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The government’s proposals to amend the Building Regulations in England in 2013 are divided in four sections: l Section one: Building Regulations Parts A, B, C, K, M and N. These cover, respectively, ‘structure’, ‘fire safety’, ‘site preparation’, ‘protection from falling, collision and impact’, ‘access’ and ‘glazing’. The section also includes a new draft Approved Document K.

l Section two: Part L – ‘conservation of fuel and power’. This section also includes proposals on ‘consequential improvements for existing buildings’ and ‘works in existing buildings’.

l Section three: Part P – ‘electrical safety – dwellings’.

l Section four: The local authority Buiiding Control system.

The closing date for comments on the documents is 27 April 2012, except for Part L, which is 27 March. All documents can be downloaded at uk/planningandbuilding/ buildingregulations/ buildingregulationschanges

Plans signal key changes to Building Regulations

l Lighter regulatory burden on builders is government’s ‘preferred’ option

The government’s announcement of proposed changes to the Building Regulations signals a significant rationalisation of the rules in 2013. The consultation on the proposals, issued last

month, says that ministers’ preferred option is for an ‘aggregate’ new homes carbon emission reduction target of 8% on 2010 levels. This is a big reduction on the 25% target previously proposed and widely backed by the sector. Ministers’ preferred target for non-domestic new buildings in 2013 is set much higher, at 20%. The consultation document on the changes also

proposes a 26% reduction target, adding that this option ‘has the advantage of reducing the impact of the 2016 change to full zero carbon’. But it says that this would ‘introduce a higher cost

for housebuilders at a time when the government has a commitment to reduce the burden on the housebuilding industry’. It adds: ‘The role of Part L is to provide reasonable

provision for the conservation of fuel, not to dictate what can or cannot be built … Setting a less demanding regulatory level now would provide more time to reassess these standards in advance of the move to zero carbon [new homes] from 2016.’ CIBSE said this argument would need ‘careful consideration’ backed by ‘hard evidence’. It added

Further reduction in emissions for new homes is cut to 8%

that it was pleased with the government’s proposals to improve the compliance process for ensuring new buildings meet required standards. The consultation document says that the government is seeking to work with the industry to establish an ‘agreed benchmark for a quality assurance approach’ next year. It also acknowledges that the ‘design-and-build’

approach to new-home construction can lead to poor-performing buildings. It adds that more data and analysis are needed

on building performance, including the PROBE-style studies published in the 1990s in Building Services Journal, the forerunner to CIBSE Journal. l Government officials comment on Part L, page 10; Barratt chief sets out low carbon challenges, page 22; post-occupancy evaluation special, page 30

Analysis Wide-ranging proposals warrant close scrutiny

This is a comprehensive package which addresses a number of issues, extending well beyond the traditional reviews of Part L, and it is a further significant improvement in the process to have the whole package co- ordinated in this way. Key topics which are addressed

in the package include the proposal to extend consequential improvements to homes, under clearly defined circumstances. The building control part of

the package looks to address the current situation in which completion certificates are made effectively voluntary by the Building

6 CIBSE Journal March 2012

Regulations themselves, which is an essential requirement of better compliance with the regulations. There are also proposals for increased application of self certification, which CIBSE will be reviewing carefully. A key change in the energy

efficiency elements is the introduction of a second method of demonstrating the efficiency of lighting, which allows the use of the lighting efficiency numeric indicator (LENI) instead of the traditional calculation based on luminaire efficacy. The Society of Light and Lighting believes that this has the potential to deliver up

to 30% improvement in installed lighting system efficiency. The package looks to introduce

common sense reforms to the Part P regime, although the electrical specialists will want to look carefully at the detail to try to achieve a balanced and reasonable approach. The proposals for reducing the

emissions from new homes may be the most contentious. Of the two options, the option preferred by the government offers a further reduction of 8%, with an alternative 26% cut also proposed. This needs some careful

consideration. ‘Sustainability’ has three elements – environmental,

social and economic, and there has to be an acceptance that targets set in the boom years may need adjusting in more straitened times. But the danger is that those who

want to minimise changes in the standard for new homes will tend to maximise the claimed costs of tougher targets, and minimise the benefits and the rate at which costs are likely to fall as the regulations tighten and everyone has to adopt new solutions. There is a real need for decisions based on hard evidence here. l Hywel Davies is technical director of CIBSE.

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