Memorandum submitted by NHBC
NHBC
Our primary purpose is to raise the standard
of new homes and provide consumer protection for new homeowners.
As a non-profit distributing company established almost 70 years
ago, NHBC is independent of both Government and the industry and
raises standards by registering house-builders, setting construction
standards, providing inspection and risk management services during
construction and providing the leading warranty and insurance
cover for new homes in the UK. With 1.7 million homeowners protected
by Buildmark cover, 19,500 registered builders registering 180,000
homes each year, and by carrying out almost 1 million inspections
of homes, NHBC is uniquely placed as an expert and independent
authority on the new homes industry.
1. NHBC WELCOMES
THE SELECT
COMMITTEE'S
DECISION TO
HOLD A
PROGRESS INQUIRY
FOLLOWING ON
FROM THE
JANUARY 2005 REPORT
"HOUSING: BUILDING
A SUSTAINABLE
FUTURE"
Whilst we understand that the Committee will
focus on many issues, such as the Planning for Housing Provision
consultation paper, which are beyond NHBC's remit, there are several
other important areas in which NHBC's expertise and experience
may inform the Committee's deliberations, particularly in relation
to Building Regulations and the proposed LPS2020.
2. SUSTAINABLE
HOUSE BUILDING
There is no doubt that sustainability has a
growing importance in the political arena, no more so than within
the housing agenda. In 2004 the Sustainable Buildings Task Group
reported that the built environment currently accounts for half
the carbon dioxide emissions in the UK. In line with this, the
scope of Building Regulations has expanded beyond health and safety
to embrace important environmental and social considerations such
as energy conservation and accessibility, and will increasingly
address sustainability issues.
NHBC recognises the challenges facing the industry
in terms of creating sustainable new homes and supports a positive
approach to sustainability. NHBC is actively involved in enabling
and facilitating the improvement in the environmental performance
of the house-building industry, new homes and their built environment.
One of the key strands of sustainable development
is "social progress which recognises the needs of everyone".
The effect of the vast under-supply of housing in the UK is that
many people are unable to "get a foot" on the housing
ladder. If more new homes are to be built to address the consequent
social need, then it is essential that they are built to appropriate
standards, taking into account all relevant environmental considerations.
Amongst other things, sustainable principles
demand that houses will not require replacement or major repairs
prematurely—this avoids waste of building materials, effort
and energy. NHBC's fundamental role is to raise the standard of
newly built and converted houses in the UK and this includes their
durability.
2.1 NHBC's Environmental Involvement
NHBC takes the sustainability agenda seriously
and is involved in a variety of schemes to enable the new homes
industry to develop more environmentally sound homes. For example,
NHBC provides energy ratings—a technical assessment of the
energy efficiency of new homes required by Building Regulations.
NHBC also provided funding and continues to work with BRE, the
industry and other stakeholders to develop the "EcoHomes"
scheme, which assesses the sustainability of homes. It has taken
only four or five years to become well established, being both
understood by the industry and a requirement in most social housing.
Additionally, NHBC sets standards, and provides
insurance cover, for contaminated land reuse—a key service
given the requirements within PPG3 for house building to be focused
on Brownfield land. NHBC is involved in the work on a Single Regeneration
Permit, aimed at simplifying legislation and the waste management
process, with organisations including the former British Gas,
ODPM and the Environment Agency.
NHBC also jointly sponsored DTLR's "Preparing
for Floods" document and sat on the Steering Group. Finally,
NHBC sponsored the CIRIA document "Repair of Buildings following
Flooding" and sat on the Steering Group.
3. SUSTAINABILITY,
BUILDING REGULATIONS
AND CODE
FOR SUSTAINABLE
BUILDINGS
In recent years Building Regulations have gone
through a period of particularly rapid change. The scope of regulation
has been expanded, embracing important social issues and is increasingly
addressing environmental and sustainability concerns. Changes
to Part L and the forthcoming introduction of the new Code for
Sustainable Building represent two different but important means
of creating more environmentally sound homes.
NHBC recognises the potential value of the proposed
new Code for Sustainable Building (CSB) and the opportunity it
should offer to incentivise sustainable best practice. However
NHBC stresses the need for absolute clarity about the relationship
and status between Building Regulations and the CSB.
As a technical authority and as an Approved
Inspector certifying almost 60% of homes in England and Wales
for Building Regulation compliance, NHBC has played a very positive
role in informing and shaping regulatory change and delivering
an efficient and consistent Building Control service. Through
our participation in a range of European and UK committees and
forums including the Building Regulations Advisory Committee (BRAC)
we work closely with civil servants and other technical bodies
to ensure that regulations are effectively framed and implemented.
Recently we worked closely with the ODPM and the house-building
industry to establish Robust Details Ltd, an important initiative
to facilitate the reliable implementation of the higher standards
imposed by changes to Part E (Sound).
However NHBC does have some reservations regarding
the current process for revising Building Regulations. Firstly,
each revision to Building Regulations requires significant operational
changes amongst building companies and building control bodies,
and with each change in regulations come costs and additional
risks as practitioners are with increasing frequency given less
and less time to absorb the changes and to ensure proper implementation.
Often the risk to the end user, the homeowner, is not sufficiently
taken into account.
Secondly, it is our view that given the now
routine scale of some recent changes, the civil service resource
in the ODPM may be insufficient to manage the complex and increasingly
wide scope of the work that needs to be done if Building Regulation
changes are to succeed. One way forward would be to build on the
success of the Robust Details framework developed for Part E,
for which we provide the Secretariat. Here the sector demonstrated,
and continues to do so, that with appropriate rigour and controls
an independent regulatory regime can be developed which achieves
excellent compliance levels and provides a good model for the
future.
Thirdly the current framework for developing
Building Regulations gives an important strategic role to BRAC,
which is tasked with advising Ministers on the Regulations. NHBC
has concerns that presently the committee, perhaps partly in light
of the resource issue identified above, seems sometimes to get
drawn too much into the fine detail to the detriment of its strategic
advisory role. In our view a partnership secretariat approach
with tasks delegated to other groups using more private sector
resource, with the committee concentrating on its strategic and
scrutiny roles, might provide a better support for Ministers and
their civil servants, as well as improved outcomes.
4. LPS2020 AND
SUSTAINABLE HOUSE
BUILDING
NHBC welcomes the work BRE is doing to further
sustainability, including to provide a single and consistent method
for assessing the design and performance of innovative building
systems, and indeed we are represented on BRE's newly-formed Sustainability
Board.
NHBC has played a leading role in facilitating
housebuilders to develop non-conventional systems of construction
(Modern Methods of Construction). We have worked closely with
builders and manufacturers over many years, providing technical
expertise and advice in respect of new construction techniques,
for example in relation to timber frame and light steel construction.
In recent months we have developed further NHBC Technical Standards
for Light Steel Frame and Cladding to assist the industry in rolling
out such innovation in a low risk manner. In addition we have
reshaped our inspection service to allow for the inspection of
factory made systems. NHBC has therefore made a real contribution
in assisting major builders such as Barratt, Redrow and Westbury,
as well as manufacturers and smaller builders to bring innovative
systems into the market place.
We believe that appropriate Modern Methods of
Construction have an important role to play in assisting the industry
to develop products and processes to improve efficiencies and
quality.
In the past year we have worked closely with
BRE and other key partners in developing a Quality Assurance Framework
for MMC systems and we will shortly be launching a web site to
assist builders, product manufacturers and others to understand
what certification and accreditation for new methods of construction
is necessary, and to provide a one stop shop for advice in this
area.
NHBC has a unique and important role as both
a standard setting technical authority and as an organisation
that protects the consumer interest. With almost 70 years' experience
we are internationally recognised as the leading model for risk
management for housebuilding and for providing warranty and insurance
protection for new homebuyers. As such we have a unique perspective
on the importance of balancing the opportunities and risks in
construction innovation.
NHBC welcomes well-thought through and robust
innovation as a valid response to the current drive for new homes,
provided that house purchasers are properly protected, by minimising
risk through research, testing and development, focusing on key
issues such as durability and "repairability".
At the recent 10th International Housing and
Home Warranty Conference (IHHWC) held in Tokyo, there was considerable
debate concerning the impact of ill-conceived modern methods of
construction. There were presentations from Canada, New Zealand
and the United States of America concerning examples of MMC systems,
which have proved disastrous for homeowners, house builders, warranty
providers and ultimately taxpayers. The Canadian experience cost
the Canadian Government $1 billion in direct repair costs, with
indirect costs raising the total to $2 billion. Recent research
in Japan into low air change environments have also raised a number
of important potential health issues that need to be understood
more fully.
There are clear lessons to learn from international
experience and from past and current UK examples which we would
be pleased to share with the Select Committee.
November 2005
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