New build heat standard consultation: part II

RICS agrees that net-zero carbon emissions should be mandated for all new buildings as soon as possible and supports the requirement to ensure zero direct emissions heating (ZDEH). However, such fundamental reform will inevitably lead to unintended consequences that will require mitigation:

• Delivery: The skills, resources, and cost required to meet new building requirements could impact on housing delivery targets.

• Cost: Effort must be made to drive down the cost of electricity, including decoupling from gas prices.

• Consumer knowledge: Poor understanding of how to operate modern buildings as efficiently as possible.

• Building performance: Potential for overheating and damp if systems not operated correctly.

As set out in the consultation document, bioenergy should be viewed as the last feasible alternative source of heating. Further research is needed on where bioenergy can be applied most efficiently to reduce emissions, potentially in the delivery of new rural developments where other technologies are not feasible. We therefore support the formation of the Bioenergy Policy Working Group and would welcome the opportunity to feed into this work stream.

RICS supports the staged introduction of trigger points to mandate the provision of ZDEH. Maximising the opportunity of disruptive works to install new systems is therefore a reasonable approach.

However, to avoid negatively impacting respective consumers, efforts must be made to communicate the need for greater energy efficiency measures to be installed prior to the installation of a ZDEH system. Similarly, the archetype of the building must be taken into account, and the feasibility of existing ZDEH solutions in the specific circumstance, i.e., multiple occupancy or tenement buildings

• Technical feasibility: The energy demand of the building must be sufficiently low to be met with NDH systems, and the heating delivery units must be suitable for NDEH, Both conditions can be achieved in most buildings by improving the energy-efficiency of the fabric and replacing heat delivery units.

• Reasonable cost and availability of funding, including the cost of buying and installing the ZDEH system (this should not be significantly higher than market average, to be considered “reasonable”) and the cost of improving energy efficiency and replacing heating delivery units, if needed. The capital cost should ultimately be justified against the realistic payback time, recognising that there will likely be some operational maintenance costs with the system that will need to be factored into this calculation also.

• Depending on whether the ZDEH system or associated energy efficiency measures are reliant on common works that require consent of other occupants.

• Beyond reasonable cost and no available external financing support options.

Buildings that require an alternative energy source to be available at all times in case of emergency may require the continued use of DEH systems, such as hospitals.

Such issues could be exacerbated by buildings in remote locations where ZDEH systems are not technically suitable.