BUILDING REGULATIONS REFORM PROPOSALS
proposals in the consultation will impact on business as a whole, and specifically house builders. One of the significant regulatory cuts, an ‘out’, is in the proposed technical amendments to AD B for wall linings and light diffusers.
Energy efficiency The primary interest for most readers is likely to be Section 2, which deals with energy efficiency. This is mainly related to Part L, but also addresses aspects of the Regulations that relate to the forthcoming Green Deal to upgrade the energy efficiency of existing buildings. The proposals for new buildings are to
require a further reduction in the carbon emissions from new homes of 8%, and of new non-domestic buildings of 20%. These proposals will save 15 MtCO2 over the life of the policy (to 2022). However, the costs and benefits do no not fall uniformly across these sectors. The 8% improvement in carbon performance, which is stated to be the ‘preferred option’ for new homes, represents an additional cost to housebuilders, or an ‘in’, of £103m per year, while for non-domestic buildings there is a net benefit. Treasury rules for calculating ‘ins’ and
‘outs’ need careful reading. Any regulatory cost to business is an ‘in’. Any benefit which accrues to business is an ‘out’. But a benefit to a homeowner does not accrue to a business, and so does not count as an ‘out’. So the saving made by the owners of the more energy efficient homes built under any revised Part L 2013 is not an ‘out’, whereas savings from non-domestic buildings are. And the target is to reduce the net regulatory burden on housebuilders by 2015. So the changes for new homes, whilst ‘preferred’, must be balanced by DCLG finding compensating ‘outs’, or else they will have to change the package accordingly. For calculating compliance of new non-domestic buildings there will be four new concurrent notional buildings. These will be side-lit heated only (similar to an office or hotel for example), side-lit including cooling (a prestige office), top-lit (a retail shed) and un-lit (a data centre, or warehouse). The proposed building will have to perform at least as well as the concurrent notional building. The notional building has assumed
values for the fabric and services, and these have stimulated some debate. While some argue that these values provide
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useful guidance to designers on the levels of performance required, there are some concerns about some of the values being proposed, in particular for some aspects of metal clad buildings and for specific fan power of mechanical ventilation systems. A consultation version of the SBEM compliance calculation tool, cSBEM, has been provided to help consultees assess the impact of the changes and to inform consultation responses. There are also proposals to formalise the incorporation of innovative technologies into SBEM through an equivalent process to SAP Appendix Q. Finally, there is a proposal to create
an ‘Integrity Group’ for SBEM, made up of industry and stakeholder interests, to provide advice and guidance on development of the compliance tool.
Consequential improvements The big issue for energy efficiency is the acknowledgement that the great savings to be made are in the existing building stock. And so the proposals for consequential improvements for the existing stock make very interesting reading. For larger non- domestic buildings (over 1,000 sq m) there is already a requirement that when they undergo controlled work to the fabric or services, then consequential improvements to the energy performance must also be made. The proposal is that from 2013 these requirements will apply to all non-domestic buildings and also to the residential stock as well. However, at time of writing this policy is in doubt as there are reports that the Prime Minister may also veto these
The proposals on Part L of the Regulations also address aspects of the forthcoming Green Deal, aimed at encouraging homeowners to make their properties more energy efficient
What is the Coalition approach to regulations?
Government priorities for the 2013 changes are to: lDeregulate and streamline wherever possible;
lRegulate only when essential and after all other approaches rejected;
lDeliver policies which support the desire to be greenest government ever; and
lFurther improve compliance.
Controlling regulation: lA one-in, one-out approach to all domestic regulations;
lSpending Review commits to cut regulatory burden on housebuilders by April 2015;
lGreater scrutiny of analysis and policy by the Regulatory Policy Committee and Regulatory Reform Committee;
lA moratorium on regulation affecting micro-businesses and start-ups until April 2014; and
lChallenging all regulation through the Red Tape Challenge.
What is not in the consultation: DCLG reported at the CIBSE Consultation Seminar on 6 March that the following proposals were not brought
forward to consultation: lRevoking Part D (Toxic substances) – this is not being considered further as evidence suggests urea formaldehyde is still used;
lReviewing Part H6 (Solid waste storage) – decisions on this issue are pending, subject to work on the Waste Review and local authorities’ waste collection approaches; and
lReviewing Part E4 (Acoustics in schools) – has not been taken forward as DfE will be consulting on changes to their guidance on this issue later this year.
May 2012 CIBSE Journal 35
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