Possible Future Performance Standards for Part L

October 2003

Contents
Introduction ....................................................................................................................2
The future basis of setting standards............................................................................5
Future Thinking for Parts L1 And L2 .........................................................................7
Future Thinking for Part L1 - Dwellings ...................................................................11
Future Thinking for Part L2 - Buildings Other Than Dwellings ............................19

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 Possible Future Performance Standards for Part L October 2003

Introduction
1. The Building (Amendment) Regulations, SI 2001/3335 and the publication of the 2002 editions of
Approved Documents L1 and L2 convey major improvements in energy performance standards in
the Building Regulations. However, as described in the June 2000 consultation paper 1, these
changes were only the first of four stages of proposed improvements in the requirements and
associated approved guidance that were expected to be introduced in the period up to around
2008. In February 2003 however, the Energy White Paper (EWP) 2 announced the Government's
aim of bringing the next major review of the Building Regulations into effect in 2005. This paper
is an initial informal response from the Office of the Deputy Prime Minister (ODPM) on the sorts
of improvements that could be achievable in the amendment now proposed for 2005.
2. Other factors that will influence this review are:-
a. The EU Directive on the Energy Performance of Buildings (EPBD) 3, which requires
transposition into UK law by January 2006
b. The need to consider how building design and construction practice might need to adapt to the
impacts of changing climate. A separate Adaptation Strategy paper relative to Part L is being
prepared, and this will be used to inform the Part L review.
3. Part 5 of the June 2000 consultation document set out the thinking amongst members of the
Building Regulations Advisory Committee and the ODPM (DTLR as then was) on how the
suggestions collected during the 1998 consultations might best be staged over time. This paper
provides a first update on that document, taking into account what has been achieved in the
implementation of Stage 1 and the new context as set out in the EWP. It summarises the issues
that are being considered for the new review, and outlines the ranges of performance standards
that are being considered with industry and other interested parties during the development of
amendment proposals.

Staging
4. In June 2000 the then "current thinking" was outlined in terms of three possible further stages of
revising Part L.

Stage 2
5. This was defined as proposals for further guidance in relation to those requirements introduced or
amended in Stage 1, and additional requirements and guidance material on other measures - but
not altering those in Stage 1. It was envisaged that there would be a formal consultation on the
Stage 2 proposals, enabling a Stage 2 amendment about a year after Stage 1.
6. Having reviewed the range of possible new requirements that could be introduced at Stage 2, it
was decided that these do not warrant consultation and a new amendment of Parts L1 and L2, and
the associated Approved Documents so soon. It was agreed that the possible new requirements
should instead be deferred to the Stage 4 consultation. Stage 2 is therefore limited to issuing
supplementary technical guidance. It is hoped that most of these can be introduced during the
remainder of 2003 by administrative action such as amending the text in the 2002 editions of the
Approved Documents, by circular letters and through drawing attention to supplementary
guidance on the ODPM web site.

1
This is still available at http://www.safety.odpm.gov.uk/bregs/consult/eep/index.htm
2
The Energy White Paper can be viewed at http://www.dti.gov.uk/energy/whitepaper/index.shtml
3
The Directive is available from http://europa.eu.int/eur-lex/en/dat/2003/l_001/l_00120030104en00650071.pdf

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 Possible Future Performance Standards for Part L October 2003

Stage 3
7. This was defined as a package of the suggestions arising from the 1998 consultations that
concerned buildings in use, and whose implementation was therefore dependent on amendments
to the Building Act. It is not possible to define whether or when the Building Act might be
amended, so the proposals were effectively placed in limbo.
8. In the meantime, the new EU Directive on the Energy Performance of Buildings (EPBD) has been
published, which requires transposition into UK law by January 2006. The requirements of the
Directive are discussed later (paragraphs 10 et seq.), and will enable some elements of the 1998
ideas for controlling buildings in use to be assimilated into the Stage 4 package. It is proposed to
do this using powers in Section 2 of the Building Act 1984, amended or supplemented as
necessary using the powers in the European Communities Act 1972.

Stage 4
9. This was envisaged as the next occasion for a comprehensive review of the whole of the
requirements of Part L and the associated Approved Documents. In the June 2000 consultation, it
was envisaged that this would take place not less than five years after the Stage 1 amendments
and would therefore not be implemented before April 2007. The EWP has brought this date
forward to late 2005, which means that formal consultations on firm proposals will need to be
carried out during the summer of 2004.

The Directive
10. The Directive aims to promote the improvement of the energy performance of new and existing
buildings, taking into account outdoor climate and local conditions as well as indoor requirements
and cost-effectiveness. Via a series of Articles, it sets out requirements covering the following
issues
a. A methodology for calculating the energy performance of buildings.
b. Setting energy performance standards for new and existing buildings.
c. Requiring more consideration of low-carbon and zero-carbon systems when constructing
larger non-domestic buildings.
d. Introducing requirements for producing building energy certificates whenever buildings are
built, leased or sold.
e. Setting up an inspection system for boilers rated at more than 20kW (or an information
system that achieves similar results).
f. Setting up a routine inspection system for air conditioning systems of more than 12kW rated
output.
11. Article 15 contains the timing obligations and requires Member States (MSs) to implement the
measures by 04 January 2006. As an exception to this, MSs may agree with the Commission that
implementation of the building certification and plant inspection requirements can be delayed for
up to three years if they have insufficient qualified and/or accredited experts.

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 Possible Future Performance Standards for Part L October 2003

12. Because the issues surrounding implementation of the Directive are broader than the aspects of
building design and construction covered by Part L, and because they apply in Scotland and
Northern Ireland as well as England and Wales, a series of separate strategy papers will be
published in due course. The first example of this separate series, which addresses the
requirement to develop a national methodology for the calculation of building energy
performance for buildings other than dwellings, was published on 15 September 2003 on the
ODPM website 4.

The White Paper

13. The EWP was published on 24 February 2003. One of the stated objectives is "to put ourselves on
a path to cut UK's CO2 emissions by some 60% by about 2050, with real progress by 2020".
Given the significant contribution that buildings make to national CO2 emissions, building energy
efficiency standards will have to improve significantly over the coming decades.
14. Specifically in relation to Building Regulations, the EWP announced the intentions of:-
a. Raising standards over the next decade, learning lessons from the standards in comparable
European countries (Para 3.12)
b. Raising the standard required for new and replacement boilers to SEDBUK classes A or B
(Para 3.13). The Government has since decided to bring this provision into effect by 01 April
2005.
c. Starting immediately on the next major revision of Part L, with the aim of bringing this into
effect in 2005 (Para 3.16).
d. Seeing how the enforcement system might be improved to enable better correlation between
design standards and as-built performance (Para 3.20).

4
Available from
http://www.odpm.gov.uk/stellent/groups/odpm_buildreg/documents/page/odpm_breg_023924.pdf

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 Possible Future Performance Standards for Part L October 2003

The future basis of setting standards

The current basis
15. The performance standards published in Approved Documents L1 and L2 give guidance on what
is reasonable provision for compliance with Parts L1 and L2 of Schedule 1 of the Building
Regulations. These standards have been based on measures shown to be cost-effective over their
service life, taking account of the market prices for materials, labour and fuel. Additionally,
Government requires that the measures are proportionate with other legislation bearing on the
construction industry, and should allow sufficient design flexibility and avoid undue technical
risk.

Carbon pricing
16. In the Stage 1 Review the Government included in its Regulatory Impact Assessment (RIA) a
qualitative assessment of the environmental cost of carbon emissions.
17. Since then, the Government has published a comprehensive review of quantitative estimates of
the social costs of carbon emissions 5. Government has accepted that for policy development
purposes, the social cost of carbon should be factored into the cost benefit analysis. This social
cost is based on a figure of £70 per tonne of carbon emitted (in 2000 price levels) 6, and that this
value should be increased at £1 per year thereafter before adjustments are made to take account of
general inflation 7. This additional social cost, which arises whenever non-renewable fuels
containing carbon are used, will therefore be taken into account as part of the future basis of
setting Part L standards. This will mean that more measures will be shown to be cost effective
than when using current market prices for the various fuels.

Present value calculation of cost-effectiveness

18. The Government uses the Discounted Cash Flow Analysis Method to establish the costs and
benefits of proposed measures on an even basis - the "present value". To date Government has
used a 6% test discount rate to determine present values. In the new edition of the Green Book
published by HM Treasury 8 the test discount rate is 'unbundled' so that the new rate of 3.5%
reflects only one factor, the social time preference rate. (The current rate of 6% implicitly takes
account of such other factors as risk, optimism bias, and the cost of variability. The advice now is
to deal with these separately and explicitly - and, for the purposes of regulatory impact
assessments for the Building Regulations, these other factors will now be excluded from the
calculations.
19. The lower test discount rate means the present value of avoiding longer-term environmental
impacts will be more significant by comparison with initial investment costs. Higher building
performance standards than could previously be justified will therefore prove to be cost-effective.

5
“Estimating the Social Cost of Carbon Emissions” : Government Economic Service Paper No 140 :
http://www.hm-treasury.gov.uk/documents/taxation_work_and_welfare/taxation_and_the_
environment/tax_env_geswp140.cfm
6
The paper also recommends consideration of a sensitivity range of between £35/tC and £140/tC.
7
In 2003, for instance, and assuming the average rate of general inflation is 2.5%, the price becomes (70 + 3) x
1.0253 = £78.61 per tonne emitted per annum at 2003 prices.
8
Can be viewed at http://greenbook.treasury.gov.uk/

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 Possible Future Performance Standards for Part L October 2003

Embodied energy
20. Embodied energy in building materials and building services plant can represent a significant
element of the lifecycle energy budget of a building and the aim is to address this in Building
Regulations within the coming decade. Although it is considered desirable that this energy and
carbon burden should be addressed however, it is considered that the analysis procedures and
supporting data are not yet sufficiently developed for this to be considered in quantifiable terms
for the revision planned for 2005.
21. To take matters forward we therefore propose :-
a. to carry out a study on how sustainability indices could be included in the Building
Regulations,
b. where practicable, to include qualitative assessments in the 2005 Regulatory Impact
Assessment, and
c. to propose provisions for addressing embodied energy in Part L (or as an additional issue
covered by Regulation 7 (workmanship and materials)) when the accounting methods and
data are sufficiently well developed.

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 Possible Future Performance Standards for Part L October 2003

Future Thinking for Parts L1 And L2

22. In the following sections, the various issues that are being considered in this review are
introduced, and ODPM's current thinking on possible revisions to Part L are summarised. This
thinking will be developed further via discussion with the BRAC Working Party, and with
industry and other interests via the Industry Advisory Groups (IAGs) and their specialist working
panels, prior to the formal public consultation scheduled for the summer of 2004.

General
23. The Stage 4 (see paragraph 9) is now being developed as the major revision envisaged in the
EWP for 2005 - an opportunity to consider further raising all the performance standards currently
in place, and possibly to introduce new ones for both new build and work on existing buildings.
However, the overall aim continues to be to make the best practicable contribution towards the
Government's carbon emission reduction policies whilst keeping the Regulations proportionate,
providing sufficient design flexibility, and avoiding inappropriate technical risk.
24. The following paragraphs outline the areas under review, grouped under a number of generic
headings. As mentioned at the start, further thinking in the light of informal consultations with
industry and other interests is required before decisions are made about which new measures
BRAC might recommend Government should consult on next Summer, and what standards they
might recommend should be regarded as reasonable provision for the conservation of fuel and
power.
25. During the course of the work, the references in the two Approved Documents will be reviewed
and updated where possible, and new references added where appropriate.

Thermal bridging
26. Stage 1 raised the awareness of the importance of minimising thermal bridges, and through
associated publications, has provided improved guidance to industry. The aim was to encourage
industry to develop its understanding of linear thermal transmittances and their effects on energy
consumption. These effects are increasingly significant as overall fabric losses and ventilation
heat losses are reduced.
27. Industry provided a significant input into the development of Robust Construction Details, which
if implemented in practice, should limit the effects of thermal bridging and air leakage. Since the
publication of the document on robust details for dwellings and similar buildings, work has been
done on other types of construction (e.g. metal cladding systems and curtain walling). It will be
important to build on this resource of good construction practice, and especially to ensure
compatibility between the thermal performance guidance and the corresponding work on Robust
Standard Details for acoustic protection, following the recent revision of Part E.
28. EN 14683 now provides the basis for quantifying the effects of thermal bridging using linear
thermal transmittances. Consideration is therefore being given to taking account of quantified
thermal bridges in setting thermal standards for the building envelope. This would allow
improved design details to be offset against poorer standards in the main elements of construction,
thereby increasing design flexibility. However, all junction details would need to meet the
temperature criteria to avoid condensation problems.

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 Possible Future Performance Standards for Part L October 2003

29. Incorporating quantified thermal bridges would require setting a specific quantified performance
standard for thermal bridges. This would either require the linear transmittances to be calculated
for all junctions, or be available from a library of previously calculated values. This could be
achieved by updating the Robust Details catalogue with the pre-calculated linear transmittance
values, or adopting a separate thermal bridge catalogue and software such as that available
through EuroKOBRA 9.
30. Given the increasing significance of thermal bridges, the current thinking is that the effects
of thermal bridges should be quantified as part of the overall assessment of whole building
energy performance. However it is recognised that simple ways of showing compliance and
more comprehensive guidance will both be needed.

Airtightness standards
31. It is suggested that airtightness standards (measured as air permeability) need to be improved, and
that different standards should be set for the different types of buildings, as suggested in CIBSE
TM23 10.
32. The degree to which the standards are raised must take account of the need to comply with Part F
in providing adequate ventilation for health, and Part J in relation to air supply for combustion
appliances. A review of Part F is starting in late 2003. For this reason, consideration of the
airtightness standards for naturally ventilated buildings must be correlated with any changes to
Part F.
33. The level of improvement that might be justified is likely to be greater for the more energy
intensive building types (e.g. commercial buildings as opposed to industrial ones, and balanced
mechanically ventilated dwellings as opposed to naturally ventilated ones).
34. Within the constraints mentioned above, it is considered likely that substantially improved
airtightness performance standards for some building types could be justified in the next (2005)
amendment, with different standards being set for different building types. The values in the
following table give an indication of the standards that might be considered, the first two
columns summarising the industry-developed recommendations for Good and Best Practice as
published in TM23 in 2000.
Permeability in m3/h/m2 at 50 Pa
Type of new building TM23 Good TM23 Best Current
practice practice thinking
Dwellings - naturally ventilated 10 5 10 **
Dwellings with balanced whole house mechanical 5 3 5
ventilation)
Offices and retail - naturally ventilated 7 3.5 10 **
Offices and retail with balanced mechanical 3.5 2 7
ventilation
Industrial and warehouses 10 3.5 7

9
see www.eurokobra.org
10
Testing buildings for air leakage, TM23, CIBSE, 2000

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 Possible Future Performance Standards for Part L October 2003

** Note - these values are subject to revision in the context of the parallel review of Part F. The
standard could be improved if it is found that this would be unlikely to compromise ventilation
for health.
35. The final column in the table contains the airtightness standards we suggest could be justified for
adoption in 2005. We further suggest that less demanding performance standards should
probably be considered reasonable for refurbishment works.
36. In addition we will be considering with DfES and NHS Estates the possibilities for setting
separate standards for specialist building types like schools and hospitals.

Pressure testing
37. In order to continue to achieve further improvements in the levels of airtightness found in
practice, it is thought that it would be beneficial to expand the application of airtightness testing.
There has been some confusion over the implementation of the guidance in the 2002 ADL2.
Consideration is therefore being given to introducing a legal requirement to carry out pressure
testing of buildings. Our current thinking on the requirements for testing different categories of
buildings is as follows:-
38. Dwellings - those builders that are not using Robust Details and a third party quality assurance
system would need to demonstrate that sufficient airtightness has been achieved via a pressure
test. In addition, if tests to be carried out during the next few months indicate that the adoption of
robust details is not delivering the required standards (see paragraph 65), then pressure testing
might be required even if robust details have been adopted. In all cases, testing would be done on
a sample basis - perhaps modelled on the sampling provisions set out in the new Part E.
39. Other types of buildings with floor areas exceeding 200m2 should each be tested. (The current
guidance is to test buildings over 1000m2. The 200m2 threshold matches the application area
limit set in ADL2, 2002 for air conditioning. It also roughly matches in with the Directive Article
9 threshold of 12kW cooling output, being equivalent to a cooling load of 60W/m2.)
We currently think that both of these new requirements could be implemented as part of the
2005 review
40. A PII project being led by the Air Tightness Testing and Measurement Association is developing
guidance on pressure testing large buildings and is likely to deliver guidance material that could
be included or referred to in the next edition of ADL2.

Improved correlation between design and as-built performance

41. There is a measure of concern that there is often significant difference between the design
assessment of energy performance and the performance achieved in practice (see paragraph d.
Focusing attention on improved design details and site supervision to improve the performance of
thermal bridges and airtightness might help to improve the correlation. Other factors might
include the robustness of assumptions about such factors as gaps between insulation, timber
fractions etc.
42. The current thinking is that there are perhaps two approaches to addressing this issue -
a. Increasing the type and frequency of pre-completion testing to check that build quality
matches the design intent, and the attention that building control inspectors pay to see that this
is being done. This has implications for availability of test equipment, competent testers and
resources for building control bodies etc.

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 Possible Future Performance Standards for Part L October 2003

b. Basing the performance standards on more realistic assumptions about build quality. This
would mean that to achieve a given U-value, more insulation would be required to
compensate for the defects in typical construction. Builders who reasonably demonstrate that
their construction methods or systems deliver better build quality than the standard could use
this to justify reducing insulation thickness. Such an approach has been used in Sweden and it
is understood that similar provisions are in place in Holland
43. We propose to explore these two approaches to see how best we could help improve the
correlation between design and as-built performance. As part of this we propose to canvass the
views of the BCBs and the experience from other countries like Sweden and Holland.

Appliances
44. It is clear that in many building types, the energy used by appliances (white and brown goods,
business machines, personal computers etc) represents a very significant proportion of the energy
budget and the carbon emissions. Currently, Building Regulations do not address the
performance of appliances, although ODPM lawyers have advised that the powers available in the
Building Act do not preclude so doing.
45. We propose to explore this issue in close collaboration with DEFRA's Market Transformation
Team to see if Part L is the most appropriate mechanism for introducing performance
standards for appliances and will report at a later date.

Swimming pools
46. Until now, Part L has only addressed those aspects of building design that provide comfort and
convenience for normal occupant activities. In line with the aims of the EWP, we are looking to
see what other activities within dwellings and other buildings might provide opportunities to
achieve reductions in carbon emissions. Swimming pools and hot tubs (whether indoor or
outdoor) are particularly suited to the application of no/low carbon systems such as solar hot
water or CHP and can be significant users of energy in respect of such issues as:
a. Insulation of the pool basin
b. Provision of pool covers
c. Pool water heating system efficiency
d. Ventilation heat recovery.
47. We are therefore giving consideration to whether standards could be defined for swimming pools
and hot tubs (and whether they would yield worthwhile and cost-effective carbon savings).

Portable buildings
48. As indicated in the 2002 edition of ADL2 as amended by the 12 February 2002 Circular Letter,
special considerations apply to buildings constructed from sub-assemblies that have been
manufactured prior to the implementation date of the new standards, and have been obtained from
a centrally held stock or from disassembly of another building. In such cases, for the 2005
edition of ADL2, we are thinking of raising standards for reasonable provision to those set out
in the 2002 edition of Approved Documents L2.

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 Possible Future Performance Standards for Part L October 2003

Future Thinking for Part L1 - Dwellings

Reference compliance method
49. In line with the requirements of the Energy Performance Directive, we are proceeding with the
thinking that came out of the Stage 2 review that energy or carbon calculation methods in SAP
should be used as the basic method for establishing what is "reasonable" - i.e. the test of
compliance with Part L1.
50. This approach provides the following benefits -
a. greater design flexibility than the Elemental Method.
b. avoidance of the somewhat arbitrary cut-offs at specific numerical values in the Elemental
Method, which can be inconsistent with standard dimensions of insulation layers in practical
construction.
c. elimination of the need to define elemental standards for linear thermal transmittances as part
of the quantification of thermal bridging. However this would require quantification of all
linear transmittances as part of the estimation of heat loss.
51. We nevertheless think that an Elemental Method will need to be retained to provide guidance on
standards for manufacturers and suppliers, and to cover extensions and replacement work.

The effect of size and shape

52. One weakness of the existing compliance methods is that they do not fully address the impact of
built form, that is to say building size and shape. Encouraging more compact built forms would
improve energy efficiency and reduce carbon emissions, and help Planning Departments tasked
with delivering increased planning densities. We therefore propose to explore in the coming
months the feasibility of introducing requirements for built form. Depending on progress, we
may be able to develop firm proposals for formal consultation prior to the 2005 amendment, but
the matter may have to be deferred to the next revision in around 2010.
53. A practical consequence of introducing a built form factor into these methods would mean that
larger dwellings, or ones that do not conform to optimum shapes, would be more expensive to
build. The significance of the factor in calculating overall performance would therefore have to
be carefully balanced. However, recent work suggests that overheating is likely to be a greater
problem in small, compact dwellings (see paragraph 67), and so this might provide a self-
balancing effect.

U-values
54. For new build, the aim is to express the reasonable standard of provision for the whole building
using the SAP energy and/or carbon methods leaving designers to follow their own inclinations
on how best to achieve it, whilst keeping within constraints of poorest acceptable U-values. In
establishing the whole-building performance standard it will be necessary to analyse a range of
house types constructed to reasonable elemental standards. The following paragraphs describe
what those elemental standards might be. Smaller builders may wish to continue using an
elemental-based method, and U-value standards will still be necessary for use in alteration and
extension work.

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 Possible Future Performance Standards for Part L October 2003

55. The first column of data in the following table shows the standards set out in ADL1 (2002). The
forward thinking paper published in the June 2000 consultation document envisaged that the U-
values adopted by Stage 4 (see paragraph 9) could be as given in the second data column of the
table below. The final two columns give the Best Practice and Advanced standards as given in
GIL 72 11. The last three columns represent significant improvements on current standards, but
they need to be considered if the EWP's challenging CO2 reduction targets are to be met.
Indicative standards for fabric ADL1 2000 GIL72 GIL 72
insulation 2002 Forward Best Advanced
Thinking Practice Standard
Roofs 0.16-0.25 0.16 0.13 0.08

External walls 0.35 0.25 0.25 0.15

Ground floors 0.25 0.22 0.20 0.10

Average of all windows, doors and 2.0-2.2 1.80 1.80 1.50

rooflights

56. Much attention has been given to the need to improve the existing stock if the Kyoto targets are to
be met. Such attention is necessary, but dwellings built now will have a service life well beyond
2050, and it is important that they make a reasonable contribution to achieving the 2050 target.
Consequently, the stock that is built between now and 2050 has to be of the best practical
standard.
57. Our current thinking is that for new dwellings, the second and third columns in the above table
should be the starting point for establishing the standard of reasonable provision for new
dwellings for 2005, with the fourth column being signalled as our current thoughts on standards
for around 2010.
58. We think that 2005 may be too soon to raise window standards for replacement work because of
handling and fabrication issues associated with soft coat technologies, and the difficulties
associated with soft coating toughened glass. We therefore think that for replacement windows,
the performance standard should be kept at the current level as set out in ADL1(2002), (i.e. 2.0
W/m2K for wood and PVCU windows and 2.2 for metal ones) - at least until the originally
targeted 5 years period between the 2002 implementation and the next revision of Part L has
passed (i.e. April 2007). However, we propose that the improved standard would apply to new
building work immediately following the implementation date. This approach should keep the
costs of replacement windows at their current level, thereby not discouraging homeowners from
investing in replacements. The period up to 2007 would allow industry to expand their soft-coat
production technologies as the market for such windows expands.
59. More guidance needs to be given on what is reasonable provision in replacement window work.
For example, we think that reasonable provision might include installing insulated cavity closers.
60. We think that the guidance introduced in ADL1(2002) that stated that such standards might not be
appropriate in some refurbishment situations, especially in relation to historic buildings, should be
retained. English Heritage has published guidance on compliance with Part L 12, and it is hoped
that this might be reviewed and widened ahead of 2005.

11
Energy efficiency standards for new and existing dwellings, GIL 72, HEEBPp, 2002
12
Part L of the Building Regulations and Historic Buildings: an interim Guidance Note, English Heritage, April
2002.

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61. Another issue for review is whether the trade-off allowed by reduced window areas allows poorer
opaque U-values than is desirable. The EPBD requires that the standards should be based on
overall energy performance, and therefore it might be argued that full trade-off should be allowed.
This view was adopted within ADL1(2002), with the only limit on trade-off being set by
establishing poorest allowable U-values, and a caution about the need to achieve sufficient
daylighting. Given the current drive to improve standards, it might be argued that U-values
should never be significantly poorer than a standard that is cost effective over the service life of
the element. Consequently, we are thinking that the standards given in Table 3 of ADL1(2002)
should be revised, such that the U-value of all element types (wall, roof etc) should not be worse
than a given threshold figure, both in terms of individual elements, and in terms of whole
dwelling averages for that element type. We are thinking for instance that the thresholds might
be as given in the following table:-

Element Worst allowable U-value Maximum average U-

of any individual element value of all elements of
of the given type (W/m2K) the given type (W/m2K)
Roof 0.35 0.25
Exposed walls and floors 0.7 0.35
Wood / PVCU windows and 3.3 ** 2.2
glazed doors
Metal windows and glazed 3.3 2.2
doors
Unglazed doors 3.0 2.2
** We think that single glazed elements smaller than a certain area might also be allowed

62. As with the current ADs, we think that the same standards should be required for extension work
as for new construction, but that, excluding windows, doors and rooflights, reasonable provision
might be something less in alteration work (see paragraph 92).

European window energy rating scheme (EWERS)

63. In the 2002 editions of ADL1 and ADL2 different U-value standards were defined, dependent on
framing material. This was accepted in recognition of the greater solar benefit from slimmer
metal frames. The difference was based on a generic difference rather than actual product
standards. We think it could be more effective for energy conservation to use a product-rating
scheme as the basis of assessing performance. Therefore our current thinking is to adopt
EWERS, principally for the quality assured fundamental properties (U-value, solar heat gain
coefficient etc) that underpin the rating, and which are required for use in the whole-building
calculation methods required by EPBD. The actual rating may also be useful as a standard for
replacement windows, where an elemental approach is most useful.
64. By adopting the EWERS as the basis for standards in the AD, industry should be encouraged to
adopt the scheme in sufficient numbers to make the scheme effective.

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 Possible Future Performance Standards for Part L October 2003

Airtightness
65. The levels of airtightness achieved in some new dwellings is to be monitored over the next few
months to help establish whether the "Robust Details" published by TSO in 2001 are delivering
satisfactory As-Built performance. If there is insufficient confidence that the standards
mentioned in paragraph 35 will be achieved in practice, then we would consider introducing
sample pressure testing of dwellings in the 2005 amendment.

Robust Standard Details

66. We propose to review the existing robust details, to add new ones to improve choice, and to cover
more severe weather exposure. We will also explore the possibility of taking advantage of this
opportunity to correlate and perhaps merge the Part L RSDs with those produced for Part E
compliance.

Control of overheating in dwellings

67. Some reservations were expressed during the Stage 1 consultation process that further increases in
the levels of insulation set out in ADL1(2002) might result in problems of overheating and
subsequent increase in domestic air conditioning. A Partners in Innovation research contract
sponsored by DTI has investigated the validity of these concerns, and is developing guidance
aimed at limiting such problems. The outcome of this work will be examined to establish overall
performance targets and see what specific guidance could beneficially be included in ADL1.
68. Although levels of insulation do have an impact on overheating, the major factors are solar gain,
internal gain, ventilation rate and thermal capacity. It is also clear that the smaller, more compact
dwellings are more prone to overheating, and that to achieve the same comfort standard
irrespective of dwelling size would require relatively greater investment in measures to limit
overheating in small dwellings. Solar control measures and appliance standards (see paragraph
44) are particularly relevant in this respect. This size and shape trend is opposite to that relating
to limiting heat loss, and so this might enable the overall cost impact of new standards to be
approximately equalized across all sizes and shapes of dwelling. We will be looking into the
possibility of introducing design standards (opening area, solar control, building mass and
ventilation provisions) that will enable overheating to be limited through passive means.
69. Even with such improved passive measures to control overheating, the impact of changing climate
could increase the demand for domestic air-conditioning. We will therefore be looking into the
possibilities of setting minimum air conditioning equipment efficiency standards for new
dwellings and for retrofit applications. The latter would require air-conditioning systems in
dwellings to be added to the list of controlled services.

Heating systems
Central heating boilers
70. For domestic gas boilers serving space-heating systems, the EWP has indicated that the standard
for normal circumstances will be increased to SEDBUK Band A or B (i.e. a seasonal efficiency
>= 86%), which is equivalent to a condensing boiler. The Government has indicated that it wants
this higher standard brought into effect by 01 April 2005 so that boilers can be removed from the
prospective new Energy Efficiency Commitment signalled in the EWP. We shall therefore be
developing proposals for an interim amendment timed to come into effect on 01 April 2005, that
revises the guidance in ADL1 (2002). The aim is to consult on this as part of the general
consultation on Part L in the summer of 2004, and then to fast-track the review and approval
process to enable the amendment to be published around February 2005.

14
 Possible Future Performance Standards for Part L October 2003

71. Because the impact of improved heating system efficiency is greatest the poorer the insulation
standards of the house, (longer heating season and greater heating demand), it could be argued
that higher standards should be set for replacement boilers than for those included in new
dwellings. However, there is currently no real technical distinction between boilers rated at
SEDBUK A and SEDBUK B and so this may not be practical.
72. We believe that lower SEDBUK standards will be justified in some exceptional circumstances,
especially for replacement boilers in existing dwellings where there may be flueing or condensate
drain problems or other significant structural and décor barriers and in dwellings away from the
gas grid or with solid or oil fuelling by choice. Industry is working to identify these exceptional
building situations in terms of the practical difficulties and the extra overcosts involved. In due
course a paper will be presented making recommendations on the cut-off point when the extra
costs make condensing boilers non-cost-effective, and hence the standard of what would be
reasonable provision post March 2005. As part of this however we would be looking to
obtaining best practical performance from non-condensing boilers. We therefore think that, in
addition to defining when non-condensing boilers replacements are allowed, ADL1 should call
for the controls package to be upgraded to the standards applying to new dwellings.
73. It will be necessary as part of this to introduce separate provisions for different classes of
boilers such as back boilers, combi-boilers and central hot water storage units, and boilers fired
with LPG, oil, or solid fuel. Multi-fuel solid fuel boilers will need particular consideration, given
the very different carbon intensity of the alternative fuels (coal, wood and wood pellets).
74. We also think it essential to make reasonable provision when microCHP units (or other new
heating technologies) are to be installed. As part of this process, SAP 2001 will need to be
updated to reflect the performance of mature new technologies as well as to align it with the
requirements of the EPBD.

Local fires - secondary heating

75. In many dwellings, a local fire supplements the central heating system, or provision is made via a
chimney or flue for a fire to be fitted by the occupier. It is thought likely that the carbon
emissions from such secondary heating systems are considerable when viewed nationally.
Consultees in the past have therefore suggested that
a. secondary heating systems should be specifically required to be efficient,
b. that the heat loss from permanently open flues should be taken into account and
c. that poorer appliance performance should be compensated for in some way.
76. We propose to investigate how compensation could be made and the practicalities and
enforcement issues arising from such a measure. The requirements of the EPBD to move to a
compliance procedure based on an integrated building performance method (likely to be based on
SAP for dwellings) seem likely to take account of this issue, because allowance would have to be
made for secondary heating systems and/or chimneys and flues in the calculation procedure.

Other forms of heating in dwellings

77. We are looking into developing proposals for introducing new performance standards and
guidance for a wider range of heating systems in dwellings including:-

15
 Possible Future Performance Standards for Part L October 2003

a. Localised fires; as insulation standards improve, the use of several local fixed heaters may
become more common instead of, rather than supplementary to, hot water central heating.
Consideration is being given to basing performance requirements on recently published
standards 13. We also propose to consider what standards might apply to electric heaters,
which are 100% efficient at point of use, but usually involve a higher carbon burden.
b. Domestic CHP - either microCHP units directly replacing domestic boilers, or macroCHP (up
to say 25kWe) in blocks of flats for instance. Following the announcement of Government
supported trials of this technology and the goals for increasing embedded generating capacity
over the next 2 decades, small scale CHP may well take a significant share of the future
market for replacement heating systems. Currently, the overall carbon emissions from CHP
units are compared with regular boilers that meet the performance standards in ADL1. It is
expected that a new CHP seasonal efficiency index similar (but not comparable with)
SEDBUK will become available, and it is hoped that this can be adopted for 2005.

Hot water services

78. As fabric insulation and airtightness standards improve, the relative importance of efficient
generation of hot water and provisions for controlling its consumption increases. We will
investigate ways of setting standards for the efficiency of hot water generation, distribution and
use. In addition to the existing guidance on central heating boilers with HWS cylinders, we
propose to introduce guidance on reasonable provision when choosing COMBI boilers, multi-
point instantaneous water heaters and economising outlet taps and valves. The on-going CEN
activity aimed at developing a standard for labelling of water heating systems will be a useful
source of information in this respect.
79. It is thought unlikely however that Part L of the Building Regulations could be used to influence
householders' demand beyond making provisions for economic delivery at outlets. In the Building
Act 1984 there are powers enabling water conservation measures to be introduced. ODPM will be
considering with DEFRA how these might be used.
80. It is proposed to investigate under what circumstances solar hot water systems are cost-effective.
It seems likely that they will be found to be so for new dwellings with favourable roof
orientations. It may also be cost-effective to require hot water replacement works, and the works
involved in installing replacement combi-boilers, to include provisions for later connection of
solar collector systems. Where systems are shown to be cost effective, our current thinking is
that reasonable provision should include their installation (or compensating for their omission
by greater energy efficiency measures elsewhere in the design).
81. The safe and effective installation of solar water heating systems requires a degree of specialist
expertise. We therefore wish to include guidance in ADL1 on appropriate installation and
commissioning practice. In parallel with this we have invited the industry to investigate with us
the prospects for a competent persons scheme.

13
These include BS EN 613:2001 Independent gas-fired convection heaters
BS EN 13278:2003 Open-fronted gas-fired independent space heaters
BS EN 1266:2002 Independent gas-fired convection heaters incorporating a fan to assist
transportation of combustion air and/or flue gases
BS 7977-1:2002 Specification for safety and rational use of energy of gas domestic
appliances. Part 1: Radiant/Convectors
BS 7977-2:2003 Specification for safety and rational use of energy of gas domestic
appliances. Part 2: Combined appliances: Gas fire/back boiler
PAS 42:2002 Test method for establishing the efficiency of decorative fuel effect gas fires

16
 Possible Future Performance Standards for Part L October 2003

82. The EWP encourages the greater uptake of renewable energy systems, and so we will be
exploring what guidance might be appropriate for other types of building integrated renewable
energy technology. The most likely candidate is PV generating systems , and as with solar hot
water, where the economics are favourable, consideration might be given to requiring some PV
provision, or at least making it practical to more easily incorporate PV as a later retrofit. Either
way, ADL1 will provide references to documents that give advice on the selection and installation
of various types of renewable energy system.

Lighting
83. The guidance on lighting for dwellings will be reviewed in the light of the perceived effectiveness
of the 2002 standards. This is an area where further significant improvements in efficiency are
achievable, but where mechanisms such as product rating schemes might be more effective.
84. Now that the domestic lighting industry has expanded the available range of fittings that can
accommodate energy efficient lamps, we are thinking that it could be reasonable to provide
energy efficient fittings at more locations in new dwellings. The guidance in the current ADL1
is based on the 1995 edition of GIL20; that document has been updated, and any new guidance
will be correlated with the new edition and any further relevant guidance.
85. Consideration is also being given to whether lighting should be included in SAP as a further
means of encouraging energy efficient lighting, since by so doing, improved standards of energy
efficient lighting could be used to offset other perhaps more expensive energy efficiency
measures. This would be in line with the option in the Annex to the EPBD.

Conservatories
86. The current exempt status for conservatories less than 30m2 is being considered by a separate
Building Regulations Advisory Committee (BRAC) working party, following consultations that
concluded on 29 March 2002.
87. A PiI project investigating the energy performance of modern conservatory designs has been
completed 14 and is being used to inform the on-going discussions. The results will be used as the
basis for setting performance standards in a new guidance document addressing all the technical
requirements that apply. The main conclusions of the PiI work are that reasonable energy
performance can be achieved provided there is effective thermal separation between the living
space in the dwelling and the conservatory, and the thermal performance standards match the
general elemental standards. The current thinking is that, if conservatories have not been
addressed in the meantime by a separate Technical Guidance document covering all aspects of
conservatory design, ADL1 should be extended to indicate that thermal separation from the
dwelling should be maintained, that the elements (opaque wall, glazing etc) should comply with
the elemental U-value standards, but that they are not required to comply with the standard
area allowances. We would also think that some form of solar protection system (e.g. roof
blinds) and high and low level vents to promote natural ventilation is also reasonable provision
for avoiding excessive summer overheating.
88. The technical guidance document referred to above will only deal with conservatories that are
thermally separated from the attached dwelling. We are therefore thinking that ADL1 may need
to provide guidance on what is reasonable provision for those situations where there is a
permanent opening between a highly glazed extension and the main accommodation.

14
See material available on http://www.fabermaunsell.com/research

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 Possible Future Performance Standards for Part L October 2003

Refurbishment of the existing stock

89. There are around twenty four million existing dwellings and the average SAP Rating of this stock
is around 44. New dwellings built to the 1995 standards were achieving SAP Ratings on average
perhaps around 75, and those being designed to the 2002 standards may be achieving SAP
Ratings up to around 90. However less than 200,000 new dwellings are being built in the UK
each year. Examining how further encouragement can be given towards improving the average
SAP Rating of the existing stock is therefore seen to be a vital element of this review.
90. The Building Regulations only apply when people propose to carry out work. In deciding what
measures are to be controlled and what standards are considered reasonable, an important
consideration is the risk of dissuading people from improving at all. The outcome of the
Treasury's consultation on fiscal measures to encourage investment in energy saving measures,
and DEFRA's programmes for supporting the activities of the Energy Saving Trust will therefore
be important considerations in how far Building Regulations can move.
91. We propose to review the performance standards for windows, boilers and hot water cylinders
that were introduced in ADL1 (2002) in the light of experience. It is thought that these
standards could be raised to keep them in line with the provisions for new dwellings (although
as discussed in paragraphs 58 and 72, particular considerations might apply to replacement
windows and some replacement boilers). In the light of the point made in paragraph 69, it could
be a prudent provision to add domestic air-conditioning systems to the list of Controlled Services
for dwellings.
92. The possibilities for widening the definition of material alterations and stiffening the performance
standards that apply in these cases will be re-examined in an effort to encompass more types of
what are now considered to be maintenance and repair work. We propose to investigate how the
existing guidance on material alterations and changes of use in paragraphs 2.6 and 2.8 of
ADL1 can be widened to address more types of work, such as replacing the weather resisting
layers of roofs. This could lead to a fundamental amendment of what constitutes a material
alteration, but as this would have an impact wider than just Part L, it needs to be considered in
that wider context.

18
 Possible Future Performance Standards for Part L October 2003

Future Thinking for Part L2 - Buildings Other Than Dwellings

The Energy Performance of Buildings Directive
93. In line with the Directive Article 3, and with help from Expert Panels, we shall be developing 15: -
a. the national methodology for calculating the energy performance of buildings, and
b. a system for establishing reference performance levels for the different types of buildings
including multi-purpose ones.
c. overall building energy performance standards in line with Articles 4 to 6,
d. in relation to Article 5, provisions for considering whether it is reasonable to provide low
carbon and zero carbon systems.
e. in accordance with Article 7, a system for requiring the supply of building energy
performance certificates for new buildings and for those substantially refurbished,
f. the case for adopting either option (a) or option (b) in Article 8, and, if option (a) is preferred,
a system for effecting boiler inspections under the powers in Section 2 of the Act.
g. In accordance with Article 9, a system for effecting air conditioning inspections under the
powers in Section 2 of the Act.
94. We shall also be participating with others in the development of the systems for appointing
suitably expert building energy surveyors and boiler and air conditioning plant inspectors.
95. As indicated in paragraph 11, our strategies for developing these new provisions will be published
separately.
96. As discussed in paragraph 23, the aim of the Part L revision is expected to be a substantial
improvement in energy efficiency standards in 2005 consistent with practical and economic
considerations. All elements of construction work will be expected to make a contribution
towards achieving this improvement. Those elements of construction work for which the 2002
Review introduced standards for the first time are areas where we think significant advances in
standards might be possible, because the standards set in introducing the requirement were
especially cautious.
97. In parallel with the development of the overall building energy performance standards mentioned
above, we shall also be considering improvements in the standards applicable to elements of
buildings (as currently set out in the elemental standards). The aim is to substantially raise
standards in line with the overall energy performance methods as required by the Directive. The
setting of improved elemental standards will help define the overall building performance
standard, and also enable builders engaged in small-scale alteration and extension work to avoid
detailed energy calculations.

15
See separate strategy paper referred to in paragraph 11.

19
 Possible Future Performance Standards for Part L October 2003

Building envelope
U-values
98. We shall be considering how U-values can be further improved, with the aim of keeping them
generally in line with those improvements applicable to dwellings (see paragraph 55). However,
since the EPBD requires a move to whole building standards, precise U-value targets are less
significant. We shall also be investigating whether it would be appropriate to set different
minimum performance standards dependent upon the building type and/or construction method.
99. We have already begun a review of the provisions applicable to buildings with low levels of
heating as set out in paragraph 0.22 of ADL2(2002). The aim is to amend this as part of the Stage
2 package (see paragraph 6).

Solar control
100. Consideration will be given to how best the solar control requirements could be applied to
window replacements. Current thinking is that the solar overheating requirement might be limited
to apply only when new or larger openings are being created, or when ACMV systems are being
installed at the same time as replacement glazing is being installed.

Display windows and glazed entrances

101. Currently, display windows are ill-defined but nevertheless exempted from considerations
when showing compliance with Part L2. However, display windows can represent a significant
proportion of the façade area in (e.g.) retail and leisure developments. We are therefore looking
to develop a more distinct definition of "display" window, with the aim of introducing this
definition as part of the 2005 review.
102. The relative impacts on heating, cooling and lighting need to be better understood, along with
the structural and durability implications of large double glazed units. We therefore propose to
review the energy balance of display windows in different contexts (corner shop, high street store,
car showroom, mall retail unit etc). The Scottish Executive has also commissioned work in this
area and we shall be looking to pool our results. Following this analysis, we will then consider
whether the exemption should be removed or modified, and make proposals for introducing
new guidance into ADL2. We think that some improvements may be possible as part of the
2005 amendment, but more time will be needed thereafter to complete this work.

Rooflights and ventilators

103. It has been suggested that non-opening rooflights typically found in large-span buildings such
as factory units, retail sheds or leisure complexes might be classified as a separate element type,
with different U-value requirements and different area allowances to those in Tables 1 and 2 of
ADL2.
104. We are aware that the current provisions for trading off in ADL2 paras 1.14 to 1.16 are
causing difficulties between developers and BCBs.
105. The performance standards and area allowances for rooflights will be the subject of a
major review, especially in relation to the area allowances. The current 20% is considerably
greater than that used in conventional designs for many building types. If any excess rooflight
allowance is used for trade-off purposes, it can create anomalies. This aspect will be the subject of
special review, so that while design flexibility is maintained and the appropriate use of daylight is
encouraged, opportunities for excessive lowering of thermal standards are eliminated from the
compliance procedures in the AD. The whole building performance approach to compliance
required by EPBD will help in this respect.

20
 Possible Future Performance Standards for Part L October 2003

106. Roof ventilators (for smoke extraction or normal ventilation) can have relatively poor thermal
performance relative to that of the opaque roof elements and their running gear introduces thermal
bridges and air leakage paths. Appropriate standards of insulation and airtightness performance
are as yet undefined for such products, and these are likely to be reviewed in conjunction with the
non-opening rooflights discussed above. The degree of insulation and airtightness that might be
appropriate has yet to be determined, but it is thought that the presence or otherwise of opening
roof ventilators should not influence the required air permeability standards.

Entrance and vehicle access doors

107. Building airtightness may be compromised by the use of large unprotected entrance
doorways. These may be closed when air pressure tests are carried out, but open for much of the
time in practice. In hospital and industrial buildings there is often the need to have doorways that
enable frequent traffic. However in hotter and colder climates it is normal to protect entrances
with draught lobbies (or similar) and it is considered that provisions like these might now be
appropriate for normal application in England and Wales.
108. It has been suggested that the current guidance on the minimum U-value standard for
vehicle access doors is somewhat impractical and this will be reviewed. The aim is to revise the
standard as part of the Stage 2 package (see paragraph 6).

Heating system efficiency standards

109. For non-domestic heating plant, we propose to consider improving the required standards of
carbon intensity. Although this will inevitably cover boiler performance standards, consideration
will also need to be given to system integration issues, since these can have a significant impact
on overall performance.
110. As part of this, consideration is to be given to the possibilities for developing a seasonal
efficiency rating similar to the SEDBUK, though it is recognised that there is much greater
variation in heating demand patterns and operating regimes than is the case for dwellings. In
many non-domestic situations, there will be multiple boilers, and so it is therefore planned to
work with industry to see how boiler selection and system design issues might improve seasonal
efficiency, with the aim of introducing improved standards in 2005.
111. Additional guidance on reasonable provision for fuel efficiency and controls for systems such
as radiant or warm air heaters is envisaged, but the extent of the advice will depend on the
availability of the proposed CEN standards.

Regular inspection of boiler plant

112. The EPBD offers member states two routes to achieving this goal and discretion on which
fuelling options trigger the inspection requirement. There are options of an inspection regime or a
system of advice to users that will achieve the same objective, namely delivering
recommendations on cost-effective improvements to, or replacements of, the heating system to
improve energy efficiency. The EPBD Article allows that inspection systems can be limited to
apply to oil and solid fuelled installations or opened up to include gas. As an urgent first step
DEFRA are preparing a statement of the merits and demerits of the options so that Ministers
can decide which is most appropriate for the UK.
113. If the decision is to go for option (a), the inspection option, we will need to develop new legal
requirements underpinned by Section 2 of the Building Act, perhaps amended by the European
Communities Act.
114. As an adjunct to this issue, DEFRA will be investigating how building owners might be
encouraged or required to carry out the improvement work recommended as a result of the
inspection.

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 Possible Future Performance Standards for Part L October 2003

Lighting
Efficacy
115. It is felt that significant improvements in the standards for lamp efficacies, luminaire
efficiency and lighting controls might be practical for all building types. However, these aspects
of the design need to be balanced against issues of lighting quality, especially following recent
professional guidance tending to increase the use of indirect lighting. We propose to explore with
industry how and to what extent, the lighting efficiency standards can be improved and to make
proposals for amendments that could come into effect in 2005 - and also to set outline targets
for future reviews.
116. The move to the whole building energy performance approach to compliance means that we
will need to consider performance standards related to the building and not just to lamps or
luminaires. This might require standards to be set in terms of kWh/m2 per annum per hundred
lux or similar, although this would not interfere with designers' discretion to select lighting
intensities to suit occupiers' needs. A CEN working group is already working in this area, and we
will seek to take benefit from their activities.

Lighting controls
117. BRE have developed further guidance on lighting controls relating controls provision to the
type of space/occupancy combination. It is expected that this new guidance will be published
next year. It is envisaged that most, if not all of it, will be referred to in the 2005 edition of
Approved Document L2 as reasonable provision for compliance. Lighting controls will be an
important element of a whole building lighting energy target, and so the controls issues may well
be integrated with the approach described in the previous paragraph.
118. CIBSE have just published a commissioning guide for lighting control systems, and this will
be referenced as part of the revision of the current section 2 of ADL2.

Air conditioning and mechanical ventilation (ACMV)

System performance
119. The performance standards given in ADL2 (2002) for buildings that are air-conditioned or
mechanically ventilated (ACMV) were equivalent to what was considered "typical" performance
in 1998. The application of ACMV in new and existing buildings continues to expand rapidly
(and may accelerate should climate change effects become more manifest). Higher standards for
effective design and appropriate commissioning are therefore being considered.
120. Because of the growth in multiple split systems that can serve small individual rooms, our
current thinking is that the limit on application of the requirement should be reduced. The
present limit of 200 m2 was derived from considerations of minimum lettable areas. The limit
might be reduced to say 100 m2, or might instead be based on considerations of fan or
refrigeration capacities. For example, the EPBD requirement on inspection of air-conditioning
systems covers those systems with an output greater than 12kW, and there may be benefit in
having a consistent application limit.

Component benchmarks
121. We have found it impossible to apply the Carbon Performance Rating Method to buildings
other than offices because of the variances of occupation and energy use in other types of
buildings, and the absence of national data (similar to that in ECON 19 for offices) on which to
base pass criteria. We are therefore exploring the possibilities of component benchmarking
systems such as the specific fan power indices already included in ADL2. Such benchmarks
might be defined for room air conditioners, central chillers and pumps etc.

22
 Possible Future Performance Standards for Part L October 2003

122. For example, work is on going to explore the potential of the Integrated Part Load Value
(IPLV) approach. This may well prove useful, especially if appropriate weighting factors for UK
climate and practice can be established. This will help to address system integration issues as
well as component performance.
123. The IPLV recognises the importance of part-load efficiency, and this issue will need to be
addressed across all the components that contribute to the energy performance of ACMV systems.

Humidity control
124. The control of humidity can result in significant energy consumption in some buildings.
Evidence suggests that energy is often wasted through over humidification in winter. To that
end, we propose to give consideration to how this should be addressed via guidance in ADL2 on
humidification methods and humidity control systems. One concern would that the more energy
efficient technologies tend to require greater maintenance effort; if maintenance regimes were
poor in practice, the risk of legionella problems might increase. This risk will have to be factored
in to the overall cost benefit analysis.
125. Energy for dehumidification is implicit in the cooling load, at least as far as normal comfort
cooling systems are concerned, and so no further action is required.

Regular inspection of air conditioning systems

126. In line with the EPBD, we will be developing proposed legal requirements and technical
guidance for reasonable provision for regularly inspecting and reporting on air conditioning
systems rated at more than 12 kW. The guidance might be included in ADL2 or could be
published as perhaps a CIBSE or FETA Technical Memorandum. CIBSE and FETA are already
working on this. This would be underpinned by deploying dormant powers in Section 2 of the
Building Act, perhaps amended by the European Communities Act 1972.

Renewable energy systems

127. We are investigating how the Building Regulations can address the requirement in the EPBD
Article 5 to take into account low-Carbon and Zero-Carbon technologies at the design stage
Various ways that have been suggested include
a. Setting the building energy performance standard based on a proportion of the building's
energy demand being generated from an on-site renewable source. This would require
designers to include renewable or low-carbon energy systems as part of the design, or else
compensate via higher energy efficiency standards in other aspects of the design. This
approach has the advantage of allowing market forces to determine the most cost effective
way of achieving carbon savings.
b. Setting a limit on the externally supplied power input to the building, requiring buildings with
high power demands to have building integrated energy generation capacity. This approach
has been used in other countries (e.g. parts of Switzerland), but has the disadvantage of being
more to do with building use than building design.
128. Further guidance is to be developed on the selection and application of a number of low-
carbon and zero-carbon technologies that can be used as part of achieving the requisite overall
building carbon performance.
129. Where such no or low carbon technologies are installed, we think that for the time being, such
provisions should not be used via trade-off to reduce the fundamental efficiency of the building
envelope or the building services systems.

23
 Possible Future Performance Standards for Part L October 2003

Power factor correction

130. Low power factors can cause significant energy losses in transmission systems. We propose
to consider whether the prospective overall building power factor can be assessed at the design
stage, and if and how it might be corrected (at a component, system or whole building level).
This will be discussed with both the building industry and the utilities. If the potential savings
are found to be significant, we will make proposals for introducing requirements in 2005. This
will depend on being able to set appropriate standards and the practicalities of checking
compliance.
131. There is also an issue for suppliers' networks of harmonic distortions, but this is probably
outside the scope of Part L.

Other energy consuming services

132. There are some energy consuming services in buildings that are not currently addressed by
Part L2 (e.g. lifts and other vertical transportation systems). We propose to give consideration to
whether setting efficiency standards for such systems might deliver worthwhile carbon
reductions.

Conservatories, atria and other sun spaces

133. Atria are common in many types of non-domestic buildings and are often much larger than
the present 30m2 threshold of exemption granted to conservatories. We therefore propose to
further examine the possibilities for defining standards of reasonable performance, and the
guidance on its achievement as given in ADL2 (2002). However, the move to a whole-building
based approach to compliance may mean that specific performance standards for atria are not
needed

Refurbishment of the existing stock

134. There were about 1.9 million business addresses in England and Wales in 1994, each on
average occupying about 650 m2 of building floor area. Total floor area is increasing at about 2%
per year. Building turnover (demolition and replacement) is somewhat higher than for dwellings,
so the potential for energy performance improvement year on year for the stock as a whole is
somewhat better. In 2000, the emissions of carbon from these buildings was about 21 million
tonnes 16, about 20% of the national total. Offices, shops, hotels, industrial buildings and schools
are the largest contributors.
135. Extensive performance data and a common energy rating system like the SAP for dwellings
are presently unavailable to assist consideration of this stock, but it is widely held that its average
performance is far short of that being achieved by new build. The EPBD will in due course help
to improve this situation. However, even in the absence of firm information, further improvement
to the average performance of the existing stock is seen to be a vital element of the 2005
amendment
136. The Building Regulations only apply when people propose to carry out work. In deciding
what measures are to be controlled and what standards are considered reasonable, an important
consideration is the possibility of dissuading people from improving at all.
137. The performance standards for windows and the building services installations that were
introduced in ADL2 (2002) will be reviewed in the light of experience. Where practical, we will
raise these standards to keep them in line with the provisions for new buildings.

16
"Carbon Dioxide emissions from non-domestic buildings: 2000 and beyond" BRE

24
 Possible Future Performance Standards for Part L October 2003

138. The possibilities for widening the definition of material alterations and stiffening the
performance standards that apply in these cases will be re-examined with the aim of
encompassing more types of maintenance and repair work (see the general discussion under
paragraph 92).

Extensions
139. As with the current ADL2, we suggest that extension work should continue to be required to
meet the same standards as for new-build.
140. The performance standards for windows, boilers and building services introduced in ADL2
(2002) will be reviewed in the light of experience. It is suggested that these standards should be
raised to keep them in line with the provisions for new buildings (although as discussed in
paragraph 58, particular considerations might apply to replacement windows).
141. The possibilities for widening the definition of material alterations and stiffening the
performance standards that apply in these cases will be re-examined in an effort to encompass
more types of what are now considered to be maintenance and repair work. We propose to
investigate how the existing guidance on material alterations and changes of use in paragraphs 2.6
and 2.8 of ADL1 can be widened to address more types of work.

25