What do you think of Part L?

Last month's Part L consultation report¹ put wind in the sails of people who, like environment minister Michael Meacher, argue for higher energy efficiency². The Department of the Environment, Transport and the Regions (DETR) tested construction's reaction to a raft of ideas put forward by the industry itself.

A colossal majority of the 229 consultees welcomed most of the proposed amendments to Approved Document L: conservation of fuel and power. There was widespread acceptance of the need to improve the existing building stock, with 95% saying that all large-scale repair or refurbishment work to non-domestic buildings should be covered by the Regulations (table 1).

Almost as many (94%) thought that energy performance could be added to the requirements for a material alteration.

A staggering 99% said it is time to bring the crown estate into line with the energy requirements of the building regulations. The long-standing anomaly of this exclusion from Part L seems to have forged a real consensus in the industry. After all, shouldn't the crown really be taking a lead on energy and environmental issues? Also very popular was the idea of getting owners to keep log books recording design, maintenance and operating information. This would make it easier to feed forward experience from existing buildings into new design work. It was one of many strategies for encouraging action that the DETR included in the consultation (table 2).

Introducing the amendments

Almost everyone agrees that the new amendments should be introduced as soon as is practicable. 92% said that the DETR should also publish a long-term programme for amending the energy efficiency part of the Regulations – so that industry can plan ahead.

Despite the consensus that the DETR should move fast, opinions differ as to how to encourage action on energy. For example, the industry is only lukewarm on fiscal penalties like energy taxes. Three possible failings were highlighted.

First, energy use is inelastic. Even if there are short-term energy savings, energy users are likely to backtrack in the future. Second, only a very high rate of tax would truly cut consumption. The resulting energy price hike would make the UK uncompetitive. Third, less well off people would suffer most from an energy tax. People with little or no money would be forced to suffer even colder, damper homes.

New ideas surface from consultation process

Novel suggestions for improving Part L came along with commentary on the amendments already on the table.

First came the idea of using a list of valid upgrades for different construction elements. This would allow existing buildings to be improved step-by-step, in a cost-effective manner. It would give more flexibility than an overall performance measure. And it would mean that requirements can evolve as technology develops.

Second was the idea of introducing NOx limits on boilers and combined heat and power. Third, one respondent suggested new requirements stipulating which refrigerants may be used in air conditioning. Thus, for example, R22 could be banned from new buildings.

Fourth, still on air conditioning, designers could demonstrate they have evaluated alternative methods of cooling a building before they are allowed to include air conditioning. This suggestion might encourage wider use of greener heat management strategies.

First reactions

Richard John, the CIBSE chief executive, thinks it is important to consider the Part L consultation process in the context of the DETR's climate change agenda. He observes that the "single most important step towards lower CO₂ emissions would be to include existing buildings in the regulations".

He also sees the consultation as "very valuable, because it has helped to inform government officials about the problems faced by construction".

Mike Duggan, representing the Federation of Environmental Trade Associations (FETA), welcomes the new report as well. He says that the FETA is "fully committed to helping to improve the environment" and played a "full part in commenting on the initial consultation paper".

With this much enthusiasm for the Part L consultation, the concluding chapters of the process cannot fail to be dramatic. Watch this space.