7 February 2020
Future Homes Standard: Grosvenor's response
Read Grosvenor Britain & Ireland's response to the UK Government consultation. We believe it should be introduced before 2025 and include embodied carbon requirements as well as high fabric efficiency.
Grosvenor Britain & Ireland creates great places where communities, business and nature thrive. We are part of a global property business that has been developing and managing land and property for over 340 years. Our heartland is in London’s West End, where we support 9,000 residents, 840 businesses and 50,000 workers every day. We also create sustainable new neighbourhoods in London and across the South of England. We think long-term and give equal weight to the social and commercial impact of everything that we do. We have drawn on this perspective and experience in providing our response to the Future Homes consultation.
In May 2019, Grosvenor Britain & Ireland set four environmental goals for the coming decade:
- Zero carbon: By 2030, we will achieve net zero carbon operational emissions from all our directly managed buildings; measuring, reporting on and significantly reducing, the carbon emissions embodied in our supply chain, development and tenant activity.
- Eradicating waste: We will eradicate waste from buildings and developments in our control by 2030; and by working with our customers and stakeholders, we will eradicate waste from communities where we operate by 2050.
- Valuing nature: By 2030, our standing portfolio and largest development sites will have achieved a significant net biodiversity gain contributing to local, regional and national conservation priorities.
- Bringing our partners with us: Through collaboration, innovation and supportive networks, all our strategic suppliers must meet the minimum standards in our Supply Chain Charter.
Summary Response to this Consultation
Bold, decisive action is needed if we are to tackle the climate emergency and we applaud the Government’s ambition to be a leader in this space. We also welcome the focus on decarbonising heat, using heat pumps and promoting renewable energy. However, we are concerned that the current proposals to the amendments to Part L, outlined in the Future Homes Standard 2020 will not deliver the radical change that is needed to tackle the climate emergency. These proposals will not provide the right signals to the industry that it has to design, deliver and operate zero carbon homes at scale.
We have provided a detailed response via the online consultation portal but summarise below our main observations.
There is a disconnect between the proposed changes to Part L and the need for an urgent response to the global climate emergency. Two million homes are likely to be built between 2020 and 2025. If the required standard is not met when homes are first constructed, they will require retrofit before 2050. The proposed changes are likely to impact negatively on the industry’s ability to deliver its net zero carbon commitments because they would not come into force until 2025 and do not include both regulated and unregulated carbon emissions or embodied carbon. In practice, construction supply chains and developers will be less likely to build true zero carbon homes because there is no requirement to do so.
The Future Homes Standard 2020 targets a reduction in carbon emissions compared with the current Part L rather than zero carbon emissions. This approach is unnecessarily complex and does not respond directly to the UK's legal commitment to achieve zero carbon by 2050.
Clear communication is also fundamental to incentivising rapid decarbonisation of our industry. These regulations will impact every built environmental professional, from facilities teams, developers and real estate lawyers to asset managers, agents, property managers and investors. Many of these professionals are just starting to understand the impacts of investing and managing carbon in buildings. So we have to make the transition as easy as possible.
3. Cost differentials
Within the economic viability assessment for this consultation there is no distinction between dense high-rise inner-city housing schemes and large-scale housing developments on the outskirts of urban areas. In our experience, the cost differentials can be significant. Grosvenor supports the Government’s ambition to achieve a zero carbon economy by 2050 but we urge the government to use economic data from developers, rather than modelling costs, and to be transparent about the costs of transitioning to zero carbon homes for both embodied carbon and operational energy (both regulated and unregulated).
4. Fabric efficiency
In our view, Option 1 and Option 2 do not go far enough on fabric efficiency. We should not be designing and building homes in 2020 that will need retrofitting with additional insulation in the future. Based on extensive industry research and post occupancy evaluation from buildings on our estate, we believe a well-insulated building represents the greatest chance of meeting the Government’s zero carbon economy commitments in relation to UK homes.
5. Post-occupancy monitoring
The Future Homes Standard 2020 makes no requirement for post-occupancy monitoring. Currently most houses do not meet the energy efficiency standards to which they are designed. Without monitoring, we will be unable to measure or ensure compliance with the building regulations. We support the London Energy Transformation Initiative’s call for action (LETI) that all new buildings should undergo post occupancy monitoring. This should ideally be for a period of up to five years. That would rapidly help the industry understand the key performance gaps and innovate faster.
Whilst we understand that there is an EU directive to use a Primary Energy metric, we believe that disclosure of performance metrics such as (EUI) in KWh/m2/yr should be used in addition to the actual building performance that consumers experience. This aligns with the Better Buildings Partnership Industry initiative of Design for Performance (DfP) whereby developers must achieve energy in use performance targets before achieving sustainable accreditation. Whilst DfP is designed for offices, the principles could be applied to new homes as well.
6. Whole life carbon
The Future Homes Standard 2020 does not consider the embodied carbon emissions related to building homes. Reducing embodied carbon is a necessary next step to reduce carbon emissions quickly and effectively. Without a focus on whole life carbon, the UK house building sector stands little chance of decarbonising before 2050. Grosvenor proposes that the Government include embodied carbon targets and considers the targets set out by London Energy Transformation Initiative Climate Emergency Design Guide.