OPINION
PART L – SHOULD WE BE WORRIED?
Earlier this year, the Department for Communities and Local Government consulted on the Building Regulations. There was much press coverage of the so-called conservatory tax and, since then, silence. Hywel Davies asks whether the delayed publication is a cause for concern
In January of this year the Department for Communities
and Local Government (DCLG) issued a major consultation package on its proposals to revise the Building Regulations, in particular Part L, in 2013. The consultation closed in April 2012, and the revised Regulations and Approved Documents were promised for this autumn. The consultation was split into two
parts. One section covered proposals for householders to be required to install certain energy efficiency measures, known as consequential improvements, when doing other regulated work. This required responses in late March to enable the changes to be made in time to support the launch of the UK-wide Green Deal, which was then intended to start in October 2012. CIBSE members and staff spent
many hours reading the package and preparing a thorough response, which suggested some modifications to the proposals, and supported the idea that when people improve their home they should do the simple, energy efficient things that have not yet been done. We have heard nothing since. It is now highly unlikely that changes will be ready for introduction in April 2013, as originally proposed, leaving aspects of the Green Deal in disarray. But will they even be ready for October 2013? And should CIBSE members be concerned? During the consultation, DCLG
officials made a series of public presentations on the proposed changes to Part L and accompanying impact assessments. The proposed changes are all cost beneficial, with benefits outweighing costs over the life of the measures. In the domestic sector, the additional costs fall predominantly onto housebuilders and their land banks, while homeowners benefit. Under Treasury rules for assessing proposed regulations under the one
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as the costs, and it is a cost beneficial change overall. So what is the problem? Why are we
waiting for an announcement about the 2013 changes to Part L? Simply, we do not know, since DCLG
in/one out rules, only benefits to businesses count. And the coalition had already promised to reduce the net burden of regulation on housebuilders by the end of this parliament. But at that stage, DCLG officials suggested, they had identified various potential ‘outs’ to enable their proposals to proceed. The uncertainty holding back activity in the sector apparently does not count as a burden or a cost. A key element of the changes is
an 8% uplift in the carbon emissions target for new homes, as a step towards achieving zero carbon homes in 2016, which is the official policy position. There have been many reports that housebuilders are seriously concerned about the costs of achieving this, and wanted no change in 2013, allowing the general economy – and especially the housing market – to recover from recession, with the tighter emissions targets coming later. Meanwhile, DCLG proposed a 20% tightening of the emissions targets for non-domestic buildings. This was less challenging in terms of one in/one out, as the benefits accrue to business as well
It would be disastrous if the ‘greenest government ever’ allows its desire to reduce burdens on house- builders to scupper much needed changes to Part L
is saying nothing. But it is not hard to see that the changes for new homes have run into trouble, being seen by the Treasury as a burden on housebuilders and a barrier to getting Britain building again. The facts that more energy efficient homes would be cheaper for their owners to run, year after year, and that more efficient homes add less to UK imported energy, seem to have been disregarded. And we all saw the furious onslaught regarding consequential improvements, launched in April by elements of the press, with ‘sources close to 10 Downing Street’ indicating that the proposals would not be implemented. So that leaves the non-domestic proposals. A failure to sort out domestic changes is no reason to fail to sort out non-domestic, where there are clear business benefits and new technologies can be better targeted. So surely we should hear soon about the timetable for introducing the changes and for publication of the revised Approved Documents? Then the industry as a whole, and CIBSE members in particular, can begin to prepare, assess the implications, brief their clients and train their staff. It would be disastrous if the self-
styled ‘greenest government ever’ allows its desire to reduce burdens on housebuilders to scupper much needed, cost beneficial changes to Part L for the non-domestic market. For those businesses committed to better building performance, that should be a serious worry.
l HYWEL DAVIES is technical director of CIBSE
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December 2012 CIBSE Journal
21
LIANEM / SHUTTERSTOCK
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