the delegate list I’d estimate 36%. Interesting?

Sue Innes of Constructing Excellence kicked off the proceedings and quoted one of my favourite stats – 1% absenteeism in an office can account for the same amount of money as running the office for a year.

Deborah Brownhill of BRE then presented a quick whistlestop tour through the Code for Sustainable Homes, Part L1A and EcoHomes. CSH is currently post-consultation, and there have been 400 responses for the BRE to assess. We’re not due a response until September when hopefully all will become clear. It is based on EcoHomes, but with minimum standards to be met in each of six categories (EcoHomes is tradable). A case of ‘watch this space’…

David McCullough from Carillion was one of the most animated speakers of the day. He had the tough task of whizzing through Part L in 30 minutes and did a decent job of it. He answered back to all the doom and gloom around the implementation of Part L and suggested that perhaps our expectations of parliament were too high and we should just all get on with accepting the principle and getting on with things. He highlighted the change in roles between architects and ‘experts’ – the building regs are now a science and ought to be done by competent persons (a great opportunity for some of us). He also mentioned that SAP tends to favour slightly larger dwellings due to the scaling on discrete elements such as washing machines, which is a useful fact to know.

Barry Plowright from Atkins was a stand-in speaker and I don’t have his slides. The most entertaining bit of the morning came when a senior researcher from University of Oxford asked a question afterwards, one of the answers to which was to install a desalination plant. The UoO guy exploded and said a desalination plant would be ‘utter madness’ and add to the carbon emissions – good point.

Rachel Wooliscroft from Wates gave a presentation on waste. Has anyone else noticed how the Albert Hall has become a unit of measurement? Did you know, the UK produces enough waste to fill the Albert Hall every 2 hours. Wates’ target is to produce zero non-hazardous waste to landfill by 2010, a worthy goal.

After lunch Jerry Williams of Taylor Woodrow gave a quick overview of the National Assembly of Wales and how it was built as a sustainable project. 100% of the cooling comes from 27 No. 100m deep geothermal bores, and heating is via a wood chip boiler.

Rita Singh from Construction Products Association spoke about responsibility versus sustainability. Unfortunately I don’t have her slides, but she had some interesting points to make. The website has lots of the benchmarking information she talked about (almost too much information).

The final section of the afternoon were the ‘names’, Isabel McAllister, George Martin and Cal Bailey:

Isabel from Cyril Swett did a very enthusiastic cost-benefit analysis of sustainability and confirmed what I have begun to suspect. The numbers don’t add up, but if you (as a developer or a client) don’t get on board then you will begin to lose out in future (rather than gain today from implementing sustainability). The slides have yet to be issued and this is one I will definitely be looking at again.

George Martin has the oddest job title in the industry ‘Head of Re-Thinking’ at Willmott Dixon, which I suspect is a nod to Egan. I wasn’t that impressed by his presentation (not much to bring away from it) but he did highlight DQI’s which use a similar tool to the sustainability workshops which I run (I’m not yet a DQI facilitator).

And finally we listened to Cal Bailey of NG Bailey persuade us that MMC (modern methods of construction) are the key to sustainable construction. OSM (off site manufacture) solves many of the co-ordination, quality and carbon issues associated with a ‘live’ building site. I am almost convinced, although I still see the benefits of training a local workforce in certain situations.

As with all these conferences, some of the most interesting conversations went on in the tea breaks. As a result I’ll be checking out Hockerton versus BedZed.

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