Solar Trade Association Greencoat House, Francis Street, London, SW1P 1DH

t: +44(0)203 637 2945 e: enquiries@solar-trade.org.uk w: www.solar-trade.org.uk @thesolartrade

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The Future Homes Standard: 2019 Consultation on changes to Part L (conservation of fuel and power) and Part F (ventilation) of the Building Regulations for new dwellings

Response on behalf of the Solar Trade Association

About us

Since 1978, the Solar Trade Association (STA) has worked to promote the benefits of solar energy and to make its adoption easy

and profitable for domestic and commercial users.

A not-for-profit association, we are funded entirely by our membership, which includes installers, manufacturers, distributors,

large scale developers, investors and law firms.

Our mission is to empower the UK solar and storage transformation. We are paving the way for solar to deliver the maximum

possible share of UK energy by enabling a bigger and better solar industry.

Respondent details

Respondent Name: Gemma Stanley (Senior Policy Analyst)

Email Address: gstanley@solar-trade.org.uk

Contact Address: Greencoat House, Francis Street, London, SW1P 1DH

Contact Telephone: 0203 637 2945

Organisation Name: Solar Trade Association

Would you like this response to remain confidential? No

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Solar Trade Association (STA) Summary of Positions 2020 Uplift: At a minimum, the Government should implement Option 2, 31% uplift. Option 1 (20%) does not provide adequate preparation for the outlined 2025 75-80% uplift, with only negligible improvements being required to achieve 20%. It is extremely concerning that the addition of Flue Gas Heat Recovery to existing fabric standards allows for Option 1 to be achieved. Option 1 does not deliver a 20% saving across a representative housing stock. Option 2 provides a more robust specification and is a preferable interim step. There are various, established compliance routes to achieve 31%, which encourage developers to improve designs through both fabric and technological measures. This is in line with what will be required for FHS and would deliver substantial savings for householders. STA Building Regulations 2020 modelling indicates a 40% uplift in 2020 is achievable, would encourage further fabric improvements and the incorporation of low carbon technologies to the benefit of householder energy demands, running costs and preparation of the industry for 2025. The impact of implementing a higher uplift of both 31% or 40% on households, skills, jobs and UK manufacturing would be substantial. Future Homes Standard: 75-80% is the minimum uplift that should be legislated for in 2025. Net Zero Buildings and neighbourhoods are already being developed, meaning an uplift of 75-80% with a five-year lead time will be achievable for all developers. An ambitious uplift for 2025 must be defined in 2020 to provide clarity, certainty and sufficient lead time for industry to prepare. The declining carbon intensity of the grid and its effects on compliance routes as well as the achievement of the Building Mission must be kept central to decision-making. Achieving 80% will require high fabric efficiency and a suite of low-zero carbon technologies (LZC), meaning it is imperative the 2020 uplift prepares industry to develop skills and supply chains. Smart, Flexible System: The increasing electrification of transport and heat will necessitate substantial increases in renewable deployment and transitioning to a smart, flexible energy system. Local generation and storage will be central to mitigating the increased demands of individual households and energy bills as well as localised grid constraint issues. STA modelling evidences solutions with onsite generation to have the lowest costs for occupants, with solar performing better than other carbon abatement solutions. Government must capitalise on this opportunity to ingrain new homes into the smart, flexible system through a building regulation framework that encompasses onsite generation such as solar and storage technologies. Consultation Framing: The framing of the consultation is misleading and does not reflect the neutral approach that building regulations takes. The consultations framing could elicit preferences for either ‘fabric’ (as indicated in Option 1) or ‘technological’ (Option 2) improvements, with the incorrect understanding that these will be the default compliance route from developers. Transitional Arrangements: Where building work has commenced on an individual building within a reasonable period, the transitional arrangements should apply to that building, but not to the buildings on which building work has not commenced. Provisions must be included to ensure developers cannot build to previous versions of Part L for years to come. Regulations should apply to individual buildings not development sites. Restricting Local Authority Powers: The government should not commence the amendments to the Planning and Energy Act. Local Governments have led the way in stipulating higher building regulations, acting as a driver for innovation, skills and supply chains. Stifling their ability will have poor consequences for the achievement of the Future Homes Standard, the Building Mission and increasingly localised issues such as the decarbonisation of heat. National standards should be a floor not a ceiling. Performance metrics: 1) Primary energy should be the principal performance metric. The STA challenges the discriminatory setting of the Primary Energy Factors (PEF) for exported renewable electricity at 0.501 when utility scale renewable PEF export is set to 1. 2) Building regulations now do not account for more than half the energy used in homes. 2020 should measure both regulated and unregulated energy demand in households, without which the Building Mission achievement will be difficult to assess. 3) SAP does not keep up with innovation or technology and has had amendments that result in a 20% uplift being possible from negligible improvements (e.g. flue gas heat recovery). SAP is ill suited for the future where time of use becomes central to carbon intensity. Decarbonisation of Heating: the focus on heat pumps and heat networks is narrow in scope and the consultations approach to heat networks needs further consideration for their fuel sources. Different technology mixes must be considered for 2025 and smart heating should include things like, solar PV, diverters, battery storage, dry core thermal storage, solar thermal, renewable-integrated heat networks and heat pumps. Impact Assessment: based on STA evidence, the solar PV Impact Assessments (IA) costs are too high. If accurate costs, see Q.68, were reflected in the IA the costs for implementing Option 2 would be even lower. Furthermore, the IA should recognise that homes built to too low a standard today will need to be upgraded in future at a higher overall cost and therefore the IA include the future costs of upgrading homes to meet the UK’s zero carbon ambitions.

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STA: “Building Regulations 2020 Modelling” The STA consultation response utilises the evidence, expertise and understanding of members as well as information from collaborating

with other external partners. The STA commissioned Th!nk Three to assess the full impact of the building regulation proposals. This

includes analysis on the possible compliance routes to the proposed uplifts in 2020 and 2025, the introduction of PEFs, the impact on

energy demand, costs to households and more. The full report “Building Regulations 2020 Modelling” is attached with this consultation

response.

The modelling tested numerous alternative specifications for meeting the proposed targets for the Future Homes Standard for the

following four representative new build house types: 4b7p detached house, 3b5p semi-detached house, 2b4p terraced house, Small 11-

unit apartment block (3x 1b1p & 8x 1b2p).

Seven different Fabric Specifications have

been tested to provide a broad church of

options for meeting the notional

performance targets proposed in the

Consultation. Five different Low & Zero

Carbon Technologies have been tested both

in isolation (i.e. as individual measures), but

also in every possible combination to test

solutions for meeting the future Homes

Standard from 2025. Four performance

scenarios have also been tested covering

both Options proposed in the FHS

Consultation 2020, the FHS 2025 standard

and a 4th potential performance scenario as

a half-way step towards the Future Homes

Standard:

1. Option 1 – 20% improvement over ADL2013 (‘Future Homes Fabric’)

2. Option 2 – 31% improvement over ADL2013 (‘Fabric Plus Technology’)

3. Option 3 – 40% improvement over ADL2013 (broadly equivalent to current

requirements from the GLA)

4. Option 4 – 80% improvement over ADL2013 (assumed to represent the

Future Homes Standard from 2025)

The outputs provided for the housetypes, fabric specifications and LZC Solutions

include:

1. Dwelling emission reductions: Tables are provided for each housetype showing the final regulated emissions for each of the

Fabric Specifications and LZC technology solutions tested, and against four performance scenarios. The results are measured in

KgCO2/year and show the percentage difference between the Target Emissions Rates (TERs) and the Dwelling Emission Rates

(DERs) for each electric or gas fuelled option.

2. Energy Consumption: Additional tables are provided to show the regulated energy demands (space heating, hot water, pumps,

fans and lighting) and any on-site generation for each housetype and each technology solution tested. The results are measured

in kWh/yr and the ratio of regulated energy to total energy demands (regulated + unregulated) to indicate the relative

proportion of energy demands regulated under law.

3. Costs of regulated energy: The results show costs for regulated energy demands only for all the technology solutions tested to

compare the costs of using electricity vs gas to meet the dominant space heating and hot water energy demands within the

dwellings. Costs are compared against a notional baseline cost and include any benefits from on-site generation at different

levels of utilisation within the dwelling – 100% (current position); 50% (SAP10.1); 80% (PV Diverter / Battery storage).

4. Primary Energy: Primary Energy Figures are provided for the main regulated energy demands as well as a whole house figure

measured in kWh/m2/yr and compared to the new Target Primary Energy Rates (TPERs) set under each performance scenario

within the consultation (Option 1 – TPER1; Option 2 – TPER2).

Low and Zero Carbon Technologies Tested

1. Wastewater Heat Recovery (WWHR)

2. Flue Gas Heat Recovery (FGHR)

3. Solar Water Heating (SWH)

4. Solar Photovoltaics (PV)

5. Solar Thermal Space Heating (SSH)

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Overview

The STA welcomes the opportunity to response to the Future Homes Standard (FHS) and changes to Building Regulations Part L. The consultation will not only determine the standards that new build homes will be built to in 2020 and 2025 but will also establish the role new homes will have in the smart, flexible system and develop the industry’s ability to improve the retrofit market. The consultation must balance multiple intentions of tackling emissions from homes, developing the FHS, ensuring the 2020 uplift is a sufficient “steppingstone” and improving energy performance and bills of households. It is critical that 2020 does not see back-peddling from Government in their ambition due to the efforts of developer lobbying. Transitioning to a smart, flexible energy system: The housing stock requires ‘near complete decarbonisation’ (Committee on Climate Change (CCC), 20191) in order to meet the former emissions targets of 80% by 2050. Transitioning to a smart, flexible energy system is widely understood as necessary to support cost-effective decarbonisation and the increasing electrification of transport and heat. The consultation identifies the key role of building regulations in decarbonisation, however, there is insufficient recognition for its responsibility to ensure homes are incorporated within a smart, flexible system. This omission is at odds with the growing consensus for the smart agenda with Government Smart Systems and Flexibility Plan and increasing expert analyses demonstrating the economic value. ARUPS “Energy Systems: A view from 2035”2 noted the decentralised, disaggregated and multi-vector nature of the 2035 energy system ‘will make flexibility (in system architecture, system operation and the regulatory framework) essential to achieving the Government’s three objectives of decarbonisation, security and affordability’. Imperial’s analysis of the residential sector’s flexibility potential suggests whole system cost savings of £6.9bn are possible, through reducing investment requirements in network infrastructure and opting for cost-effective wind and solar instead of more expensive low carbon generation like nuclear and CCS3. A holistic approach to decarbonisation and flexibility is required and it is noticeable the consultation makes little or no references to energy storage, the Heat Roadmap, HNIP or potential requirements for new builds to have EV chargepoints. Local Generation is Critical: The direction of travel is towards more electric power; Government has stipulated there is no place for gas and oil-based heating in new homes and there is an increasing number of Electric Vehicles (EV) appearing on driveways. Analysis done by Aurora into the 2025 proposal to use electricity to heat new build homes suggested there could be an increase power demand from the sector from 27TWh/year to 100TWh/year by 2050 4 . National Grid have suggested that a deep penetration of EVs, smarter charging and V2G could increase peak electricity demand 3-13GW by 20505. The increased demand for clean power and renewable deployment is already hindered by an outdated and heavily constrained grid, which is costly and prohibitive towards renewables connecting and transporting the generation to where it is needed. Energy generated and stored at a local level, if not onsite, will be critical to mitigating increases in demand and localised constraint issues. Furthermore, increasing electricity retail prices mean that this zero-carbon future must place consumer costs at its heart. New build onsite generation provides a unique route to mitigating increases to unregulated energy that result from technologies such as EVs as well as being capable of tackling the regulated energy demands that remain after energy efficiency improvements. This vision will be integral to achieving the Government’s Building Mission to half both regulated and unregulated energy use by 2030. The cost-effective, scalable, adaptable and reversible nature of solar makes its use appropriate for rooftops, farmland, carports, fields, housing estates, schools or even bodies of water. It is a given that solar will have a central role in local generation, meaning this cannot be ignored by building regulations. The homes of the future may look like those of the past but will work differently. For a substantial number the transition has already begun. The Feed in Tariff has led to over 900,000 rooftops having installed solar and more are incorporating storage, smart meters and AI or IOT-related technology. Solar is reliable, aesthetic, has widespread public favour (BEIS Public Attitude Tracker places its support at 85% from the public, the highest out of the renewable energy sources6), a supply chain that can deliver at scale nationwide. Incorporating battery and heat storage with smart facilities allows for energy to be stored until it is required. Decarbonisation also requires the active engagement of society. No other energy generation technology empowers engagement

1 https://www.theccc.org.uk/wp-content/uploads/2019/02/UK-housing-Fit-for-the-future-CCC-2019.pdf 2 https://www.arup.com/perspectives/publications/research/section/the-future-of-energy-2035 3 https://www.ovoenergy.com/binaries/content/assets/documents/pdfs/newsroom/blueprint-for-a-post-carbon-society-how-residential-flexibility-is-key-to-decarbonising-power-heat-and-transport/blueprintforapostcarbonsocietypdf-compressed.pdf 4 https://www.reuters.com/article/us-britain-energy-demand/uk-power-demand-to-soar-on-plans-to-end-gas-home-heating-research-idUSKCN1R00V3 5 https://www.carbonbrief.org/rise-uk-electric-vehicles-national-grid-doubles-2040-forecast 6 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/844940/BEIS_Public_Attitudes_Tracker_Wave_31_key_findings.pdf

Photo Credit: HBS New Energies, Lovell Partnerships Bulford SFA

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right across society in the clean energy shift like solar through reducing energy bills, providing revenue streams for exported energy and access to renewable generation ownership. There are new opportunities for householders with onsite generation, including participation in flexibility services and demand side response, peer to peer trading and the emergence of local energy markets such as in the Isles of Scilly and Cornwall, which allow homes to generate, store and sell their energy to energy companies or neighbours. Suppliers such as Octopus Energy are offering time of use import and export tariffs able to be integrated with technology such as Amazon’s Alexa; enabling power management through voice automation. All these models are facilitated through innovation that will assist with the transition including Blockchain and Artificial Intelligence. Government must recognise this and support widespread participation – particularly given the smart power agenda and the Industrial Strategy’s pledge to ‘develop smart systems for cheap and clean energy across power, heating and transport’ (p.45). Divergence also puts the UK at a competitive disadvantage. Whilst the UK is currently in a good position for the development of a ‘smart’ energy industry, new build homes are integral to progress this development. The Government must not miss this opportunity and implement ambitious standards and a framework that encourages the incorporation onsite generation, smart technology and energy storage so that the UK domestic ‘smart sector’ is not at a major disadvantage compared to European competitors. We are disappointed that the Impact Assessment (IA) costs are not weighed or contextualised against the huge benefit for UK consumers of building smart infrastructure at the local level, nor recognise the vast expense that retrofitting homes will lead to if ambitious standards are not implemented – which will be exacerbated if Government’s increased home building ambitions are realised. New build housing is a ‘low hanging fruit’ as building regulations are easily improved to ensure new homes are energy efficient and low carbon, yet previous Government ambitions have been stymied by developer lobbying. Perspective must be kept with developer claims of the proposals resulting in high costs and “too short” transition periods. Firstly, housebuilders are making record profits facilitated in part by the scrapping of the 2015 Zero Carbon Homes as land bought at prices that assumed the build costs of Zero Carbon Homes is instead being developed with homes with almost the same specification of a decade ago, handing an enormous windfall profit to developers. BEIS Select Committee evidence highlighted Persimmon’s successful lobbying efforts to keep standards lower in 20157. This facilitated the £75million bonus Persimmon’s CEO received in 2018 after building 16,499 houses. It is notable that on a per house basis this bonus alone exceeds the impact assessments cost of implementing the higher ambition (i.e. Persimmon’s received bonus of £4,558.55 per house)89. Government schemes intended to boost housing demand and support prices, such as the Help to Buy scheme, have also increased housebuilder profits10. Secondly, developer responses against short transition periods only serve to highlight a refusal to prepare for the inevitable. There has already been a long run up to the implementation of higher building regulations arguably with interim steps already in place. Scotland improved their building regulations in 2015 and over half of UK Local Authorities have set higher building standards than national ones11. The CCC (201912), UKGBC (Net Zero Carbon Buildings Framework13) and even the property and construction industry themselves have been calling for action with increasing urgency since the scrapping of the Zero Carbon Homes policy in 201514. The direction of travel has been clear. Any claims of developer unpreparedness or concerns over alleged difficulties arising from the short transition and higher ambition should be deemed misleading or as poor business preparedness. The consultation has framed the proposed options as “Option 1 high fabric” vs “Option 2 low-carbon technology and lower fabric” in contradiction to the neutrality of building regulations. The framing of the consultation risks invalidating responses. The misleading framing could lead to energy efficiency groups favouring Option 1 in the mistaken understanding that this will result in higher energy efficiency or fabric improvements, as the consultation depicts. Government should carefully consider whether support for Option 1 is due to a preference for higher energy efficiency, which would not necessarily be the default if implemented due to the neutral building regulation framework. Analysis of compliance routes to the 2025 uplift are clear about the necessity of both fabric and technological improvements to new homes. 2020 must ensure both these skills and supply chains are developed for 2025 to be a realistic ambition as well as to ensure the retrofit market is capable of being improved on a large-scale basis.

7 https://researchbriefings.files.parliament.uk/documents/SN03668/SN03668.pdf 8 https://www.bbc.co.uk/news/business-45915486 9 https://www.persimmonhomes.com/corporate/media/370173/persimmon_ar18.pdf - see page 3 10 https://www.bbc.co.uk/news/business-47372385 https://www.theguardian.com/money/blog/2017/oct/21/help-to-buy-property-new-build-price-rise 11 https://www.solar-trade.org.uk/about/leading-lights/the-good-the-bad-and-the-leading-lights/ 12 https://www.theccc.org.uk/wp-content/uploads/2019/02/UK-housing-Fit-for-the-future-CCC-2019.pdf 13 https://www.ukgbc.org/wp-content/uploads/2019/04/Net-Zero-Carbon-Buildings-A-framework-definition.pdf 14 https://www.ukgbc.org/news/property-construction-industry-calls-government-raise-bar-environmental-standards/

Photo Credit: Viridian Solar, Forster Roofing, Alva Ogilvie

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Responses to Questions Chapter 2: The Future Homes Standard

Q.1 Do you agree with our expectation that a home built to the Future Homes Standard should produce 75%-80% less CO2 emissions than one built to current requirements?

A. Yes B. No - 75-80% is too high a reduction in CO2 C. No – 75-80% is too low a reduction in CO2

75-80% reduction in CO2 is an attainable target for 2025; providing the 2020 uplift initiates reform and preparation within the house builder industry and relevant supply chains. 80% should be the minimum uplift legislated for by 2025.

Net zero new build homes and neighbourhoods are already being developed across the UK, meaning there is a strong argument that in half a decade this would be achievable on an industry-wide basis. Two net zero neighbourhoods have been announced in Oxfordshire and Pontardawe with 25 and 35 net zero carbon homes respectively151617. GlaxoSmithKline Carbon Neutral Laboratory for Sustainable Chemistry was built in 2017 and Ssassy Property this year announced they are building 25 net zero, ‘affordable’ houses, in Oxfordshire. There has also been substantial progress in low-carbon homes development: Bickleigh Down Eco Village development of 91 new homes and apartments built to an exceptionally high environmental standard had planning dating back to 2012. Furthermore, UKGBC published an industry-led net zero framework to facilitate these developments and STA report found that over 50% of Local Authorities have already stipulated some form of higher regulation than what is required nationally.

It is critical there is a defined, ambitious target set this year for 2025, so that industry has the stability and certainty required to achieve it. The uplift implemented should be 80% at a minimum, as despite not being as ambitious as a net zero target, in five years this ambition provides a very achievable uplift to new build homes that substantially improves the new builds sectors contribution to achieving net zero 2050. Setting 80% uplift to be achieved in 2025 also sends a message about the direction of travel to developers in 2020. A lower 2025 ambition could jeopardise substantial improvements to homes in 2020 as there would be greater effort from developers to ‘tweak’ designs, foreseeing a radical approach in 2025 had been averted and simpler ‘bolt-on’ measures could still be utilised in 2025. STA Building Regulations 2020 Modelling found achieving the FHS would require a suite of LZC and fabric efficiency improvements. The five-year lead time until the FHS is implemented should not be missed as an opportunity for industry to prepare and substantially improve the upcoming new build housing portfolio.

The Building Mission must be kept integral to decision-making, with both 2020 and 2025 targets being crucial steps to its achievement in 2030. Former STA modelling indicated that even with passive house fabric efficiency halving unregulated and regulated energy in new build homes would require onsite generation. STA Building Regulations 2020 Modelling researched different compliance routes to 80%. The findings were supportive of this earlier research as confirmed that as heating and hot water demands decrease with the installation of the excellent fabric and LZCs required to achieve a 75-80% improvement, plug loads represent ~65-80% of the total energy demands for homes built to the FHS. Building regulations must incorporate and measure energy use (regulated and unregulated) within homes moving forward. The analysis evidenced further benefits to consumers for the inclusion of onsite generation through how “solutions with on-site generation have the lowest energy costs for occupants” and that “costs savings to occupants can be augmented by maximising the use of local generation within the dwelling”. Carbon Intensity of the grid has decreased substantially and led to the consultation proposing primary energy, carbon and affordability as metrics for compliance routes. Clearly where carbon intensities of the national gas and electrical grids lowers, the absolute CO2 emissions associated with the energy use of these primary fuels will lower correspondingly. Whilst it is not unreasonable to predicate future emissions trajectories for new homes on projections for the carbon intensities of the national grids, consideration should be given to ensuring new homes constructed today are future proofed for a low carbon infrastructure in the future. For instance, a sensitivity analysis on lower grid intensities shows that electrically heated dwellings could achieve the FHS 2025 standard with a Relaxed Fabric Specification using heat pumps. This can be mitigated through higher uplift requirements in the interim but requires careful consideration moving forward.

STA Building Regulations 2020 Modelling findings reflect that it is possible to achieve >80% reductions in CO2 as well as meet corresponding targets for Primary Energy. The ambition for the Future Homes Standard can be realised but will require very

15 https://www.theguardian.com/environment/2019/dec/23/net-zero-carbon-neighbourhood-to-be-built-in-south-wales 16 https://electrek.co/2019/10/22/uk-builds-first-net-zero-energy-neighborhood-houses/ 17 https://www.ukgbc.org/ukgbc-work/net-zero-carbon-buildings-a-framework-definition/

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high-performance building fabric combined with efficient appliances and building services coupled with optimised local generation, ideally using Solar PV. If this standard is regulated, the new home of the future will have very low heating demands, use systems to supplement energy supplied from a decarbonised electricity grid and generate significant energy locally from renewable sources, predominantly from solar. PassivHaus Electric only specifications will potentially exceed 100% reduction in emissions, negative Primary Energy rates and very low running costs.

In the interim years to 2025, designs using gas should consider how alternative electric systems could be retrofitted where it becomes cost-effective and carbon-effective to do so. Heat emitters should operate at lower temperatures; space for larger electrical appliances including outside space should be factored into the designs; roof designs should be optimised for solar generation since this delivers significant benefits in lowering running costs for occupants; Space for storage should be made available within the internal floorplan; space and suitable connection arrangements for storage and EV charging should be future-proofed for higher loads and potentially 3-phase power supplies.

To guarantee the level of CO2 emissions abatement required for meeting the FHS standard across all typologies, the following recommendations were recommended from STA Building Regulations 2020 modelling:

• Enhanced or PassivHaus building fabric standards

• Electricity is the primary fuel for all energy demands

• Heat pumps are used to supply the space heating and hot water

• Significant use of LZC technologies would be required (e.g. WWHR + SWH + PV)

• Designs are optimised for maximising on-site generation use

• Grid carbon intensities would need to reduce

Government must ensure the building regulation framework incorporates the Government’s smart agenda in achieving the FHS and allows new build homes to participate in the smart, energy system as an “Active Building”.

Q.2 We think heat pumps and heat networks should typically be used to deliver the low carbon heating requirement of the Future Homes Standard. What are your views on this and in what circumstances should other low carbon technologies, such

as direct electric heating, be used?

There will be no one size fits all approach for the future of low carbon heating in the UK; localised approaches will be necessary and factors such as an area’s population density and existing network infrastructure will influence what solutions are appropriate. This is pertinent to the suggestion that local authorities should have their building regulatory powers removed; which the STA sees as being detrimental to the different approaches and innovation needed to decarbonise heat. The timing of energy use will soon be as important, if not more important than the quantity of energy use. Technologies that provide flexibility on timing will enable the country to use low-cost, low-carbon energy from renewable sources at times of high generation and low demand. We are already seeing instances of negative energy costs. – where suppliers pay consumers on flexible energy tariffs to use electricity at certain times. Buildings that can be flexible about when energy is used will be able to reduce carbon emissions, primary energy use and energy bills by responding to signals from smart electricity grids. As the grid tends towards zero carbon, buildings that have higher energy use, but use it at the right time, will have lower emissions than more efficient buildings (measured on total energy consumption) that cannot supply this flexibility.

The direction towards the electrification of heat in new build homes will have substantial implications on demand, grid imported and running costs for consumers. Solar (PV and thermal) is able to contribute significantly to a household’s low carbon heating, reducing electricity bills and ensuring that the household supply is decarbonised as much as possible. The consultation doesn ’t take sufficient account of the role for energy storage. Combining smart thermal or chemical storage will enable a more rapid and low-cost transition to electric heating.

Whilst we agree that for now in new build homes, electrification of heat will be the principle means of decarbonisation, we see direct electric heating playing a much larger role than suggested by the FHS. Direct electric heating is appropriate for new developments with a small heat load mitigated by onsite generation (such as solar) and low-cost storage technologies (such as battery or thermal storage including dry core thermal storage). Direct electric heating can provide dynamic flexibility as heat for space heating can be accumulated in water tanks, phase change materials or even high heat capacity building fabric and released slowly to maintain temperatures.

It is important that low carbon heating technologies, such as heat pumps, are considered in combination with other low carbon technologies and that building regulations and the associated methodologies behind it (such as SAP) remain up to date with the

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rapid rate of innovation taking place within the heat sector. Heat pumps are configured to run at low intensity over long periods and are less capable of dynamically responding to pricing/carbon signals. To ensure effective uptake consideration for distribution systems, heat emitters, space for the units and suitable locations for external fan coils is needed. Public awareness, understanding and perception of technologies such as heat pumps must also be tackled. For instance, even with higher standards in Scotland, developers have demonstrated reluctance to incorporate heat pumps into designs, which could be due to the lack of understanding and popularity with the public.

Furthermore, heat networks are not easily low carbon and zero-carbon supply must be considered during design phase to ensure heat networks can become so. Heat networks should have their distribution temperatures lowered and raised at point of use to reduce losses. As efficiency in homes increase, space-heating demands will become lower - passivhaus standards indicating that space heating demand will be minimal – so it is important that the consultation focuses on energy for water heating and cooling. The consultation does not reflect a holistic approach to the BEIS heat roadmap nor HNIP.

Q.4 When, if at all, should the government commence the amendment to the Planning and Energy Act 2008 to restrict local planning authorities from setting higher energy efficiency standards for dwellings?

a) In 2020 alongside the introduction of any option to uplift to the energy efficiency standards of Part L b) In 2020 but only in the event of the introduction of a 31% uplift (option 2) to the energy efficiency standards of Part L c) In 2025 alongside the introduction of the Future Homes Standard d) The government should not commence the amendment to the Planning and Energy Act. Please explain your reasoning.

That the amendment should be made on the basis that higher national building standards are set is pre-emptive without a finalised decision. Regardless, the consultation itself recognises that the Planning and Energy Act “has been very useful in delivering more energy efficient homes and reducing carbon dioxide emissions in local areas”. STA “Leading Lights” report and findings that over half of local authorities have implemented some form of building regulations above national standards already supports this. 17% of local authority higher standards were rated “Leading”, with some already setting higher standards than those proposed in Option 2 (e.g. the London Plan). The higher standards set across devolved powers such as Scotland, Cambridge and Milton Keynes have evidenced how higher, variable standards does not lead to less homes being built.

Without these additional powers, the supply chains and skills required to reach the FHS would be even less developed. The Planning and Energy Act has driven higher standards, innovation, local jobs and local authority leadership with regards to improving households and tackling climate change and fuel poverty in their areas. The consultation stipulates that as we improve standards ‘there may be no need for local authorities to seek higher standards’ but this completely ignores the Building’s Mission challenge of halving both unregulated and regulated energy demands by 2030, local authorities declaring climate emergencies and setting their own net zero targets. The achievement of all of these would benefit from local authority freedom to explore and encourage localised solutions. Removing powers held by local authorities to improve their areas is only serving to reduce the capability of those with the greatest understanding and knowledge to tackle localised issues. There is no substantive evidence for why the consultation states: “inconsistency creates inefficiencies in supply chains, labour and potentially quality of outcomes”, as developers and local authorities that have been developing buildings to fit these higher build standards, will have progressed with skills, partnerships and supply chains to incorporate the more stringent designs.

There are also alternatives to removing the power completely if inconsistent standards remain a substantive concern. A “gold standard” (akin to that in Scotland) of building regulations significantly higher than the 2020 Part L uplift could be available for local authorities to “opt in” to. This would remove the lack of uniformity issue whilst ensuring areas wanting to improve the quality of their homes quicker are able to. Finally, the statement “Not all home-builders are ready to build to higher fabric specifications yet”, is unsubstantiated. If true, it would be due to home builders having refused to develop homes in accordance with any of the local authorities implementing higher standards or prepare for the inevitable tightening witnessed already in Scotland but on the horizon since the initial zero carbon policy in 2015. For this statement to have weight in the outcome of the consultation would be hugely restrictive. The following excerpts from STA “The Good, the Bad and the Leading Lights” highlight local authorities experience of achieving their set higher standards, evidencing the positive experience and achievability of the requirements.

London Borough of Merton Policy Detail: London Plan Implementation Monitoring: Positive outcomes. Most if not all developments can meet these targets on site. Most developers are now considering these issues at the start of development (and not as a bolt-on towards the end, which was the case about 5 years ago, resulting in some compromise and additional costs for the developer).

Bedford Borough Council

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Policy Detail: New development must achieve a minimum 10% reduction in carbon emissions (below the normal requirement set by the Building Regulations) …In new developments above a threshold of 1000m2 or 50 dwellings, the supply of at least 10% of the energy consumed in the new development to be provided from decentralised and renewable or low-carbon energy sources. Implementation Monitoring: The adopted policies have been successfully implemented through the grant of planning permission for relevant development. The requirements of the policies are generally not challenged by applicants for planning permission

Sheffield City Council Policy Detail: Requirement for residential developments of 5 or more dwellings … provide a minimum of 10% of predicted energy needs from decentralised and renewable or low carbon energy. The policy also sets out that developments over the same thresholds should incorporate measures to reduce carbon emissions by 20%, however this has not been implemented in recent years in light of changes to the Building Regulations which have increased the standards for developments. Implementation Monitoring: We do not formally monitor the implementation of these policies and guidelines; however, we have anecdotally observed a significant increase in the standards of new developments following the adoption of the policies and guidelines.

GLA Policy Detail: Energy Monitoring Report: Implementation Monitoring: A carbon reduction of 36.9 per cent more than required by the 2013 Building Regulations, comfortably surpassing the London Plan target of a 35 per cent reduction. 80% of the 130 applications reached the 35% target set by the London Plan (this dismisses the notion that the offset fund is the sole beneficiary of the higher building regulations within the London Plan). 78 residential applications were required to meet the zero carbon homes target of 35% and make a carbon offset payment, achieving an overall saving of 39.4% in the carbon emissions, comparatively to the previous figure of 35.6% before the requirement was implemented.

Q.5 Do you agree with the proposed timings presented in Figure 2.1 showing the Roadmap to the Future Homes Standard?

a) Yes b) No – the timings are too ambitious c) No – the timings are not ambitious enough

The Future Homes Standard Implementation consultation has too short a lead time. The FHS has five years until implementation, meaning all efforts should be made toward giving the industry as much preparation time as possible, especially as consultations are often delayed or pushed back. A longer lead time will facilitate a smoother transition. Additionally, it is unclear within this timeframe what “case-study on homes built to 2020 standards and early FHS adopters” is in reference to. It is also unclear whether the taskforce and technical working groups are interlinked. If the technical working group is interlinked to the taskforce, particularly the industry task-force interim report, then it would be pertinent for the technical working groups to also be established earlier.

Chapter 3: Part L Standards for New Homes in 2020

Q.6 What level of uplift to the energy efficiency standards in the Building Regulations should be introduced in 2020?

a) No change. b) Option 1 – 20% CO2 reduction c) Option 2 – 31% CO2 reduction (the government’s preferred option) d) Other

The consultations preferred option to ‘go as far towards the Future Homes Standard as possible in 2020’ is welcomed as the 2020 uplift will be critical as an interim step to making the FHS achievable. Ensuring that the 2020 uplift results in adequate industry preparation for 2025 must be the key consideration for what is implemented, whilst balancing the benefits to households, the cost of implementation and (not included in the impact assessment) the costs of inaction such as additional expense due to increased retrofit requirements.

At a minimum Option 2 31%, should be implemented in 2020. STA Building Regulations 2020 Modelling supports 40% as an alternative interim step to an 80% uplift in 2025. The findings reported that compliance routes for 80% will necessitate both fabric and technological improvements to new homes (to the benefit of achieving the Buildings Missions, low energy costs and preparing new homes for the smart, flexible energy system of decarbonised transport and heat). Compliance routes for 40% are not only achievable but more likely to incorporate both fabric and technological improvements to design than a 31% uplift, thereby readying the skills and supply chains for the FHS and retrofit market far more effectively.

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SAP: Compliance has been made easier through changes to complex, unsuitable SAP calculations. SAP does not keep up with innovation or technology and is ill suited for the future where time of use becomes central to carbon intensity. For instance, SAP currently does not allow the combination of both battery storage and solar heating diverters. Furthermore, updates to SAP has inadvertently allowed negligible improvements to design to contribute substantially toward compliance. STA Building Regulations 2020 modelling identified the addition of flue gas heat recovery as able to contribute significantly towards achieving uplifts, despite the fact this technology will have no role in new build housing come 2025. Government should fully analyse the compliance routes SAP promotes and discourages and whether this fits in with their overarching ambition.

Carbon Intensity of the grid has decreased substantially and led to the consultation proposing primary energy, carbon and affordability as metrics for compliance routes. Clearly where carbon intensities of the national gas and electrical grids lowers, the absolute CO2 emissions associated with the energy use of these primary fuels will lower correspondingly. Whilst it is not unreasonable to predicate future emissions trajectories for new homes on projections for the carbon intensities of the national grids, consideration should be given to ensuring new homes constructed today are future proofed for a low carbon infrastructure in the future. For instance, a sensitivity analysis on lower grid intensities shows that electrically heated dwellings could achieve the FHS 2025 standard with a Relaxed Fabric Specification using heat pumps. A similar affect will be true for lower uplifts in the coming years between 2020 and 2025.

The consultation has framed the proposed options as “Option 1 high fabric” vs “Option 2 low-carbon technology and lower fabric” in direct contradiction to the neutral approach of building regulations. The framing of the consultation risks invalidating responses. The misleading framing could lead to energy efficiency groups favouring Option 1 in the mistaken understanding that this will result in higher energy efficiency or fabric improvements, as the consultation depicts. The consultations claim ‘we expect this [Option 1] to be delivered predominantly by very high fabric standards, which means lower levels of heat loss from windows, walls, floors and ceilings’ is misleading because so long as the minimal U-values are met, developers have complete freedom to choose the compliance route to primary energy and carbon targets. Government should carefully consider whether support for Option 1 is due to a preference for higher energy efficiency, which would not necessarily be the result of legislating for Option 1 due to the neutral building regulation framework.

20% Uplift

A 20% uplift is achievable through several compliance routes and requires only minor amendments to existing house design. The compliance routes would have little tangible impact on homeowners and would not contribute sufficiently toward the Government’s intention of tackling emissions from homes, ensuring the 2020 uplift is an interim step to the FHS, improving householder energy performance and reducing bills.

In assessing potential compliance routes STA Building Regulations 2020 Modelling did not assume “very high fabric standards” were necessarily the route opted for by developers. In reflection of the neutral approach of building regulations and that the consultation did not propose raising U-Values in line with their notional house, STA Building Regulations 2020 Modelling analysed a full range of potential compliance routes.

Firstly, the modelling has exposed some weaknesses in the proposals put forward in the consultation, where the proposed

Options fail to secure the performance targets across all typologies tested. Whilst Option 1 Specification proposed in the

Consultation provides a significant improvement to the building fabric over current standards, STA Building Regulations 2020

Modelling found the specification need further refinement by industry to ensure the targets for CO2 emissions reduction and

Primary Energy were met across all typologies constructed. Option 1 does not deliver 20% savings across a representative

housing stock. The modelling indicates that for most house types considered, the Option 1 notional house specification reduces

carbon emissions by only around 12% compared to current regulations (see Table 04 of report). The only dwelling modelled

that gave more than a 20% reduction on current building regulations was a 4bed/7person home of 117m2 floor area. This is due

to diminishing returns on energy savings from additional insulation on joined properties with less external wall area. By contrast,

the savings from the Option 2 notional house specification is more consistent across housetypes and therefore a more robust

option.

STA Building Regulations 2020 Modelling found that without updated U-values for the performance of the building fabric,

both the targets for 20% CO2 emissions reduction and Primary Energy can be achieved comfortably using negligible fabric only

and technology only approaches, against the intention for 2020 to be preparation for the FHS. Whether adopting a poor-

performing building fabric with LZC technologies or fabric and no LZC technologies there is flexibility in the choice of route to

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compliance. Across all uplifts it was found that savings in energy costs (space heating demands) from improved fabric

specifications are marginal.

The ease at which 20% is met is highlighted by the fact it would be possible to meet this standard using a Relaxed

Specification (which mimics the specification for the current minimum standard in 2016) with all four LZC technologies

installed for all typologies, whether using gas or electricity as the primary fuel for the dominant space heating and hot water

energy demands. Changes to SAP have made Option 1 trivial to achieve. This would be attractive for house developers, where

changes to the built form for new homes constructed from 2020 would remain largely the same as they are today. i.e. there

would be minimal impact to the core dimensions of the dwelling. Whilst some of the modelled technologies will inevitably be

important and have a role in achieving the FHS, such as solar thermal and solar PV, our modelling indicates that under SAP10.1,

Flue Gas Heat Recovery (FGHR) has an over-sized impact on both CO2 emissions and Primary Energy. It is likely that

housebuilders would meet targets based on Option 1 with the lowest-cost package – adding FGHR systems to a gas boiler

coupled to very modest tweaks to insulation (see Table 16, page 44 of report) - as costs for FGHR can be as little as £180. It is

extremely concerning that technologies such as Flue Gas Heat Recovery can simply be added to existing fabric standard and

meet compliance as this achieves nothing in terms of industry preparation for low-carbon heating and the movement away from

gas and will have a minimal effect on householder energy reduction and bills. STA modelling found in line with the Impact

Assessment that Option 1 produces much lower benefits in energy bill savings. This is due to Option 1 principally delivering

savings against cheaper gas, whereas Option 2 notional house specification offsets more expensive electricity use.

A 20% improvement poses no substantial challenge to the housebuilders, minimal tangible benefits to householders and insufficient preparation for 2025. Comparatively to 31% the results found whatever method is used to deliver 31%, it provides greater CO2 emissions reduction, lower Primary Energy levels and where on-site generation is preferred, lower energy costs for the occupants.

31% Uplift Whilst comparatively more onerous, a 31% uplift or above has already been implemented by local authorities around the UK. Table 1 in the GLA Energy Monitoring Report, highlights that the Local Plan energy policies in 2018 achieved: ‘a carbon reduction of 36.9 per cent more than required by the 2013 Building Regulations, comfortably surpassing the London Plan target of a 35 per cent reduction.’ On this basis, 31% has already been demonstrated as a safely achievable improvement for developers. STA Building Regulations 2020 Modelling supports this, highlighting the variety of compliance routes available using established, proven design improvements. Comparatively to 20% uplift, whatever method is used to deliver this, it provides greater CO2

emissions reduction, lower Primary Energy levels and where on-site generation is preferred, lower energy costs for the occupants. The specification put forward in the consultation uses a lower performing building fabric coupled with two LZC technologies (WWHR + a large PV array) and was found to secure a significant improvement in emissions reduction. Option 2 was found to provide a more robust specification than Option 1, with the savings from the Option 2 notional house specification being more consistent across housetypes. In line with the Impact Assessment Option 2 delivers significant savings for householders as the notional house specification offsets more expensive electricity use. To determine other likely routes, STA assessment included only fabric improvements and only technology improvements finding these still to be possible. A fabric only 31% uplift would require a very high-performance specification (≡ to PassivHaus), indicating this route would is unlikely be opted for by developers due to the higher cost of such specification and reluctance in redesigning their portfolio in 2020. Similarly, technology only compliance routes such as a combination of solar PV and Solar Thermal are unlikely to be opted for by developers due to the associated cost of both these technologies and potential limits on available roof-space.

This taken together with the findings of the notional house suggest a balanced approach is likely to be opted for by developers to achieve compliance. This could reflect the notional house as suggested by Government. A cost-effective and therefore popular option to meet the targets defined as Option 2 would include solar PV in combination with improved insulation. Housebuilders in Scotland have enthusiastically embraced solar PV since the 2015 changes to Scottish regulations with around 80% of new homes there now including solar panels. Other routes could see developers raising fabric standards to something akin to the ‘Basecase Specification’ in combination with a single LZC technology or where heat pumps are specified to supply the space heating and hot

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water demands. It is clear from STA modelling that 31% is easy achievable, provides tangible benefits to homeowners and a wide array of compliance combinations that would prove beneficial to achieving the FHS.

40% Uplift

STA Building Regulations 2020 Modelling analysed possible compliance routes to 40% uplift in order to assess whether a higher 2020 step would result in better preparation for FHS in 2025 and lead to improved energy and bill reductions for households. STA Building Regulations 2020 Modelling concluded that a more ambition 40% CO2 reduction is straightforward to achieve, and that consideration should be given to setting this performance target. Technology combinations of modest cost (combi boiler-FGHR-WWHR-PV or heat pump-WWHR-PV) coupled to readily deliverable fabric improvements can exceed 40% CO2 reductions across all house types modelled.

It is possible to achieve 40% reduction in emissions using alternative fabric specifications with at least three LZCs as a half-way step towards the FHS (>80% CO2 reduction). Comparatively to 31% where some routes to compliance do not result in sufficient preparation for FHS or reflect Government ambition or overarching direction of travel, a 40% uplift is far more likely to elicit more substantial improvements to fabric whilst preparing industry, skills and supply chains for the myriad of technologies that will be required to achieve the FHS in 2025. 40% uplift would provide a pragmatic steppingstone to achieving a Future Homes Standard from 2025 where 75%-80% reduction in emissions is envisaged and is reportedly achieved in Greater London.

If this option is not implemented in 2020, it could be considered as a further step up in the coming years prior to 2025.

STA Building Regulations 2020 Modelling: Solar

• Solar Technologies tend to perform better than other carbon abatement solutions (E.g. WWHR / FGHR ) across different fabric specifications. This is not exclusively the case and there will be situations where different LZC solutions/combinations are preferable.

• Solar technologies compliment both gas and electrically heated homes. Solar Water heating will help to reduce emissions and energy costs for heating water, which will become more of a dominant energy demand in high-performance dwellings. Solar PV compliments all primary fuels but has the most significant impact when used with direct electric heating. As the grid decarbonises, solar PV will have less carbon abatement impact, but critically, it will continue to generate significant energy savings for occupants, particularly where on-site generation use can be maximised or traded using Smart tariffs.

• Solar PV benefits are highly sensitive to PEF for export. Unless battery storage or solar diverters are present (the latter requiring a hot water cylinder), the impact of solar PV on the Dwelling Primary Energy is sensitive to the PEF chosen for exported electricity. (Tables 11-13). STA strongly disagrees with the PEF for export set.

• Whilst solar PV is complementary to an all-electric solution in delivering valuable kWh of energy that would supplement on-site electricity usage (particularly if used during daylight hours), the carbon benefit is significantly reduced and now requires ~nearly 4x the capacity in kWp to abate the same quantity of carbon as under SAP9.92.

• Utilising a greater proportion of on-site generation through diverters or batteries favours electric systems over gas systems.

Skills and job development and UK Manufacturing

Alongside the benefits of savings to consumers and carbon reductions there are substantial benefits from skills and jobs that a higher uplift would secure.

2019 saw the publication of The Solar Commission: A bright future: opportunities for UK innovation in solar energy. This report specified the potential for UK to develop a leading BIPV sector. Raising new build regulations to the point whereby solar PV is a commonplace option for all new build homes, would develop UK expertise in this already emerging market, with a myriad of applicable opportunities for oversees export.

“Examples of UK organisations playing a leading international role in the sustainability of buildings include BRE National Solar Centre which provides expertise to support the use of PV in the built environment. Companies such as the NSG Group, Viridian, Polysolar and Romag all have UK-based capabilities in manufacturing, research and development of panels and cells for BIPV projects.” “Rooftop BIPV is beginning to gain traction in the new build market – there are many areas for UK professions to innovate in this sector, for example, structural strength, fire safety, weathertightness, and durability issues. Once these areas have been tackled properly, then the solutions are likely to be

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applicable for the overseas market. We have a great potential to add value to these areas and enhance the export market”. Dr. KT Tan, chief technical officer, Viridian Solar”

This in turn would develop further jobs in the UK clean energy sector by virtue of solar PV being particularly labour intensive. The

most comprehensive literature on this remains UKERC (2014) which results in the following estimate range for solar PV jobs:

Installation: 7 to 33 jobs per MWp (median = 16.8). O&M: 0.04 to 0.27 jobs per MWh (median = 0.11). Manufacturing: STA

assumes roughly 400 FTE jobs at Oxford PV, Pilkington NPG, Loughborough University.

Solar also has a high UK Content. STA analysis of member installations shows that around two-thirds of the value of domestic rooftop solar PV accrues to the UK, broadly consistent with international analyses. Rooftop solar therefore offers some of the highest UK value of all sources of energy and it could match European levels, given a stable policy framework and a proactive industrial strategy. Installer members of the STA are largely UK companies employing local people in quality jobs. As a rough rule of thumb, for small rooftop solar (50kW schemes and under), each kW of capacity installed generates one person-day of work in installation work alone. Many more are employed in the supply chain. Installing solar with battery storage gave a potential UK value of 45% - 80%, depending squarely on whether the storage system is manufactured in the UK. This value gap underlines how vital it is that storage commercialisation is supported by removing barriers to the battery storage markets in the UK as quickly as possible. Solar thermal installations in the UK can provide almost entirely UK content. Sector skills and technology should be better valued, particularly given considerable cross-over with the construction and the smart energy sectors with the digitalisation of the solar PV ecosystem. Attached is a briefing outlining our initial work on this topic.

7. Do you agree with using primary energy as the principal performance metric?

A. Yes - primary energy should be the principal performance metric B. No - CO2 should remain the principal performance metric C. No - another measure should be the principal performance metric

We agree that primary energy should be the principal performance metric. The consultation rightly identifies how with a completely decarbonised grid it would still be possible to have an extremely ‘leaky’ house able to meet the specified carbon uplift. Primary energy as the principal performance metric, alongside carbon intensity and household affordability is a suitable combination of performance metrics to ensure new dwellings meet the intended standards whilst not resulting in extremely high running costs for homeowners or foregoing carbon reduction measures. It is noted that the questions are framed in terms of the CO2 uplift whereas the compliance route will be in primary energy, making analysis difficult and unclear.

However, we strongly disagree with the primary energy factor in SAP for renewables exported from the building. Since the natural energy renewables convert is limitless, the convention is that the PEF for renewable energy is 1.0 at the point of generation. The building regulations rightly focuses on the Net Primary Energy use over the year - which considers both the flows of energy into and out of the building and allows for energy generation to be considered as part of/in the building. Since the solar PV system is then part of the building the energy flows that cross the boundary consist only of the solar generation exported to the grid (See image). We agree with this methodology which has significant ramifications for achieving the Buildings Mission – please see below and more detailed briefing of its implications on Building Mission attached.

Solar energy generated by the building and used in the building reduces the electricity needed to be imported by the building. A benefit of putting a solar system on a house for the net Primary Energy used is the solar energy kept in the building multiplied by the Primary Energy Factor of the electricity use that was avoided - the PEF of grid electricity. A further benefit of installing a solar system on a house is that the solar energy exported is a negative flow of energy and so should reduce the net Primary Energy use of the house. The government has suggested in the consultation that the PEF for this exported electricity

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should be 0.51. The SAP team at BRE highlighted the reason for this to be: “Since grid electricity has a PEF of 1.51, and solar electricity has a PEF of 1.0, the net benefit of the exported electricity is 1.51 - 1.0 = 0.51 per unit of electricity exported.”

This follows SAP treatment for CO2 content of electricity, which does not have an intrinsic value and therefore needs to be defined. SAP does this by considering the CO2 emissions avoided by exporting to the grid. However, solar generated electricity does have an intrinsic primary energy value – a PEF of 1.0 – so the primary energy of the solar export should not be calculated in relation to its impact on the grid, only it’s impact on the building’s net primary energy use. The Net Primary Energy of the building is calculated as the primary energy crossing the control volume of the house, see image). It is equal to the primary energy of imports less the primary energy of solar energy exported – and solar energy has a PEF of 1.0.

Large-scale solar and wind feed into the grid at a Primary Energy Factor of 1.0. Treating micro-generation differently is unfair to small-scale generators and disadvantaging solar PV as a measure for the reduction of primary energy use in new dwellings.

The difference between the PEF of grid imported electricity at 1.51 and exported solar at 1.0 would still create an impetus for designers to consider measures that keep the solar energy use in the house such as battery energy storage or solar energy diverters to hot water. SAP currently does not allow the combination of both battery storage and solar heating diverters, which compounds the disadvantages the calculation method is heaping on solar PV. The PEF for exported solar energy should be set to 1.0 in SAP18.

STA Building Regulations 2020 Modelling stipulates that: “The Primary Energy Factor (PEF) will now play a critical role in determining routes to compliance given the introduction of Target Primary Energy rates (TPERs). The PEF for renewable electricity generation that displaces grid electricity, has the same Primary Energy factor as grid electricity – 1.501. The PEF for renewable energy generally is 1. The PEF for exported renewable electricity is 0.501 (1.501 – 1). This seems counter-intuitive and unfairly discriminates against renewable generation, given the national grid includes a blend of generation, accounting for other more carbon intensive fuel sources (gas, coal, oil) as well as other low carbon fuel sources (biomass, large wind & solar etc.), which leads to a PEF >1.”

Q.8 Do you agree with using CO2 as the secondary performance metric?

A. Yes B. No

CO2 is an important measure and should be kept within remit of building regulations.

Q9. Do you agree with the proposal to set a minimum target to ensure that homes are affordable to run?

A. Yes B. No

A measure of affordability within a home is agreed with in principle. Option 2 was found to deliver significant savings for householders with the cost of regulated energy under Option 2 being 50% to 75% lower than under Option 1. Solutions with onsite generation were found to have the lowest energy costs for occupants and cost savings to occupants can be augmented by maximising the use of local generation within the dwelling. With passive house standards it will be possible to get very near to zero running costs (excluding unregulated energy).

Building regulation improvements have significantly more value than the energy savings provided to households once they have moved in. However, further steps must be taken to ensure this value is recognised by lenders and buyers and that mortgages are reflective of such. Currently there is very little incentive for buyers to consider EPCs and running costs as a core aspect of their decision-making process.

Q21 Do you agree with the proposal to adopt the latest Standard Assessment Procedure, SAP 10?

A. Yes B. No. If no, please explain your reasoning.

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Yes, subject to the Primary Energy Factor for solar PV exported electricity being set to 1.0

Q23 Do you agree with the method in Briefing Note – Derivation and use of Primary Energy factors in SAP for calculating primary energy and CO2 emissions factors?

A. Yes B. No If no, please explain your reasoning.

See explanation for primary energy factor export in Q7. Repeated below:

We agree that primary energy should be the principal performance metric. The consultation rightly identifies how with a completely decarbonised grid it would still be possible to have an extremely ‘leaky’ house able to meet the specified carbon uplift. Primary energy as the principal performance metric, alongside carbon intensity and household affordability is a suitable combination of performance metrics to ensure new dwellings meet the intended standards whilst not resulting in extremely high running costs for homeowners or foregoing carbon reduction measures. It is noted that the questions are framed in terms of the CO2 uplift whereas the compliance route will be in primary energy, making analysis difficult and unclear.

However, we strongly disagree with the primary energy factor in SAP for renewables exported from the building. Since the natural energy renewables convert is limitless, the convention is that the PEF for renewable energy is 1.0 at the point of generation. The building regulations rightly focuses on the Net Primary Energy use over the year - which considers both the flows of energy into and out of the building and allows for energy generation to be considered as part of/in the building. Since the solar PV system is then part of the building the energy flows that cross the boundary consist only of the solar generation exported to the grid (See image). We agree with this methodology which has significant ramifications for achieving the Buildings Mission – please see below and more detailed briefing of its implications on Building Mission attached.

Solar energy generated by the building and used in the building reduces the electricity needed to be imported by the building. A benefit of putting a solar system on a house for the net Primary Energy used is the solar energy kept in the building multiplied by the Primary Energy Factor of the electricity use that was avoided - the PEF of grid electricity. A further benefit of installing a solar system on a house is that the solar energy exported is a negative flow of energy and so should reduce the net Primary Energy use of the house. The government has suggested in the consultation that the PEF for this exported electricity should be 0.51. The SAP team at BRE highlighted the reason for this to be: “Since grid electricity has a PEF of 1.51, and solar electricity has a PEF of 1.0, the net benefit of the exported electricity is 1.51 - 1.0 = 0.51 per unit of electricity exported.”

This follows SAP treatment for CO2 content of electricity, which does not have an intrinsic value and therefore needs to be defined. SAP does this by considering the CO2 emissions avoided by exporting to the grid. However, solar generated electricity does have an intrinsic primary energy value – a PEF of 1.0 – so the primary energy of the solar export should not be calculated in relation to its impact on the grid, only it’s impact on the building’s net primary energy use. The Net Primary Energy of the building is calculated as the primary energy crossing the control volume of the house, see image). It is equal to the primary energy of imports less the primary energy of solar energy exported – and solar energy has a PEF of 1.0.

Large-scale solar and wind feed into the grid at a Primary Energy Factor of 1.0. Treating micro-generation differently is unfair to small-scale generators and disadvantaging solar PV as a measure for the reduction of primary energy use in new dwellings.

The difference between the PEF of grid imported electricity at 1.51 and exported solar at 1.0 would still create an impetus for designers to consider measures that keep the solar energy use in the house such as battery energy storage or solar energy diverters

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to hot water. SAP currently does not allow the combination of both battery storage and solar heating diverters, which compounds the disadvantages the calculation method is heaping on solar PV. The PEF for exported solar energy should be set to 1.0 in SAP19.

STA Building Regulations 2020 Modelling stipulates that: “The Primary Energy Factor (PEF) will now play a critical role in determining routes to compliance given the introduction of Target Primary Energy rates (TPERs). The PEF for renewable electricity generation that displaces grid electricity, has the same Primary Energy factor as grid electricity – 1.501. The PEF for renewable energy generally is 1. The PEF for exported renewable electricity is 0.501 (1.501 – 1). This seems counter-intuitive and unfairly discriminates against renewable generation, given the national grid includes a blend of generation, accounting for other more carbon intensive fuel sources (gas, coal, oil) as well as other low carbon fuel sources (biomass, large wind & solar etc.), which leads to a PEF >1.”

Chapter 7 Transitional Arrangements

Q65 Do you agree that the transitional arrangements for the energy efficiency changes in 2020 should not apply to individual buildings where work has not started within a reasonable period – resulting in those buildings having to be built to the new

energy efficiency standard?

A. Yes – where building work has commenced on an individual building within a reasonable period, the transitional arrangements should apply to that building, but not to the buildings on which building work has not commenced. If yes, please suggest a suitable length of time for the reasonable period in which building work should have started. If no, please explain your reasoning and provide evidence to support this.

B. No – the transitional arrangements should continue to apply to all building work on a development, irrespective of whether or not building work has commenced on individual buildings

It is critical that provisions are made within these transitional arrangements to ensure that developers can no longer build to previous versions of Part L for years to come. It is scandalous that homes are being built to standards that were out of date more than 10 years ago. Transitional issues have been apparent since the 2015 Scotland building regulation uplift and learnings should be taken from this example. With sufficient foresight of upcoming regulations, developers will be able to budget for build rates when negotiating land valuations.

Q66 Do you foresee any issues that may arise from the proposed 2020 transitional arrangements outlined in this consultation?

A. Yes B. No

It is unclear what the definition of “commenced” is, which leaves the door open for developers to exploit new “spade in the ground” manoeuvres. It will be necessary to carefully define what qualifies as commenced to avoid loop-holes that will be exploited if they exist.

Chapter 8: Feedback on the Impact Assessment

Q68 The Impact Assessment makes a number of assumptions on fabric/services/ renewables costs, new build rates, phase-in rates, learning rates, etc for new homes. Do you think these assumptions are fair and reasonable?

A. Yes B. No

No, the costs of solar PV solar are too high, which makes the costs to housebuilders for delivering Option 2 over-stated. Solar PV costs continue to fall, which is difficult for government departments to keep track of and so is rarely reflected accurately in consultations. Based on STA member feedback, the consultations assumptions on the costs of solar PV are higher than market costs.

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Solar PV cost reductions have been significant since 2010, largely due to the global market increasing solar PV manufacturing in countries such as China. As such, module costs are falling and are becoming an increasingly small share of the overall cost of installation. There are learning and installation efficiencies possible within the new build market, such as in planning and design costs, and it is notable that costs for PV can vary considerably depending on the size of the housing developer. However, it is unclear what the assumed 40% cost reduction in 11 years is based upon. The STA would welcome a further discussion with MHCLG to explore the assumptions behind this.

Below highlight the costs factored into the consultations impact assessment, which assumes solar PV are £1,100 fixed costs plus £800 variable per kWp installed. Implying the following installed costs:

1kWp £1,900 £1.90/kWp

2kWp £2,700 £1.35/kWp

3kWp £3,500 £1.17/kWp

STA member cost evidence

1kWp £1,625.16 £1.63/kWp

2kWp £2,539.31 £1.27/kWp

3kWp £3,083.33 £1.03/kWp Other members are aware of solar installers operating in the new-build sector that typically charge an installed price the range of £1.10-£1.20/kWp for 1 -1.25 kWp, which fall as system sizes increase.

Q69 Overall, do you think the impact assessment is a fair and reasonable assessment of the potential costs and benefits of the proposed options for new homes?

A. Yes B. No

The impact assessment has attempted to calculate the potential costs and benefits of the proposed options. However, there are stark omissions from its evaluations. Firstly, the impact assessment is weighted in its evaluation of the costs on industry and housing developers for improving their building stock and the subsequent energy bill savings consumers will benefit from. These costs and benefits are considered against the baseline scenario of doing nothing, which assumes that there will be no cost repercussions to consumers, industry or the UK as a whole for inaction. There is a wealth of research, such as the Stern Review (2006) supporting ‘the benefits of strong and early action far outweigh[ing] the economic costs of not acting’. New build housing must not continue to contribute to the UKs emission share. Government analysis of the potential costs of inaction in the same timeframe (up to 2050) would be pertinent. For instance, the IA should recognise that homes built to too low a standard today will need to be upgraded in future at a higher overall cost meaning the IA should include the future costs of upgrading homes to meet the UK’s zero carbon ambitions. Finally, for the renewables sector connecting to the grid has become a primary barrier to deployment. This is relevant for multi MW solar park projects as well as for the domestic retrofit market and housing developments with renewables, EVs or heat pumps incorporated into their design. A ‘flexibility first’ approach should be adopted to mitigate grid costs where possible such as through: ensuring that generation can be used locally, maximising self-consumption and that flexibility is incorporated into design such as through electrical storage and thermal storage. However, due to the already constrained grid with limited capacity available, the moves toward the electrification of heat and transport requiring more renewables on the grid will necessitate grid reinforcements. The Government, networks and regulator must start analysing the potential implications of policy recommendations on network costs, how best to manage these and when investment is required. Whilst this reason must not be used for delayed or subdued policy decisions, a full understanding of the network, potential reinforcements and therefore ways to mitigate this are imperative to ensure that the costs for transitioning to net zero are fairly distributed amongst end consumers.