Comment

The Future Buildings Standard

Last week the Government published a consultation on the Future Buildings Standard [1] (FBS). Similar to the Future Homes Standard (FHS) published in 2019, the FBS sets out a pathway for the delivery of highly efficient non-domestic buildings. Below is a summary of the key points of the consultation document.

Read our previous commentary on the FHS.

As with the FHS, the FBS proposes the introduction of an interim standard in 2021 providing a ‘stepping stone’ to the full FBS in 2025, and ultimately the delivery of ‘zero carbon ready’ buildings. The consultation recognises that the diversity of non-domestic buildings means that some will be able to transition quickly and others will need time to adapt.

Key to the delivery of zero carbon ready buildings will be the switch away from fossil fuels to the use of low carbon heating technologies; including heat pumps, low carbon heat networks, direct electric heating and emerging technologies such as hydrogen.

Given the diversity of non-domestic buildings, alongside variances in heating demands, the consultation sets out future work streams to understand in more detail the demands of different building types and how they may transition to the Future Buildings Standard by 2025. In advance of this work the Government has not proposed a carbon reduction target for non-domestic buildings from 2025, but it would be reasonable to suggest that this is likely to be similar to the FHS. With a view to 2025, the FBS consultation includes details of a proposed interim standard in 2021 to encourage low carbon systems and enhanced fabric performance. The Government has proposed two potential options for improvement on average per building compared to the existing Part L standard:

Option 1 – a 22% improvement in emissions above the current Part L standard. It is anticipated this would be delivered through an increase in the efficiency of building services and use of on-site low carbon technology, such as heat pumps or solar PV systems.

Option 2, the Government’s preferred option – a 27% improvement in emissions above the current Part L standard. It is anticipated that this would be delivered through very high fabric standards, improved building services and use of on-site low carbon technology such as heat pumps or solar PV systems.

It is expected that carbon reductions will vary by building type - with retail warehouses achieving a greater reduction (36%) than hotels and hospitals (0.5% - 11%), where energy demand is dominated by hot water demand which will remain a significant carbon impact until there is a switch to low carbon systems.

The Impact Assessment ^[2] which accompanies the consultation sets out potential costs for different building types to achieve the proposed options. For the Government’s preferred option, potential costs range from £23 / sq m for a hospital, to £75 / sq m for a retail warehouse. For warehouses, options 1 and 2 assume that 40% of the roof area includes solar PV systems. While the cost for retail warehouses is high, many developers within the sector are already pushing forward with net zero ready development, reducing operational emissions, as well as reducing and offsetting construction stage emissions in line with the UK Green Building Council Net Zero Framework.

In addition to the proposed carbon reduction targets a number of other changes are proposed:

• From 2021 the Government is proposing to introduce primary energy as a principal metric to set energy performance targets to prioritise the energy efficiency of the building. This will sit alongside the carbon target and minimum fabric and building services standards. 
• Changes to the calculation methodology are proposed, including modification of how water and space heating are treated for the notional and actual building will be made to discourage the use of high-fossil fuels, as well as making buildings fit for the installation of low carbon heat in the future. 
• To help monitor the as-built performance of buildings, changes are proposed to require additional sub-metering to allow comparison between design-stage energy forecasts and measured results. It is anticipated this will make it easier to find and fix problems with building performance.

In addition to changes to Part L the consultation also outlines proposals for changes to Part F, creating separate ventilation standards for existing and new non-domestic buildings, and providing clearer guidance on developer requirements.

The FBS sets out an ambitious timeframe for improving non-domestic building performance, initially with the 2021 interim target but also in meeting a greater challenge in 2025. At this stage the Government has not provided clarity on what level of improvement will be required in 2025, recognising there are many different types of non-domestic buildings and different target levels and timeframes may be needed for each. Given the timeframe for consultation, when the targets for 2025 are released there will likely be a significant challenge in delivering buildings to the new standards.

For more information please contact Paul White.

26 January 2021

[1] https://www.gov.uk/government/consultations/the-future-buildings-standard

[2] https://www.gov.uk/government/publications/the-future-buildings-standard-consultation-impact-assessment