The Good Homes Alliance and Bioregional, supported by the UK Green Building Council and LETI (the Low Energy Transformation Initiative), have expressed concerns to the Government over the adequacy and potential drawbacks of the Future Homes Standard consultation draft.
The letter, addressed to the Department of Levelling Up, Housing and Communities (DLUHC) and the Department for Environment, Sustainability and Net-Zero (DESNZ), has been signed by around 70 built industry players and will be submitted ahead of the consultation deadline on 6 March.
While acknowledging positive elements in the proposed draft, the consortium raises immediate issues that require attention in the upcoming 2025 regulations and is urging a change of direction away from a focus on retrofitting existing buildings to targeting a “fabric first approach”
The letter highlights that one of the major contentions lies with the Option 2 notional specifications, particularly the omission of solar panels and a lowering of building fabric standards.
The group warns that such measures could lead to an additional £600-£700 per year on energy bills for residents of new homes and emphasises the importance of considering the public sector equality duty, ensuring that Government standards do not disproportionately affect those with lower incomes or protected characteristics.
The letter also warns that lowering fabric standards could put additional burdens on the electricity grid, especially as demand is expected to quadruple by 2050 due to the electrification of heat, transport and industry.
A key demand in the letter is for all new homes to incorporate integrated solar PV as a standard feature, maximising the use of renewable energy, particularly as installation costs continue to decrease.
Additionally, the consortium supports voluntary post-occupancy performance testing but is adamant enhanced testing must be mandatory post-completion. It argues that transparency on actual performance is crucial, supporting the introduction of Building Performance Evaluation (BPE).
They say there is no evidence that higher standards would impact scaling and accelerating the delivery of new homes and believe the additional cost of implementing higher standards can be absorbed through adjustments to land values, as seen with previous regulation changes, without increasing household costs.
The group is calling on the Government to consider a more ambitious revision of the Future Homes Standard by 2028, incorporating embodied carbon, improved ventilation and building fabric.
The letter proposes starting with an industry and Local Authority agreed voluntary standard by 2025 to inform future building regulations.
LETI workstream lead Michela Ravaglia said: “Ultimately, the regulation described in this consultation draft will not deliver the carbon cuts within the construction sector necessary for the Government to maintain its wider, legally binding, carbon reduction pathways over coming years.
“By the third iteration of the consultation, the time is now for the Future Homes Standard and Future Building Standard to become the driver net-zero carbon, by targeting highly efficient fabric-first approach and regulating embodied carbon, rather than relying more heavily on retrofitting existing buildings.”
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