The Future Homes and Buildings Standards
2023 consultation on changes to Part 6, Part L (conservation of fuel and power) and Part F (ventilation) of the Building Regulations for dwellings and non-domestic buildings, and seeking evidence on previous changes to Part O (overheating). Summary of responses received and Government response.
Executive Summary
Overview
The UK Government is committed to reaching net zero carbon emissions by 2050. Given the significant contribution that our homes and buildings make to national emissions, improving their energy efficiency is central to this ambition. While the challenges in reducing emissions from buildings are considerable, new-build is an area where meaningful progress can and must be made.
This document sets out the Government's response to the Future Homes and Buildings Standards consultation on proposed changes to energy efficiency and ventilation requirements for new homes and buildings set out in Part L (Conservation of fuel and power) and Part F (Ventilation) of Schedule 1 to the Building Regulations and to Approved Documents relating to Part L and Part F, as well as the call for evidence on Part O (Overheating). The consultation also included proposals relating to work to existing buildings, which are covered in this response where relevant.
At the same time as the publication of this document, regulations have been laid in Parliament which amend the Building Regulations 2010 and the Building (Registered Building Control Approvers etc.) (England) Regulations in order to implement the Future Homes and Buildings Standards. Updated Approved Documents, which provide the statutory guidance accompanying the Building Regulations, have also been published. The regulations and amended guidance will come into force on 24 March 2027, subject to transitional provisions.
The Future Homes and Buildings Standards will make sure that new homes and non-domestic buildings are future-proofed with low carbon heating and high levels of energy efficiency. Homes and buildings constructed to these standards will not require retrofitting to become zero carbon in use once the electricity grid is fully decarbonised.
Chapter 3: Performance Requirements for New Buildings
Chapter 4: Metrics
Chapter 5: Updated Guidance and Minimum Standards
Chapter 6: Material Change of Use
Chapter 7: Real-world Performance of Homes
Chapter 8: Heat Networks
Chapter 9: Smart Meters
Chapter 10: Accounting for Exceptional Circumstances
Chapter 11: Legislative Changes
Chapter 12: A Review of Our Approach to Setting Standards
Chapter 13: Transitional Arrangements
Chapter 14: Part O
Chapter 1Introduction
Net Zero Emissions and Climate Change
The Government remains committed to achieving net zero emissions by 2050. This goal is supported by a series of interim targets set out in successive Carbon Budgets, which chart a pathway to decarbonisation. In 2025, the Climate Change Committee recommended a reduction of emissions of 87% relative to 1990, by 2040, the middle year of the Seventh Carbon Budget period. Improving the energy efficiency of new builds, and transitioning away from volatile fossil fuels to clean heat sources, is an important part of this.
While there are significant challenges in improving the energy efficiency of and reducing the carbon emissions from our buildings, this is a key area where we must make significant progress. In 2021, there was an uplift to Part L (Conservation of fuel and power) and Part F (Ventilation), which came into effect on 15 June 2022 (subject to transitional provisions). As a result, new dwellings and non-domestic buildings are now expected to produce significantly lower carbon emissions compared to those built to the 2013 standards. Part O was introduced at the same time, which sets out a new requirement to mitigate overheating risk in new residential buildings.
While the changes made in 2021 were a step in the right direction, further action is needed to accelerate progress towards achieving net zero by 2050. The Future Homes and Buildings Standards will therefore introduce more ambitious requirements for energy efficiency and heating in new dwellings and non-domestic buildings. Buildings constructed to these new standards will be designed to achieve zero carbon emissions in use as the electricity grid continues to decarbonise. Under the Future Homes Standard, dwellings are expected to have reduced running costs compared to the typical existing dwelling and, alongside previous improvements to ventilation and energy efficiency standards, will have reduced risk of damp and mould, excess cold and heat, and improved air quality.
Supporting the Government's Plan for Change
Alongside its environmental goals, the Government is committed to national growth and renewal, with a target to deliver 1.5 million new homes during this Parliament. This ambition is not only about increasing the number of homes, but about ensuring they are high-quality, affordable, and sustainable. The energy efficiency improvements outlined in this consultation response are central to achieving that vision.
These changes will ensure that new homes are built with low-carbon heating, high levels of energy efficiency, and, in most cases, solar panels. By improving building performance and embracing innovation, we can cut carbon emissions, enhance climate resilience, and protect consumers from rising energy costs – while strengthening the UK's energy security through clean, homegrown power.
Building Safety and the Grenfell Tower Inquiry Report
The Grenfell Tower Inquiry Phase 2 Report, published in September 2024, concluded that the tragedy that led to the entirely avoidable deaths of 72 innocent people was the result of a culmination of decades of failures by central government and by those in positions of responsibility within the construction industry. The Inquiry called for the government to learn from this tragedy and to prioritise the safety of residents in all aspects of building standards.
As the Future Homes and Building Standards have been developed, it has therefore been important to understand potential health and safety risks. We have considered numerous aspects relating to safety, such as the importance of ventilation and the risks of overheating, throughout our analysis of the consultation responses. Government will continue to keep the safety and standard of buildings under review.
Chapter 2Overview of Consultation
Consultation Responses
The Future Homes and Buildings Standards consultation was published in December 2023, seeking views on plans for a further update to the energy efficiency requirements for new homes and buildings. The consultation closed in March 2024.
The minimum energy efficiency requirements for new homes and non-domestic buildings are set through Part L (conservation of fuel and power) of Schedule 1 (requirements) to the Building Regulations and Part 6 (energy efficiency requirements) of the Building Regulations. The consultation set out technical proposals for changes to the Building Regulations, the associated Approved Document guidance and calculation methods.
There was a high level of engagement with this consultation. A total of 2,421 responses were received from a range of organisations, representative and trade bodies, industry professionals, academics and individuals. Eight email submissions were excluded as they fell entirely outside the scope of the consultation, meaning that 2,413 responses were included in the final analysis.
| Respondent Type | Number of Responses |
|---|---|
| Member of the public | 1,747 |
| Builder / Developer | 63 |
| Building Control Approved Inspector | 4 |
| Competent Persons Scheme Operator | 7 |
| Designer / Engineer / Surveyor | 144 |
| Architect | 122 |
| Energy sector | 56 |
| Installer / Specialist sub-contractor | 28 |
| Local Authority | 64 |
| Housing Association | 26 |
| Manufacturer / Supply chain | 126 |
| National representative or trade body | 75 |
| Professional body or institution | 31 |
| Property Management | 10 |
| Research / Academic organization | 21 |
| Other | 86 |
This response provides a summary of the feedback received on the 95 consultation questions and sets out the Government's decision and next steps for each issue. The question numbers used throughout align with those in the original consultation document. Questions 1–6 are not included, as they relate to personal data.
Approved Documents
The finalised versions of Approved Document L, Volume 1: Dwellings; Approved Document L, Volume 2: Buildings other than dwellings and Approved Document F, Volume 1: Dwellings have been published.
Timetable for Implementation
At the same time as publishing this document, regulations have been laid in Parliament, which will amend the Building Regulations 2010 and the Building (Registered Building Control Approvers etc.) (England) Regulations 2024, which, along with new statutory guidance, will implement the Future Homes and Buildings Standards. There is a 12-month period before the new regulations and guidance come into effect (subject to transitional provisions), on 24 March 2027, for non-higher-risk building (HRB) work (and on 24 September for HRB work and work to existing HRBs) to allow industry time to prepare.
Chapter 3Performance Requirements for New Buildings
Introduction
The energy performance of buildings has an important contribution to make to meeting the government’s target of net zero emissions by 2050, and the way that homes and non-domestic buildings perform can also impact the energy bills occupants incur and the comfort they feel.
Through the Building Regulations, the government sets whole-building, minimum energy performance requirements. Performance requirements for new homes and non-domestic buildings are set using a notional building approach. We modelled different building specifications to produce the proposed notional buildings that we presented in the Future Homes and Building Standards consultation. The three major variables across these specifications were heat source, solar photovoltaic (PV) panels and fabric.
Dwelling Notional Buildings (Q7 & Q8)
| Response | Number of Responses | % of All Responses | % of Responses to Q7 |
|---|---|---|---|
| Option 1 | 2,196 | 91.0% | 96.8% |
| Option 2 | 72 | 3.0% | 3.2% |
| Not Answered | 145 | 6.0% | – |
Key Themes
The main point raised by respondents who preferred Option 1 was support for the inclusion of solar panels. Other common points included the importance of reducing pressure on the national electricity grid and the importance of minimising energy bills. Respondents said that it is important to set high standards now to avoid retrofitting in the future.
The most common concern raised by respondents who preferred Option 2 was that the proposed solar panel coverage in Option 1 is not achievable in practice for certain house or roof types. Concerns were also raised about the capital costs and the resulting impact on small housebuilders and on housing supply.
Heat Network Dwelling Notional Buildings (Q9)
| Response | Number of Responses | % of All Responses | % of Responses to Q9 |
|---|---|---|---|
| Option 1 | 2,155 | 89.3% | 96.8% |
| Option 2 | 72 | 3.0% | 3.2% |
| Not Answered | 186 | 7.7% | – |
Non-Domestic Notional Buildings (Q10 & Q11)
| Response | Number of Responses | % of All Responses | % of Responses to Q10 |
|---|---|---|---|
| Option 1 | 2,034 | 84.3% | 97.9% |
| Option 2 | 44 | 1.8% | 2.1% |
| Not Answered | 335 | 13.9% | – |
Chapter 3 Summary
Chapter 4Metrics
Introduction
Currently, performance requirements for individual homes and non-domestic buildings are set using a combination of complementary metrics. For homes, these metrics are the Target Emission Rate (TER), target primary energy rate (TPER) and fabric energy efficiency (FEE). For non-domestic buildings, the metrics used are the TER and TPER.
In the consultation, 5 policy outcomes were proposed for the metrics used for the Future Homes and Future Buildings Standards, in order of priority:
- Protect occupants against high energy bills.
- Reduce energy demand of homes and non-domestic buildings by requiring high performing building fabric and building services in new buildings, thereby improving energy security.
- Reduce total operational carbon emissions and produce net-zero ready buildings by requiring low-carbon heating and increasing general electrification of buildings.
- Are simple to understand and use by industry and provide developers with flexibility in meeting consumer preference regarding design, form and operation.
- Consider peak electricity demand to reduce costs associated with national and local grid infrastructure upgrades.
Metrics for the Future Standards (Q12)
| Response | Number of Responses | % of All Responses | % of Responses to Q12 |
|---|---|---|---|
| Yes | 343 | 14.2% | 42.6% |
| Yes, and I want to provide views on suitability | 112 | 4.6% | 13.9% |
| No, I think delivered energy should be used | 279 | 11.6% | 34.6% |
| No, I think FEE should be changed | 10 | 0.4% | 1.2% |
| No, for another reason | 62 | 2.6% | 7.7% |
| Not Answered | 1,607 | 66.6% | – |
Key Themes
There were mixed views amongst respondents. Those who supported retention noted familiarity with the current system and its alignment with established industry practices. However, some respondents expressed a preference for delivered energy as a clearer and more direct measure of energy consumption.
Chapter 4 Summary
Chapter 5Updated Guidance and Minimum Standards
Introduction
In addition to setting whole-building performance requirements, the Approved Documents include additional guidance for the energy efficiency of both fabric and fixed building services. This additional guidance helps secure delivery of the performance requirements in practice, by including minimum standards for individual elements of the building and building services.
Minimum Building Services Efficiencies (Q13)
Some respondents supported the proposed minimum services standards, but others advocated higher COP standards for heat pump technologies. Specific concerns were raised that the proposed maximum Specific Fan Powers (SFP) for distributed mechanical ventilation systems were set too low, and that the SEER for comfort cooling was set at an unrealistic level.
Heat Pump Controls (Q14)
The majority of respondents agreed with the proposed additional guidance. A small number expressed concerns about smart controls, including that controls should be suitable for all users and not dependent on smartphone or internet access.
Heat Pump Operating Information (Q15 & Q16)
There was general consensus that operating and maintenance information should be fixed to heat pump units in new homes. Respondents warned that affixing instructions directly to the heat pump may be impractical and suggested information should also be available online or in the Home User Guide.
Limiting Heat Loss from Low Carbon Heating (Q17)
Some respondents pushed for more stringent minimum standards for heat losses. Specific concerns were raised about the proposed minimum U-value for floor coverings, insulation requirements causing practical problems with pipes and ducts, and hot water cylinder insulation standards.
Hot Water Storage Vessel Sizing (Q18)
While 83.9% of respondents answered “Yes”, many provided wide-ranging caveats. Concerns included that the guidance was too prescriptive, not suitable for some system types, relied on outdated assumptions, and used inappropriate temperature and reheat times.
Non-Domestic Building Services (Q19)
Lifts, Escalators and Moving Walkways (Q22 & Q23)
Over 90% of respondents agreed that lifts, escalators and moving walkways should be included in the definition of fixed building services. Concerns included that building control inspectors may lack specialist knowledge to test compliance.
Chapter 5 Summary
Chapter 6Material Change of Use
Introduction
A Material Change of Use (MCU) is a conversion of a building from one purpose to another. Currently, the minimum standards set for a dwelling created under an MCU are lower than those for a new dwelling and are regulated separately from those of newly built dwellings. In the consultation, we proposed illustrative ways of uplifting MCU standards to protect consumers from high bills and reduce emissions as far as practical.
Whole-Building Standards for MCU (Q25)
The main comments from respondents who supported the proposal were that whole-building standards would help reduce energy bills of MCU dwellings and the need for future retrofitting. A common concern was that the proposed standards would be difficult to meet in many situations, as many aspects of MCU buildings are beyond the builder/developer’s control.
There were mixed views on whether heritage buildings and those in conservation areas should be subject to the same standards as other buildings.
Energy Efficiency Requirements for MCU (Q29 & Q30)
A concern among respondents who did not agree with the proposed notional building specification was that the proposed requirements were not ambitious enough. There was support for more stringent U-values and a ‘fabric first approach’. Conversely, a handful of respondents expressed concerns that airtightness requirements would be unfeasible for existing buildings.
Home User Guides for MCU (Q38)
A common view was that the Home User Guide for MCU dwellings should be more specific than that of a typical new build dwelling. Written responses showed a desire for parity between new build owners and MCU owners.
Airtightness Testing for MCU (Q39)
An overwhelming majority of respondents agreed that homes that have undergone an MCU should be airtightness tested. Reasons given included delivering energy efficiency and carbon savings, ensuring appropriate ventilation, ensuring good workmanship, providing more information to consumers, and identifying failures in fire compartmentalisation.
Government Response to Q25–Q39
Chapter 6 Summary
Chapter 7Real-world Performance of Homes
Introduction
Several studies of new homes suggest that measured energy performance once occupied can be worse than the energy performance expected at the design stage. We implemented several measures through the 2021 uplift to Part L to improve building performance in homes. In the consultation, we explored what more can be done to close the gap.
Post-Occupancy Performance Testing (Q40)
While most respondents supported the introduction of voluntary post-occupancy testing, there were a range of views on how this should be implemented. Many respondents stated that they believed post-occupancy testing should either be mandatory or move to becoming mandatory. A key desire was for greater clarity on how data would be collected, whether data would be made public, and the exact testing method.
Future Homes Standard Brand (Q41)
The majority of respondents were in favour of a Future Homes Standard brand. However, there were significant reservations about implementation, including concerns that a brand would be less effective if not well enforced, could create confusion if added to existing brands, and the name might become quickly outdated.
Commissioning Fixed Building Services
Ventilation Systems (Q42)
Respondents had specific comments about ductwork guidance, with concerns that the draft guidance limiting dMEV ductwork to 2m was problematic for certain building types. There was support for using Competent Persons Schemes and concerns around enforcement.
Regulation 42 Extension (Q43)
Heat Pump Commissioning (Q45)
Certifying Fixed Building Services (Q47)
Home User Guides
Heat Pump Information (Q48)
Most respondents felt that the proposed additional information is sufficient to ensure occupants can use their heat pumps efficiently. Some felt written information alone is not sufficient and advocated for supplemental walkthroughs by a member of the customer care team.
Digital Accessibility (Q50)
Chapter 7 Summary
Chapter 8Heat Networks
Introduction
Heat networks will play an important part of our net zero future in any scenario. In the consultation, we proposed supporting the expansion of heat networks where they are making demonstrable steps to decarbonise. We proposed that new homes and buildings should be allowed to connect to existing and new heat networks where they can demonstrate sufficient low-carbon generation to supply the buildings’ heat and hot water demand. A sleeving system was proposed to implement this principle.
Heat Network Compliance Routes (Q53–Q58)
Key Themes
Overall, there were mixed levels of support for the heat network proposals. A common concern was that proposed standards need to be better aligned with other measures to regulate heat networks, such as the upcoming heat network zoning regulations or the Heat Network Technical Assurance Scheme framework.
A number of respondents felt that the proposals were too challenging or too expensive for heat networks to achieve. In contrast, some respondents were doubtful of the benefits of heat networks and felt their expansion should not be encouraged.
- Annual consumption should be used rather than peak demand within the sleeving calculation.
- The proposed scheme would lead to too rapid removal of gas CHP, potentially increasing CO2 emissions short-term.
- There was insufficient oversight of the proposed sleeving process.
- Temporary heating sources used before connection to a heat network are unlikely to meet low-carbon requirements.
- The proposed three-year window for a future plant to be connected is too short.
Chapter 8 Summary
Chapter 9Smart Meters
Introduction
Smart meters are an important upgrade to our national energy infrastructure and a key enabler of the energy system flexibility needed to achieve the Government’s Clean Power 2030 Mission. We consulted on updating guidance originally published in November 2020 for developers, builders, architects and all those involved in the specification of metering locations in new buildings.
Smart Meter Guidance (Q59 & Q60)
The majority of respondents agreed that the draft guidance would be effective in supporting smart meter installations. Many found the guidance useful, providing clear instructions on meter placement and installation procedures. Some argued smart meters are already an industry standard, while others noted smaller developers may lack the same standards.
Some major national suppliers argued that smart meter installations should be a mandatory requirement rather than relying on voluntary guidance. Several respondents raised the relevance of the guidance for all new buildings, not just dwellings.
Chapter 9 Summary
Chapter 10Accounting for Exceptional Circumstances
Introduction
We recognised in the consultation that, as the energy efficiency requirements we set for new buildings becomes stricter, there may be exceptional circumstances where these standards cannot reasonably be applied. Instead of setting less ambitious standards, we proposed that we allow dispensation or relaxation in these exceptional circumstances.
Regulation 26 is the requirement not to exceed the target CO2 emission rate for the building. Currently, it is not possible to relax Regulation 26. By contrast, almost all other parts of the Regulations can be relaxed or dispensed with where the relevant building control authority judges the requirement to be unreasonable.
Relaxation of Regulation 26 (Q61 & Q62)
| Response | Number of Responses | % of Responses to Q61 |
|---|---|---|
| Yes | 251 | 37.0% |
| No | 427 | 63.0% |
| Not Answered | 1,735 | – |
A number of responses noted that, whilst their preferred option would be against providing means of relaxing Regulation 26, there may be exceptional circumstances where relaxation may be permissible under tightly defined guidelines. Potential reasons identified included historic or conservation areas, existing energy infrastructure limitations, scientific trials for new energy technologies, and long-term stalled sites.
Chapter 10 Summary
Chapter 11Legislative Changes to the Energy Efficiency Requirements
Introduction
The Future Homes and Buildings Standards primarily involve changes to the Approved Documents and notional building specification. However, we also consulted on making changes to the Building Regulations to ensure they reflect our dual aims of reducing carbon emissions and conserving energy.
Amending Part L1 of Schedule 1 (Q65)
On the whole, respondents agreed that Part L1 of Schedule 1 should be amended to require that reasonable provision be made for the conservation of energy and reducing carbon emissions. There were comments that the proposed amendment does not go far enough, with some urging for stronger wording than “reasonable.”
Regulations 25A and 25B (Q66)
Respondents were divided on whether Regulations 25A (consideration of high-efficiency alternative systems) and 25B (nearly zero-energy requirements) should be repealed. Those who disagreed argued that the Future Homes and Buildings Standards do not go far enough and these regulations are still needed as a backstop.
Chapter 11 Summary
Chapter 12A Review of Our Approach to Setting Standards
Introduction
Currently, to determine the energy performance of new buildings and to demonstrate compliance against performance requirements, calculations must be carried out according to the national calculation methodologies approved by the Secretary of State. For dwellings, this includes fabric energy efficiency rates.
In the consultation, we proposed adopting the new Home Energy Model (HEM) as the approved calculation methodology to demonstrate compliance of new homes with the Future Homes Standard, replacing SAP. We also proposed retaining the notional building approach.
Home Energy Model (Q67)
Many respondents agreed with adopting HEM, though several indicated a desire for further development before rollout. Concerns included the accuracy of the model, its complexity (with assessments taking triple the time of SAP), and consequences for the SAP assessment profession. Some SAP assessors were reported to be leaving the industry.
Notional Building Parameters (Q68)
Some respondents disagreed with using notional buildings. A common concern was how solar panel standards are set in the notional building, including that south-facing orientation is too challenging and the amount of PV may conflict with local place-making. Others noted buildings should be designed to meet requirements rather than retrofitting PV into existing designs.
Local Weather in the Notional Building (Q69)
91.2% of respondents supported using local weather. Heat pump manufacturers felt it would better ensure appropriate sizing. However, concerns included data accuracy and potential supply chain disruption for little marginal benefit.
Average Compliance for Terraced Houses (Q70)
Chimneys and Flues (Q71)
Window and Door U-values (Q72)
89.3% of respondents agreed with the proposed approach. Supporters noted it would reduce the gap between design and real-world performance. Critics said it was impractical and costly, particularly for small developers.
Thermal Bridges (Q73)
National Calculation Methodologies for Non-Domestic Buildings (Q75–Q77)
A common theme was that major revisions to the NCM and SBEM would be welcomed. There were general concerns with suitability and suggestions for adopting PHPP or approaches closer to TM54. The average luminous efficacy proposed was considered too ambitious.
Chapter 12 Summary
Chapter 13Transitional Arrangements
Introduction
The consultation sought views on proportionate transitional arrangements that would provide a reasonable period for industry to adapt to the Future Homes and Buildings Standards, whilst making sure that the momentum towards our net zero targets is maintained.
Transitional Arrangements Options (Q78)
| Response | Number of Responses | % of Responses to Q78 |
|---|---|---|
| Option 1 (shorter: 6 months to force, then 12-month transition) | 568 | 77.8% |
| Option 2 (longer: additional 6 months to force) | 162 | 22.2% |
| Not Answered | 1,683 | – |
Key Themes
Those preferring Option 1 were concerned that longer transitional arrangements would increase the number of less efficient dwellings built and allow more gas boilers to be installed. They noted the sector has had advance knowledge of the new standards.
Those preferring Option 2 raised concerns over HEM readiness, the need for heat pump installer training and upskilling, supply chain disruptions, grid connection capacity, and negative impacts on small and medium-sized developers.
Impact on Planning Permissions (Q79)
Respondents identified concerns about solar PV requiring rooftop re-design, air-source heat pumps requiring planning amendments for noise and visual concerns, fabric demands affecting building size, and the need for electricity sub-stations on large sites previously planned with gas infrastructure.
Closing Historical Transitional Arrangements (Q80 & Q81)
97.1% of respondents to Q80 agreed that the 2010 and 2013 energy efficiency transitional arrangements should be closed down. Respondents cited concerns around carbon budgets and the future burden of retrofit, with strong sentiments that old transitional arrangements enable industry malpractice.
Chapter 13 Summary
Chapter 14Part O – Call for Evidence
Introduction
In December 2021, a new legal requirement was introduced in the Building Regulations (Part O) to reduce the risk of overheating in new residential buildings. In the consultation, we sought views and evidence from housebuilders who had experience applying Part O to real projects.
Widening the Scope of Part O
Material Change of Use (Q82)
Most respondents supported applying Part O to dwellings created through an MCU, ensuring fair and equitable standards across all residential units. A common concern was that overheating risks will worsen as the climate changes. Some recommended revising the methodology to be more practical for converted buildings.
Extensions and Conservatories (Q84)
Many respondents stated that large areas of glazing can lead to significant solar gain. Examples included conservatories and highly glazed rear extensions. Several respondents described that adding a conservatory or extension can reduce the effectiveness of natural ventilation. Mitigations described included shading, large opening areas, and thermostatically controlled exhaust ventilation.
Requirement O: Overheating Mitigation
Simplified Method (Q85)
There was a strong theme that the simplified method is too complex and would benefit from further guidance, detailed examples or supporting tools. Some respondents felt it was too restrictive and only suitable for basic buildings, citing omissions in vernacular design, thermal mass, building fabric performance, and active cooling.
Many respondents highlighted the need for the ‘high risk’ category to be reviewed, noting areas outside Manchester and London may have similar overheating risk. Multiple areas of conflict with other Building Regulation requirements were identified, specifically Parts Q, B and K.
Dynamic Thermal Modelling (Q86)
Several respondents stated that passive cooling strategies and natural ventilation are not well modelled. Inconsistencies in results across different assessors and modelling software were described. There were concerns over how noise limitations are incorporated, and a lack of opportunity to account for internal shading.
Usability of the Mitigation Strategy (Q87)
Respondents stated various omissions related to noise considerations including duration and regularity of noise exposure, daytime noise levels, limits on mechanical services noise, and the impact of different types of noise. Some noted that current noise requirements push developments to use mechanical cooling solutions, which does not align with the original intent of Part O.
Respondents highlighted Part O requirements contradict or conflict with Part F (purge ventilation), Part L (maximising heat retention), Part Q (window security), Part B (window sizes for escape), and Part K (guarding heights).
Protection from Falling (Q88)
A major recurring theme was the conflict between increased guarding requirements of Part O and existing standards in Parts K and B. There was a strong call for clearer, more consistent guidelines. Respondents frequently questioned the empirical basis for believing the changes markedly improve safety outcomes. Concerns about accessibility for wheelchair users were also raised.
Regulation 40B: Information about Overheating
Regulation 40B requires the person carrying out building work to give sufficient information to the owner about the overheating strategy of the home. Respondents suggested adoption of the new CIBSE TM59 guide once published, and raised concerns about the difficulty of complying with security requirements, particularly for ground floor bedrooms.
Government Response to Q82–93
Chapter 14 Summary
Chapter 15Equalities and Impact Assessments
Equality Assessment
The Public Sector Equality Duty requires ministers to have due regard to the need to eliminate discrimination and other conduct prohibited under the Equality Act 2010, to advance equality of opportunity, and foster good relations between persons who share protected characteristics and those who do not.
Key Themes from Q94
Many respondents said that the proposals could have financial implications for individuals with protected characteristics, particularly those more likely to experience poverty. Where specific, respondents most commonly referenced disability and age. Concerns focused on affordability of technologies, running costs of electric heating, and potential for increased rents in MCU dwellings.
Some respondents said the proposals should do more to ensure accessibility for disabled people and older individuals, including making the Home User Guide available in accessible formats and ensuring heating and ventilation systems are easy to operate.
Impact Assessments
The consultation stage Impact Assessments were carried out in line with HM Treasury’s Green Book guidance. Respondents raised concerns about embodied carbon, electrical grid capacity and connection costs, health impacts, ventilation costs, and the need for more rigorous testing and monitoring.
Appendix – List of Acronyms
Acronyms
| Acronym | Definition |
|---|---|
| BACS | Building Automation and Control Systems |
| BEMS | Building Energy Management System |
| BNG | Biodiversity Net Gain |
| BREL | Building Regulations England Part L |
| CHP | Combined Heat and Power |
| cMEV | Centralised Mechanical Extract Ventilation |
| cMVHR | Continuous Mechanical Ventilation with Heat Recovery |
| COP | Coefficient of Performance |
| DESNZ | Department for Energy Security and Net Zero |
| dMEV | Decentralised Mechanical Extract Ventilation |
| DNO | Distribution Network Operator |
| DSM | Dynamic Simulation Method |
| EPC | Energy Performance Certificate |
| FEE | Fabric Energy Efficiency |
| HEM | Home Energy Model |
| HRB | Higher-Risk Building |
| IA | Impact Assessment |
| iSBEM | Interface for Simplified Building Energy Model |
| MCU | Material Change of Use |
| MCS | Microgeneration Certification Scheme |
| MIS | Microgeneration Installation Standard |
| MDU | Multiple Dwelling Unit |
| MVHR | Mechanical Ventilation with Heat Recovery |
| NCM | National Calculation Methodology |
| OCGT/CCGT | Open Cycle Gas Turbine / Combined Cycle Gas Turbine |
| PCDB | Product Characteristics Database |
| PM | Particulate Matter |
| PV | Photovoltaic |
| SAP | Standard Assessment Procedure |
| SBEM | Simplified Building Energy Model |
| SEER | Seasonal Energy Efficiency Ratio |
| SFP | Specific Fan Power |
| TER | Target Emissions Rate |
| TPER | Target Primary Energy Rate |