WHITECODE CONSULTING’S RESPONSE TO UK NET ZERO BUILDINGS STANDARD TECHNICAL UPDATE AND CONSULTATION

The UK Net Zero Carbon Buildings Standard (UK NZC) aims to establish a benchmark for decarbonising the built environment in the UK, with the intention of publication in 2023. Although there has been a notable advancement in defining how we can achieve net zero for buildings in the UK, a market analysis revealed a strong need for a unified and accepted methodology. As a leading Mechanical Electrical Plumbing consultancy, Whitecode is offering its insights in response to the Chartered Institution Building of Service Engineers (CIBSE) call for industry consultation while the standard is being developed.

The UK Net Zero Carbon Building Standard will address the need for a single methodology by offering a single definition and reference point for developers, contractors, asset owners and managers, occupiers, financiers, and funders who seek to showcase that their buildings align with the net zero principles established by the industry and support the climate targets of the UK. The standard is currently being developed by the Better Buildings Partnership (BBP), Building Research Establishment (BRE), the Carbon Trust, Chartered Institution of Building Services Engineers (CIBSE), IStructE, London Energy Transformation Initiative (LETI), Royal Institute of British Architects (RIBA), Royal Institution of Chartered Surveyors (RICS), and the UK Green Building Council (UKGBC), with consultation from the industry.

Whitecode is pleased that the recent technical on the UK Net Zero Carbon Building Standard suggested that the metrics for assessing the net zero carbon performance of buildings will encompass various aspects, including upfront embodied carbon, lifecycle embodied carbon and space heating/cooling demand and peak load. The standard also looks to address important considerations such as carbon accounting methodologies, the procurement of renewable energy, and the handling of residual emissions, including the use of carbon offsetting techniques. However, Whitecode hopes to see certain topics expanded upon in the standard’s final iteration to truly maximise energy efficiency in the UK’s construction sector.

Stronger Guidelines for the Retrofit Market

We believe that the coverage of the retrofit market will need to be more extensive in the final publication. When retrofitting both commercial and residential buildings, the use of on-site renewables is not yet an absolute requirement. Although CIBSE has suggested that there will be constraints on operational energy in the final standard, how will this be enforced? Although many in the industry will strive to attain the required operational energy levels, what will the consequences be for those who don’t? Our concern is that if the government does not establish a clear mechanism for implementation, the UK will miss its target of Net Zero 2050 by decades.

The UK has the oldest housing stock in Europe, with heritage buildings making up a great sector of the UK’s real estate. It is common knowledge within the industry that energy efficiency improvements are a far easier proposition for the new build market than it is for heritage buildings. Therefore, if the UK wants to realistically achieve its goal of carbon net-zero by 2050, it will have to address the issue of retrofitting historic buildings head-on. As such, Whitecode strongly supports the requirement for on-site renewables for all new-builds and we hope to see the introduction of greater regulations concerning retrofit for heritage buildings to encourage more energy efficiency across this sector.

More Robust Consequential Improvements

In this vein, we would also argue that the consequential improvements under Approved Document L were a missed opportunity to enforce real, tangible change. Improvements such as solar PV panels and battery storage systems to limit carbon footprints are a much-needed addition. The existing regulations lay the foundations for the consequential improvements of commercial buildings to become tighter. It is clear that many within the industry are engaged and want to enforce change – but for the members of the industry who don’t see the incentive of improving their energy efficiency, there is no impetus for them to do so. A government roadmap for improving EPC ratings would be highly beneficial in creating a sense of urgency and supporting the industry to plan its developments in energy efficiency.

Carbon Offsetting and Embodied Carbon

Furthermore, more attention needs to be paid to offsetting. In pursuit of net-zero carbon emissions, offsetting the industry’s carbon output will be critical. However, carbon offsetting will need to be better regulated to ensure that funds allocated for carbon offsetting are being used effectively. Providing grants to asset owners to upgrade their building fabric and install solar PV panels would be an effective measure.

Increasing carbon offsetting payments will also be an effective measure to incentivise owners to improve their energy efficiency, as owners may see it as more convenient to pay the offsetting charge which is typically cheaper to pay than the costs associated with building improvements. In London, the carbon offsetting payment is £95 per tonne over 30 years, whereas in Bristol the carbon offsetting payment is £373 per tonne over 30 years, to encourage owners to invest in their energy efficiency.

Likewise, going forward it will be increasingly important for the UK to regulate its embodied carbon, as carbon emissions produced during the extraction, transportation and manufacture of raw materials should be as much of a concern as carbon produced during the operational phase of the building. Clear regulatory guidelines around embodied carbon will highlight the importance of this issue and help to lower carbon emissions in the early phases of construction.

Widespread Use of District Heating

We would also like to see district heating become more widely used. Currently, it is only generating around 2% of the UK’s energy, but this could be the low-carbon solution for heating the UK’s homes. For example, looking at the success of Southampton’s main energy centre which has 45 different kinds of users - ranging from 1,000 residential properties, a hospital, a shopping centre, a university, police headquarters and a television studio - show how successful this solution could be for the UK if employed on a wider scale. The UK Government has targets in place for 15-18% of heat to be generated from district heating networks by 2050, but without any regulations in place for district heating, how can we make this ambition a reality?

Improved Demand Management

Finally, we posit that there is a growing need for demand management. We need only look at Whitecode’s own self-sustaining office in South Africa, where our South Africa team utilises a battery system that is modular, scalable and compatible with solar PV panels that enables them to go off the grid. While much of the rhetoric within the UK is centred on demand management for residential buildings, we believe that this is also a practical solution for commercial buildings. Demand management regulations have already been incorporated into the Greater London Authority’s London Plan, demonstrating its relevance as an energy efficiency strategy for urban infrastructure; showing that this is a viable solution to consider throughout the UK.

In summary, we acknowledge the progress made in developing the UK Net Zero Buildings Standard. While appreciating the standard's focus on embodied carbon, energy efficiency metrics, and carbon offsetting, we are suggesting improvements in several areas. These include expanding coverage of the retrofit market, strengthening consequential improvements for new builds and commercial buildings, regulating carbon offsetting effectively, addressing embodied carbon, promoting district heating with regulatory support, and emphasising demand management. By addressing these considerations, the UK Net Zero Carbon Building Standard can create a more significant impact on decarbonising the built environment and achieving the UK’s Net Zero 2050 target.