Background material F, 40% House Project

BUILT FABRIC & BUILDING REGULATIONS

Background material F
40% House project
Gavin Killip, Environmental Change Institute
University of Oxford
March 2005
1. INTRODUCTION
Building control was first recorded in the time of King Herod who introduced a law, which
stated that:
should a man construct a building which falls down and kills another then this man should
be slain.
Shortly after the Great Fire of London in 1666, the 1667 London Building Act aimed to
achieve some degree of fire resistance in buildings. Many local Acts followed in the
expanding towns, which meant that standards varied and were specific to local areas. The
1875 Public Health Act aimed to introduce some consistency to the regulations and
propelled a series of local byelaws. In 1936 a single model series of controls regarding the
construction and condition of buildings was introduced, along with British Standards.
However, this was optional not compulsory. The first mandatory Building Regulations that
had to be enforced by local authorities were introduced in 1966, which were revised in
1972 and then again in 1976.
The 1985 Building Regulations were the first to include the modern system of Building
Control (revised in 2000). Under the 1984 Building Act provision was made for future
changes to technical specifications using a system of Approved Documents (England &
Wales) and Technical Standards (Scotland and Northern Ireland). This system allows for
regular revision of the design standards without the need for primary legislation to amend
the Act.
Building regulations were first concerned with the safety of a buildings structure and its
resistance to fire, but the range of issues covered by the building regulations has
expanded considerably since the Great Fire of London (table 1).
The 40% House project is primarily concerned with energy conservation in dwellings, but
the other technical requirements of the regulations are clearly important too. Building
design for energy efficiency needs to pay particular attention to the requirements for sound
insulation and ventilation: the choice of materials and construction techniques needs to
achieve a harmonious whole, with energy conservation an important consideration, but not
a goal to be sought at the expense of nuisance from noise or inadequate fresh air.
Some buildings are exempt from the building regulations: small extensions and
conservatories, agricultural buildings, small detached buildings not used for sleeping,
buildings housing machinery but not used as a workplace (except for inspection and
maintenance), buildings for keeping animals, temporary buildings.

Background material F, 40% House Project

Approved Documents (England & Wales)

Structure
Fire Safety
Site preparation & resistance to moisture
Toxic substances
Resistance to the passage of sound
Ventilation
Hygiene
Drainage & waste disposal
Combustion appliances & fuel storage systems
Protection from falling, collision & impact
Conservation of fuel & power in dwellings
Conservation of fuel & power in buildings other than dwellings
Access & facilities for disabled people
Glazing safety in relation to impact, opening & cleaning
Fixed Electrical Installations in Dwellings
AD to support reg 7: Materials & workmanship

Part
A
B
C
D
E
F
G
H
J
K
L1
L2
M
N
P

Technical Standards (Scotland)

General (definitions, references, regulations, schedules)
Fitness of materials and workmanship
Structure
Structural fire precautions
Means of escape from fire, facilities for fire-fighting and means of warning of fire
Combustion appliance installations and Storage of liquid and gaseous fuels
Preparation of sites, Resistance to moisture and Resistance to condensation
Resistance to transmission of sound
Conservation of fuel and power
Ventilation of buildings
Drainage, Sanitary facilities
Electrical installations and Aids to assist the hard of hearing
Miscellaneous hazards
Access and Facilities for dwellings
Storage of waste
Access to and movement within buildings, and protective barriers

Part
A
B
C
D
E
F
G
H
J
K
M
N
P
Q
R
S

Technical Standards (Northern Ireland)

Interpretation and general
Materials and workmanship
Preparation of site and resistance to moisture
Structure
Fire safety
Conservation of fuel and power
Sound insulation of dwellings
Stairs, ramps, guarding and protection from impact
Solid waste in buildings
Ventilation
Heat-producing appliances and liquefied petroleum gas installations
Drainage
Sanitary appliances and unvented hot water storage systems
Access and facilities for disabled people
Glazing

Part
A
B
C
D
E
F
G
H
J
K
L
N
P
R
V

Table 1 Approved Documents and Technical Standards for building regulations in

the UK (source: ODPM, Scottish Executive, HMSO websites)

Background material F, 40% House Project

2. BUILDING REGULATIONS AND THE CONSERVATION OF FUEL AND POWER
The regulations relating to the conservation of fuel and power in dwellings have been regularly
revised. The most recent amendments came into force on 1 April 2002, and there is another
revision due to be finalised in 2005.

Heat is lost from buildings through the fabric of the building itself (roof, walls, floor,
windows and doors) and through infiltration of cold air via any holes and gaps. Fabric heat
loss can be slowed down with insulation materials, the performance of which is a function
of the material used, its thickness, and a number of other factors to do with how well the
insulation is installed: gaps in insulation quickly compromise performance, for example.
Ventilation heat loss can only be reduced by minimising infiltration of cold air: construction
needs to be airtight, with controlled ventilation supplying adequate fresh air, possibly with a
heat recovery system to reduce the heat loss even further. Airtight construction requires
good design and close attention to detail during construction. As insulation standards have
improved in the UK for new construction, the issue of ventilation heat loss has become
relatively more significant (ODPM 2004a).
The efficiency of heating systems also has a major influence on the amount of delivered
energy required to provide adequate warmth.
2.1 Fabric heat loss

Building regulations deal with design standards for fabric heat loss, and have historically
set minimum insulation levels in terms of elemental U values. Each element of the building
envelope (roof, wall, floor, window, door) is assigned a maximum heat loss rate. The unit
of measurement, Watts per square metre Kelvin (W/m2K), is an expression of how quickly
energy passes through a square metre of the element for a given temperature drop
between inside and out (the Kelvin scale is quoted conventionally, but the temperature
difference is practically measured in degrees Celsius). The aim is to slow down the rate of
heat loss, which means a lower U value. Tables 2 - 5 summarise the changes in elemental
U values in the building regulations from 1985 2002.
Max U-value (W/m2K)

Element
Exposed walls
Exposed floors
Ground floors
Roofs
Semi-exposed walls and floors

0.45
0.25
0.6

Table 2: Maximum U-values in 1985 Building Regulations (England and Wales)

Element

SAP 60 or
less
0.2
0.45
0.35
0.6
3.0

Roofs
Exposed walls
Exposed floors and ground floors
Semi-exposed walls and floors
Windows, doors and rooflights

SAP over
60
0.25
0.45
0.45
0.6
3.3

Table 3: Maximum U-values in 1991 Building Regulations (England and Wales)

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Element
Pitched roof with insulation between rafters
Pitched roof with integral insulation
Pitched roof with insulation between joists
Flat roof
Walls, including basement walls
Floors, including ground and basement floors
Windows, doors and rooflights (area-weighted average),
glazing in metal frames
Windows, doors and rooflights, glazing in wood/PVC frames

U-value
0.2
0.25
0.16
0.25
0.35
0.25
2.2
2.0

Table 4: Maximum U-values in 2000 Building Regulations (England and Wales)

Element
Pitched roof with insulation between rafters
Pitched roof with insulation between joists
Flat roof
Walls, including basement walls
Floors, including ground and basement floors
Windows, doors and rooflights (area-weighted average),
glazing in metal frames
Windows, doors and rooflights, glazing in wood/PVC frames

A*
0.2
0.16
0.25
0.30
0.25
2.2

B*
0.18
0.16
0.22
0.27
0.22
2.0

2.0

1.8

Table 5: Maximum U-values in 2002 Building Regulations (Scotland)

*Column A refers to a building with a heating system boiler efficiency above a certain standard.
Column B applies to all other dwellings.
It is clear from these tables that standards have both become more detailed (U-values
specified for an increasing number of building elements) and more stringent since 1985. Tables
4 and 5 also show that Scottish regulations in 2002 required lower elemental U-values for walls
than the equivalent regulations in England and Wales.

2.2 Changing methods of compliance

Regulations of the conservation of fuel and power have historically concentrated on the thermal
insulation of the building fabric, specifying design standards for different building elements
(wall, roof, floor etc). These standards were initially set in terms of elemental U values,
stipulating a maximum rate of heat loss for each element. In the 1990s new methods of
compliance were introduced:
The Elemental method treats each element of the built fabric separately as in the tables
above. This is suitable for alterations and extension work, and for new building when the aim is
to minimise calculations. New editions of building regulations can for example, change
maximum wall U-values without altering the standards for roofs.
The Target U-value method sets a requirement for the average U-value of the dwelling, which
can be achieved through any combination of insulation levels of individual elements and areas
of windows, doors and rooflights. It also takes into account the effect of the heating system and
solar gains. The target is derived from a calculation involving total floor area, total area of
exposed elements (fabric exposed externally to outside air), proportion of window area facing
south and efficiency of heating system. This target value is changed in new editions of the
building regulations through altering the coefficients in the calculation.

Background material F, 40% House Project

Although this method is still specifically referred to in Scotland, the revised 2002 England and
Wales regulations have tried to simplify the situation. Rather than having a separate method,
the Elemental method now includes a higher degree of flexibility. A dwelling will meet the
requirements if its rate of heat loss does not exceed that from a notional building of the same
size and shape that meets the criteria of the Elemental method.
The Carbon Index method allows yet greater flexibility still. The Building Regulations
requirement is met if the CI for the dwelling is above 8.0 (2000 Regs).
2.3 Trade-offs
The Target U value and CI methods allow designers and developers a certain amount of
flexibility, with some trading off of performance in one part of the construction on condition that
it be counter-balanced elsewhere. This has led to some undesirable outcomes, notably the
relaxation of thermal performance for walls to be compensated for by the provision of smaller
windows. This was attractive to developers because it reduced overall costs, but it created
homes with low levels of natural daylight and a consequent energy penalty for higher levels of
electric light.
Similar anomalies arose where a long-lived feature (the building fabric) was down-graded in
exchange for an improvement in a short-lived feature (the heating system). Compliance could
even hang on water heating tariffs, which bear no relation to energy, carbon or the long-term
sustainability of the building (Bell & Lowe 2000).
The relaxation of thermal standards for walls and floors is particularly regrettable, as these are
elements of a building which are practically difficult to upgrade later (AECB 2003). By allowing
the thermal performance of walls or floors to be down-graded in a trade-off with another
building element means that those buildings will under-perform for many years to come.

3. COMPLIANCE
3.1 Design versus performance
Relatively little is known about the performance of homes built to the design standards as
set out in the Building Regulations. Anecdotal evidence suggests that workmanship on UK
construction sites is poor, that buildings lose more heat in practice than in theory, and that
the construction industry is ill-equipped to deliver airtight buildings. These conclusions are
supported by a study on construction practices (Olivier 2001), one on building heat loss in
real life (Doran 2000) and one on airtightness testing (EST 2004).
A key weakness of the Building Regulations is its continued reliance on design standards.
Pressure testing of new construction is now required on some commercial buildings and
may be required for a percentage of homes in the 2005 revision. It is hoped that this will
not only lead to improved airtightness, but to a general increase in quality generally.
Building airtight buildings requires accurate, thorough methods and so, the theory goes, an
airtight building is likely to have been built accurately and well. This theory has yet to be
proven.
3.2 Thermal bridging
Insulation materials are rarely continuous throughout a building element. Heat loss is
increased where structural materials bridge the insulation. Thermal bridging is of 3 broad
types (Lowe and Bell 2000):

Background material F, 40% House Project

Repeating thermal bridge

Non-repeating thermal bridge

Geometrical thermal bridge

Structural elements that interrupt the insulation at regular

intervals, eg ceiling joists in an insulated loft; timber
framing studs in an insulated timber frame; mortar in a
lightweight block wall
Structural elements that interrupt the insulation at one
point, eg steel or concrete lintels above doors or windows
Two- or three-dimensional junctions (even where
insulation is continuous) resulting in divergent heat flows,
eg where the roof meets a wall or corner made by 2
external walls

Table 6 Classification of thermal bridging. (adapted from Lowe and Bell 2000).
Building Regulations first addressed repeating thermal bridges in 1990. However, the
percentage of structure in real buildings often exceeds the notional amount in the
standard, say by having timbers at narrower spacings than in the design, so that the
fraction of timber in a wall is increased, and the fraction of insulation is decreased. This
leads to an under-estimate of the real effect of thermal bridging and an over-optimistic
standard. Non-repeating and geometrical thermal bridges are still not addressed by the
building regulations. (Lowe and Bell 2000).
3.3 Delta U values
In Sweden the discrepancy between design standards and performance standards was
addressed by over-tightening the design standards. This pragmatic approach does not set
out to make unrealistic expectations in the real world: instead, it compensates for realworld shortcomings by making the design standards tighter. It was found that performance
is typically 20% below the design standard, thus allowing the design U value to be
adjusted in order to deliver the level of performance that was originally intended (Doran
2000).
The implications of such a system are slightly increased costs of materials for housebuilders, and slightly thicker walls. More research is needed on the energy performance of
buildings in use in order to inform policy and help develop new approaches to the current
problems of lack of compliance.
3.4 Airtightness
Ventilation heat loss has become increasingly important as steps have been taken to
reduce fabric heat loss with each revision of the building regulations. In an old home with
no insulation, the amount of heat lost directly through the fabric is appreciably higher than
the heat lost through the uncontrolled exchange of warm air for cold air. In a home built to
the 2002 standard, the opposite is true: the fabric insulation is of such a standard that the
ventilation heat losses predominate.
The recommended rate of air exchange is between 0.5 and 1.0 air changes per hour,
providing adequate fresh air for human health, for safe combustion of fuels and to prevent
damage to the building fabric from excess moisture in the air (EST 2003).
Where buildings achieve greater airtightness, ventilation needs to be provided by an
appropriate ventilation strategy, either making use of the stack effect to draw stale air out,

Background material F, 40% House Project

or through mechanical aids, such as fans. The energy used in fans can be off-set if the
heat in the exhaust air is recovered, allowing incoming air to be pre-warmed.
3.5 Enforcement
There is a shortage of building control inspectors in the UK (RICS 2004) to deal with the
current level of building work. Any increase in rates of construction will make the problem
worse unless additional building control officers can be recruited to (and retained by) the
profession.
Partly in recognition of the shortage of building control officers, new self-certification
schemes have started, where installers authorise their own work. The FENSA
(Fenestration Self-Assessment) scheme is run by the Glass and Glazing Federation for
windows, with FENSA-registered installers able to issue their own certificates. Local
authority officers giving evidence to the House of Commons Environmental Audit
Committee reported varying degrees of satisfaction with the scheme, giving some cause
for concern that certified work was sometimes not of sufficient quality (EAC 2005).
4. TOWARDS A ZERO SPACE HEATING GOLD STANDARD
4.1 Building Regulations and the EU
Table 7 compares Building Regulations in England and Wales, Denmark and The Netherlands.
These countries are chosen because of the broad similarities in climate. Data on Sweden is
included as it is presently the best EU standard. The standards required in Denmark are much
higher than England and Wales and were also issued over 4 years before. As a result of these
regulations a detached house built to the latest standards in England and Wales consumes
nearly 20% more energy than an equivalent home in Denmark.

Country

Roof

Walls

Floors

Windows

E&W
Denmark
Netherlands
Sweden

0.16-0.25
0.1-0.2
0.2-0.4
0.1-0.2

0.35
0.2-0.3
0.2-0.3
0.1-0.2

0.25
0.1-0.2
0.2-0.3
0.1-0.2

2.2-2.0
1-1.5
1.5-2.5
1-1.5

Area Weighted
Average
0.31
0.24
0.33
0.19

Table 7: The elemental U-value requirements for new build under four EU countrys
Regulations (EST, 2002)

4.2 Super-insulation standards for UK homes

Modern UK homes perform better than old ones (for which there were no thermal
performance standards at all), but the standards in the 2002 Building Regulations still fall
short of the best available practice using todays technology. BedZED and the Hockerton
Housing Project are two examples of recent new housing schemes with zero net space
heating demand. In addition, a number of theoretical standards have been proposed,
including the Energy Efficiency Best Practice for Housing advanced standard and the
Association for Environment Conscious Buildings gold standard (table 2).

Background material F, 40% House Project

Elemental U
value

BedZED
0.10
0.11
0.10
1.2

EEBPH
advanced
standard
0.15
0.08
0.10
1.5

Proposed
AECB gold
standard
0.15
0.15
0.15
0.8

Building
Regulations
2002 part L1
0.35
0.16-0.25
0.25
2.0-2.2

Walls
Roofs
Floors
Windows, doors
Airtightness
Air changes/hour

2.0 @ 50 Pa

0.75 @ 50 Pa

Table 8 Comparison of 3 superinsulation standards with 2002 building regulations

part L [Sources: Twinn 2003, EST 2002, Olivier 2004, ODPM 2002]
The energy consumption of developments such as BedZED and Hockerton is very low by
conventional standards due to careful design to maximise useful solar gains, combined
with an envelope of insulation about 300 mm thick in the walls, roofs and floors. From table
2 it can be seen that the 2002 Building regulations part L1 comes close to this standard for
roofs, but not elsewhere. As mentioned above, the amount of insulation put in floors and
walls during construction is particularly important, as retro-fitting extra material at a later
date is practically very difficult.
The AECB gold standard has lower levels of insulation in the walls, roofs and floors, but
comparatively high standards for windows and a very stringent test for airtightness.
The point of this discussion is not to argue which of these gold standards is the best, but
rather to underline the general principle that they all capture: with a thick layer of insulation
in the building fabric (including high-performance windows and doors) and attention to
airtightness, it is possible with existing technology to build homes with zero or close to zero
space heating demand.
5. EXTENDING COVERAGE OF PART L1
5.1 Recent history
Whole-window replacements (ie frame and glazing, not just replacement panes of glass)
came under the control of Building Regulations in 2002. From April 2005 replacement
boilers will have to meet a minimum efficiency standard, effectively making condensing
boilers mandatory.
5.2 Future coverage
5.2.1 Major refurbishments
A key time to consider energy efficiency improvements is when other building works are
being planned. The marginal cost and disruption of energy efficiency measures can be
small when they are combined with other activities. For example, if a timber floor is being
taken up for repair or replacement, this is an ideal opportunity to install floor insulation (and
seal the floor to prevent draughts) before the boards are re-laid.
Revisions to part L for 2005 include a proposal to extend the scope of part L to major
refurbishment works. Above a threshold amount (possibly of the order of 8,000), an extra
10% on top of the original budget would have to be spent on energy efficiency
improvements (King, pers comm.)

Background material F, 40% House Project

Government-backed advice and grants programmes support cost-effective measures,
while more costly and disruptive works are only promoted to an audience of housing and
energy specialists in the form of Energy Efficiency Best Practice guides.
5.2.2 Low- and Zero-Carbon technologies
Article 5 of the EU Energy Performance of Buildings Directive requires new developments
above a certain size to demonstrate that consideration has been given at the design stage
to the inclusion of low and zero carbon energy systems within the development, including
sources of renewable energy and combined heat and power (CHP).
Demonstrating that consideration his been given to LZC will not necessarily lead to LZC
being taken up. This provision of the Directive is relatively weak compared with the
innovative use of Planning law in some local authority areas, where consent for large
developments is subject to a percentage of energy coming from local renewables. Policy
guidance from central government supported the lead taken by forward-thinking local
authorities in a Planning Policy Statement in August 2004 (PPS 22), stating that:
Local planning authorities may include policies in local development documents
that require a percentage of the energy to be used in new residential, commercial
or industrial developments to come from on-site renewable energy developments
(ODPM 2004b)
This requirement for on-site renewables effectively motivates developers to achieve
greater levels of energy efficiency: for as long as the renewable energy technology is more
expensive than the energy efficiency measures, it makes financial sense to reduce
demand first and therefore reduce the cost of the percentage from renewables.
5.2.3 Lights and appliances
Although space heating dominates residential energy consumption at the moment, the
trend is for space heating to fall. The fastest-growing area of new demand is from lights
and appliances, notably from consumer electronics. In a possible future world where all
homes are super-insulated and airtight, the single largest component of residential energy
consumption could easily be from electricity for lights and appliances. Can and should
building regulations cover the energy from non-fixed items such as fridges, TVs and lights?
The success of the Market Transformation approach to increasing the energy efficiency of
white goods in the 1990s has shown that the entire stock of available appliances can be
improved over the normal life-cycle of the appliance.
6. CONCLUSIONS
Building regulations have become tighter with every revision, but are still some way short
of the zero or ultra-low space heating standards characterised by BedZED. Compliance is
still a key issue, with the performance of new buildings regularly failing to meet design
standards.
The confusion of compliance methods during the 1990s led to many anomalies, with
different building designs all of which were compliant showing wide variations in energy
performance and carbon emissions. The focus in recent years has turned back to
insulation and carbon emissions, which is to be welcomed, as the trading off of heating
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Background material F, 40% House Project

system performance for fabric insulation gave rise to poorer quality in the very elements
that are hardest to upgrade later, and which have the longest life expectancy. If nothing
else, the story of how energy efficiency was covered in the building regulations in the
1990s underlines the prime importance of measures to reduce heat loss, as the building
fabric tends to be more long-lived and harder to adapt retrospectively than the heating
system.
References
AECB (2003) 2005 review of Part L of the building regulations, consultation response,
Association for Environment-Conscious Building http://www.aecb.net/PDFs/part_L.pdf
Bell M and Lowe R (2000) Building Regulation and sustainable housing. Part 2: technical
issues Structural Survey 18 (2), 2000, 77 88, MCB University Press

Doran S (2000) Field investigations of the thermal performance of construction elements

as built BRE client report 78132 for DETR (report ref 36/8/79 cc 1637), November 2000
(revised June 2001), BRE, East Kilbride http://projects.bre.co.uk/uvalues/U-values.pdf
DTI (2003) Our energy future creating a low carbon economy. Energy White Paper, London.

EAC (2005) Housing: building a sustainable future, House of Commons Environmental

Audit Committee first report of session 2004-2005, vol 1, HC 135-I, The Stationery Office
EST (2002) Energy efficiency standards for new and existing dwellings,
General Information Leaflet 72, Energy Efficiency Best Practice for Housing, Energy
Saving Trust, September 2002
http://www.est.org.uk/bestpractice/uploads/publications/pdfs/GIL072.pdf
EST (2003) Energy efficient refurbishment of existing housing Energy Efficiency Good Practice
guide 155, Energy Saving Trust, January 2003, available from
http://www.feta.co.uk/downloads/GPG155.pdf

EST (2004) Assessment of energy efficiency impact of Building Regulations compliance.

BRE client report 219683, November 2004, Energy Saving Trust
http://www.est.org.uk/partnership/uploads/documents/Houses_airtightness_report_Oct_04.
pdf
King E (pers comm.) Ted King, ODPM, meeting 11.11.04
Lowe R and Bell M (2000) Building Regulation and sustainable housing. Part 1: a critique of
Part L of the Building Regulations 1995 for England and Wales Structural Survey 18 (1), 2000,
28 37, MCB University Press
Lowe R and Bell M (2001) A Trial of Dwelling Energy Performance Standards for 2008:
Prototype standards for energy and ventilation performance, Leeds Metropolitan University.
Putting Climate Change at the Heart of Energy Policy, EST submission to the energy white
paper, 2002.

HMSO website
http://www.northernireland-legislation.hmso.gov.uk/sr/sr2000/20000389.htm
Scottish Executive website
http://www.scotland.gov.uk/build_regs/

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ODPM website
http://www.odpm.gov.uk/stellent/groups/odpm_buildreg/documents/page/odpm_breg_6092
57.pdf
ODPM (2002) Building Regulations Approved Document L1
http://www.odpm.gov.uk/stellent/groups/odpm_buildreg/documents/page/odpm_breg_02957701.hcsp

ODPM (2004a) Proposed amendment of Approved Document F of the building regulations:

Ventilation October 2004
http://www.odpm.gov.uk/stellent/groups/odpm_buildreg/documents/page/odpm_breg_0301
65-04.hcsp
ODPM (2004b) Planning Policy Statement 22: Renewable Energy, Office of the Deputy Prime
Minister, August 2004, available at
http://www.odpm.gov.uk/stellent/groups/odpm_planning/documents/source/odpm_plan_source
_030334.doc

Olivier D (2001) Building in ignorance. Demolishing complacency: improving the energy

performance of 21st century homes. Association for the Conservation of Energy/Energy
Efficiency Advice Services for Oxfordshire http://www.ukace.org/pubs/reportfo/BuildIgn.pdf
Olivier (2004) The proposed AECB energy standards for new buildings, unpublished
presentation to the Association for Environment-Conscious Building conference, Weald
and Downland Museum, West Sussex, 10 July 2004
RICS (2004) News release 25 November 2004, Royal Institute of Chartered Surveyors
http://www.rics.org/Careerseducationandtraining/RICSaccreditationandcertificationschemes/En
ergyperformanceofbuildings/Energy%20Performance%20of%20Buildings%20Directive.html
Twinn C (2003) BedZED Arup Journal 1/2003
http://www.arup.com/DOWNLOADBANK/download68.pdf

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