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Review of the Future Homes Standard Review of the Future Homes Standard June 2021 Disclaimer This report (Report) was prepared by Ernst & Young LLP for the Independent Networks Association using information provided by the Independent Networks Association, interviews with representatives from industry participants and publicly available data. Ernst & Young LLP does not accept or assume any responsibility in respect of the Report to any readers of the Report (Third Parties), other than the Independent Networks Association. To the fullest extent permitted by Scott Fotheringham law, Ernst & Young LLP will accept no liability in respect of Director the Report to any Third Parties. Should any Third Parties Strategy and Transactions — choose to rely on the Report, then they do so at their Energy Sector own risk. M: +44 7384 908 425 Ernst & Young LLP has not been instructed by its client, E: [email protected] the Independent Networks Association, to respond to queries or requests for information from any Third Party and Ernst & Young LLP shall not respond to such queries or requests for information. Further Ernst & Young LLP is Tim Bunnell not instructed by the Independent Networks Association Partner to update the Report for subsequent events or additional Strategy and Transactions — work (if any) performed by Ernst & Young LLP. Accordingly, Energy Sector without prejudice to the generality of the foregoing, Ernst & Young LLP accepts no responsibility to any Third M: +44 7824 897 141 Party to update the Report for such matters. E: [email protected] Ernst & Young LLP reserves all rights in the Report. Contents Executive summary 2 1. Introduction 12 1.1 Background 15 1.2 Purpose of this report 15 1.3 Structure of this report 16 2. Future Homes Standard 18 2.1 Building Regulations (change to Part L and F for new homes) 19 2.2 Overview of relevant Government policies and their interaction 23 3. Low-carbon technologies 28 3.1 Hydrogen 29 3.2 Review of alternative heat options 33 3.3 Conclusions 41 4. Impacts on energy sector and supply chain 42 4.1 Quantitative and qualitative review of the impact on the consumer and energy industry participants 43 4.2 Review of the considerations for the electricity and gas networks 51 4.3 Review of the impact of the transition period 58 5. Our recommendations 60 Appendix A Glossary 62 Appendix B List of interviews 64 Appendix C Background and basis of the Future Homes Standard consultation 66 Appendix D Gas transition projects 70 Appendix E Hydrogen policies 71 Appendix F Hydrogen generation implications and costs 72 2 | Review of the Future Homes Standard Executive summary economic recovery.05 The report also considers Purpose of this document the implications of the Future Homes Standard on This report explores the issues highlighted by the wider exploitation of alternative decarbonising the Future Homes Standard01 and the resultant heat technologies, the use of hydrogen in the gas changes to the Building Regulations, specifically network, as well as the transition to the Future the impact of the prohibition of the installation of Homes Standard and the implications for house gas boilers in new homes from 2025. builders and and energy network providers. This Future Homes Standard review is in the Methods employed in context of other related Government policies which have objectives such as, (i) reducing carbon drafting the report emissions from homes as a contribution to the Climate Change Committee’s recommendation This report undertakes a high level qualitative and to target a 78% reduction in carbon emission by quantitative review of the Future Homes Standard 2035,02 (ii) improving housing affordability,03 and the other relevant Government policies. (iii) levelling up economic performance across The analysis also draws upon the information the UK04 and (iv) COVID-19 pandemic related collected during interviews with a selection of stakeholders.06 01 Ministry of Housing, Communities & Local Government, ‘The Future Homes Standard: 2019 Consultation on changes to Part L (conservation of fuel and power and Part F (Ventilation) of the Building Regulations for new dwellings- Summary of responses received and Government response’ (Jan 2021) 02 https://www.gov.uk/government/news/uk-enshrines-new-target-in-law-to-slash-emissions-by-78-by-2035 03 HM Treasury, Autumn Budget 2017 (November 2017 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/ attachment_data/file/661583/autumn_budget_2017_print.pdf 04 HM Treasury, ‘Levelling Up Fund: prospectus’ (3 March 2021): https://www.gov.uk/government/publications/levelling-up-fund-prospectus 05 HM Treasury, ‘A Plan for Jobs’ (8 July 2020) https://www.gov.uk/government/publications/a-plan-for-jobs-documents/a-plan-for-jobs-2020 06 The list of the interviews held as part of the study is provided in Appendix B. Review of the Future Homes Standard | 3 Our key findings The Future Homes Need for an Standard sets a pathway impact assessment to zero carbon homes Ahead of implementing policies, there is a general expectation that Government departments will Heating and powering homes accounts for undertake an impact assessment,10 which is an approximately 22% of the UK’s greenhouse gas analysis used to inform policy decision-making by emissions,07 therefore reducing their carbon using cost-benefit and other analysis tools to build emissions is essential to meeting net-zero targets. a robust evidence base.11 The Future Homes Standard sets out enhanced building fabric specifications, as well as heating Neither the Government response to the and ventilation requirements (the so called ‘fabric consultation on the Future Homes Standard or plus’ option),08 the combination of which are the original consultation12 were accompanied expected to reduce emissions from domestic by a departmental analysis of its impact.13 It is premises by some 75% to 80%, starting with a stated that the impact assessment on the Future 31% reduction in 2021, compared to current Homes Standard will be based on the full technical standards.09 consultation planned for spring 2023.14 Therefore, decisions could be taken by Government and We recognise therefore that the Future Homes industry participants prior to the impact analysis Standard makes an important contribution to the being made available which could negatively overall reduction in carbon emissions. influence the transition to, or implementation of, the Future Homes Standard. 07 Op.cit 1 Section 1.2 pg. 7 08 Ibid — Table 2 Pg. 18 09 Ibid — Section 3.3 Pg. 27 10 Department for Business, Energy & Industrial Strategy (2020), Better Regulation Framework Interim Guide https://assets.publishing.service.gov. uk/government/uploads/system/uploads/attachment_data/file/916918/better-regulation-guidance.pdf 11 Ibid. p. 11 12 Ministry of Housing, Communities & Local Government (2019), The Future Homes Standard: 2019 Consultation on changes to Part L (conservation of fuel and power) and Part F (ventilation) of the Building Regulation for new dwellings https://assets.publishing.service.gov.uk/ government/uploads/system/uploads/attachment_data/file/852605/Future_Houses_Standard_2019_Consultation.pdf 13 MHCLG did publish an impact assessment alongside its consultation in 2019, but the impact assessment focused on updates to the standards for new houses in 2021 and did not cover setting the standard for new houses such that they cannot be built with fossil fuel heating from 2025 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/836925/REQUEST.pdf 14 Ministry of Housing, Communities & Local Government, ‘The Future Homes Standard — 2019 Consultation on changes to Part L (conservation of fuel and power) and Part F (ventilation) of the Building Regulations for new dwellings: Impact Assessment’ (Jan 2021) p.5 4 | Review of the Future Homes Standard Interviewees have expressed The UK heat pump supply chain concerns about the transition will need to ramp up rapidly to timetable for the Future support the target of 300,000 Homes Standard new homes per year The Government's response to the Future Homes Standard Only a few tens of thousands of heat pumps are currently consultation in January 2021, sets what is clearly a 'fabric installed annually, compared to the annual boiler installations plus technology' policy,15 that is to say it seeks to both of approximately 1.67mn16 (mostly gas and oil17 across increase the insulation standards of homes to reduce overall the 24.4mn dwellings in England at 31 March 2019).18 energy demand and mandate low-carbon heating. The Government target to build 300,000 new homes per year by 2025 would significantly increase this install level. It should be noted that a further consultation on the exact Additionally, the Government has a target of 600,000 heat nature of the building’s fabric specification for compliance pump installations in total per year by 2028 (which includes with the Future Homes Standard is not due until the spring the 300,000 heat pumps for new homes).19 of 2023, thus the specification will not be available to house builders until late 2023 or early 2024. This means that the Currently there is limited domestic heat pump manufacturing exact ‘recipe’ for the fabric of new houses may not be known capacity, with most heat pumps produced in Asia.20 Of the until close to the current implementation date for the Future just under 33,600 heat pumps installed in the UK in 2019, Homes Standard in 2025. 22,753 were imported and only 10,830 were manufactured in the UK.21 Thus to meet the 300,000 or the 600,000 Therefore, putting in place a robust supply chain (UK annual installation target with UK manufactured heat pumps, manufacturing of heat pumps, component supply and there will have to be a significant increase in capacity if the qualified installers) in the period between confirmation of the UK is to avoid relying on global manufacturing capacity.
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