The Future Buildings Standard (2021)

The IET welcomes the opportunity to comment on a consultation from The Ministry of Housing Communities and Local Government on the Future Buildings Standard (FBS) Annex B.

This is the second stage of the 2-part consultation on proposed changes to Part L (Conservation of fuel and power) and Part F (ventilation) of the Building Regulations. It builds upon the first part by setting out energy and ventilation standards for non-domestic buildings and existing homes.

The IET believes that improvement in operational efficiency through the adoption of highly efficient and sustainable technologies is key to successfully delivering net zero and beyond. Our main points are:

• Reducing demand for energy must be maintained as the key initial focus to minimize the cost of change and to achieve the transfer to alternative fuel types progressively.
• The categorization of building types to space and water heating, linked to the vagaries of demand, should be aligned to a set of defined metrics such as used under BREEAM. This would allow potential demand to be linked to effective capacity available and consumption. Potential additional building types should be considered, contrasting across spatial and water heating choices, as differences in empirical requirements will exist.
• The heat pump and water industry are not yet ready to meet the challenge of the FSB. Currently cost v payback is not attractive in many cases. A phased approach would be appropriate and would allow suitable time to model the commercial realities against the defined building types and allow technology funding opportunities to be developed.
• Reduced occupant consumption and volumetric allowances must be developed, accepted, and incorporated into the FBS. The energy performance gap is fundamentally driven by too high design allowances and poor occupation profiling. The commercial office is changing to meet workplace demands, and a reduction in daily occupation can be expected. A suite of efficiency metrics linked to occupation would drive the relationship of occupant, energy, building and emissions to focus on efficient design and operations.
• It’s key to stop the over-design of systems such that redundant systems are installed in non-domestic buildings. Duplicate power supply, cooling or heating systems are not required within the ICT industrial revolution that we are experiencing.