Parts A and B sets specific standards for space heating and energy use. The HBF recognises the need to move towards greater energy efficiency via a nationally consistent set of standards and timetable, which is universally understood and technically implementable. The Government Response to The Future Homes Standard consultation on changes to Part L and Part F of the Building Regulations for new buildings published early in 2021 establishes a clear timetable for the transition to lower standards having regard to Governments legal commitment to be zero carbon by 2050. The transition to the Future Homes Standard in 2025 allows for an interim uplift that will require homes produce 31% less CO2 emissions compared to current standards.

To ensure as many homes as possible are built in line with new energy efficiency standards, transitional arrangements will apply to individual homes rather than an entire development and the transitional period will be one year. This interim uplift will see significant improvements on existing standards and allow the industry to ensure that by 2025 it is able to deliver the Future Homes Standard – which will require new homes to produce at least 75% lower CO2 emissions than one built to current energy efficiency requirements. By delivering carbon reductions through the fabric and building services in a home rather than relying on wider carbon offsetting, the Future Homes Standard will ensure new homes have a smaller carbon footprint than any previous Government policy. In addition, this footprint will continue to reduce over time as the electricity grid decarbonises.

The HBF supports the Government’s approach in allowing for a transition to the Future Homes Standard and the significant improvements this achieves as it recognises the difficulties and risks to housing delivery given the immaturity of the supply chains necessary to deliver the technologies required to meet the higher standards being proposed. Therefore, to support the industry, achieve the ambitious goals set by Government the HBF established a Future Homes Task Force to develop workable solutions for the delivery of the home building industry’s contribution to meeting national environmental targets and objectives on Net Zero.

Early collaborative work is focussed on tackling the challenges of implementing the 2025 changes to Building Regulations successfully and as cost-effectively as possible, in particular providing information, advice and support for SME developers and putting the customer at the centre of thinking. To drive and oversee the plan, a new delivery Hub (https://www.futurehomes.org.uk/) has been launched by the HBF with the support and involvement of Government. The Hub will help facilitate a sector-wide approach to identify the metrics, more detailed targets where necessary, methods and innovations to meet the goals and the collaborations required with supply chains and other sectors. It will incorporate the needs of all parties including the public and private sector and crucially, consumers, such that they can all play their part in delivering environmentally conscious homes that people want to live in.

The Government’s proposed approach which delivers a transition to low and zero carbon homes in line with it legal commitments is also reflected in national planning policy and guidance. Firstly paragraph 152 of the NPPF is clear that the planning system should support a transition to a low carbon future. As set out above a transition is necessary to ensure that homes can still be delivered before the higher standards required from 2025 come into force.

Secondly, the Government have now set out in Planning Practice Guidance the level of improvement to CO2 Councils can require through their local plans. As the Council note in the consultation document the Government have confirmed that local authorities are able to set policy requirements related to carbon reduction in their local plans. However, paragraph 6-012 of PPG states that for new housing this can only be up to the equivalent of level 4 of the Code for Sustainable Homes. This is roughly the equivalent to a 20% improvement on the 2013 Building Regulations and will soon be superseded by the proposed changes to building regulations. Indeed, by the time this local plan is expected to be adopted in 2025 the future homes standard will be in place requiring a 75% improvement in CO2 emissions.

Therefore, the policy being proposed which sets its own standards for operational emissions in new homes is not consistent with national policy. The HBF considers that the Councils should comply with the Government’s intention of setting standards for energy efficiency through Building Regulations and not set its own standards as part of the local plan. The key to success is standardisation and avoidance of individual Councils specifying their own policy approach to energy efficiency, which will create difficulties by creating an entirely separate requirement alongside that of building regulations. Indeed, the Councils’ own evidence for its proposed standards notes that for houses the recommended building fabric values are not much different to the Government’s proposed Future Homes Standard that will be enforced from 2025. As such the Councils proposed approach to energy use and efficiency in policy CC/NZ will only cause confusion in its implementation and enforcement with seemingly little additional improvement in energy efficiency.

Part C requires development to generate the same amount of renewable energy as they demand over the course of the year. Whilst the NPPF requires development to comply with policies relating to decentralised energy supply it is also necessary to recognise, as set out in paragraph 157 of the NPPF, that the implementation of such policies must have regard to site specific viability and deliverability. In some case it may not be possible to meet the required standard, and this should be recognised in the policy. The policy also makes no allowance for the decarbonisation of the national grid through the increasing level of supply from renewable sources of energy generation. Such improvements will need to be taken into account within any assessment of energy use and the level of onsite renewable energy that is required to be generated.

Part D allows for offsetting of carbon emissions in exceptional circumstances and that an assured performance method be used to ensure operational performance reflect design intentions. Firstly, the HBF consider that offsetting should not be a requirement of the local plan where it is not feasible to deliver local plan requirements for decentralised energy supply. Development should deliver the energy efficiency improvement required by building regulations and where feasible and viable meet some its energy demand through onsite renewable energy generation. Further offsetting should not be required. Secondly, with regard assessing operational performance, and as highlighted above, the most effective mechanism for ensuring a building is built to the required standard is through building regulations. By requiring additional standards, the Council will require additional assessments to be applied in parallel to building regulations creating confusion and adding costs. As we state above the most effective mechanism for delivering improved energy efficiency in new homes is through the nationally applied change to building regulations being proposed through the Future Homes Standard.