The Future Homes Standard (FHS) and Future Buildings Standard (FBS) Consultation was released on 13th December 2023 by the Department for Levelling Up, Housing and Communities (DLUHC). This consultation is looking to both industry and consumers to gather opinions on the Future Standards.
The purpose of the consultation is to guide the government’s plans for implementation of the FHS and FBS in 2025, and it runs until 27th March 2024.
What are the key proposals?
The key proposals put forward focus on making new buildings ‘zero-carbon ready’, and reducing the gap between expected and real-world performance.
ERS has read through the consultation and put together a summary of the key parts affecting our work:
Performance standards and metrics for new builds
The current metrics used to determine compliance are to be retained in the FHS and FBS. These are a building’s emission and primary energy rates (BER & BPER respectively) for non-domestic properties, and a dwelling’s emission rate (DER), fabric energy efficiency (DFEE) and primary energy rate (DPER) for domestic properties.
Alternative metrics were considered, Energy Use Intensity (EUI) and Delivered Energy. It is argued that DPER is a more effective at supporting policy objectives than Delivered Energy, and EUI includes unregulated energy over which designers have no control.
While the metrics won’t be changing, the bar is being raised in terms of performance required for compliance. For this, different options have been put forward for new and improved notional standards, focusing mainly on building services as it is thought standards for fabric are at a sufficiently high benchmark already.
Option 1 balances higher initial costs for developers during the build phase with lower running costs and carbon emissions for consumers, against Option 2 with lower build costs, but potentially higher running costs and emissions.
It should be said though that in both cases, due to standards being raised, the notional buildings would likely require ‘zero-carbon ready’ systems (i.e., Air Source Heat Pump) be installed to achieve a pass. So, while Option 2 may seem worse than Option 1, it would still represent a significant improvement over the current standards applied to new buildings in the UK.
Change of Use standards
This section applies more to domestic properties, as homes created through a Material Change of Use (MCU, or a conversion), made up roughly 12% of all new dwellings in 2021-22.
Previously, these have been held to significantly lower standards, which has resulted in them costing up to 180% more to run, while producing up to 148% more carbon emissions than their new build equivalents.
To combat this, multiple options have been proposed which include notional baselines using heat pumps or, if more relevant, high heat retention storage heaters. Also being considered is the possibility of categorising MCUs, and applying different standards to them depending on factors such as their height (i.e., low, mid or high rise), their floor area, or whether the whole building is being converted, as opposed to a small part.
Standards currently exclusive to new builds could also be bought in, with BREL reports, photographic evidence, overheating risk assessment and mitigation, along with mandatory air tightness testing potentially set to be applied to MCUs.
Real world performance
For dwellings, the gap between real world performance and modelled performance was addressed in part by the release of Part L 2021. The removal of Approved Construction Details (ACD’s) and the requirement for photographic evidence were the main parts of this, but the Future Homes Standard will look to build on that for domestic properties.
Developers are set to be incentivised into publishing the performance of their homes to the public (on a voluntary basis), with the reward being a Future Homes Standard logo/brand that they can display to distinguish properties built to the higher standard. It is hoped that by allowing comparisons between developers and their competitors to be drawn, the overall quality of the UK’s housing stock will only rise.
Another aspect of real-world performance that is set to be improved are the standards relating to the commissioning of heating, hot water and ventilation systems. The proposals are that guidance is offered to installers on routes to certification, as well as detailing how the rules surrounding commissioning are to be enforced.
Transitional arrangements
At times when the building regulations are changed, transitional periods are put in place allowing the industry to understand, update and adapt their procedures to be in line with the new standards. The consultation seeks views on two options; Option 1 – a 6-month period between publishing of the final document and those standards coming into force; Option 2 – a 12-month period.
In both cases, a further 12-month transitional period is to be applied to projects where the initial notice, building notice or full plans were submitted before the new standards become enforced can still be built to the previous standards, providing work on-site begins before the end of that transitional period.
Part O
Building Regulations Part O was introduced at the same time as the current Part L, designed to reduce the risk of overheating. This only applied to new-build residential properties, from dwellings to care homes. Overheating can affect converted buildings, and it is proposed that the scope be widened to include MCU projects or a sub-set, depending on how they are categorised.
Aside from this, the guidance provided in the current Approved Document O is under review, and now the industry has had experience applying it to real projects, the consultation is calling for feedback to identify areas for review. Here at ERS, we know it has been challenging for our clients!
Conclusion:
The consultation on Future Homes Standard and Future Buildings Standard is essential step toward decarbonising the UK’s built environment and making future developments ‘net-zero ready’. There is to be an even-greater emphasis on the installation of heat pumps in homes and PV in non-domestic buildings through improvements to notional targets. Higher targets are also to be applied to MCUs as their performance significantly lags behind that of new-builds.
We hope this news item, provides insight on the most important aspects of the consultation, and we encourage our partners to respond to the questionnaire and give their thoughts on the potential developments to future regulations – by the end of Wednesday 27th March.