Building regulations must mandate insulation protection to ensure homes are fit for the future

The government’s consultation on the Future Homes and Buildings Standard is a significant opportunity to ensure all new homes built from 2025 produce up to 80% less carbon emissions than currently, and for the UK to reach net zero by 2050. 

The proposed new Standard complements further amendments to Part F and Part L of the Building Regulations and aims to decarbonise new homes by improving heating and hot water systems and reducing heat waste – supporting an overall drive for homes that are better for the environment and future-ready. Once legislation is passed (planned for 2025), all new homes must be built according to the Standard. 

Neither the importance of this change nor the context can be overstated. It is widely accepted that the UK has the oldest and least energy-efficient housing in Europe. For example, 25% of a home’s heat is typically lost through an uninsulated roof, yet 8 million lofts in the UK have less than half the required levels of insulation. 

The main specifications of the Standard go a long way to address some of these challenges and are appropriately ambitious. However, despite the Standard’s positive intentions, there remain some critical considerations that require urgent government attention.

Protecting loft insulation is one such consideration, which is missing from both the specifications and the revised Building Regulations that must be included if zero-carbon homes are to be delivered. This is because increasing the uptake of insulation alone will not be sufficient as it becomes less effective if it is not protected. The government’s Domestic National Energy Efficiency Data-Framework (NEED) indicates that loft insulation loses 10% of its effectiveness after just 5 years. 

Moreover, consumer surveys show that the vast majority, around 80% of homeowners with lofts, will use their lofts for storage, with many using more than half the floor area. Consequently, these homeowners are compressing a significant proportion of their insulation, and this is materially affecting the actual U-value and thermal performance of their homes. Scientific testing by the National Physical Laboratory has shown that compression of loft insulation reduces its thermal resistance by at least 50%, resulting in higher energy use and bills. 

The government has the opportunity through its consultation to make the much-required reforms to ensure all new homes are zero-carbon ready. It could do this by strengthening Part L of the draft Building Regulations to mandate the protection of loft insulation. This needs to be strengthened both to protect against damage to insulation from the very widespread case of lofts being used for storage and to ensure safe access walkways for maintenance. 

Simply boarding insulation as the current draft plans suggest is insufficient as it will still result in the compression of insulation and will cause a thermal bridge to be created. The wording of Part L therefore must require that a raised platform be built above the insulation to ensure it is not compressed and made from materials that do not cause a thermal cold bridge or conduct heat, such as timber. 

For maintenance access, it should become mandatory that raised boarded access walkways and working platforms be provided to all mechanical and electrical equipment placed in a loft space. This is already a requirement in the HSE’s Construction and Design Management Regulations 2015, but not always implemented in reality. 

Without the Standard and Building Regulations mandating insulation protection, the expected carbon savings and energy cost reductions will simply not be realised. For consumers, this will mean the energy efficiency properties of their loft insulation will degrade over time and roof U-values will be diminished forcing them to pay to reinsulate their loft spaces at some point. 

If we are on the cusp of building modern homes genuinely fit for the future that limit environmental impacts, then the Standard and the Building Regulations must recognise the critical role that loft insulation protection plays in energy efficiency, reducing bills and achieving net zero

www.nwhc.org.uk

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