Amending the regs

Elaine Coles, head of research at IMS Group, asks whether the revised building regulations will deliver energy efficiency

So, the consultation process has ended and the building sector is waiting to find out exactly how the far-reaching proposals from ODPM for amending Part L of the Building Regulations and implementing the Energy Performance of Buildings Directive are going to affect them.

According to Phil Hope, the minister responsible, the government anticipates that its “proposals will contribute carbon savings of 1.1 million tonnes by 2010 and rising thereafter”. The regulations are due to come into force on 31 December – but the key question is how quickly will they make a real difference to the buildings sector’s carbon dioxide emissions. Buildings account for about 50% of the UK’s emissions, with about 30% from the 24 million dwellings in the UK and 20% from other buildings.

On that basis, improving the energy performance of existing building stock is key to achieving the government’s Energy White Paper target for reducing CO2 emissions by 60% by 2050. New build represents only a very small proportion of overall construction expenditure – the vast majority relates to repairs, maintenance and renovation. About 180,000 new units are being built each year while around only 20,000 are demolished.

Will the proposals deliver?

In December 2004, director of the Association for the Conservation of Energy and senior adviser to EuroACE Andrew Warren argued that Europe should move quickly to strengthen the Energy Performance of Buildings Directive. A report commissioned by EuroACE concluded that, using existing technologies, Europe could reduce greenhouse gas emissions from the building sector alone by 400m tonnes – easily more than the total EU commitment made at Kyoto.

To put this into context, to achieve equivalent levels of emissions reductions from other measures we would need to take six million cars off London’s roads for 15 years and plant forests three times the size of France.

Targeting smaller homes and offices

According to Warren, although the directive provides a good first framework for new and large buildings, existing smaller buildings such as homes and offices (less than 200m2) alone account for over half the potential emissions savings that remain untapped in the European building sector. In his view: “These buildings are less likely to be renovated and their energy efficiency is less likely to be improved without strong government support and incentives. That is why the Commission has to enact Article 11 of the directive – which instructs them to recommend further upgrading measures. It should implement this article very swiftly.” This, before even the existing legislation has become law in the UK.

Serious concern has been expressed over the proposals’ current lack of clarity as to where the necessary funding and resources will come from. There are also reservations about how quickly dissemination of the strategy to its numerous and diverse target audiences can be implemented.

For many in the sector, energy efficiency isn’t even on the radar screen. At a seminar on the proposals held by BRE, Roger Watts, former chairman of the Building Surveying Faculty of the Royal Institute of Chartered Surveyors commented: “I have undertaken many hundreds of pre-acquisition surveys. Never in all that time has the issue of energy efficiency been raised by one of my clients. There has been no press coverage of any substance in any of the press which the property-owning world reads.”

Setting standards

As they stand, the proposals do not compel the incorporation of specific solutions, with the government leaving the introduction of new technologies, including low to zero carbon systems, to the marketplace.

“Setting standards at the level of the whole building leaves designers the freedom to choose their own way of achieving the standard required for compliance. This means that no individual technology, system or product is unfairly disadvantaged,” according to the proposals. This despite the Royal Commission on Environmental Pollution’s
recommendation that all new buildings should incorporate combined heat and power systems.

The other key area not covered by the proposals is the provision of grants, tax and other financial incentives to stimulate swift and effective uptake of carbon-reducing solutions – the proposals simply state that “these fiscal measures are outside the scope of Building Regulations and so they have not been included in the cost benefit calculations in this regulatory impact assessment”.

Given the gloomy climate change scenarios emanating from various quarters, these issues may have to be revisited as a matter of urgency. If the government wants to have an immediate impact on the single major source of CO2 emissions in the UK, it may need to take a different tack.

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