The Northern Ireland Assembly is running a public consultation on Part F of the Northern Ireland Building Regulations. This affects how well buildings are insulated and the cost of heating them. The consultation closes on 19th December 2021.
Part F of the Northern Ireland building regulations relates to how well we insulate our buildings. Currently Northern Ireland falls behind the rest of the UK and Ireland in these standards and whilst the Department of Finance proposes to uplift them, we believe that they do not go nearly far enough. The consequence is that if we continue to build poorly insulated homes, there will be a greater rise in fuel poverty. Doing ‘the bare minimum’ in terms of an uplift in standards means that buildings will constantly require upgrading to meet the standards needed in a climate emergency. The Department of Finance should be taking the opportunity to help families and businesses with rising energy costs by ensuring all new and refurbished buildings are insulated to the highest standard.
Please see below for ways you can support this campaign to ask for better building regulations, including our letter to the NI Finance Minister, voicing our concerns with the proposals. Your contribution is incredibly important, given the IPCC’s recommendations that global emissions need to be halved by 2030, while the UK is expected to miss its 2025 and 2030 decarbonisation targets. The consequences of climate change in Northern Ireland and globally will be catastrophic for human life and come at great financial cost.
Here's how you can find out more
Read and sign our open letter to the NI Finance Minister
Respond to the public consultation
Write to your MP / MLA / Local Councillor
Share these on social media with a link to this page using the hashtag #InsulateNI
We have written to Northern Ireland Minister of Finance Conor Murphy MLA to voice our concerns.
As the minister responsible for administering the Building Regulations, it's really important that we hold the Finance Minister to account over any changes that are proposed or enacted. The Building Regulations are one of the key legislative drivers for change in the industry, and if we are to respond adequately to the climate and ecological emergency then changes to the Building Regulations are of paramount importance. Reviews of the regulations do not come around frequently, so it is crucial that this is done in a way that will enable us to mitigate catastrophic climate change and tackle fuel poverty now.
We urge you to sign our open letter below.
Conor Murphy MLA
Department of Finance
303 Airport Road
Belfast, BT3 9ED
Dear Finance Minister,
We are writing to you regarding your department's current consultation on the proposed uplift to Part F of the Building Regulations. With almost 15% of all carbon equivalent emissions in Northern Ireland a result of energy used in our homes an update to these regulations is critical.
As a group of independent professionals working in the construction industry, we are concerned about how far these proposals go. We feel that they need to be significantly more onerous in the context of the climate and ecological emergency, and do not go far enough in supporting Northern Ireland to reduce its carbon emissions.
With rising energy costs many in our society are facing the choice between heating and eating, the Department of Finance has a responsibility to ensure buildings are insulated well enough so as to eliminate fuel poverty. The Department of Finance should be taking the opportunity to help families and businesses with rising energy costs by ensuring all new and refurbished buildings are very well insulated.
Our five main areas of concern with the proposed uplift are as follows.
1) The uplift should not be based on percentage based improvements. It should instead comprise a comprehensive and clear reworking of the regulations based on current data and calculation methodologies. The use of percentage increases over regulations that are unchanged in their detail since 2012, and based on out of date performance criteria, will result in buildings which do not provide the levels of thermal performance necessary.
2) Existing buildings should not be forgotten in this uplift. The omission of updates to limiting factors for existing buildings - including new extensions - means they can continue to be constructed to poor thermal standards. Furthermore the lack of requirement to upgrade any existing fabric when extending an existing dwelling continues to store up problems for the immediate future.
3) Fabric performance requirements should be more onerous. The proposals for fabric performance requirements are welcomed however they could be greatly improved, reducing the energy use of all new buildings designed to net zero.
4) This consultation should also cover Part K (Ventilation) in tandem. Elements covered in this consultation will impact on compliance with areas covered in other Technical Guidance Documents, such as Part K - Ventilation, and vice versa. These areas should be addressed in tandem to see meaningful progress on the efficiency of buildings.
5) Embodied Carbon. The carbon footprint of construction, known as embodied carbon, accounts for 11% of global emissions and can account for around 70% of a building’s emissions in its lifetime. The new Part F should therefore also include Embodied Carbon. Otherwise the department should set out a clear and immediate time frame for introducing new Embodied Carbon Building regulations in line with Part Z proposals in England.
Whilst we welcome the consultation, the scale of destruction globally caused by the climate crisis is shocking in its speed and severity, and our response must be proportionate. We urgently require far reaching changes to the regulatory landscape, and we urge you to reconsider the current proposals laid out for this uplift to Part F.
Architects Climate Action Network Northern Ireland
(Our full response to the consulation will be attached)
Kerry Watton, Tonn Architecture / ACAN NI
Ben James, University of Ulster / ACAN NI
Ivor Hession, tóg architecture / ACAN NI
Andrew Abraham, Architect / ACAN NI
Jessica Scott, I&E / ACAN NI
Christopher Fleming, Barrister (self-employed)
Rachel Woods MLA, Green Party NI
Vicky Black, Western Health & Social Care Trust
Francesca Di Palo, Sustainable NI
Emma Campbell, Queen's University Belfast
Rosie Le Garsmeur, National Museums Northern Ireland
Ross Kirker, Caruso St John Architects
Megan Coe, Arco2 Architecture
Deborah Phillips, Phillips Chartered Architect
Thomas Bennett, Studio Bark / ACAN UK
Rachael Owens, Buckley Gray Yeoman
Bobby Jewell, ACAN UK
Mhairi Grante, Paper Igloo Ltd
Taleen Josefsson, ACAN UK
Chiarraí Gallagher, Gallagher Architectural Practice
Flavien Mercier, Architects for Future
Lorna Cummins, Student
Niall Patrick Walsh, BDP / Architect / shareyourgreendesign / ACAN NI
Nuala Mc Closkey
Caoimhe Donaghy, WHSCT
Janna Laan Lomas, Grain Architecture
Cllr Barry McKee, Green Party NI, Belfast City Council
Simon Peter Lee, Lisburn and Castlereagh City Council
Mal Ohara, Green Party
Lauren Kendall, Green Party NI
Toby Osbourn, Tosbourn Ltd
Marc Tuitt, Natureworks Design
Eugenia Mompó, Grand Bequest
Debbie Mauger, ASBP
Emily Norman, ACAN UK
Carol Totten, NI Resident
James Allister, Environmental Activist
Sara Edmonds, Studio seARCH
Colin McClelland, Managh Beg Mushrooms
Shane Birney, Shane Birney Architects
Misha Bellinger, Antin
Michelle Wooderson, Cancer focus
Aoife Mcgee, MMAS
Brendan Roberts, Design ID Consulting Ltd
Emily Harris, Donald Insall Associates
Amy Service, Isherwood + Elis Architects
Ryan Ward, Architect
Dan Hyde, Everything is User Experience
Lauren Shevills, Studio Bark / ACAN UK
Joe Penn, Rock Townsend Architects
Cassidy Wingrove, FCBStudios
Gracious Muzamhindo, FCBStudios
Geoff Rich, FCBStudios
Kastytis Donauskis, FCBStudios
Joe Jack Williams, FCBStudios
Diego Crehuet, FCBStudios
Ersnt ter Horst
Cormac Maguire, FCBStudios
Joya Zaman, FCBStudios
Andy Macintosh, FCBStudios
Sophie McCombes, FCBStudios
Patrick Hoban, FCBStudios
Filipa Oliveira, Architect / ACAN UK / ACAN PT
Sam Tyler, FCBStudios
Anagha Rangarajan Narasimha, Queen's University Belfast
Rita Farrell, Darren Oldfield Architects
Stephen Gallagher, FCBStudios
Eve Choy, ACAN UK
James Rixon, Rixon Architecture
Anja Van der Watt, TU Delft
George Brazier, The Bartlett School of Architecture
Michael Dowds, Isherwood + Ellis Architects
Jennifer Harper, Isherwood + Ellis Architects
Karen Lewing, Green Party
Tom Dollard, Pollard Thomas Edwards
William Flint, Flint Architecture
Patrick Folkes, Graphenstone Paints
Joe Giddings, The Alliance for Sustainable Building Products
Stephanie Crombie, ACAN Natural Materials
Tom Gwilliam, Etude
Anna Bardos, Max Fordham / University of Sheffield
Joanne Stewart, AECOM Architecture
Oisín Higgins, University College Dublin
Alasdair Ben Dixon, Collective Works, ACAN UK
Martin McCrae, Paper Igloo Architecture
Andrew Wardrope, FCBStudios
Alan Little, FCBStudios
Aurore Baulier, Atelier Baulier
Stuart Pavitt, Sheppard Robson
Diane Skidmore, Fuel Poverty Action
Etienne Marès, ACAN UK
Charles Robert Reid
Roddy Evans, ACAN UK
Cllr Áine Groogan, Green Party
Clara Bagel George, Elementa Consulting
Ben Weir, Artist
Lara Magee, Queen's University Belfast
Rowena Creagh, University of Liverpool
Iva Stanisheva, Arney Fender Katsalidis
ACAN is a network of individuals within architecture and related built environment professions taking action to address the twin crises of climate and ecological breakdown.
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