UKGBC has responded to MHCLG’s consultation on proposed changes to energy performance and ventilation requirements for non-domestic buildings and dwellings; and a new overheating standard for homes.

Jenny Holland, Public Affairs & Policy Specialist said:

“UK buildings’ emissions have largely flatlined since 2015 – so improved Building Regulations have a vital role to play in starting to drive down new buildings’ emissions and to set us on a path towards achieving our 2050 net zero target.  In this context, we welcome the stated intention of this consultation, i.e. that from 2025 buildings should not need to be retrofitted to be zero carbon in 2050.  However, we are concerned that the consultation proposals do not go far enough to deliver on that intention.

“In particular, the consultation is completely silent on embodied carbon, which can account for up to half of a building’s emissions during its lifetime.  Government must urgently address this by introducing requirements for measuring whole life carbon, followed at the earliest opportunity by targets for reductions.  Government must also do much more to address the ‘performance gap’, whereby in-use energy consumption can be 2 to 5 times higher than modelling would suggest.  We need to transition towards in-use performance as the basis of compliance with Building Regulations, starting with requirements at the next uplift for the measurement and disclosure of in-use performance.”

Download UKGBC’s consultation response here.