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Is it RIP CSH?

by Mel Starrs on March 7, 2011

in Code for Sustainable Homes

Does it feel like the end of days for Code for Sustainable Homes or is it just me? Remember of course that I love a bit of DOOM and can see a conspiracy theory behind every incompetent decision (I need to try and remember Hanlon’s Razor more often – “Never attribute to malice that which is adequately explained by stupidity”). Perhaps my previous posts have me hunting out evidence to back up my gut feeling? Previously I said:

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).

I’m now utterly convinced that CSH will cease to exist.

Firstly, let’s look at the mandatory credits (from the latest manual):

Mandatory minimum performance standards are set for some issues. For three of these, a single mandatory requirement is set which must be met, whatever Code level rating is sought. Credits are not awarded for these issues. Confirmation that the performance requirements are met for all three is a minimum entry requirement for achieving a Level 1 rating. The three un- credited issues are:
•    Environmental impact of materials •    Management of surface water run-off from developments •    Storage of non-recyclable waste and recyclable household waste
If the mandatory minimum performance standard is met for the three un-credited issues, four further mandatory issues need to be considered. These are agreed to be such important issues that separate Government policies are being pursued to mitigate their effects. For two of these, credits are awarded for increasing levels of achievement recognised within the Code.
The two issues with increasing mandatory minimum standards are:
•    Dwelling emission rate •    Indoor water use.
The final two issues with mandatory requirements are Fabric Energy Efficiency and Lifetime Homes. To achieve an overall Code rating of level 5 it is necessary to achieve at lease 7 credits in Ene 2. To achieve an overall Code rating of level 6 it is necessary to achieve at least 7 credits in Ene 2 and 3 credits in Hea 4 – Lifetime Homes.

The emphasis in italics is mine. By pursuing these mandatory issues as seperate policies, the need for them to be included in the Code disappears. This government has been very clear about the desire to cut out bureaucracy and red tape. Duplication of effort would surely fall under this category.

But does the government have the ability to abolish the code? Although the standard is administered by DCLG, it has always remained voluntary (indeed when HIP’s were abolished the requirement for nil rated certificates was dropped). The drivers for pursuing CSH remain HCA funding and some planning authorities. What I haven’t been able to work out (despite my best efforts at trawling through DCLG spending figures and BRE’s accounts) is if the scheme as it stands is self funding – do the licence fees and registration fees effectively pay for the administration of the scheme? This would be where DCLG could effectively scrap it – if was felt not be value for money. More worrying for CSH assessors (i.e. those who make their livelihood from the scheme) is if HCA drop the requirement or if planners drop the requirement.

Both these scenarios now seem very likely. On a recent press release, HCA said:

The HCA’s requirement to achieve Code for Sustainable Homes, or other successor targets, 3 years in advance of their anticipated mandatory enforcement has also been addressed in the layout.

Again, emphasis mine. But it looks like HCA are looking beyond Code to something else.

CSH 3* still currently requirement for HCA funding (and from April 2011, HCA funding in London will require CSH 4* despite Grant Shapps ditching the HCA standards). See:

The Design Standards Prospectus sets out how HCA London will integrate the Mayor’s Interim London Housing Design Guide into funding processes for the capital. All developments, for which funding is sought, must be accompanied by a completed London Design Proforma.

As for planners, we all know they are in a state of flux. Until the National Planning Policy Framework emerges, various authorities are pressing ahead with planned changes, whilst others are reverting back to woefully out of date policies. Good news for planning consultants who are trying to make head or tail of it all, confusion for the rest of us. In addition, Inside Housing are reporting that:

The government is considering merging the code for sustainable homes with a new menu of local house building standards.

Councils will be able to pick and choose from the new range of options, which will replace the Homes and Communities Agency’s design standards.

Like I said, feels like the end of days to me. So what would ditching CSH mean? Architects and designers would still have to meet the mandatory requirements (if the policies mentioned above are brought in). But these are minimum levels – where will the drivers to go above and beyond the minimum be?

And what of the tradable credits? Are there any which will be missed? Bike sheds won’t be missed by some (see last paragraph of that post). Is there anything else which developers have only been doing because CSH has forced their hand which ought to be an integral part of the design? Housing is an odd fish compared to BREEAM and the non-domestic market. Often there are no M&E engineers and sometimes the architect doesn’t follow through post-planning (i.e. a different architect is used for working drawings than for the planning drawings). Does CSH provide some continuty across the design of the building? I’m not so sure.

One other big difference between Code and BREEAM has been the role of the assessor. On Code, it is much more tightly defined:

The role of the Code assessor is to undertake credit score calculations and verify the validity and authenticity of evidence provided. The assessor will also carry out calculations which are pertinent only to the Code assessment, where these are not undertaken by a professional under an appropriate regulatory requirement, competent persons scheme or specialist requirement. At the post construction stage, the assessor is required to carry out sufficient site inspections to audit the as-built evidence. At least one visit will be required for all sites. Each specification employed to meet the criteria at the design stage and/or post construction stage must be reviewed or assessed as appropriate, and detailed documentary evidence recorded, to confirm that it complies with the requirements for post construction assessment given in the Technical Guidance manual. The Code assessor is at all times responsible for the content and scoring within the assessment report.
It may be that assessors have competencies in other disciplines and as such are employed to undertake additional tasks that feed into the Code assessment, but these fall outside their role as an assessor.

Advice was NOT included in the job description. This was always an error in my eyes, and by devaluing the role of assessor to box-ticker, devalued the scheme overall.

Could the Code be scrapped in the Budget this month? I’m not sure it will be that soon, nor indeed if it can be scrapped by government. But I stick to my guns – it will not survive to April 2013. It is simply looking untenable.