Targets arriving faster than the estate can absorb them
By webmaster · · 6 min read
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Decarbonisation targets are arriving faster than the estate can
absorb them. That is true, and true for a reason most estates papers
miss. On a school estate you own, occupy and are not currently altering,
the targets are not arriving as law at all. They are arriving as
expectation and as funding condition. The funding was switched off at
the June 2025 Spending Review.
Neither
regime everyone quotes actually reaches your buildings
Two regimes get quoted at education estates teams. Neither does what
the quoting implies.
Part L is triggered by building work. The edition
that applies to building work today is the 2021 edition incorporating
2023 amendments. An Approved Document L (2026) exists, published on 24
March 2026 and retitled “Energy and greenhouse gas emissions”, and it is
not in force. SI 2026/335, made 23 March 2026, provides that the
regulations “come into force on 24th March 2027”, with higher-risk
building work following on 24 September 2027. The gov.uk page for the
2026 document does not state that date anywhere on it, which is
precisely how it gets quoted as current.
There is no Part L duty to improve a building you are not working on.
It bites on new build, extensions, material changes of use, replacement
of controlled services and fittings, and consequential improvements.
Leave a 1970s teaching block standing and untouched, and Part L has
nothing to say about it.
MEES is triggered by letting. The minimum standard
in England and Wales is EPC band E, defined at regulation 22(b) of SI
2015/962 as “an energy performance indicator of band E”. Letting below E
has been prohibited for new tenancies since 1 April 2018 and for
continuing tenancies since 1 April 2023. That is the entire law today.
There is no 2026 instrument amending it. And it applies to privately
rented property, which most of a school estate is not. For most of your
estate MEES is not a soft obligation, it is not an obligation.
The
trajectory your capital plan was built on was abandoned four weeks
ago
If a board paper on your desk says “EPC C by 2027, EPC B by 2030”, it
is quoting a trajectory that was official policy from the 2020 Energy
White Paper until last month, and is now gone.
The DESNZ interim response of 18 June 2026 states
that “the previously proposed interim EPC C milestone for 2027 will not
be taken forward”. EPC B moved to 2031 and now reaches only buildings
over 1,000 square metres. Buildings below that threshold are intended to
stay at EPC E, with “no set deadline for going beyond this level”.
Then the sentence that governs all of it: “The changes to raise MEES
to EPC B for larger buildings will only take effect following the
successful passage of secondary legislation through Parliament.” Not
law. Intention.
Notice which obligation has not moved. Band E has bound continuously
since April 2023 while every threshold proposed above it was consulted
on and never arrived. The deadlines that generated the planning effort
are the ones that did not survive.
The 2037
target survived. Its mechanism did not.
The Public Sector Decarbonisation Scheme “supports the aim of
reducing emissions from public sector buildings by 75% by 2037, compared
to a 2017 baseline”. That aim stands.
The scheme does not. From the Phase 4 summary report, which describes
Phase 4 as “the final phase”:
At the Spending Review in June 2025, ministers have decided not to
allocate further funding to the Public Sector Decarbonisation Scheme. As
a result, no further phases are planned.
And from its conclusion: “there is currently no dedicated funding
stream planned to replace the Public Sector Decarbonisation Scheme”.
The target is a policy aim delivered through funding rather than a
duty on any individual school. The funding has been withdrawn and the
aim left in place.
The final round also shows where schools sat in the queue. It drew
383 applications requesting over £1bn and awarded 245 grants worth
£816.6m. Schools and academies took 43 of those grants, 18% of the
total, worth £51.4m, six per cent of the money. The NHS took £408.1m,
half of it. If your decarbonisation plan assumed a future PSDS
bid, it does not contain a funding line. It contains a hope, and the
department that would have funded it has said in writing that nothing is
planned to replace it.
The
number anchoring your capital case is a re-priced walk-round
£13.8bn is the schools maintenance backlog as at October 2024, from
the NAO’s Maintaining public service facilities, published 22
January 2025. Read its footnote before you cite it again:
We have converted that figure to 2023-24 prices and followed the
Office of Government Property in treating condition need as indicative
of schools’ backlog. DfE’s estimate is based on data collected between
2017 and 2019 and does not account for any subsequent investment to
improve schools or deterioration of their condition.
So £13.8bn is CDC1’s £11.4bn wearing a 2023-24 price tag. CDC1 graded
condition “based on a visual assessment” and disclaims its own output:
“These modelled costs are not an accurate estimate of the actual repair
costs at any individual school.” The NAO adds that DfE “did not publish
the underlying data for individual schools”, so you cannot find your own
buildings inside the national figure.
CDC2 has since visited every government-funded school in England,
from 2021 to 2026. Its national findings are not published. The estate
has been surveyed twice and the public evidence base is still survey
one. The only official CDC2 signal available is one clause in DfE’s
Education Estates Strategy of 16 February 2026: “preliminary findings
show that there has been continuing deterioration in the condition of
the estate”.
CDC2 also tells you what it did not look at. Per its programme guide,
surveying teams “undertake a high level, visual inspection only and will
not access roof voids, remove ceiling tiles or test any ‘plant’
equipment such as boilers and heaters”. The national evidence base for
decarbonising the school estate contains no measurement of the plant
being decarbonised.
What this means on Monday
Write the distinction down, because it survives contact with a board.
Band E is law. EPC B in 2031 is an intention awaiting an SI. Approved
Document L (2026) is a 2027 event with transitional cover for anything
noticed before it. The 2037 aim is a policy target with no delivery
mechanism attached.
That should not read as a reprieve, and here the honest limit
matters. DfE is responsible for “37% of emissions from public sector
buildings, but has not yet set a target to reduce them”, and intends to
rebuild 500 schools as net zero, “two per cent of the school estate”.
Meanwhile 43% of the estate by size was built between 1941 and 1980 and
32% of schools report overheating in at least one building. Those are
physical facts about masonry and plant. A deadline slipping does not
insulate a wall, and a target with no funding behind it will still be
quoted back at you in 2037.
The regulatory pressure on your estate is lighter than the sector
believes. The engineering problem is exactly as heavy as it was. Those
two sentences are not in tension, and confusing them is how an estate
ends up planning against dates instead of against buildings.
