44 There was general support for amending the exemptions from the energy efficiency requirements, although particular cautions were expressed in relation to historic buildings and places of worship. However, there was strong support for the additional guidance on historic buildings which had been proposed.
…………………………………..
1.51 The Historic Housing Association expressed deep disappointment that an association that represents the interests of the nation’s most significant listed buildings was not included in the formal list of organisations to be consulted.
……………………………………
2.30 Some three comments across all groups raised the question of summer ventilation for cooling purposes and expressed some concern that this aspect of ventilation remained unchanged, relying on window opening interventions for purge ventilation when the control of cooling ventilation was likely to become important under future climate scenarios. A small number of comments expressed concern about the impacts of both Parts F and L on works to historic buildings with a general desire to see clearer mechanisms by which the historic issues were taken into account. In the case of Part F concerns related principally to replacement windows and the likely requirement for trickle ventilators.
……………………………………
2.35 Some 113 respondents made comments in addition to answering the headline question. Of these a total of 94 (83%) comments were received from those answering “no”, 13 (12%) from those answering “yes” and 6 (5%) from those registering a “don’t know” response. A content analysis of the comments indicated that approximately 70% of all comments related to either the nature of the building control system (40%) or the adequacy of the building control resource (30%)8. Other comments (usually between one and five) reiterated such things as reducing complexity so as to make it easier to enforce the requirements, improving the quality of design information to ease the burden on building control bodies (BCBs), and strengthening the provisions for historic buildings. In the case of historic buildings the concern was not to prevent improvement but to ensure that provisions were more likely to lead to dialogue with conservation officers than currently. However, it is the two dominant areas that need further analysis and discussion.
……………………………….
4.12
e) Greater education around historic building construction, conservation techniques, and related philosophies. Increased training around the performance and role of traditional building materials.
………………………………
5.78
c. Conflicts between building regulation guidance and planning legislation need to be addressed, especially with regard to historic buildings and conservation areas.
……………………………….
Question 48: Do you agree with the proposal to remove the current exemptions for certain classes of building/building work from the energy efficiency regulations, and to use guidance to demonstrate what is reasonable in each particular
There was strong support across the board for this proposal (139 out of 182 responses). However, as noted below there were a number of strong objections
7.2 There was strong support across the board for this proposal (139 out of 182 responses). However, as noted below there were a number of strong objections from the historic and religious buildings sectors.
…………………………..
7.5 Historic buildings and places of worship: the strongest set of objections to the proposals came from these sectors. The majority stressed that while they were committed to improving energy efficiency where practical and appropriate, they were concerned that removing the exemption would simply result in a significant weakening of the safeguard presently in place to protect historic buildings from unsuitable work. Such work could result in historic fabric no longer being able to “breathe”, with consequent increased risk of deterioration and mould growth. Key points were as follows:
a. A lack of resources would mean that no reference would be made to the detailed guidance and so inappropriate measures would be applied. Some responses accepted that the proposals were appropriate in theory, but felt they were unworkable in practice without a major education campaign to bring BCBs up to speed with the special requirements of historic buildings. Particular concern was expressed over listed buildings and those with Article 4 direction on them, when Building Regulations could require changes to the building without respect for, or reference to the conditions of the listed building consent. It was suggested that there are local authorities where building control officers (BCOs) are routinely consulted on planning issues, but that planners are less frequently consulted on applications under Part L, particularly with regard to unlisted buildings in conservation areas. Consequently, there was a concern that any dilution of the text by removing the explicit reference to “exemption” could lead to confusion among less experienced BCOs and other stakeholder groups. The exemptions send a clear message that the Government values historic and traditional buildings. They do not prevent appropriate energy conservation measures being undertaken, but highlight the need for a balanced approach. The drive for compliance without qualification by the exemptions is likely to result in greater reliance on options with a track record of receiving approval, rather than selection of the most appropriate options for the particular building in question. It was also suggested that there would be benefit in making it clear who has the final say when it comes to improving the energy efficiency of existing buildings – is it the building control officer or the local conservation officer?
b. Another concern was the implications of Regulation 20D on Consequential Improvements in respect of work in historic buildings. It was felt that there was a need for greater clarity on when such improvements would apply to historic buildings.
c. Some responses welcomed the wider definition of historic buildings given in the guidance (e.g. buildings of traditional construction), but felt the existing exemption should remain, leaving the non-exempt buildings included in the wider definition to be covered in the guidance. In contrast, some responses suggested that many buildings in conservation areas have little historic merit, and so the automatic exemption might be inappropriate.
d. Particular concerns were raised by the steel window industry who felt it important to maintain the character of facades where the slim profile of metal windows was a key feature and owners wanted to maintain the aesthetic. As discussed under the responses to Question 67, steel windows cannot meet the WER rating of C, but it was suggested that it was important to allow like-for-like replacement in terms of appearance, while noting that replacement double glazed steel windows offered a 500% improvement over the single glazed originals.
e. With regard to places of worship, it was suggested that the intermittent use and heating of these buildings can cause specific practical problems that are likely to be exacerbated by ill-conceived interventions. As many places of worship are struggling with dwindling and ageing congregations, and a severe lack of income, this often prevents them from being able to commission technical advice and instead, they are forced to rely on local builders or volunteers who may not have experience of working with historic and traditional buildings. As a consequence, it was suggested that a more cautionary approach to places of worship would be appropriate. In contrast, several responses challenged why newly built places of worship or extensions to existing places of worship should be exempt. It was pointed out that most places of worship are exempt from listed buildings control but are subject to statutory denominational controls which should be included in the proposals.
…………………………
7.24 It was pointed out that conservatories are often attached to historic buildings, and the special characteristics of the host building should be taken into account in determining reasonable standards for the conservatory.
…………………………..
7.59 In relation to the guidance itself, it was suggested that it needs to be specific and simple so that it is easy to follow and removes ambiguity. One approach that was suggested was to have a target emission rate, so that if fabric can not be upgraded, other more appropriate measures are provided to achieve comparable energy savings. It was also suggested that the CIBSE Guide to Building Services for Historic Buildings might provide suitable guidance material.
7.60 One suggestion was that greater emphasis needs to be given to improving energy efficiency, and so the emphasis should shift from a presumption of nothing needing to be done, to the provision of evidence that it should not be done. There were many counters to this view relating to the frequent lack of dialogue between the BCB and the Conservation Officer, and the need to clearly define whose opinion should take priority.
7.61 There was recognition of the need for sympathetic treatment of works involving the restoration of the historic character of a building that has been subject to previous inappropriate alteration, or the rebuilding of a former historic building. Nevertheless, it was suggested that the substitution of the phrase “the work should not prejudice the character...” for “provided that the work does not prejudice...” could possibly be interpreted as being less prescriptive and more permissive, leaving greater opportunity for interpretation.
7.62 In the list of buildings to which special considerations apply, the following points were made:
a) Item d) in the list should add “or local development framework”, as these are progressively replacing “local development plans”.
b) The reintroduction and extension of the classes of buildings requiring special consideration included in sections (d) and (e) was especially welcomed, as their omission from the 2006 edition was at odds with national policy on the historic environment. It was pointed out that the text will need to be revised once the Heritage Protection Bill has passed through Parliament. Under section (f), the substitution of “buildings of traditional construction” for “historic buildings” was also welcomed, since it was felt that the type of construction rather than the historic nature of the building should determine what works are appropriate.
c) More could be done to define what buildings should be protected – phrases like “in a conservation area” are much too broad and would therefore include buildings which in themselves warranted no special treatment.
d) With regard to monuments, it was suggested that the differences between scheduling and listing are not always understood, and so it would be useful to include an explanatory note to clarify that any work to a Scheduled Ancient Monument requires consent, irrespective of whether the character or appearance are affected.
e) It was felt that “hard to treat” buildings should also be exempt from the typical assessment process.
……………………
10.34 It was suggested that the guidance on historic and traditional buildings in ADF 2006 is more appropriate than the proposed new guidance for 2010 because it allows for greater discretion. Replacement windows should not lead to a loss of historic character, or conflict with planning or other legislation. Fitting trickle ventilators into replicas of historic windows (e.g. timber sash windows with very slim frame sections) would harm their appearance and character. One respondent suggested that as historic buildings are not as airtight as newer buildings, there is often no need for trickle ventilators anyway. Where further ventilation is considered necessary, the AD should allow alternative measures to be used, such as air bricks. Another respondent added that if windows were openable, trickle ventilators were unnecessary.
………………………..
(And never a truer word)
10.35 Many commented on customer resistance to having trickle ventilators in replacement windows, due to concerns about noise transmission, draughts and increased energy losses. It was suggested that if trickle ventilators were fitted to all replacement windows, in many cases occupants would simply tape over them.
……………………….
10.58
i. Paragraphs 4.38 to 4.39: It is not clear why the guidance on the classes of historic and traditional building requiring special consideration differs from that given in paragraph 3.6 of Approved Document L1B and paragraph 3.9 of Approved Document L2B. Historic and traditional buildings should be treated in the same way in ADF as in the ADLs.
u. Section 7: Some existing buildings need to “breathe”. Buildings in this category, including those of historical importance, should be considered on a case by case basis.
w. Paragraph 7.22: The reference to “character” in relation to historic buildings ignores the additional controls over Scheduled Ancient Monuments. In Wales, advice should always be sought from Cadw at an early stage on any works affecting SAMs.
And on a more general note, from the accompanying document I've taken a selection from the recently published Part L changes.
Apologies for the lack of differentiation between my comments (in brackets) and the text of the document itself, but I'm sure you'll sort it.
>>>>>>>>>>>>>>
8.12 Approved Document F 2006 says that where original windows in dwellings
are fitted with trickle ventilators, replacement windows should have trickle
ventilators (or an equivalent means of ventilation). However where the original
windows are not fitted with trickle ventilators it would be good practice only
to fit trickle ventilators. The Consultation set out the option of requiring the
use of trickle ventilators for all replacement windows in dwellings subject
to ongoing cost benefit analysis supporting such a change. Although many
consultees support the proposals, they also suggest that the costs in the IA
were too low.
………………
(Possible implications for barn conversions in conservation areas?)
Proposed measures to improve compliance
9.4 The policy proposals include a number of measures aimed at improving
compliance with Part L of the Building Regulations and closing the
performance gap described above. These are as follows:
• An Accredited Construction Details (ACD) scheme aimed at ensuring that
developers only claim enhanced benefits in their SAP modelling from using
accredited construction details where these details have actually been used. The
proposed scheme(s) would require developers to register their use of accredited
details in order to receive a unique reference number which they could input
into SAP. The operators of the scheme would validate the thermal performance
of construction joint details and carry out random spot checks on a sample of
developments to ensure that the accredited details were being used in practice.
…………………..
(Yup!)
10.1 Property developers will be directly affected by the policy, since the legal
obligation to comply with the new policy would lie with them.
…………………
10.6 In addition to the higher capital costs of constructing new buildings,
developers may also incur additional administrative costs associated with the
proposed Accredited Construction Details (ACD) scheme(s), the provision of
a design-stage submission to BCBs, an increased sample size for air pressure
testing for Part L and the introduction of airflow measurement for Part F. These
are considered later in this IA.
………………….
10.8 There will be both winners and losers among suppliers to the building industry, since demand is likely to fall for products with lower energy efficiency and rise for products with higher energy efficiency and for LZC products. Overall,
however, the increased capital cost of constructing buildings will mean a larger
market for suppliers in total.
…………………..
11.19 There may be difficulties for the manufacturers of some bespoke products,
such as wooden window frames and doors, in adapting to producing their
products to a higher specification. Particular concern was expressed during
the consultation that the new Regulations would have a serious effect on steel
framed window manufacturers, particularly if demanding specifications were
set for the replacement market. However developers would continue to be
able to choose how to meet energy targets and so would not be prevented
from continuing to use particular bespoke products (assuming products met
the backstop levels of energy efficiency). There will continue to a wide choice
of products and suppliers.
(This seems to ignore the fact that meeting the new energy requirements isn’t a problem where double-glazing is possible in an older building, it’s the need to prove compliance where a detail change would require a new assessment and new accreditation that’s the devil in the lack of detail.)
………………..
11.37 Although there may be some limited effects on the number of suppliers in
the market due to the increased demand for higher specification construction
materials, we do not expect these to be significant. In the vast majority
of cases producers of low specification products will be able to switch to
producing products of a higher specification.
(Which again ignores the COST of proving compliance to a sole-trader workshop making a multitude of different designs to meet the characteristics of the older buildings he’s working on.)
………………..
12.6 Manufacturers of bespoke products (such as a particular type of door or
window frame) may find that they are unable to adapt to producing the
product to meet a higher energy efficiency specification.
(Again, it concentrates on the need to produce a higher-spec product, not the hassle of proving compliance.)
………………..
12.8 During the consultation period we contacted nine associations representing
small firms involved in the construction trade in order to gather the views of
small firms on the effects of the policy (either directly via being put in touch
with trade association members, or through a summary response from the
trade association). It was not feasible to consult formally on the proposals
earlier due to there being insufficient clarity on what the final proposals would
be, although a general industry perspective was obtained through industry
working groups.
12.9 Unfortunately amongst the small firm representatives we contacted there did
not appear to be much awareness/ understanding of the proposed changes to
the regulations, with most small firm representatives describing them as “very
complex” and “difficult to understand”. As a result of this it was difficult to
find representatives with sufficient understanding of the changes as to be able
to share their views.
(Ah well, that explains it away then!)
…………………………………..
1.51 The Historic Housing Association expressed deep disappointment that an association that represents the interests of the nation’s most significant listed buildings was not included in the formal list of organisations to be consulted.
……………………………………
2.30 Some three comments across all groups raised the question of summer ventilation for cooling purposes and expressed some concern that this aspect of ventilation remained unchanged, relying on window opening interventions for purge ventilation when the control of cooling ventilation was likely to become important under future climate scenarios. A small number of comments expressed concern about the impacts of both Parts F and L on works to historic buildings with a general desire to see clearer mechanisms by which the historic issues were taken into account. In the case of Part F concerns related principally to replacement windows and the likely requirement for trickle ventilators.
……………………………………
2.35 Some 113 respondents made comments in addition to answering the headline question. Of these a total of 94 (83%) comments were received from those answering “no”, 13 (12%) from those answering “yes” and 6 (5%) from those registering a “don’t know” response. A content analysis of the comments indicated that approximately 70% of all comments related to either the nature of the building control system (40%) or the adequacy of the building control resource (30%)8. Other comments (usually between one and five) reiterated such things as reducing complexity so as to make it easier to enforce the requirements, improving the quality of design information to ease the burden on building control bodies (BCBs), and strengthening the provisions for historic buildings. In the case of historic buildings the concern was not to prevent improvement but to ensure that provisions were more likely to lead to dialogue with conservation officers than currently. However, it is the two dominant areas that need further analysis and discussion.
……………………………….
4.12
e) Greater education around historic building construction, conservation techniques, and related philosophies. Increased training around the performance and role of traditional building materials.
………………………………
5.78
c. Conflicts between building regulation guidance and planning legislation need to be addressed, especially with regard to historic buildings and conservation areas.
……………………………….
Question 48: Do you agree with the proposal to remove the current exemptions for certain classes of building/building work from the energy efficiency regulations, and to use guidance to demonstrate what is reasonable in each particular
There was strong support across the board for this proposal (139 out of 182 responses). However, as noted below there were a number of strong objections
7.2 There was strong support across the board for this proposal (139 out of 182 responses). However, as noted below there were a number of strong objections from the historic and religious buildings sectors.
…………………………..
7.5 Historic buildings and places of worship: the strongest set of objections to the proposals came from these sectors. The majority stressed that while they were committed to improving energy efficiency where practical and appropriate, they were concerned that removing the exemption would simply result in a significant weakening of the safeguard presently in place to protect historic buildings from unsuitable work. Such work could result in historic fabric no longer being able to “breathe”, with consequent increased risk of deterioration and mould growth. Key points were as follows:
a. A lack of resources would mean that no reference would be made to the detailed guidance and so inappropriate measures would be applied. Some responses accepted that the proposals were appropriate in theory, but felt they were unworkable in practice without a major education campaign to bring BCBs up to speed with the special requirements of historic buildings. Particular concern was expressed over listed buildings and those with Article 4 direction on them, when Building Regulations could require changes to the building without respect for, or reference to the conditions of the listed building consent. It was suggested that there are local authorities where building control officers (BCOs) are routinely consulted on planning issues, but that planners are less frequently consulted on applications under Part L, particularly with regard to unlisted buildings in conservation areas. Consequently, there was a concern that any dilution of the text by removing the explicit reference to “exemption” could lead to confusion among less experienced BCOs and other stakeholder groups. The exemptions send a clear message that the Government values historic and traditional buildings. They do not prevent appropriate energy conservation measures being undertaken, but highlight the need for a balanced approach. The drive for compliance without qualification by the exemptions is likely to result in greater reliance on options with a track record of receiving approval, rather than selection of the most appropriate options for the particular building in question. It was also suggested that there would be benefit in making it clear who has the final say when it comes to improving the energy efficiency of existing buildings – is it the building control officer or the local conservation officer?
b. Another concern was the implications of Regulation 20D on Consequential Improvements in respect of work in historic buildings. It was felt that there was a need for greater clarity on when such improvements would apply to historic buildings.
c. Some responses welcomed the wider definition of historic buildings given in the guidance (e.g. buildings of traditional construction), but felt the existing exemption should remain, leaving the non-exempt buildings included in the wider definition to be covered in the guidance. In contrast, some responses suggested that many buildings in conservation areas have little historic merit, and so the automatic exemption might be inappropriate.
d. Particular concerns were raised by the steel window industry who felt it important to maintain the character of facades where the slim profile of metal windows was a key feature and owners wanted to maintain the aesthetic. As discussed under the responses to Question 67, steel windows cannot meet the WER rating of C, but it was suggested that it was important to allow like-for-like replacement in terms of appearance, while noting that replacement double glazed steel windows offered a 500% improvement over the single glazed originals.
e. With regard to places of worship, it was suggested that the intermittent use and heating of these buildings can cause specific practical problems that are likely to be exacerbated by ill-conceived interventions. As many places of worship are struggling with dwindling and ageing congregations, and a severe lack of income, this often prevents them from being able to commission technical advice and instead, they are forced to rely on local builders or volunteers who may not have experience of working with historic and traditional buildings. As a consequence, it was suggested that a more cautionary approach to places of worship would be appropriate. In contrast, several responses challenged why newly built places of worship or extensions to existing places of worship should be exempt. It was pointed out that most places of worship are exempt from listed buildings control but are subject to statutory denominational controls which should be included in the proposals.
…………………………
7.24 It was pointed out that conservatories are often attached to historic buildings, and the special characteristics of the host building should be taken into account in determining reasonable standards for the conservatory.
…………………………..
7.59 In relation to the guidance itself, it was suggested that it needs to be specific and simple so that it is easy to follow and removes ambiguity. One approach that was suggested was to have a target emission rate, so that if fabric can not be upgraded, other more appropriate measures are provided to achieve comparable energy savings. It was also suggested that the CIBSE Guide to Building Services for Historic Buildings might provide suitable guidance material.
7.60 One suggestion was that greater emphasis needs to be given to improving energy efficiency, and so the emphasis should shift from a presumption of nothing needing to be done, to the provision of evidence that it should not be done. There were many counters to this view relating to the frequent lack of dialogue between the BCB and the Conservation Officer, and the need to clearly define whose opinion should take priority.
7.61 There was recognition of the need for sympathetic treatment of works involving the restoration of the historic character of a building that has been subject to previous inappropriate alteration, or the rebuilding of a former historic building. Nevertheless, it was suggested that the substitution of the phrase “the work should not prejudice the character...” for “provided that the work does not prejudice...” could possibly be interpreted as being less prescriptive and more permissive, leaving greater opportunity for interpretation.
7.62 In the list of buildings to which special considerations apply, the following points were made:
a) Item d) in the list should add “or local development framework”, as these are progressively replacing “local development plans”.
b) The reintroduction and extension of the classes of buildings requiring special consideration included in sections (d) and (e) was especially welcomed, as their omission from the 2006 edition was at odds with national policy on the historic environment. It was pointed out that the text will need to be revised once the Heritage Protection Bill has passed through Parliament. Under section (f), the substitution of “buildings of traditional construction” for “historic buildings” was also welcomed, since it was felt that the type of construction rather than the historic nature of the building should determine what works are appropriate.
c) More could be done to define what buildings should be protected – phrases like “in a conservation area” are much too broad and would therefore include buildings which in themselves warranted no special treatment.
d) With regard to monuments, it was suggested that the differences between scheduling and listing are not always understood, and so it would be useful to include an explanatory note to clarify that any work to a Scheduled Ancient Monument requires consent, irrespective of whether the character or appearance are affected.
e) It was felt that “hard to treat” buildings should also be exempt from the typical assessment process.
……………………
10.34 It was suggested that the guidance on historic and traditional buildings in ADF 2006 is more appropriate than the proposed new guidance for 2010 because it allows for greater discretion. Replacement windows should not lead to a loss of historic character, or conflict with planning or other legislation. Fitting trickle ventilators into replicas of historic windows (e.g. timber sash windows with very slim frame sections) would harm their appearance and character. One respondent suggested that as historic buildings are not as airtight as newer buildings, there is often no need for trickle ventilators anyway. Where further ventilation is considered necessary, the AD should allow alternative measures to be used, such as air bricks. Another respondent added that if windows were openable, trickle ventilators were unnecessary.
………………………..
(And never a truer word)
10.35 Many commented on customer resistance to having trickle ventilators in replacement windows, due to concerns about noise transmission, draughts and increased energy losses. It was suggested that if trickle ventilators were fitted to all replacement windows, in many cases occupants would simply tape over them.
……………………….
10.58
i. Paragraphs 4.38 to 4.39: It is not clear why the guidance on the classes of historic and traditional building requiring special consideration differs from that given in paragraph 3.6 of Approved Document L1B and paragraph 3.9 of Approved Document L2B. Historic and traditional buildings should be treated in the same way in ADF as in the ADLs.
u. Section 7: Some existing buildings need to “breathe”. Buildings in this category, including those of historical importance, should be considered on a case by case basis.
w. Paragraph 7.22: The reference to “character” in relation to historic buildings ignores the additional controls over Scheduled Ancient Monuments. In Wales, advice should always be sought from Cadw at an early stage on any works affecting SAMs.
And on a more general note, from the accompanying document I've taken a selection from the recently published Part L changes.
Apologies for the lack of differentiation between my comments (in brackets) and the text of the document itself, but I'm sure you'll sort it.
>>>>>>>>>>>>>>
8.12 Approved Document F 2006 says that where original windows in dwellings
are fitted with trickle ventilators, replacement windows should have trickle
ventilators (or an equivalent means of ventilation). However where the original
windows are not fitted with trickle ventilators it would be good practice only
to fit trickle ventilators. The Consultation set out the option of requiring the
use of trickle ventilators for all replacement windows in dwellings subject
to ongoing cost benefit analysis supporting such a change. Although many
consultees support the proposals, they also suggest that the costs in the IA
were too low.
………………
(Possible implications for barn conversions in conservation areas?)
Proposed measures to improve compliance
9.4 The policy proposals include a number of measures aimed at improving
compliance with Part L of the Building Regulations and closing the
performance gap described above. These are as follows:
• An Accredited Construction Details (ACD) scheme aimed at ensuring that
developers only claim enhanced benefits in their SAP modelling from using
accredited construction details where these details have actually been used. The
proposed scheme(s) would require developers to register their use of accredited
details in order to receive a unique reference number which they could input
into SAP. The operators of the scheme would validate the thermal performance
of construction joint details and carry out random spot checks on a sample of
developments to ensure that the accredited details were being used in practice.
…………………..
(Yup!)
10.1 Property developers will be directly affected by the policy, since the legal
obligation to comply with the new policy would lie with them.
…………………
10.6 In addition to the higher capital costs of constructing new buildings,
developers may also incur additional administrative costs associated with the
proposed Accredited Construction Details (ACD) scheme(s), the provision of
a design-stage submission to BCBs, an increased sample size for air pressure
testing for Part L and the introduction of airflow measurement for Part F. These
are considered later in this IA.
………………….
10.8 There will be both winners and losers among suppliers to the building industry, since demand is likely to fall for products with lower energy efficiency and rise for products with higher energy efficiency and for LZC products. Overall,
however, the increased capital cost of constructing buildings will mean a larger
market for suppliers in total.
…………………..
11.19 There may be difficulties for the manufacturers of some bespoke products,
such as wooden window frames and doors, in adapting to producing their
products to a higher specification. Particular concern was expressed during
the consultation that the new Regulations would have a serious effect on steel
framed window manufacturers, particularly if demanding specifications were
set for the replacement market. However developers would continue to be
able to choose how to meet energy targets and so would not be prevented
from continuing to use particular bespoke products (assuming products met
the backstop levels of energy efficiency). There will continue to a wide choice
of products and suppliers.
(This seems to ignore the fact that meeting the new energy requirements isn’t a problem where double-glazing is possible in an older building, it’s the need to prove compliance where a detail change would require a new assessment and new accreditation that’s the devil in the lack of detail.)
………………..
11.37 Although there may be some limited effects on the number of suppliers in
the market due to the increased demand for higher specification construction
materials, we do not expect these to be significant. In the vast majority
of cases producers of low specification products will be able to switch to
producing products of a higher specification.
(Which again ignores the COST of proving compliance to a sole-trader workshop making a multitude of different designs to meet the characteristics of the older buildings he’s working on.)
………………..
12.6 Manufacturers of bespoke products (such as a particular type of door or
window frame) may find that they are unable to adapt to producing the
product to meet a higher energy efficiency specification.
(Again, it concentrates on the need to produce a higher-spec product, not the hassle of proving compliance.)
………………..
12.8 During the consultation period we contacted nine associations representing
small firms involved in the construction trade in order to gather the views of
small firms on the effects of the policy (either directly via being put in touch
with trade association members, or through a summary response from the
trade association). It was not feasible to consult formally on the proposals
earlier due to there being insufficient clarity on what the final proposals would
be, although a general industry perspective was obtained through industry
working groups.
12.9 Unfortunately amongst the small firm representatives we contacted there did
not appear to be much awareness/ understanding of the proposed changes to
the regulations, with most small firm representatives describing them as “very
complex” and “difficult to understand”. As a result of this it was difficult to
find representatives with sufficient understanding of the changes as to be able
to share their views.
(Ah well, that explains it away then!)