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, we 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, we have aligned to collectively raise two fundamental shared concerns which require Government’s direct intervention, in advance of the three consultations closing on the 27th March.
1. 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, we cannot ensure 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. We must ensure the performance requirements within Part L of the Building Regulations protects specification flexibility and that Government publishes alternative compliant specifications beyond air source heat pumps and heat networks.
2. We 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, we 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, chief executive BEAMA, said:“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 need to deliver Net Zero and future energy security.
Time and resource 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.”
Charlotte Lee, chief executive of the Heat Pump Association added: “Whilst we are fully supportive of the proposal to introduce the Future Homes Standard to support a Net Zero future, and update SAP, we call on the Government to continue to engage with industry as the Home Energy Model is adjusted to help ensure it is fit for purpose, well ahead of the introduction of the Future Homes Standard. The industry also requires certainty on the planned changes to the Product Characteristic Database and request a decision is made and communicated to industry swiftly. These steps are vital to the success of the transition and will provide the industry with confidence and time to understand the implications of the changes.’
Stewart Clements, director of HWA & HHIC, commented: The development and introduction of the Future Homes Standard and a new Home Energy Model is extremely important to driving forward reductions in carbon emissions and addressing energy bills for consumers in New Homes, and is therefore essential that these standards and tools are fit for purpose and that government has engaged thoroughly with industry experts to ensure they are realistic and achievable, and not forgetting the HEM will be further amended in the near future of existing properties, so the impact and need to get this right could not be more significant.