When the theory doesn’t match the practice

If the potential for energy saving is to be met then the Government must take a closer look at whether its policies are being implemented or just ignored

“Evidence-based policy making” is a litany endorsed by every government since well before the Millennium. As a result, impact assessments are de rigueur before any new initiatives see the light of day.

The current proposals for altering Part L of the building regulations are certainly supported by swathes of the latter. However, they are backed up by very little hard evidence as to whether these savings identified can ever become a reality. 

During their anticipated lifetime, the proposed tighter standards for new English homes and non-residential buildings are forecast to save 14.51m tonnes of carbon dioxide (MtCO2).

Of course, such savings can only occur if new buildings are built to the required standards, and perform as they are supposed to do. It seems that, whenever actual “in use” surveys are undertaken, these reveal that many new buildings fall risibly short of design intent.

Most of this evidence has come from external sources (the Energy Efficiency Partnership for Homes; the Joseph Rowntree Housing Trust; the Energy Saving Trust). Almost none has been overseen by the government department in charge of Buildings (now called Communities & Local Government (CLG). The absence of such empirical evidence enables the official Consultation document to dismiss the concerns about levels of compliance with Building Regulations as simply “often anecdotal”.

Sadly, this is not the only policy area where the buildings Department seems wilfully to avoid seeking empirical evidence as to how well – indeed whether – their policies are being implemented, or ignored.

Existing buildings are where the really big impact from the new regulations is due to occur. During their subsequent lifetime, improvements in existing buildings triggered by these changes are due to deliver a whopping 135.40MtCO2 saving ten times as much as new buildings. Each home improved is due to gain up to £440 lower fuel bills each year.

The most familiar addition to buildings is a conservatory. If there is a door between this extension and the original building, then there is nothing to stop the former still being built to the most minimal energy efficiency standards. Again, “anecdotal” evidence suggests that after construction, many such doors are left open or removed altogether, making the conservatory occupiable throughout the year. The consultation document scarcely mentions anything to do with conservatories. There is no reference to any research as to whether these are used, as per the theory, only during the non-heating seasons. Or whether in practice many are nowadays occupied and heated throughout the year.

As well as tightening minimum standards for replacement boilers and windows (saving 4.3MtCO2), the main benefits are scheduled to emerge from the expansion of “consequential improvements” into smaller buildings. Ever since 2006, whenever you expand the size of a building over 1,000m2, the requirement has been that the existing building is upgraded. Now the size restriction is to be dropped from this autumn – delivering lifetime savings of 22.10MtCO2.

At least, theoretically delivering. Because it seems that the buildings department has undertaken no research at all on the levels of compliance in larger buildings over the past six years – where, again, “anecdotal” evidence suggests a woeful absence of compliance.

European regulations dictate that a change in occupants is supposed to stimulate the production of an Energy Performance Certificate (EPC). Again, there has been no official research published regarding levels of compliance – although the Kingfisher subsidiary NES did publish a large survey back in 2010 which revealed that an EPC was present in less than half of non-residential buildings transactions.

Similarly, since 2008, all public buildings to which people have access have been required to post their energy performance over the past 12 months “in a prominent place” – and to update this each year. To be fair, the Department of Energy did publish a survey of the 28,800 qualifying buildings, giving details of their current and previous ratings – and revealing than in 40 per cent of these public buildings, nobody seems to be bothering to update their Display Energy Certificates (DECs).

But given the strong desire from the property industry to expand such DECs into the private sector, again one might reasonably have expected the buildings department to have looked at the evidence available, so as to estimate how cost-effective these were being in cutting fuel bills in the public sector - and hence the potential impact of widening such requirements into other buildings. But, yet again, there is no evidence one way or the other available from CLG.

The really bold step in the new regulations, due to save 108.90MtCO2, is set to come from additional energy saving triggered following replacement of boilers or windows. This is a completely new concept. These are works which councils merely have to be “notified” about, with which local authority building control departments are not currently concerned. Despite this, the government is proposing that a council “would not be under an obligation” to follow up to check if any additional measures have actually been installed. Almost inevitably, there has been no research to test likely levels of compliance given such a “laissez faire” approach.

Forecasting enormous energy saving figures like this in impact assessments makes everyone aware of the great potential that exists. But the continuing failure by CLG to trouble to investigate how or whether theory can be turned into practice, simply serves to undermine the entire policy’s credibility. I really do hope that is nobody’s intention. 

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