Has the Government broken the Code for Sustainable Homes?
The government has published the Housing Standards Review which looks at reducing the number of local and non-Building Regulations requirements on house builders.
The Housing Standards Review consultation proposes a new ‘nationally described standard set’ to provide clear differentiation between standards which can be asked for by Local Authorities as part of planning conditions, and areas where voluntary, market led approaches are to be encouraged. There are various issues covered including accessibility, space, domestic security and water efficiency, but from our point of view the main issues are that the higher Energy, CO2 and renewables requirements of the Code for Sustainable Homes and those standards from the Code relating to construction materials, are both proposed to be dropped.
Code for Sustainable Homes: Energy and CO2
The government has concluded that the Code has been successful in doing its job in terms of pointing the way forward, but they do not now see a need for Code levels, or for separate carbon and energy targets. Carbon and energy targets should instead be set in Building Regulations as we move towards zero carbon homes.
They suggest that any interim targets would only have a shelf life of at most 3 years, with a risk of developers being led up technological blind alleys if they are required to focus on an interim level (e.g. small arrays of solar panels that may not be cost effective). The government therefore does not believe that an interim level would be helpful to developers and is not minded therefore to set one in a nationally described standard.
The government also considers that the progressive strengthening of Building Regulations means it is no longer appropriate for local plan policies to specify additional standards for how much of the energy use from homes should come from on-site renewables. Developers should be free to decide the most appropriate solutions to meet stronger Building Regulations.
I’ve long held the view that it is better to minimise heating and hot water demand, than it is to compensate for a poorer building with bolt-on’s. However when moving to improved housing standards, both fabric and renewables have their place.
I think that the government is missing a trick with their proposals. The Code since 2008 has served as a scheme to advocate going beyond the minimum and getting ‘credit’ for having done so.
A Code 3 dwelling prior to 2010 and a Code 4 dwelling now, shows that a house has been constructed to a better standard. It shows that a purchaser is buying something nationally recognised as having been constructed sustainably and going beyond that which is required. Social housing providers and those looking to produce better houses have been looking at building to Code 4 and beyond for a while now. Housebuilders have had it on their radar as the next step towards low/zero carbon; If anything, the Code needs expanding to give more interim steps between where we are now and the Code 5 target of zero carbon (excluding cooking and appliances) and Code 6 (including them).
As it is, the Government isn’t actually proposing people building zero carbon homes. It is proposing hitting a carbon compliance level, with allowable solutions to make up the shortfall. More Code targets for Energy and Carbon Emissions would serve as a means of showing just how low carbon a dwelling is.
Removing the targets entirely means builders will be more likely to just do the minimum.
A baby step of 6% improvement from current levels barely registers as an improvement from where we are now and a planning requirement locally to build to Code 4 may be justifiable in sensitive areas, or where the potential occupants would benefit greatly from cheaper to heat buildings.
The Code for Sustainable Homes contains two areas of credits for sustainability of materials. The first, MAT1 covers the environmental impact of materials. The second, MAT2 covers the responsible sourcing of materials. These standards are a bit complex and only apply to Code housing. As such they affect only a relatively small proportion of all new homes built, with the majority being social housing funded by the public sector. Some authorities have also apparently also set their own ’embodied energy’ materials standards.
The Government notes that there is an absence of clear understanding as to what embodied energy standards should embrace, or clear evidence of what works (nationally or internationally). They do not therefore propose to include materials within the Nationally Described Standards document. This one’s a little less clear cut; the materials section of the Code is a little complex, but I can see the benefit of at least weighing up a products environmental impact and how it is sourced against it’s performance when considering it’s use.
Overall, I agree that the setting of local standards does need some rationalisation and standardisation across the country to encourage housebuilding and to ensure that builders and designers have more clarity. I’m just not sure that ditching the Code and it’s guidance towards more sustainable building is the way to go about it.
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