Open-access content
Monday 17th August 2009
The long-awaited consultation document on the energy conservation elements of the Building Regulations has now been published and FMs ought to have their say
by Samantha McDonough
20 August 2009
FMs need to be aware of the proposals contained in Part L (conservation of fuel and power) of the Building Regulations 2010 as they will have implications for how buildings are commissioned and subsequently refurbished. The regulations form an important piece of legislation in the government's journey towards reducing carbon emissions by 80 per cent by 2050 and the headline proposal is that from 2010 the target emissions rating for new buildings should be reduced by a further 25 per cent relative to current 2006 standards.
Although the key target on the horizon is zero carbon housing by 2016, it is recognised that we cannot afford to ignore the existing building stock and progressively more stringent energy efficiency requirements will be needed in future versions of Part L. Indeed there is a section on future thinking in this consultation, looking at options for 2013 and beyond. For example, do we want to see the energy used by lifts and escalators included in the Part L calculations? Should security and feature lighting be included?
Commissioning
The regulations state that a notice must be given to the local authority that the fixed building services have been commissioned correctly. It is now proposed that the accompanying guidance should state that reasonable provision would be for the designer to prepare a commissioning plan, identifying the systems that need to be tested and the tests that will be carried out. The LA notice should confirm that the commissioning plan has been followed and that every system has been inspected in an appropriate sequence and to a reasonable standard and that the test results confirm that performance is reasonably in accordance with the design requirements.
Provision of information
CLG cites log books as a way to provide a simple, easily accessible summary of a new or refurbished building rather than the detail contained in operation and maintenance manuals. CLG also intends to improve understanding of the design and construction of low and zero carbon buildings at all levels within the industry from designer and energy specialist to the site operative. Cibse and BIFM will be running an awareness campaign on building log books later in the year.
Guidance
The Non Domestic Building Services Compliance Guide sets the minimum recommended energy efficiency standards for compliance with building regulations and a significant amount of general "good practice" guidance on building services specifications and installation. It covers work on both new systems and replacement systems, identifying the differing requirements where these exist and contains recommended minimum standards for appliance efficiency, system control, and installation and commissioning procedures. It includes minimum provisions for the conventional means of providing primary space heating, domestic hot water, mechanical ventilation, comfort cooling and interior lighting. In addition, it covers low carbon generation of heat and electricity from renewable energy. Guidance on boilers includes biomass. The consultation asks whether minimum efficiency of gas and oil-fired new and replacement boilers should be raised to 90 per cent and if a minimum rating of "Band C" is an appropriate requirement for the performance of heating system pumps and circulators. Before there was no minimum standard for pumps.
Special considerations
It is proposed that current exemptions for historic buildings be removed, but specific guidance be provided in the Approved Document as to where special considerations apply, and how to arrive at an appropriate balance between heritage and energy conservation. Similarly special considerations apply to buildings with low energy demand, modular and portable buildings and shell and core developments. Guidance for shell and core developments has been amended. If a building is offered to the market for sale or let as a shell for subsequent fit-out the designer will have produced a calculation to demonstrate how the energy efficiency requirements for the building can be met once the space has been fitted out. However since fit-out is specific to the needs of the particular tenant, a revised compliance calculation will be required and also a new Energy Performance Certificate for the part of the building covered by the fit out under a section "part designed or altered for separate use" in Regulation 17E.
Compliance
Finally facilities managers will need to be aware of the proposals for compliance and enforcement. The person carrying out building work to which any requirement of building regulations applies has a responsibility to ensure that the work complies with any such requirement. The guidance also states that the building owner "may also have a responsibility for ensuring compliance with building regulation requirements and could be served with an enforcement notice in cases of non-compliance" - something that may fall into the lap of the FM.
Samantha McDonough is a policy manager at Cibse
Free joint seminar
BIFM and Cibse are holding a free joint seminar in London specifically for professionals involved in the operation of buildings to learn more about the proposals in Part L and to discuss some of the issues. Views will be fed back to the CLG. The seminar is on Tuesday 1 September 2009 at 2pm at the offices of Hilson Moran near London Bridge. For more information and to book call Samantha McDonough on 020 8772 3626 or email [email protected]