I thought that I would review the Housing Standards Review document and set out how it proposes to incorporate Sustainable Standards into legislation, or more accurately, how it doesn’t.
I will set out below the section of the Code for Sustainable Homes and illustrate how they are each to be dealt with. Some of my positive comments are ironic, so watch out for those.
ENE1: Dwelling Emission Rate: Replaced by Building Regulations
The consultation is effectively saying that we don’t need to consider going beyond the proposed definition of ‘zero’ carbon set out for 2016. Nor is there any real mechanism for considering whether we should or shouldn’t continue to improve building energy efficiency. I think that is pretty unambitious. Is the current definition of ‘zero’ the best one? Won’t new technologies make it easier and cheaper to build to higher levels of building efficiency than we are currently aware of? This is a recipe for stagnation and a poor result for home occupiers.
ENE2: Fabric Energy Efficiency: See above
ENE3: Energy Display Devices: Believed by DCLG to form part of the smart meter roll out. Mass roll out isn’t due to start until the end of 2014, so what about the 250,000 homes that we are going to build between now and then? Why not be a bit ambitious and ensure that all new homes built from the New Part L 2014 have smart meters?
ENE4: Drying Space: Deemed unnecessary, but no evidence provided.
ENE6: External Lighting: Deemed to be overtaken by legislation on low energy light bulbs, no mention of the potential for LED’s to save time and money.
ENE7: Renewable Technologies: Retain as a future role for Building Regulations and local policy. Future role? The consultation proposes to remove the ability of Local Authorities to set local renewable standards aka ‘The Merton rule’.
ENE8: Cycle Storage: Proposes security measures for cycle storage where it is fitted, makes no recommendations about whether homes should actually provide any.
ENE9: Home Office: Deemed inappropriate as a standard, ‘not the responsibility of local or national policy to promote home working’. Is it the responsibility of Government to reduce CO2 emissions from transport? Yes.
WAT1: Indoor Water Use: Incorporated into Part G of the Building Regulations and capped at 110 litres/person/day. Unless a Local authority can demonstrate a case for a higher standard.
WAT2: External Water Use: Included in Part G calculation.
MAT1,2,3. “Leave it to the market” No consideration given to the embodied energy contained in materials, whether they are good or bad for health, whether they are imported or not, or whether they have a positive or negative impact on the environment at source or in use or at end-of-life. Pathetic.
SUR1,2:Surface Water Run-Off and Flood Risk: Silence. Flood Risk? What Flood Risk?
WAS1: Storage of Waste: Incorporate into Part H6 of Building Regulations: Mr Pickles doesn’t like bins, so this one got some attention.
WAS2,3: Site Waste and Composting: Silence: Mr Pickles couldn’t care less.
POL1,2: Pollution from Insulants and Boilers: Silence.
HEA1: Daylighting: Leave it to the market:
HEA2: Sound Insulation: Silence, possible appropriately.
HEA3: Private Space: Silence.
HEA4: Lifetime Homes to be centrally managed in a three tier system, a universal definition of wheelchair housing, a standard definition of Lifetime Homes and a basic Part M provision.
MAN1: Home User Guide: Silence
MAN2: Considerate Contractors Scheme: Silence
MAN3: Construction site Impacts:Silence
MAN4: Security: Bizarrely this gets a detailed section covering everything you ever wanted to know about locks, bolts and Secure By Design. Some Staffer in DCLG has had his dream come true. This will make SUCH a difference to all our futures. Our grandchildren will be grateful.
ECO1,2,3,4,5: Ecology: Silence on all counts. Well, if you are planning to build all over the Green Belt, it doesn’t do to draw attention to the fact, does it?
Half of the provisions in the Code for Sustainable Homes are not considered in the consultation, nor are there any mechanisms put in place to replace them. I accept that the Code is out of date, but that is simply because DCLG has allowed it to fall out of date. It is the only standard we have and having it is better than nothing, which is what DCLG intends to replace it with.