The performance requirements in this consultation closely resemble the fabric standards in the 2021 Part L uplift to the Building Regulations. We investigated including better walls, floors, roofs, triple glazing and improved thermal bridging. However, the only cost effective and practical improvement we found could be made to the standard was an improvement in airtightness. This improvement in airtightness is matched with the change to a decentralised mechanical extract ventilation system, in line with Approved Document F, Volume 1: Dwellings.
The decision to keep fabric standards largely the same is driven by several factors. Firstly, the level set in 2021 will ensure that (with adequate ventilation) new homes do not generally experience damp and mould or excessive temperatures; an increase in fabric beyond this level does not give significant additional benefit. Secondly, it allows efficient low carbon heating, including modern heat pumps, to function well. The move to low carbon heating is central to the government’s commitments to decarbonise housing, and so fabric must be set at a level that allows these systems to work efficiently. Again, increasing fabric beyond the proposed level does not deliver significant gains to the efficiency of heating systems. Thirdly, because the electricity grid is decarbonising rapidly, and the efficiency of heat pumps significantly reduces energy demand, further reducing total energy use is relatively less important than switching to electric sources of heat in efforts to decarbonise. Grid decarbonisation also means that fabric improvements are increasingly not a cost-effective intervention to reduce carbon. This means that as we increase fabric beyond the proposed level, the monetary value of carbon saved by increasing fabric efficiency is less than the cost of installing that additional fabric. As such, there are other interventions that decrease carbon and consumer bills in a more cost-effective way, such as (above) switching heat source and including solar PV panels.
It is vital that the industry responds now to this judgement by completing the consultation process before 6th March. Whilst STA will be responding on your behalf the sheer number of respondents will influence outcomes.
It is a weighty document but please go direct to Fabric in Section 4
This link will take you to the online survey where you can skip many of the questions that are not relevant. Any supporting evidence you might have should also be used.
Also see this link to the Future Home Hub Guidance