Rig for Regs, Set Course for Outcomes

The housing sector is bracing for a wave of regulatory change. In just a few years:

• The Warm Homes Plan (the Optimised Retrofit Programme in Wales) is funding delivery, around £15 billion over five years in England, against a bill to bring social homes up to standard variously put at £36 billion to over £100 billion depending on fabric, maintenance and condition assumptions.
• Social housing Minimum Energy Efficiency Standards (MEES) require Energy Performance Certificate (EPC) band "C" by 2030 in England. Wales pursues the same EPC "C" for each home through the Welsh Housing Quality Standard 2023 and its Target Energy Pathways, with EPC "A" the long-term aim, though the detail is under review.
• EPC reform turns the single rating into three metrics and a cost figure (fabric, heating and smart readiness, plus an estimated running cost few expect to be used as a real target), while the Standard Assessment Procedure (SAP) behind it gives way to the Home Energy Model (HEM) from the second half of 2027, swapping twelve monthly averages for a half-hourly simulation across the year.
• The Social Housing (Regulation) Act 2023 (Awaab's Law) widens its reach year on year.

An experienced sailor does not fight the wind. They rig for whatever conditions they face and keep the destination in view, where a less experienced one gets blown wherever the weather takes them. Chasing each new target keeps you permanently reacting, because a home optimised for yesterday's benchmark can score quite differently under tomorrow's without a single brick moving; I argue instead for anchoring to a few durable outcomes that let you navigate with confidence.

Rig for the conditions you face. Set your course by the outcomes that matter.

Three outcomes worth anchoring to

Build the strategy around three things that stay meaningful whoever is in power: an affordable home, a comfortable and healthy one, and a decarbonised, energy secure one. All three are measured in the home, in use, not modelled at design stage.

The figure comes from the definition of fuel poverty, spending more than ten per cent of income on energy, applied to a real resident. With one in four of a household working a 35-hour week at the adult National Minimum Wage, the family takes home about £1,680 a month; ten per cent of that, shared across the four-person household, is roughly [£42] per person for heating and hot water. Occupancy comes from the government's Bedroom Standard, meaning it's a ‘design’ number, not a requirement to monitor people. Each landlord should set the [£42] per person per month to suit its own residents.

The energy can be read in kWh from the smart meter, ideally behind a split consumer unit that separates regulated energy (heating, hot water, lighting) from the rest (appliances, cooking, car charging), so you hold the retrofit to the part it can move. Convert energy to bill using a forecast Ofgem domestic tariff cost cap. There's a role for the National Energy System Operator (NESO) here, but in the interim a landlord can model this out for the next decade or more to allow for the long timeframe work of home improvement: we clearly need the goal posts not to move every three months.

Again, a landlord can set their own bars, as they know their residents. They might want a higher floor, [20°C], for homes with more vulnerable residents. And getting ventilation right means knowing how many people a home is built for, the Bedroom Standard's other important use, which we cover in a companion post on designing out damp and mould.

Measuring this in the home is cheap now: three devices sensing temperature, humidity and carbon dioxide across the living space, main and smallest bedroom likely cost under £400 to buy, still modest against a single damp and mould callout. The cost that can mount up is the recurring one: the connectivity and platform that store and read the data, running for as long as you monitor. New solutions giving one data connection hub per home, rather than many devices each with its own mobile bill, are the way to rationalise that (but that's a whole other blog!).

Anchor on the carbon or on security of supply, whichever your organisation cares about more; the home you build is the same. It matters because it aligns with the Greenhouse Gas Protocol⁵: a home's total emissions, from both ‘regulated’ and ‘unregulated’ energy, fall into the landlord's Scope 3 reporting. Building Regulations cover only the ‘regulated’ part, though HEM will report it better than SAP for the new EPCs. Even so, measuring from the meter is the most robust way.

As with cost, the target needs a forward view, so that today's decisions are judged against the future grid a home will meet, not the one it starts on. NESO is the natural body to publish that forecast, but until it does, a landlord (or a group of them) can make sensible forecasts of its own. Wales' Optimised Retrofit programme modelled exactly this some years ago.

From measuring outcomes to contracting for them

There is a step beyond measuring these outcomes, which is to contract for them. At Cosmeston Farm in the Vale of Glamorgan, the United Kingdom's largest housebuilder has agreed to deliver homes whose net zero carbon performance is verified in operation, with reasonable and measurable resident activity included, and real accountability for the outcome itself rather than a prediction made at design stage. As far as we know it is a first, and it sets a precedent worth borrowing for retrofit. There is more in our Cosmeston Farm write-up.

The same idea transfers cleanly. A landlord agrees the outcomes it wants, affordability, comfort and carbon, each as a measurable target, and contracts a turnkey provider to hit them. Performance is monitored for at least three years, with a real incentive on the contractor tied to the measured results. Sensible provisions cover maintenance, and evidence-based allowances cover resident behaviour and unusual weather where they genuinely move the numbers. Success is judged by what the homes deliver in use, not by what a certificate predicted the day the scaffolding came down.

Why this matters now

The organisations that come through this in the strongest position will be the ones that stayed clear about their real purpose: warm, healthy homes that people can afford to live in. That purpose does not move when the methodology does, and it happens to be where the economics point too. At a national scale the cheaper route to lower carbon runs more through cleaning up the grid than through wringing the last drop of fabric performance out of every home, a point we make in Retrofit and the Middle Ground.

Rig for the conditions. Set course for the outcomes. The rest follows.

References

1. BS EN 16798-1: Energy performance of buildings. Ventilation for buildings.
2. Approved Document O (Overheating); CIBSE Technical Memorandum 59 (TM59), Design methodology for the assessment of overheating risk in homes.
3. Approved Document F (Ventilation), including Table B3.
4. CIBSE guidance on indoor carbon dioxide concentrations as a marker of ventilation adequacy.
5. Greenhouse Gas Protocol: Corporate Value Chain (Scope 3) Accounting and Reporting Standard.