Future Homes Standard – SHIFT Environment and others’ view

In readiness for 2025, the Government has issued its response to a consultation on the detail of the Future Homes Standard (FHS).

Others [1] [2] , who have been closer to the consultation process, have noted that the proposed standards are far weaker than initial options explored.  They say that the amount of energy required to heat homes built to the FHS is about twice the energy needed to heat homes were built to higher specifications e.g. PassivHaus and beyond.  One group has even written an open letter to the Secretary of State expressing their disappointment [3].

Another key issue raised is that planning authorities will not be allowed to require higher standards in their areas.  At SHIFT we have seen the impact of better planning rules resulting in more homes being built to EPC A, compared to the usual EPC B for new build.  So, this clearly is a backward step.

Some key points we note from our look at the consultation response:

• We certainly echo the concerns about planning authorities not being able to impose better standards
• There is even more clarification that hydrogen is unlikely to be used for domestic heating in new homes
• Even though the FHS is supposed to be technology neutral, it does discuss certain technologies like heat pumps and district heat networks. But there is no mention of Mechanical Ventilation with Heat Recovery (MVHR) – in our opinion this technology has lots of advantages in new homes and is the technology used in PassivHaus homes.  But perhaps the sector will recognise this and start using these systems anyway.
• There will be no requirement to build to an affordability standard. There is an assumption that building to the fabric and other standards, that better affordability will be achieved.  The ubiquitous affordability standard is the current EPC rating – EPC A is very cheap to run, whilst EPC B is more expensive to run.  This EPC is used in every other part of a home after it has been built (sales, letting, improvement planning etc) so why not in building regulations?  In our experience homes that are cheap to run, also emit less CO₂.  Could this be a signal that Government has no intention of making electricity cheaper and gas more expensive?
• Despite the widely publicised announcement that new homes won’t have gas boilers, there are exemptions. The FHS claims that in rural areas it may not be possible to install heat pumps due to inadequate electricity provision.  Therefor oil and LPG can be installed, provided the modelled CO₂ emissions are better than an equivalent good standard home.  There is an assumption that housebuilders will build better fabric and PV to counter the CO₂ emitted from these fuels.  There is nothing about leaving sufficient space around the new home to easily retrofit a heat pump in the future when the electricity provision is better.  In any case an MVHR system would be better than fossil fuel without the need for the extra electricity.

We list some other observations below and then some observations on the proposed replacement for SAP, which is being rebranded as the “Home Energy Model”

• There is a claim that there will be a 31% CO₂ reduction in homes built to FHS – this hard to square given the confusion over the carbon factors used – see comments on Home Energy Model below.
• Fabric Energy Efficiency Standard (FEES) is staying – this is good, but we’re surprised it was even up for consultation
• There is an acknowledgement of the “performance gap” – i.e. actual energy efficiency is sometimes worse than designed energy efficiency (we’ve heard of some terrible examples [4])
• To combat the performance gap air tightness test are now going to be carried out on all homes, not just a representative sample
• We’re surprised that actual heat loss testing is not being introduced – this is a real test of build quality
• There is nothing on embodied CO₂ of construction materials, but it did at least get a mention. We are not sure this should sit building regulations, but we think it should be nationally regulated – e.g. materials produced in this country and imported should transition to net zero embodied CO₂
• The notional specification has dropped the solar PV that is currently in place. The current requirement doesn’t require solar PV, but it says that any home built must have emit less modelled CO₂ than a home built with them.  This issue constantly perplexes people – why isn’t there solar PV on new build homes?  We’ve even heard of cases where, even if the homeowner wanted to retrofit solar PV themselves, the roof isn’t strong enough.  Installing solar PV at new build stage is far cheaper than retrofitting and some are even saying cheaper than traditional roof tiles.
• The U-values of build elements are tighter than current, but still could do better as per PassivHaus.
• FHS will proceed with something called the “Primary energy target”. We think this figure should be made really clear on any EPCs, because we have seen this figure cause confusion in other work
• There is a requirement to ensure that heating systems work with a flow temperature of 55^oC maximum – this is good as it sizes heat emitters (radiators, underfloor heating) for heat pumps, even if heat pumps aren’t installed straight away.

Notes on the new SAP or Home Energy Model

• Modelling to be done on half-hourly basis instead of monthly – really not sure what benefit this will bring, and it is bound to use up loads of computing power – not sure on this one. But perhaps it is just a sample of a 24-hour period in a day so that variations in the day are taken into account.  This section of the consultation mentions heat pumps so perhaps the extra modelling is designed to favour heat pumps.
• The carbon factor used seems really low and we may be in danger of deluding ourselves that the CO₂ emissions of new homes is much less than they really are. The references in the document don’t refer to the figure used.
• Occupancy rates to be changed – but new occupancy rates are based on pre-pandemic research – not in the current “work from home” norm.
• We’re told that builders are still coming to terms with the current version of SAP
• As well as reviewing what is in the consultation, it is telling what is actually omitted. A crucial factor in helping to transition away from fossil fuels is the price of electricity compared to gas. There is no mention in the consultation about this. The ratio of gas to electricity prices in the current version of SAP is worse for electricity compared to the previous version. The new Home Energy Model (and national policy) will need to reverse this trend if we want to end up, we want electrically heated homes feeding off a net-zero grid.
• The Environmental Impact Rating (EIR) disappeared from EPC’s some time ago (we’re not sure why). We hope this will be brought back as it serves as a useful indicator of CO2 emissions (unlike the normal EPC rating which is an indicator of running cost).  In Wales the EIR rating is included in their net zero homes strategy.

If you would like to satisfy yourself that the energy efficiency of your new build homes are as good as you intend, please ask us about our POE services.

 

[1]   https://www.bioregional.com/news-and-opinion/architects-journal-future-homes-standard

[2]   https://www.bioregional.com/news-and-opinion/future-homes-standards-2023

[3] The group is made up of people from:  Bioregional, Etude, Good Homes Alliance, Clarion, CSE, Climate Emergency UK, IEMA, LETI, Passivhaus Trust, Pollard Thomas Edwards, Rights Community Action, TCPA, UK Green Building Council (UKGBC).  The letter is reproduced in the appendix below.

[4]   https://shiftenvironment.co.uk/news/a-horror-story-poor-quality-in-new-builds/

Photo by James Feaver on Unsplash

 

Appendix:

The Rt Hon Michael Gove MP

Secretary of State for Levelling Up, Housing, and Communities

2 Marsham Street

London SW1P 4DF

Cc: The Rt Hon. Claire Coutinho MP, Secretary of State for Energy Security and Net Zero

February 2024

Dear Secretary of State,

Re: Future Homes and Building Standard (FHS) and Home Energy Model (HEM) consultations

As leading businesses and organisations involved in delivering new homes and buildings to high sustainability standards, we are writing with our view on the FHS and HEM consultations. We would like to meet you to discuss the consultations and are available to provide further information in addition to our organisational responses.

We support the following elements of the proposals which should be implemented without delay. We welcome the end of fossil fuel heating and commitment to electric heating. We support integrated on-site renewables for new homes, and the extension of energy efficiency measures for dwellings created under material change of use. We welcome the proposed HEM as a replacement for SAP.

However, this is not a definitive Future Homes Standard, but rather a positive step towards it. Many of us involved in the development of the Future Homes Hub’s (FHH) five contender specifications (CSP) are disappointed that the two weakest options are being consulted upon. We request a further iteration of the Standard be developed to ensure new buildings are of higher specification by 2028. In this letter we set out immediate concerns to be addressed and outline why further development of the FHS is needed.

We have immediate concerns to be addressed in the 2025 regulations:

1. We strongly disagree with the Option 2 notional specifications. Omitting photovoltaics (PV) and lowering building fabric standards will lead to an additional £600-£700 per year on energy bills for residents of new homes compared to the current Part L 2021 and Option 1 respectively. The public sector equality duty ensures Government does not introduce standards which unduly affect those on lower incomes or with protected characteristics. A lower fabric standard would increase the pressure new homes place on the electricity grid at a time when the electrification of heat, transport, and industry means demand for electricity is expected to grow fourfold by 2050.iii All new homes should have integrated PV as standard to maximise available renewable energy, especially as the cost of installation continues to plummet.
2. We strongly disagree with the choice of Primary Energy over Delivered Energy. We see no evidence provided to justify this choice, with 76% of respondents to the previous FHS consultation opposing Primary Energy as a metric. The Climate Change Committee (CCC) supported Delivered Energy for domestic Energy Performance Certificates (EPCs) vi. The HEM consultation discusses the use of Delivered Energy and a different metric for the FHS creates Government inconsistency and confusion. Delivered Energy should become the key metric in this Standard.
3. We support post occupancy performance testing, but it must be mandatory. The proposal to ensure transparency on actual performance – acknowledged by Government as a key outcome for EPC reform following the 2021 consultation – is urgent. We support the introduction of Building Performance Evaluation (BPE), but a wholly voluntary approach will not provide the necessary protection from homes built to a sub-standard. BPE needs to include mandatory post-completion testing as a simple, low-cost first step.

There is a need to improve on the proposals for a higher standard which delivers on the FHS aims. There are substantial issues not addressed in this consultation and a demand for higher standards. The Written Ministerial Statement of 13 December 2023 calls for Local Authorities to converge on a common definition of higher levels of performance and these should be co-developed during the course of 2024, based on the recommendations set out below. This higher standard can then be brought into buildings regulations by 2028.

1. a) Regulate embodied carbon in new buildings. Embodied carbon makes up 20%viii of UK built environment emissions and declarations of whole life carbon are already required for large building projects. Policies to measure and limit embodied carbon and apply circular economy approaches within the construction sector are urgent and should be included in FHS.
2. b) Improve fabric standards to include U values and air tightness. Alignment with current good practice can improve comfort and achieve a level of thermal resilience and stability to permit sufficient flexibility for grid peak load management. The FHH CSP4 has just 25% of the home heating demand compared to FHS Option 1.
3. c) Improve new home ventilation systems. Decentralised mechanical ventilation (dMEV) relies on ventilation from holes in the fabric (‘trickle vents’) which are unreliable, reduce air quality and comfort for residents, and waste heat. FHS should mandate systems such as mechanical ventilation with heat recovery (MVHR) to deliver good air quality, reduce condensation and mould, and recirculate heat (as addressed in the FHH CSP3, 4, and 5).
4. d) Reduce electricity generation investment required. Improvements to building fabric and ventilation outlined above have been calculated to save circa £22.6 billion in electricity generation investment over 20 years compared to Option 1, and would result in a £190/year reduction in bills for occupants.

Higher standards will not limit housing supply. The FHS consultation stated concern that higher standards will increase costs and complexity for housebuilders and limit housing supply. Recent Government studies xi xii did not find higher standards to be a constraint on housing supply. The additional cost of CSP4, for a one-off 200 home site, compared to Option 1, was £13.8Kxiii per plot and will be considerably less when delivered at scale. This cost will be absorbed through adjustments to land values, as with previous regulation changes, not increasing householder costs and not limiting housing supply. Homes built to higher standards have been feasible and viable at a local authority level across England, having passed tests of Local Plan inspection.

Collaborating for better standards that really work. Lessons from the 2021 FHS pilots, and existing homes built to higher standards, should inform a future homes standard. We collectively bring knowledge and experience of building to higher standards, and offer practical justification for achievable standards which benefit industry and residents in line with net zero goals. We urge you to collaborate with us to develop the standard further.