BEAMA, alongside several other trade bodies, has written to the Secretary of State for Levelling Up, Housing, and Communities, Michael Gove MP, to seek ministerial intervention on key areas of the Future Homes Standards (FHS) and Home Energy Model (HEM) consultations, following a series of conversations with the Department for Levelling Up & Housing Communities and the Department of Energy Security & Net Zero.
The signatories represent a cross-section of trade associations covering manufacturers who supply the key net zero enabling technologies which allow new homes to decarbonise heat, use energy responsibly and supply domestic EV charging capabilities. As such, they are strong supporters of the general policy direction which will electrify future homes and move to a more accurate, open-source model for compliance assessments. However, they have aligned to collectively raise two fundamental shared concerns which require the Government’s direct intervention, in advance of the three consultations closing on the 27 March.
- The Home Energy Model does not allow for informed understanding of the specification impact of the Future Homes Standard.
There are significant limitations within the current HEM FHS Assessment Tool which makes accurate, trustworthy modelling of the two proposed notional build options for new dwellings impossible to undertake. Without this modelling, the trade bodies say that they cannot ensure that specification choice remains within the market to allow for the potential application of a range of zero-carbon ready and affordable whole building heat strategies. They say that the performance requirements within Part L of the Building Regulations must protect specification flexibility and it must be ensured that the Government publishes alternative compliant specifications beyond air source heat pumps and heat networks.
- The trade bodies are concerned about the lack of formal consultation plans for key changes to the Product Characteristics Database (PCDB) and SAP Appendix Q.
There is currently no detail within the HEM consultations on the future process for PCDB integration and the process by which the model will recognise new technologies. The current PCDB has been developed through many years of investment by hundreds of manufacturers. The missing detail on these future processes and the formal consultations on these details with industry undermines confidence in the HEM.
As an industry, the trade bodies are calling for Government intervention to ensure that no finalising decisions are made on the performance requirements of new build homes without accurate modelling capability, and that the future process for the PCDB and adding new technologies into the Home Energy Model will be transparent and include future industry consultation.
Yselkla Farmer, CEO of BEAMA, says, “The Future Homes Standard and the Homes Energy Model and associated wrapper will be crucial for decarbonising homes, as well as key indicators for UK supply chain investment in this sector. It is therefore essential we get this right or risk undermining a supply chain that the UK needs to deliver net zero and future energy security.
“Time and resources must be allowed within the Government process to get this right and we do have concerns over the validity of the current consultation process. This letter is intended to elevate this consideration and ensure Government are fully aware of the significance of this decision – if we get this wrong, we risk limiting UK technology innovation and market delivery. This is business critical for us and we are putting fundamental resources into helping Government with this process and ensuring industry have their input.”
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