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 There is something rather important missing from the consultation documents issued yesterday by the communities department, regarding proposed changes to Part L of the building regulations, covering the conservation of fuel and power.
It concerns the issue of consequential improvements for existing buildings. Whenever a building is extended or has other major works done to it, the argument is that other reasonable, cost-effective energy improvements should be made.
The consultation paper includes quite a number of strategic questions, seeking positive or negative reactions to the principles raised. There was no need for any specific question to be asked on the consequential improvements issue. Back in 2004, just such a question was included in an earlier consultation on Part L – and received endorsement from 80% of respondees.
What is far more surprising is the absence of any reference in the accompanying technical documents as to how such requirements might satisfactorily be met, apart for buildings over 1,000m2 in size.
That 1,000m2 figure reflects the requirements of article six of the Energy Performance of Buildings directive. Adopted in 2002, this directive made “consequential improvements” in these larger buildings mandatory right across Europe from 2005. And that is an obligation that has been included in our building codes ever since.
But as long ago as last November, the European Commission published a new text, effectively a “recast” of the existing directive. And in that text, the barrier figure of 1,000m2 for “consequential improvements” disappears. Effectively – with just a few exceptions for historic or very temporary buildings – the requirement is extended to all existing buildings, of any size. Including all homes. To be introduced in 2011.
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