At the back end of last week the revised Code for Sustainable Homes Technical Guidance November 2010 was published (late as usual – should have been the latter half of October 2010). I won’t go through the changes in this post, but there’s a handy summary document on the same page.
For a while now I have been picking up hints that the Code may not be long for this world (in it’s current form at least). Those who know me will know I have a suspicious, glass half empty attitude when it comes to such matters and a propensity to exaggerate and dwell on the DOOM (the reporting of the effects on the construction industry of the recession has held me in morbid fascination). So take what I say here with a pinch of salt. The evidence so far:
I’m a big fan of the TheyWorkForYou.com website where the following snippets come from (emphasis my own). I’ve set up various keyboard searches which get pushed to my RSS feeds in Google Reader. I’m not scanning every word written in Hansard! Anyway, on 30 June 2010 during the Energy Efficiency Bill debate, Martin Horwood (Lib Dem) had the following to say:
On new buildings at least, the other possible pitfall is the rather prescriptive and increasingly complex code for sustainable homes. I welcomed the code when the previous Government introduced it, and generally, as an instrument of policy, it is a welcome development. However, it has been painfully slow at raising energy efficiency levels in new buildings, and it risks becoming so over-prescriptive that it defeats our objectives.
On 18 October Stephen Mosley (Con) asked Andrew Stunnell (Parliamentary Under Secretary of State, Communities and Local Government; Liberal Democrat):
…what steps his Department is taking to encourage the building of new housing stock using energy efficient construction standards.
To which Stunnell replied:
Communities and Local Government encourages the building of energy efficient housing through the requirements of part L (conservation of fuel and power) of the building regulations. The most recent changes to part L standards introduced on 1 October 2010 require a 25% improvement for every new home. Further changes to strengthen standards in part L and take the next step towards zero carbon buildings are planned for 2013. The Government have announced that a minimum fabric energy efficiency standard will form part of their approach to ensuring that all new homes post-2016 can be zero-carbon.
The Code for Sustainable Homes, which is a voluntary set of standards reaching beyond building regulations, also encourages high levels of energy efficiency. The 2010 revisions to the Code for Sustainable Homes are expected to be published shortly; thereafter the Government plan to review the future role of the code.
So we’ve just had the Code published, and sure enough, within the summary changes document document:
Next update to the Code
The Government is committed to reduce the burden of regulation, and to reducing duplication. Future plans to review the future role of the Code are currently being considered, alongside a wider rationalisation of housing standards.
What can this all mean? Can we guess what’s coming?
Zac Goldsmith (Con) has also been busy with written answers and statements. On 14 October 2010 he asked Stunnell:
…what plans he has for the future of (a) the Code for Sustainable Homes and (b) Part L of the Building Regulations.
To which Stunnell replied:
The 2010 revisions to the Code for Sustainable Homes are expected to be published shortly. Thereafter the Government plan to review the future role of the code, in the context of our aims to simplify the overall system of new build standards.
The Government have committed to continuous improvements in the energy efficiency of new housing as part of the Zero Carbon Homes agenda, and are considering their approach for new non-domestic buildings. In this context, we are scoping work for further changes to Part L in 2013.
Which was followed up on 26th October 2010 with:
…on housing: sustainable development, what timetable he has set for the review of the future role of the Code for Sustainable Homes.
The Government’s plans to review the future role of the code are currently being considered, along with a wider rationalisation of housing standards following a consultation which focused on streamlining and simplifying the code, resolving problems which have arisen during its use, and upgrading it to align with revisions to part L of the Building Regulations. A further announcement about the way forward will be made soon.
There have been other clues that the “burden” of regulation is soon to be reduced. A recent report from the soon to be no longer CABE, Improving the design of new housing: What role for standards?Â recommended the following:
If we are to achieve consistency, simplicity and increasedÂ supply, CABE believes that in place of the plethora ofÂ current standards we need a robust and comprehensiveÂ national standards framework, focusing on standardsÂ for both houses and housing. This framework should beÂ shaped according to the following aims:Â
Avoid duplication and overlap – we should not haveÂ standards that overlap and mean aspects ofÂ performance are measured in several places forÂ different purposes.Â
Clarify what elements belong in planning and whatÂ should be included within building regulations. ForÂ example the requirements in Lifetime Homes for size ofÂ parking spaces should be included in planning policy,Â whereas the detailed requirements for switch heightsÂ should be included in building regulations.Â
Demonstrate clear linkage to an enforcementÂ process. Standards need to be linked with the processÂ that will enforce them.Â
Prevent unnecessary compliance, for exampleÂ by requiring information at planning stage showingÂ compliance on detailed items when fundamental issuesÂ may be wrong.Â
Ensure that standards are driven by the publicÂ interest. Standards should not be owned by the privateÂ sector or single interest groups; however, certificationÂ and enforcement may be led by private sectorÂ organisations such as NHBC.Â
A national framework for housing standards should thenÂ do three things:Â
1. Create a single set of measures by whichÂ developments can be designed, judged and developedÂ through the planning system, under the oversight ofÂ elected local representativesÂ
2. Specify the standards, to be delivered through theÂ planning system, into two areas, addressing:Â
a) housing layouts and the wider development; andÂ
b) the design of individual homesÂ
3. Identify those that should be delivered through buildingÂ regulations or included in them in futureÂ
From this framework, a basic minimum requirement couldÂ be drawn, which addresses the policy principles requiredÂ to meet our environmental commitments and the basicÂ needs of communities and residents.Â
So with the localism bill about to be published (later this week I believe) and the evidence above, I’m convinced this could be the last time we see the Code for Sustainable Homes, in this guise at least.
At one stage I had started to suspect CSH might just be shifted back to the BRE (it was developed from their EcoHomes scheme), and become voluntary again, but I think there are enough drivers for something to be retained within government mandate, especially with regards to public sector funding. Note the passage above which recommends that standards “should not be owned by the private sector or single interest groups; however, certification and enforcement may be led by private sector organisations such as NHBC”.
My current feeling is that the Code as we know it will be broken down and reassembled in a very different guise, keeping the energy and possibly the water targets (perhaps within Building Regulations which are due for a shake-up too). EPC’s will have to remain (given they are an EU EPBD requirement).
Any thoughts? Anyone disagree?