NLA responds to the Future Buildings Standards consultation

Tuesday 20 April 2021

Ashley Bateson

Director
Hoare Lea

Luisa Brotas

Sustainability and Infrastructure Lead
Royal Borough of Kingston upon Thames

Gary Clark

Principal and Regional Leader of Science + Technology
HOK

Katie Clemence-Jackson

Partner and Senior Engineer
Max Fordham

John Davies

Head of Sustainability
Derwent London

Paul Dipino

Chief Operating Officer
Joseph Homes

Sonal Jain

Sustainability Director
JLL

Nathan Millar

Principal, Sustainability
Introba UK

Juliette Morgan

ESG Consultancy Director - Global
British Land

Douglas Phillips

Senior Environmental Analyst
Historic England

Nils Rage

Head of Environment, Social and Governance (ESG)
Stanhope PLC

Dr Craig Robertson

Head of Sustainability
Allford Hall Monaghan Morris

Charlie Scott

Board Director
Waterman Group

Tom Steel

Founding Director
Heyne Tillett Steel

Derek Wilson

Head of Sustainability
Places for London

NLA responds to the Future Buildings Standards consultation

FutureHomes Passivhaus, South Gardens by Maccreanor Lavington © Tim Crocker. Project features in NLA's Zero Carbon London report

The NLA Expert Panel on Net Zero have submitted a response to the government consultation ‘Future Buildings Standards’ on behalf of New London Architecture (NLA) on Tuesday 13 April, while NLA joins several other built environment organisations in signing a letter to the Permanent Secretary at the Ministry of Housing, Communities and Local Government demanding more ambitious actions.

NLA’s response to the consultation welcomes the government’s commitment to tackle carbon emissions from buildings and the built environment sector, however it highlights the shortfall in acknowledging the challenge of bringing down emissions to net zero by 2050 and in setting an ambitious and achievable roadmap for the sector.

These are some of the key points highlighted in the response:

·The proposal to be net zero relying on the decarbonisation of the grid and heat networks is welcome but it doesn’t go far enough. The introduction of an interim upgrade to Part L in 2021 is long overdue, and so is the new future building standard by 2025. But they fall short of the expectations for 2050. A roadmap with future targets should be proposed. LETI, for instance, has created a net-zero roadmap that can be a basis for achieving net-zero carbon by 2030.
The new Future Buildings Standard should be more ambitious to also consider the ‘unregulated energy’ and a metric that can be easily comparable with the metered energy in kWh. The ‘energy in use’ metric proposed by LETI and endorsed by industry (i.e. RIBA) is a better solution that can be in the short term compared with benchmarks and in post construction monitoring with the real consumption.
The interim uplift to the energy efficiency standards for non- domestic buildings in 2021 should be at least 35% CO2 reduction. This is the minimum target that the GLA and boroughs in London have already adopted as part of the net-zero carbon policy for non-domestic buildings since 2016.
Buildings must be designed to reduce energy, avoid reliance on active systems, result in reduced carbon emissions and at the same time provide comfort and wellbeing to occupants. The decarbonisation is welcome but new buildings must not heavily rely on it to reach the net zero target.

Whilst not a specific question in the consultation, the matter of proper enforcement of building regulation compliance needs to be addressed. The Dame Judith Hackett review of building safety and regulations highlighted the low levels of site competency (especially in the residential sector) and poor levels of site inspections to check compliance. Various studies, including from the Zero Carbon Hub, highlighted the large performance gap between expected and actual performance outcomes. The government needs to be sure that enforcement of compliance with regulations is adequately resourced and penalties for compliance are sufficiently high. Many contractors have found that it is cheaper to pay a penalty for non-compliance than get it right the first time. The effectiveness of regulation improvements will depend, therefore, on an effective regulation enforcement system with adequate competency and resources.

View the full response

The response was led by:

Ashley Bateson, Partner, Hoare Lea (Chair)

Luisa Brotas, Senior Sustainability and Climate Change Officer, London Borough of Hackney

Gary Clark, Principal, Science and Technology Regional Leader, HOK London Studio

NLA Expert Panel on Net Zero members:

Marion Baeli, Partner, PDP London Architects

Ashley Bateson, Partner, Hoare Lea (Chair)

Luisa Brotas, Senior Sustainability and Climate Change Officer, London Borough of Hackney

Gary Clark, Principal, Science and Technology Regional Leader, HOK London Studio

Katie Clemence-Jackson, Principal Sustainability Consultant, Max Fordham LLP

John Davies, Head of Sustainability, Derwent London

Paul Dipino, COO, Joseph Homes

Sonal Jain, Director - Net Zero Carbon, Workplace and Clients, JLL
Nathan Millar, Principal, Sustainability, Elementa

Juliette Morgan, Head of Sustainable Development, British Land

Douglas Phillips, Senior Environmental Analyst, Historic England

Nils Rage, Sustainable Design and Innovation Manager, Landsec
Craig Robertson, Associate, Head of Sustainability, AHMM

Charlie Scott, Director of Waterman Structures, Waterman Group

Tom Steel, Director, Heyne Tillett Steel

Derek Wilson, Senior Sustainable Development Supervisor, TfL

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