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Ready for Action?

15 January 2006

Clear advice on the changes to Parts L and F is hard to find, and as Frank Booty reports from the CIBSE/ODPM conference on the subject, there is confusion and complexity where there should be action and joined-up Government

PARTS L AND F OF THE BUILDING REGULATIONS GOVERN the energy efficiency and ventilation in buildings, respectively, and are designed to help prevent further environmental damage caused by carbon dioxide emissions. The changes affecting all building designers, owners and operators, come into effect in April 2006 and the CIBSE and ODPM conference on the subject held in late November was a key event in the build up to this deadline.

The ministerial keynote, originally to be given by Yvette Cooper MP, Minister for housing and planning, was replaced with one by Anne Hemming, head of buildings division, ODPM. "We're here to save the planet," she said. "Parts L and F are a small part of how to save the planet and certainly not a waste of time. Part L represents the UK's implementation of the EU's Energy Performance in Buildings Directive (EPBD). We spend 90 per cent of our time in buildings whose use is responsible for 40 per cent of carbon emissions. New buildings represent about 1 per cent of building stock per year and 66 per cent of the stock that'll be around in 2050 has already been built.

"This legislation is not easy - it is the most complicated building regulation. Why is the Government producing something so complex and difficult? It is being driven there by the EPBD. Across Europe this is a key issue - some countries are ahead of us in its implementation, others are behind. We know how critical this is, and like it or not, it has to be implemented quickly."

Notwithstanding that point, there were many mutterings around the conference and in the many networking gatherings that "we'll never meet the deadline", "where will we find the engineers to do the necessary compliance testing, let alone train them", "where's the money coming from" and "this is so damned confusing."

Nevertheless, Ted King of ODPM Buildings Division, when asked whether the Government would be ready to implement the regulations in April simply said, "Yes." He stressed that since an announcement in September, the revised Parts L and F were regulatory requirements and not guidance.

Key elements to the revised Part L are:
... Maximum carbon dioxide emissions for whole buildings using the software tools SAP (standard assessment protocol - used for dwellings) and SBEM (the simplified calculation procedure for buildings that are non-dwellings) or accredited commercial software
... Limits on design flexibility
... Limits for summer solar gains in non airconditioned buildings
... Encouragement of the use of low and zero carbon (LZC) systems
... More attention paid to 'as built' performance

He recognised that “With self-certification and testing, we need more approved persons and competence schemes. Part L also makes mandatory testing to ATTMA Air Permeability Measurement and proper commissioning to CIBSE Code M. And it also requires information in the form of CIBSE TM 31 Energy Log Book.”

The legal requirements in Part F, King explained, are unchanged. “The Regulation gives guidance on the purpose of ventilation and explains strategy in extract, whole building and purge ventilation. There’s guidance for offices and car parks – and the minimum ventilation rate for offices has increased from 8 to 10 litres/sec/person (with reference to CIBSE AM10: Natural Ventilation and AM 13: Mixed Mode Ventilation).”

There was advice for anyone with a project already in progress, ODPM is reviewing with lawyers how to limit the impact of the new Directives. But, in a nutshell, the amendment will not apply if you have full plans approval, if you have conditional approvals that do not relate to Part L and/or if you have started on site.

According to King, by the end of 2005, the Government should have issued a second statement on EPBD articles 7 to 10, given a consultation on the sustainable building code and handled a preliminary exam of Part L competent persons’ scheme candidates. By April it expects, amongst other things, to have laid statutory instruments, published an e-learning package and maybe consulted on the existing building stock – “one way or another.”

It was left to Phil Jones, Chairman of CIBSE’s Energy Performance Group, to bring some reality to the conference participants. He lauded the 28 per cent improvement in carbon emissions from buildings to date but continued, “We need clear, sensible mechanisms not only to implement Part L, but to go beyond it. Part L is a minimum standard – we need a gold standard, and a register of low carbon consultants.”

He reported that CIBSE is working with ODPM – with contributions of £150,000 from the Carbon Trust and £70,000 from CIBSE – to establish a Competent Person Scheme to support compliance with Part L of the Building Regulations. The scheme will improve the level of performance in building design and operation by creating and promoting a new elite register of people able to carry out low carbon design and operation. Those on the register will be able to claim an expectation on the part of building control officers that they have provided plans which fully meet the provisions of Part L – and they will be able to sign off their work and the work of others as meeting the regulations. The register will cover the areas of signing off plans under Part L 2005; signing off completed buildings under Part L 2002; asset ratings; and operational ratings, including CIBSE TM22 Building Log Books

“This is aimed at all building professionals – not just CIBSE – so that includes RIBA, RICS, BIFM, etc,” said Jones. “The key driver is to attract people onto the register. The timescale runs through 2006 – January to March for developing training materials, April to November for workshops, and marketing. We will work out minimum qualification requirements and a prequalification system, training and pre-training, the exam, registration, annual carbon returns based on consultants’ projects to provide feedback, and quality checks on the system.”

Training is likely to cover what’s in Part L and EPBD, the use of SBEM, how to go beyond Part L and a formal system for appraising Part L not just related to construction but addressing the certificate of sale or rent of the building and its operational rating. Note that operational ratings are not in Part L which is design-oriented but they should be fully adopted for the existing building stock.

The benefits for these competent persons include a green badge of achievement, recognition by building control officers and under the EPBD, improved status through accreditation and extra responsibility. Next comes the development of a training register and the exam, marketing the register. It’s hoped training may have started by the time this article appears. There’s more information at

This was a much-needed event, with everyone agreeing it was worthwhile, despite many anguished delegates wondering about financial implications and timescales. The overarching phrase that hung silently in the air was Hemming’s bald statement that, quite simply, “We’re here to save the planet”. Even if you are quite confused, you can’t argue with that. Can you?

CIBSE Part L and F Conference was held on 8-9 November 2005 in London. All the presentations from the conference can be viewed as a webcast on Click on Events.

MORE INFO performance figures/faq.cfm

● Frank Booty is a freelance writer

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