Comment
The return of the Future Homes Standard
This week the Government finally published its response to the Future Homes Standard (FHS) launched back in October 2019 [1]. The FHS aims to future proof the design of new homes to reduce carbon emissions and help meet the 2050 zero carbon target. Below is a summary of the key points of the Government’s response.
As part of the response the Government has stated that from 2025 the FHS will ensure homes will achieve a least a 75% reduction in carbon emissions above current requirements. To help achieve this, technical work on the FHS has been accelerated and will be consulted upon in 2023, with legislation introduced in 2024 ahead of implementation in 2025.
In the meantime, the Government has confirmed that an interim carbon reduction target of 31% will be implemented to act as a stepping stone to 2025, helping to ensure the industry is ready to meet the challenge of the FHS in 2025. The Government’s aim is for the interim target to be technology neutral, however the changes are likely to lead to a significant uptake of heat pumps as we switch from gas to electricity, as well as increased use of solar PV. Developments will need to ensure more homes are able to accommodate these technologies.
In addition to confirming the key carbon reduction targets, the consultation response also states:
- In the short term the Energy Act 2008 will not be updated, Local Authorities will retain the power to set local standards. This means areas such as London, Manchester and Bristol, which are progressing their own net zero targets, will continue to be able to set targets beyond the Building Regulations.
- The Fabric Energy Efficiency Standard (FEES) will be revised and will be a key performance metric in assessing the performance of new homes. This will ensure the minimum fabric performance of homes is maintained.
- Measures to help address the performance gap noted in the consultation will be implemented. These include a new style Part L compliance report, improving the accuracy of as-built energy models, and additional guidance for home owners on how to operate low carbon homes.
Alongside the FHS response the Government has issued Part 2 of the consultation, the Future Buildings Standard (FBS) [2], which includes details on overheating assessments and FEES for domestic dwellings. The FBS sets out questions on how overheating should be assessed, including the potential for new legislation to ensure a consistent approach which will likely include the need for dynamic thermal modelling to assess homes. The FBS also sets out proposed changes for energy performance in non-domestic buildings.
Subject to the Part 2 consultation, the Government is aiming for the interim Part L (conservation of fuel and power) and Part F (ventilation [and overheating]) to be regulated for in late 2021, coming into effect in 2022. Transitional arrangements will also now only apply to individual homes rather than the whole development. Developers must submit a building notice by June 2022 for transitional arrangements to apply. This will likely mean that outline applications, under consultation now, will in the future need to comply with the interim target as a minimum, and will therefore need to give consideration to the use of heat pumps, solar PV and enhanced fabric performance.
The consultation response provides clarity and certainty on the timing of the new interim standard, but also highlights the short time frame between the implementation of the interim target and the full FHS and delivery of zero carbon ready homes beyond 2025. This will require a rapid increase in skills and the supply chain in relation to technologies such as heat pumps if developers are going to be able to meet this challenge.
For more information please contact Paul White.
22 January 2021
[2] https://www.gov.uk/government/consultations/the-future-buildings-standard
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