The Future Homes Standard consultation - Passivhaus Trust response

“The Passivhaus Trust is disappointed with the proposals being put forward for the Future Homes Standard. We believe that what is being proposed is a missed opportunity to address fuel poverty and the climate crisis, and will not deliver what we would consider to be a 'Future Home':

• Neither of the Options proposed offers a meaningful improvement on current fabric standards. There are only some very minor improvements to U-values based on the notional building compared to Part L 2021. We believe that there should be an option 3 in the consultation which allows better building fabric performance, to improve occupant comfort, reduce energy bills, and reduce demand on the grid during winter. We would propose that the Passivhaus standard - with electric heating - should be considered as option 3 and should be accepted as “Deemed to Satisfy” the Future Homes Standard.
• Both options in the consultation require a move to a heat-pump-based heating system. This is to be applauded as an important step towards decarbonising our domestic heating supply. However, on its own, this move will not reduce energy bills or improve occupant comfort. Whilst the heat pump may deliver some of the efficiencies, electricity is still around three times the cost of gas. Option 2 in the FHS proposals would still have hot water and heating costs of £1220 per year. Is this really the best that we can expect of a 'Future Home'?
• We are also not convinced by the proposed approach to deal with the performance gap within the standard. If new homes are not certain to achieve the expected levels of energy efficiency, and could require between 40 and 200% more energy for heating than expected, then there could easily be examples of 'Future Homes' that are cold, costly to heat, and detrimental to the health of the inhabitants. 

Instead, the UK Government should consider developing a “Passivhaus equivalent” standard, like their bolder counterparts in Scotland. This would ensure that homes are warm in winter, cool in summer, have fresh indoor air and low heating bills. Surely that is the minimum we should expect from a 'Future Home'?"

Jon Bootland, CEO, Passivhaus Trust