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By Raffaele De Angelis. HLMGreenbuild

The building regulatory system in UK for dwellings.

For the definition of the current research, a reference must be given to the official method
used in UK for the assessment of dwelling performance.
Currently dwellings performance is calculated and assessed uniquely via a standardised
procedure which was first developed in 1992 by BRE, the Building Research Establishment
for the former Department of the Environment in 1992, as a tool to help deliver its energy
efficiency policies. The SAP methodology is based on the BRE Domestic Energy Model
(BREDEM), which provides a framework for calculating the energy consumption of

The Standard Assessment Procedure (SAP) is the methodology used by the Government
to assess and compare the energy and environmental performance of dwellings. Its purpose
is to provide accurate and reliable assessments of dwelling energy performances that are
needed to underpin energy and environmental policy initiatives.

Typically, compliance and performance assessment are performed by the definition of a

common set of assumptions in order to enable benchmarking. Homogeneous conditions
permit a comparison between dwellings. SAP works by assessing how much energy a
dwelling will consume, when delivering a defined level of comfort and service provision. The
assessment is based on standardised assumptions for occupancy and behaviour. This
enables a like-for-like comparison of dwelling performance. Related factors, such as fuel
costs and emissions of carbon dioxide (CO2), can be determined from the assessment.

SAP quantifies a dwellings performance in terms of: energy use per unit floor area, a fuel-
cost-based energy efficiency rating (the SAP Rating) and emissions of CO2 (the
Environmental Impact Rating). These indicators of performance are based on estimates of
annual energy consumption for the provision of space heating, domestic hot water, lighting
and ventilation. Other SAP outputs include estimate of appliance energy use, the potential
for overheating in summer and the resultant cooling load.

The calculation is based on the energy balance taking into account a range of factors that
contribute to energy efficiency:
materials used for construction of the dwelling
thermal insulation of the building fabric
air leakage ventilation characteristics of the dwelling, and ventilation equipment
efficiency and control of the heating system(s)
solar gains through openings of the dwelling
the fuel used to provide space and water heating, ventilation and lighting
energy for space cooling, if applicable
renewable energy technologies
Steady State and Dynamic Simulation Modelling
A Steady State simulation does not consider the effects of time. It assumes that the system
has reached steady operating conditions. The single effect of each aspect in the system is
calculated separately and then summed with the other aspects to form the total effect of the
system. In our case the effects that are being explored are all related to energy and fuel
consumption and their associated CO2 emissions.
A Dynamic simulation does consider the effects of time. It assumes that the system is in a
state of change and transfers information between sub-systems at given time steps and
through this process it considers their interaction.

Passivhaus is a steady state procedure based on the same principles as BREDEM. The
difference is in the detail of the information used in the model definition and in the stricter
assumptions and conditions defined. The Passivhaus defines a number of assumptions
which are imposing some design conditions meant to guarantee performance. The strength
of the Passivhaus procedure is in the strict definition of a number of parameters to be
respected in the dwelling specification to guarantee a consistent outcome with the calculated
results. In other words, PHPP overcomes the uncertainties residing in the steady state
calculation by imposing higher specifications and reducing the freedom of the design options
in regards to the fabric u-values, the percentage of glazing, ventilation and systems
efficiency. Through this strategy, Passivhaus schemes can guarantee performance without
having to deal with a more complex dynamic calculation and this is one of the reasons for
its popularity. The restrictions, on the other hand, represent also the weakness of the
procedure, as design freedom is severely limited and the specification level can be rather

Dynamic Simulation Modelling

Dynamic Simulation Modelling (DSM) is a calculation procedure that uses a more accurate
description of the building geometry details of construction materials, HVAC design
strategies (including renewables), solar gain, occupancy data and hourly (or even sub-
hourly) weather data to enable the performance of the building to be modelled for a wide
range of purposes, from design development through to Building Regulations compliance.
The performance of the building can be quantified in a number of different ways, including
energy consumption, peak summer time temperatures and the adequacy of passive
engineering solutions, such as thermal mass, solar shading and natural ventilation. DSM
packages therefore offer a way of assessing how a building might perform and the impact
of making modifications to the design all through the design process. The model can be
used to monitor compliance with the Building Regulations and fine-tune the scheme as a
whole. DSM packages therefore have many advantages as a design tool over compliance
only steady state software such as iSBEM which can only usefully assess compliance with
the Building Regulations and are not appropriate as a design tool. However, DSM packages
should be used appropriately and with caution, particularly where automated control of
systems is assumed. As with any model using weather data and anticipated occupant
behaviour, a DSM package is not able to provide a guarantee of future performance, but
instead can be used to compare alternative designs and/or other buildings on a regulated,
like for like basis. For building design purposes, a number of packages can be used.
However, where the packages need also to provide Building Regulations compliance, only
accredited software can be used. The Building Energy Calculation Software Approval
Scheme defines and maintain a list of approved DSM software for compliance calculation.
(Andy Hutton, Carbon Bite, CIBSE, Feb 2012)
Compliance and operational building: the performance gap.
The performance gap in buildings defines the difference between the predicted energy
demand and the actual operational demand. Its been a widely discussed issue in the
building industry and numerous initiatives have been put in place in order to explore
strategies to close the gap. The Zero Carbon Hub has been leading the research on the
subject in regards to the residential sector producing extensive documentation on the
subject. The analysis of the factors causing the performance gap is not in our scope; we will
refer to the outcome of the research as our main reference, including its different
conclusions. The performance gap is still a controversial matter open to debate, very much
related to what is discussed in the present paper. In order to address these relationship, we
will briefly review the Compliance and the Operational scenarios.

Compliance scenario.
Compliance consists in a procedure defined by the Government based on a benchmarking
principle with the objective of a) verify that a given minimum performance is met by the
building and b) provide a mean of comparing and thus measuring different buildings. Even
though only the same type of buildings are comparable, e.g. school with school, dwelling
with dwelling, there may still be differences that do not allow for a direct comparison.
Therefore, similar types of buildings, preserving their geometry, are tested by assigning
homogenous operational parameters, that is occupancy, equipment, setpoints, etc. This is
one of factors causing the performance gap: with the exception of geometry, compliance is
verified against a fictional building that does not correspond to the actual building. Therefore,
the operational building is different from the compliance building by definition. Ideally
dwellings represent a special case because the variations in the occupancy patterns can be
negligible. In fact, the domestic requirements and habits can be considered relatively steady
across the population and, even though differences will always exist, the compliance
exercise can be regarded as not that far from the real building in operation.

Operational scenario
By modelling realistic parameters of the building occupancy, accurate predictions on the
operational performance can be provided. This should be particularly true for the residential
sector where the assumptions used for compliance are generally coinciding with the

The Zero Carbon Hub research produced a number of recommendations in order to close
the gap. A few of these address directly the Government and are the following:

In its conclusion the ZCH research defined eight priority actions for the Industry and the
Government. As a priority action for Industry, there is a call to undertake R&D to create
innovative testing, measurement and assessment techniques and develop commercially
viable methodologies for demonstrating performance and in the priority actions for
government there is a recommendation to revise the energy modelling practices:
The governments compliance tool, known as SAP (Standard Assessment Procedure),
plays an increasing role as developments progress through the detailed design stage. A
review of existing research indicates that the core building physics of SAP may be broadly
sound but further work is required on the inputs and assumptions to ensure it is a robust tool
for the future. Particular aspects of the model itself that need further work include ventilation,
thermal mass, hot water and lighting. There is concern regarding the transparency of
assumptions and the suitability of some of the inputs currently used if it is to become a more
accurate predictor of as-built performance (e.g. laboratory based thermal conductivities,
building services component efficiencies). SAP as a whole has been identified by many of
the Work Groups as a major area for further detailed investigation to establish its potentially
significant role in contributing to the performance gap. Energy literacy within the detailed
design team can be limited, and often an external energy modeller (SAP Assessor) will be
engaged for design and specification advice. A lack of ongoing communication between the
design team and SAP Assessors can mean that the performance implications of design
changes are not fully understood.

The report has also produced a breakdown of discrepancies measured per specific aspects,
with the compendium that the overall discrepancy is the result of the compound
discrepancies from different items.

(The Zero Carbon Hub)

The growing divide between SAP and DSM
An indicative calculation was set up for a historical evaluation of the procedure, comparing
SAP an DSM results for a same dwelling in SAP and DSM at different times in the recent
history of building regulations in UK. A dwelling of 70 m2 was assessed with different sets of
specifications corresponding to the baseline compliance at different times in the UK building
regulations in the past 20 years. A set for 1997, 2000, 2005, 2009, 2014. The dwelling
performance for space heating was calculated in SAP and DSM for each set.
The results, reported on the graph in fig 1 show how the progressive increase in the baseline
required specifications corresponds to an increasing difference between the SAP and DSM
results. Specifically, as the baseline requirements grow, the performance accounted by SAP
is progressively lower than the performance accounted by DSM. It is observed therefore,
that as buildings become more efficient, the discrepancy of the steady state calculation
increases, even though there is no sufficient evidence to assess that the SAP is providing
lower performance result, the pattern is clear in showing the discrepancy.

Figure 1 Historical comparison of SAP & DSM

The SAP calculation framework has been updated, revised and upgraded in the years in
order to incorporate additional calculation capability for new efficient technologies, as these
were made available for the residential market. In fact, the need for the accounting of new
features has been always evident and addressed. The question that we present in this paper
deals with this: can we accept that the mere addition of new elements in the sum is providing
a correct modelling of the reality?
Addressing the high density complexity
SAP is conceived for the assessment of a single dwelling although it allows the input for
multi-residential parameters. These parameters are limited though to the adjacency types
of the party-walls, ceiling/floor and roof boundary elements. In high density developments,
complexity can extend far beyond the adjacency and require consideration of the near
development and of neighbourhood context geometries and features. The interaction with
the surrounding conditions influences the effect of winds and solar direct/indirect radiation,
as well as the energy patterns that can occur with the adjoining buildings. These elements
can be considered only in an approximate mode in SAP.

The case study in presented in this paper is a high density development in central London,
consisting of 350 residential units. The Greater London Authority requires that buildings
achieve a 35% reduction on Part L 2013 carbon emission targets. The buildings were
designed and assessed with both SAP and DSM. The following is a report on the DSM
results and the comparison with the SAP calculation.
The masterplan consists of a six storeys development organised around three courtyards,
mews and a public realm street, designed to provide a balanced distribution of solar &
daylight access to the building faades and outdoor amenity spaces.

The dwellings are equipped with a whole house mechanical ventilation with heat recovery
system (MVHR) and provided with a Winter Garden, or sunspace, directly connected to the
dwelling. The function of the MVHR is that of providing fresh air through a heat exchange
system that recovers heat from the air exhausted from the apartment. The process provides
the benefit of eliminating most of the heat loss due to direct ventilation and allows for higher
ventilation rates ensuring constant good air quality levels.

The Winter Gardens are extensions of the dwelling and can be fully open or closed
depending on the weather conditions. These are thermally separated from the dwelling and
are equipped with a performing fabric, that is the glazing is a relatively good double glazing
with a u-value=1.4W/m2K and an infiltration rate of 6 m3/m2.h@50Pa.
With the MVHR, the dwelling is operated in mixed mode. Mixed mode defines the use of
natural ventilation, by opening windows, whenever the outdoor air temperature makes it
comfortable, with the mechanical system taking over the ventilation when the outdoor air
temperature is too cold and its use becomes uncomfortable.
SAP - modelling aspects.
The MVHR technology is among the newly accepted technologies in SAP. Through
Appendix Q, the exact product can be specified and its contribution taken into account.

Conservatories are contemplated in SAP, although with some limitations as per the following

3.3.3 Conservatories
Thermal separation between a dwelling and a conservatory means that they are divided by
walls, floors, windows and doors for which
i) the U-values are similar to, or in the case of a newly-constructed conservatory not greater
than, the U-values of the corresponding exposed elements elsewhere in the dwelling;
ii) in the case of a newly constructed conservatory, windows and doors have similar draught-
proofing provisions as the exposed windows and doors elsewhere in the dwelling.
For a conservatory which is thermally separated, the calculation should be undertaken as if
it were not present. (SAP2012)

Being thermally separated from the dwelling, the Winter Gardens cannot be considered in
the calculation.

The actual modelling of the dwelling in SAP is produced via the input of geometric
parameters, with particular care in regards to the

Exploring the Passivhaus option

The general concept of mechanically ventilated dwellings suggested the possibility of
applying the Passivhaus scheme and certification principles to the development. The
Passivhaus certification is based on an excellent fabric thermal performance, strong air
tightness and controlled ventilation via a very efficient MVHR system.
The following parameters were to be met:
Specific Heating Demand 15 kWh/m2. yr
Specific Cooling Demand 15 kWh/m2. yr
Specific Heating Load 10 W/m2
Specific Primary Energy Demand 120 kWh/m2. Yr
Air Changes Per Hour 0.6 @ n50
MVHR SFP 0.64 W/l
Further to these basic conditions, in order to be certified the consultancy process made it
clear that all windows should have been mounting triple glazing and that the Winter Garden
should have been removed, since the Passivhaus Planning Package, does not allow the
calculation of sun-spaces / winter gardens, therefore inhibiting their adoption.
Considered these conditions and the prohibitive cost of the required fabric, the option for a
Passivhaus certification was not further pursued.

The DSM model

The dynamic simulation calculation engine is Apache by IES-VE. IES-VE is a suite of tools
that can be linked in a single simulation process.
The core thermal simulation is performed by the Apache engine, connected with the solar
radiation calculation module SunCast, the natural ventilation module Macroflo and the
mechanical system module ApaceHVAC. With the exception of SunCast, which is run prior
to the main simulation to analyse the radiation pattern for every month, the simulation is run
in transient mode: the results of each module are exchanged at every time step. This means
that the interaction between the three systems thermal and optical exchanges, natural
ventilation and mechanical - is simulated dynamically and reported with good
The model is based on 3D geometry, with a description of all the relevant characters of the
actual building geometry. The buildings are modelled in their whole geometry, with a level
of definition down to the zone partitioning, in our case consisting in living rooms, bedrooms,
kitchens, bathrooms, circulation and common areas. This level is necessary in order to
investigate the performance dwelling by dwelling and with consistent occupancy

Figure 2 DSM model

Occupancy schedules. BRE Estimates.

The National Calculation Methodology (BRE) has elaborated assumption schedules for the
dwelling typology, among the other types of occupancies. The schedules describe the

Figure 3 NCM - the BRE occupancy profiles for dwellings

occupancy patterns for the different room types in regards to no. of people, lighting,
appliances, heating/cooling setpoint, domestic hot water (DHW), infiltration and ventilation.
For consistency, the heating set points have been modified in the schedules in order to be
homogeneous with the SAP assumptions.
Figure 4 The winter gardens
Simulating windows operation.
The windows are modelled to operate according to the following principles. With the mixed
mode, users will tend to open the windows if the indoor air is stale or if the temperature is
above 24 C, when the outdoor temperature is around 15C or above. When outdoor
temperature is below 15C, it is assumed that mechanical ventilation will operate and
windows will be kept closed. The windows on the winter gardens are also set to be opened
according to the air temperature in order to avoid overheating.

Figure 5 - Modelling Natural ventilation
Simulating mechanical ventilation with heat recovery
The MVHR model supplies air to the living space and the bedrooms. From there air
circulates to the rest of the dwelling and is eventually extracted. The operating principles
are the following. Minimum ventilation rates between 13-35 l/s, depending on the dwelling
floor area, are constantly provided. Further to these, when outdoor temperature is below
15 C and when CO2 levels raise above 700 or the indoor air temp is higher than 24C, the
rates start to increase up to 40-120 l/s, providing the required fresh air and/or ventilation

Integration of Winter Gardens and MVHR

The winter gardens provide beneficial effects by increasing the fabric u-value, reducing
infiltrations, creating a buffer air pocket, where the heat dispersed by conduction is
temporary collected, and by generating free solar gains thanks to the greenhouse effect.
Further to this, we believed that the winter gardens could also be used to provide pre-heating
by locating the MVHR air inlet directly within the WG. For this to be provided, the ability of
connecting the three systems in the DSM becomes a necessary condition for an integrated

Figure 6 Modelling the mechanical systems integration

Weather data
A necessary condition in DSM is the use of hourly weather data representative of a whole
typical year. This procedure cannot be homogeneous with the SAP, where monthly average
data are used instead.
Weather data for the DSM are sourced from CIBSE files Test Reference Year (TRY) and
the Design Summer Year (DSY)
The UK Meteorological Office (MO) collects weather data at stations across the UK. Climate
variables measured at hourly intervals include dry bulb temperature (C); wet bulb
temperature (C); atmospheric pressure (hPa); global solar irradiation (Wh/m2); diffuse
solar irradiation (Wh/m2); cloud cover (oktas); wind speed (knots); wind direction (degrees
clockwise from North); and Present Weather Code. The TRY is composed of 12 separate
months of data each chosen to be the most average month from the collected data. The
TRY is used for energy analysis and for compliance with the UK Building Regulations (Part
L). The DSY is a single continuous year rather than a composite one made up from average
months. The DSY is used for overheating analysis. (

Benchmarking design options against a baseline scenario.

For design support, different options are assessed against baseline scenarios; space
conditioning performance for each option is reported in the graph (Figure 7)
- (LIMIT VALUES). Minimum required values for the fabric performance.
- (Baseline_NOTIONAL) Notional values.
- (NCM UValues_HR_AP03) Notional values, HR, permeability of 3 m3/m2.h50Pa.
- (HR&_WG_AP025) Notional values, HR , Winter Gardens, permeability of 2.5
- (HR_WG_AP_01) Notional values, HR, WG, permeability of 1 m3/m2.h50Pa




50 Baseline_NOTIONAL

NCM U-values_HR_AP03
40 HR_&_WG_AP025



Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
01- 01- 01- 01- 01- 01- 01- 01-
31 30 31 31 30 31 30 31

Figure 7 Monthly heating loads (MWh)

In this comparison. The graph shows as the most effective option is the one with the
Winter Gardens and a permeability of 2.5 m3/m2.h@50Pa, while a permeability of 1 would
be prohibitive in cost with little additional benefit in performance.
Analysis of the integrated system
In order to demonstrate the integration of different systems, the following simulation sample
for a winter day is presented. It show the air temperature pattern from outdoor through an
in-let within the winter garden, rather than direct, and the pre-heating effect in conjunction
with the MVHR. Figure 8 shows the air temperature variation from outdoor to room supply
as it passes through the winter garden and the HRU.

Figure 8 The integrated passive and active systems

1) Fresh air inlet, when outside temp. is less than 16C or when windows are closed.
2) Air is pre-heated in the winter garden
3) In the HRU, heat contained in used air is transferred to fresh air. Pollutants are filtered out.
4) Fresh pre-conditioned air is supplied to main rooms
5) Used air is extracted through kitchen and toilet and driven to the HRU
6) Once its heat content has been recovered, used air is exhausted

Figure 9 Temp (C) sequence - 12th Feb

Specific information detail

The same process is then measured at different locations in the building, permitting a
detailed understanding of the different behaviour due to specific local conditions. The
process permits a responsive design and allocation of resources. In the example in Fig 10,
the two apartments on the right hand side, show a peak in solar gains in the bottom one,
and a reduction in solar gain in the top one, where it is assumed that the winter garden
windows have been opened. This is also used to simulate different possible scenarios.

Figure 10 different performance due to different exposures

Figure 11 Comparison of heating demand in the two methodologies (SAP-DSM)

Direct comparison
A direct comparison of DSM and SAP energy demand for space conditioning, Fig 11, shows
important differences. It should be noted that the difference we found are not evenly
distributed among the development dwellings, and in some cases the SAP shows a better
performance than what is assessed via DSM. This confirms that more complex scenarios
must be addressed in detail in order to be reliable for both the compliance and the
operational assessment.

Quantitative vs Qualitative design

A fundamental question that must be addressed. If the lack of accuracy is inducing the
adoption of higher specifications or the implementation of LZC/Renewable energy
installations, isn't that eventually beneficial to the overall sustainability balance?
This could be the case if the inaccuracy would shift all parameters towards efficiency. But
this is not the case for, at least, the following reasons:
- The inaccuracy is actually leading to unexpected results which are not necessarily
beneficial. In our case, the winter garden would be not implemented, with a demonstrated
reduction in efficiency.
- Increasing the specification values, e.g. insulation, triple-glazing, air-tightness is adding not
only to the cost, but also to the total environmental impact.
- Excessive specification can be detrimental of performance, for example reducing glazing
areas to control overheating or thermal losses, will reduce daylight provision and beneficial
solar gains.
- The lack of accuracy impairs the Carbon Hierarchy bypassing the fundamental steps Be
Lean + Be Clean in favour of the latest resource Be Green.
Figure 12 Performance distribution by apartment, at intermediate design iteration

Figure 13 Performance distribution by apartment after latest optimisation

Figure 14 - Comparison achieved performance with benchmark and other values in the industry

Figures 12 and 13, show the results of responsive design, where the units with lower
performance (fig 12) have been addressed by design, achieving an optimised performance
(fig 13).
The average performance achieved by the Phase 1 of the development equals 6.86
kWh/m2.yr, with the adoption of fairly standard fabric specifications. This result, while
outstanding in comparison of other benchmarking and reference values, is demonstrating
the importance of responsive qualitative design instead of a quantitative approach (Fig 14).

Integrating DSM data in the SAP

The Standard Assessment Procedure represents a comprehensive framework based on a
worksheet structure. Considered that as a government adopted tool and considered that
different aspects can be developed separately and at different times, SAP appears to be the
ideal instrument to implement upgraded calculation procedures as they become available
and accepted. In other words, integrating DSM results within SAP is an immediately
available strategy. Integration is performed by replacing the space conditioning demand
figures in the worksheet. This seems to be a most effective way forward because it affects
a minimal part of the procedure. It also proposes what could be the upgraded procedure
once the DSM would be officially accepted for the calculation. The newly calculated figures
are inserted in the worksheet. And since those figures are used into other formulas in the
worksheet, the implementation affects also other connected aspects and eventually affects
the final assessment of energy demand and CO2 emissions.
Figure 15 shows a comparison of the two worksheets, the standard SAP(left) and the DSM-
integrated-SAP(right) for the same dwelling.
Figure 15 integrating DSM into SAP worksheet
Presenting the case to the Local Authorities Royal Borough of Kensington and
Chelsea & Greater London Authority

The following is the information package produced using the evidence collected in both
procedures, SAP and DSM-SAP by MTT Sustain consultancy.



The Standard Assessment Procedure (SAP) is the methodology adopted by Government in

the UK for calculating the energy performance of dwellings and may be used for other
purposes, such as in energy statements for planning purposes. It is recognised in the GLA
Energy Teams Guidance Note as a robust methodology for such purposes. The software is
produced by the Building Research Establishment on behalf of the Department for Energy
and Climate Change and is accredited for Building Regulations and Energy Performance
Certificate purposes by the Department for Communities and Local Government. SAP was
developed for the former Department of the Environment in 1992, as a tool to help deliver
its energy efficiency policies and is based on the BRE Domestic Energy Model (BREDEM).


SAP applies the principle of energy balance, where the heating energy a dwelling will
require across a typical year is evaluated by subtracting the fabrics steady state heat loss
multiplied by monthly degree-days, from internal and solar gains (based on standardised
assumptions for occupancy and behaviour). This method evaluates the heat losses based
on average daily temperatures for one day in each month and multiplies this by the number
of days in that month. To simplify data entry, a significant number of the calculation inputs
are based on default or simplified figures, such as for hot water primary losses, fan and
pump energy, boiler electrical use and ventilation energy use/heat recovery performance.
SAP does not provide well for passive solar design in that windows and shading are not
modelled in detail and the effects of thermal mass are not included beyond specifying that
the dwelling is light weight, medium weight or heavy weight.

Commentary on Application at Chelsea Redevelopment

A number of academic and industry studies have shown that SAP has a poor track record
of predicting the energy demand of buildings in general and especially for low energy
buildings. The governments own website for SAP states that future development is needed
to accurately reflect carbon emissions reduction from both on-site and off-site performance
measures for the new generation of very low and zero carbon dwellings.

SAP and BREDEM were developed in the 1980s from a study of homes with relatively poor
levels of insulation and therefore high levels of heat loss. It was subsequently noted that
The sample used for this study was dominated by medium to large dwellings with a good
standard of heating, so that the good agreement observed should be extrapolated cautiously
to other situations

Robust validation of SAP has not been carried out for over fifteen years, with the most recent
validation exercise was completed on just 19 dwellings. There has never been a validation
exercise conducted for BREDEM on a sample of more than 45 dwellings or for a sample
spanning any significant geographic-climatic region in the UK. The energy consumption from
the new generation of buildings has never been tested against BREDEM and SAP
estimations. SAP therefore lacks precision about aspects that become critical in modern
very low energy dwellings, such as those proposed for the case study development scheme.
Specific areas of criticism include anomalies in how MVHR energy use is calculated, the
inaccuracy of calculation of solar gains for windows (due to limitation imposed on
standardised U Values, orientation, actual frame factors and shading by reveals and
overhangs) and the use of a very limited set default value for thermal capacity, which cannot
be changed.

Whereas provision for some of these features is present in SAP, it is has been noted Within
SAP, the Appendix Q procedure enables an overall allowance to be made for the notional
benefits from an approved new technology. However, the implementation of Appendix Q in
its current form compares less well with the ability of a dynamic simulation to model the
benefits from new products and technologies, let alone to differentiate between them. It can
blunt the rewards, and thus the incentives, for innovation. In the case study dwellings, the
effect of the winter gardens cannot be modelled effectively to represent the summer/winter
conditions and the benefits of the MVHR system and its controls are underrepresented.

This shows a 26.38% CO2 reduction under Building Regulations Part L 2013 demonstrating
the London Plan 35% CO2 reduction target is not met.

Dynamic Simulation Modelling (DSM) is typically used to demonstrate compliance with Part
L for non-residential schemes in the UK as well as in energy statements for planning
purposes. It is recognised in the GLA Energy Teams Guidance Note as a robust
methodology for non-domestic applications. The software tools are produced by
independent software houses and are accredited for Building Regulations and Energy
Performance Certificate purposes by the Department for Communities and Local
Government. They are also accredited by the Chartered Institution of Building Services
Engineers under their AM11 process.

DSM is a significantly more sophisticated means of assessing building energy performance
than SAP, using zone specific operational profiles (occupancy, lighting, ventilation and hot
water demand) and building services performance data along with 3D building geometry
and appropriate weather data to effectively model and predict the energy performance of a
building. DSM combines mathematical routines simulating a range of heat and mass transfer
mechanisms to calculate the buildings response. This level of detail allows realistic
variations in fabric thermal storage (thermal mass effects), weather conditions, ventilation
and heat recovery, internal and solar gains to be taken into account and their effects upon
the buildings internal environment and plant operation to be modelled effectively. The
thermal state of the building is tracked on an hourly basis using standardised location-
specific weather data, resulting in a detailed and realistic picture of the buildings energy

Commentary on Application at the case study

All the inputs used in SAP are present within the DSM model (with a large number of
additional factors considered) and so it is possible to replicate all the building form and fabric
data, the occupancy and plant operating profiles and all other items used in a SAP model
within the DSM approach. Considering the importance of standardisation for comparison
and benchmarking, the DSM model for the case study development was also built to strictly
correspond with the modelling conventions and calculation parameters published for SAP.
The use of DSM results in this manner demonstrates that the London Plans 35% CO2
reduction target can be met.
Carbon offsetting

Although not explicitly required within RBKCs Core Strategy, it is understood that the Royal
Boroughs expectation is that the London Plan, including the further alterations up to March
2015, and the GLAs Energy Planning: Greater London Authority guidance on preparing
energy assessments (April 2015) document should be followed with respect to applying and
calculating carbon offset payments, where the target of a 35% reduction in CO emissions
against Building Regulations Part L1A 2013 cannot be met.
Where boroughs do not have an established price, a figure of 60/tonne for a period of 30
years should be applied as recommended in the Mayors Sustainable Design and
Construction SPG. This is the case in RBKC, which means a price of 1,800 per tonne CO2
is assumed.

The commercial building industry and associated ethical aspects

It could be argued that the use of DSM implies a laborious, expensive process that is not
widely accessible to everybody. After all SAP is conceived to provide a readily available
free tool to anybody involved in the housing industry, without requiring a complex
engineering expertise. It is our vision that the argument should be open to debate, to which
we offer the following considerations. Although we would encourage the use of the highest
accuracy in every case, that may be scaled in accordance with the complexity of the
building. The utility of DSM becomes evident in complex, high density residential
developments. This sector offers an important potential for efficiency and optimisation, a
potential much higher than, for example, detached or terraced housing. This is due to a
number of factors, including the synergetic and interchanging mechanisms available
through density, vicinity and complexity. In order to take into account, the synergetic of the
system, a comprehensive approach is necessary.
DSM measures design integration, where the performance of the whole system is
considerably higher than the cumulative performance of the single parts.

The calculation methodology used for SAP is the main reference for the assessment of the
dwellings energy performance for compliance and also for the operational scenario. It is
SAP that is used to verify the operational performance. For this specific reason, it is rather
important finding a methodology that enables, with the increasing performance required in
buildings, implementation of integrated strategies. Integrated strategies rely extensively on
the interaction of multiple and also different aspects. Steady state methodologies cannot
account for the effects of integration. The lack of accuracy can direct the design strategies
towards the wrong decisions and frustrate the exploration of new, different, innovative

The SAP framework is well structured to comprehensively manage different types of input
and can be successfully used to implement alternative DSM methodologies where these
are demonstrated to be providing the required information support for design and
compliance assessment as well as for the operational building assessment. This would
widely help in improving efficiency and performance by recognising the synergetic effects
of comprehensive integrated design, particularly in the complex residential scenarios such
as high density developments, and will support overcoming the performance gap.

I would like to thank Caroline Buckingham and David M. Cafferty, board directors at HLM and its
linked companies for enthusiastically embracing the cause for integrated design and the full
support to the application of its principles.

We would also like to thank:

- The MTT Sustain team, directed by Jodi Willis for their contribution to the integrated design
- Sarah Graham Director at IES Ltd, Glasgow, for her continuous support with the software.
- John Henderson and Jose Ortiz, Directors of Building Energy Modelling at BRE for sharing their
invaluable comments and opinions that greatly improved the research and its application.