REA Response to MHCLG Consultation on the Future Homes Standard

(Including amendments to part L; conservation of fuel and power of the building regulations)

View the REA response here.

With thanks to REA members for their input on this consultation.

The REA Response states that:

Despite the transition to the low carbon energy system being well underway, just 1% of new homes built in 2018 were rated EPC band A (MHCLG, 2019). Strong progress has been made in decarbonising the power sector, although it is now clear that the buildings sector lags behind.  Cross-sector collaboration between the construction and energy industries, and immediate action, is imperative to meeting our newly adopted net zero GHG emissions target by 2050.

Homes and buildings have a key role to play in the transition to a decentralised energy system. On-site renewable energy generation, alongside clean tech such as EV charging and battery storage systems are crucial to creating the smart homes of the future. Not only is this part of a move to create more affordable, comfortable and healthy living spaces, but it is also striving to democratise the energy system by engaging prosumers and offering them the power to address climate change through their energy generation and consumption. The rollout of smart homes can also reap macro benefits such as offering grid flexibility to reduce the risk of blackouts and lower infrastructure costs, creating sustainable jobs, improving air quality and health, alleviating fuel poverty and more.

It is also fundamental that the Future Homes Standard  incorporate heat in two respects: 1) Mandating the use of high energy efficiency materials, thereby reducing the energy demand of properties 2) Ensuring all homes utilise a suitable low carbon heating system.

The nature of heat demand within different types of building means that there is no ‘one size fits all’ solution. Rural areas, apartment blocks, houses and commercial buildings all face differing challenges and opportunities. The current consultation correctly puts a strong focus on electrification of heat, however potentially also risks stifling the opportunity to use other renewable heat technologies more appropriate to regional infrastructure opportunities. Some of the key technologies expected to play a role include: heat pumps, biogas, biomethane and other green gases, biomass, biopropane, hybrid systems and district heating schemes.

This consultation response demonstrates the opportunities for the review of Part L of the Building Regulations, to support the construction sector and related sectors to transition the built environment into a net-zero emissions market. New buildings offer a no-regrets, obvious solution to tackling long-term carbon emissions reduction and improving housing stock.

This response calls for six key policy implementations which are crucial as a baseline for all new buildings:

1. Solar PV Roofing mandated as a minimum standard
2. All new buildings to be smart electric vehicle charge point “ready”
3. Energy Storage mandated in all new buildings or developments
4. Three-Phase electricity supply connections in new homes as standard
5. Renewables and Clean Tech to be fairly acknowledged in Energy Performance Certificates (EPCs) and the Standard Assessment Procedure (SAP)
6. Renewable heat as standard in all new developments

The REA has a preference towards option 2 (31% reduction in carbon emissions in comparison to the current standard), considering both proposed options, although we strongly believe that neither option is ambitious enough to support the construction sector efficiently to prepare for the FHS introduction in 2025, or for the related markets to prepare, consolidate and scale-up the required supply chains.

The urgency of the implementation of these updates is key.