1 Introduction |
Housing Standards Review
1. The Housing Standards Review (HSR) was launched
by the Department for Communities and Local Government (DCLG)
in October 2012. It was a fundamental review of Building Regulations
and voluntary housing standards. The aim was to rationalise codes,
standards, rules, regulations and guidance, which DCLG judged
"add unnecessary cost and complexity to the house building
standards included the Code for Sustainable Homes (CSH), Lifetime
Homes, Secured by Design, the London Housing Design Guide and
local space standards.
2. The HSR was underpinned by DCLG's rationale:
The house building process is difficult in itself,
but it is not assisted by the large and complex range of local
and national standards, rules, and Codes that any developer has
to wade through before they can start building. Across the sector
it is a widely acknowledged that there is a strong case for a
review of housing standards, to rationalise and simplify them,
and to decide what is fit for purpose.
Some witnesses to our inquiry agreed in principle
with DCLG that the overall housing standards regime was not currently
fit for purpose. For example, the National Housing Federation
(NHF) highlighted the "widespread industry consensus during
the review of the need for, and the potential to, rationalise
point was echoed by other witnesses representing a range of interests
related to home building.
However, we heard differing views on which standards should be
amended or scrapped and what, if anything, should take their place.
3. The HSR was completed in August 2013, at which
point DCLG announced a consultation on the review's findings.
This Report is intended to feed into that consultation with specific
reference to the CSH. Peter Schofield, Director General, Neighbourhoods
Group, DCLG, confirmed that DCLG is "keen to hear the views
of the Committee."
Code for Sustainable Homes
4. Launched in 2007, the CSH is a method of assessing
the environmental performance of new homes. Our predecessor Committee
scrutinised and championed the introduction of the CSH in its
Report on sustainable housing in 2006.
The CSH is applied in England, Wales and Northern Ireland, but
it is not used in Scotland, where housing policy is devolved.
It was developed to encourage continuous improvement in sustainable
home building. In particular, it was designed to reduce carbon
emissions and to promote higher standards of sustainable design
than the minimum standards set out in Building Regulations. Approximately130,000
homes have been built to the CSH since its launch in 2007. In
2012, 39% of new dwellings completed in England, Wales and Northern
Ireland achieved one of the various levels of CSH compliance.
5. The CSH covers nine categories of sustainable
design: energy and carbon emissions, water, materials, surface
water run-off, waste, pollution, health and well-being, management
and ecology. It includes mandatory performance requirements in
six of the nine categories, namely energy and carbon emissions,
water, materials, surface water run-off, waste and health and
well-being. Performance requirements are flexible in the other
three categories. When new homes are assessed against the CSH,
they are awarded an overall level between zero and sixlevel
six is the most sustainabledepending on the standards achieved
in each category.
6. CSH assessments are carried out in two phases.
First, an assessment is carried out at the design stage. This
is based on detailed documentary evidence and commitments, which
results in an interim certificate of compliance. Secondly, final
assessment and certification is carried out following construction,
which includes the examination of site records and a visual inspection.
A recent DCLG report pointed out that the CSH assessment process
leveraged sustainability into developments from the planning stage
onwards, which is not the case with post-construction Building
Unlike Building Regulations, the CSH incentivises
developers and designers to think about sustainability from the
outset and throughout the development process.
7. The CSH is applied both compulsorily and voluntarily
depending on local circumstances. The Welsh Assembly Government,
the Northern Ireland Executive, the Homes and Communities Agency
and some local authorities make the CSH a mandatory requirement
in certain cases: all new housing funded by the Homes and Communities
Agency must meet CSH level 3; all new housing promoted or supported
by the Welsh Assembly Government or its sponsored bodies must
meet CSH level 3; all new, self-contained social housing in Northern
Ireland must meet CSH level 3; and some local authorities specify
a particular level of CSH compliance as a condition of granting
planning approval. Equally, some home builders voluntarily comply
with the CSH, because they want to build sustainable homes.
8. The HSR consultation set out three options on
the reform of housing standards:
A. whether government should develop a nationally
described standards set which would operate in addition to the
Building Regulations (where rigorous local needs and viability
testing indicated it could apply);
B. whether government should develop a nationally
described standards set as a stepping stone en route to integrating
standards into Building Regulations at a future date;
C. whether the government should move now to
integrate standards directly into Building Regulations, as functional
tiers, and no technical standards would remain at all outside
of the Building Regulations system, recognising that this will
take time and may require legislative change.
The government's preference, subject to consultation,
is option B.
DCLG described the three options as "a proposal
that removes unnecessary bureaucracy but still retains the standards
required to enable high quality sustainable housing to be built."
9. Several witnesses questioned the nature of the
choices set out in the HSR consultation. The Building Research
Establishment (BRE), which manages the CSH under contract to DCLG,
The Housing Standards Review is not allowing
true consultation on issues that matter. If you look at the document
itself, it is very much a multiple-choice exercise of saying,
'Is it A, B or C' and not necessarily allowing the industry to
express their views in terms of, 'How do we achieve these challenging
targets that we know we need to achieve for improved housing,
and how do we do it in a way that engages the industry?'
The Local Government Association (LGA) expressed
a similar view:
The overall goal was to 'rationalise' what was
described as 'an untenable forest of codes' and so on that add
unnecessary cost and complexity to the house building process,
to report by a timescale that was not in the end met, and the
aim was to achieve deregulation. Those terms of reference will
take one in a particular direction. If the terms of reference
had been, 'How can we build fantastic homes for the next generation
in a way that is viable?', the outcome might have looked slightly
10. DCLG described options A, B and C as "a
proposal" rather than, for example, "three separate
differences between the three optionswhether, when and
how a national code of standards should be included in Building
Regulationswere less striking than the similarities. All
three options entailed stripping away regulation and setting minimal
baseline standards. Options A, B and C were tactical rather than
11. The HSR consultation addressed the fate of the
CSH in a single paragraph:
With regard to the Code for Sustainable Homes,
as already noted this has been considered as part of the review.
Where there are significant issues for carrying forward, these
have been reflected in the consultation proposals. In the light
of that, and the outcome of this consultation, the government
proposes to wind down the role of the Code.
The HSR consultation did not include a specific question
on the impact of winding down the CSH. That approach does not
appear to go with the grain of the DCLG Business Plan, which details
DCLG's commitment to
put local people and communities in charge of
planning so they can determine the shape of the neighbourhoods
in which they live, ensure that regulations support our ambition
to drive sustainable economic growth and development, including
our ambitions for a low carbon and green economy.
DCLG may have overstated the case in dismissing the
CSH as "unnecessary bureaucracy".
Retaining and evolving the CSH may offer a better way of driving
incremental increases in sustainable home building than the proposed
options set out in the HSR consultation. Part 2 examines the costs
and benefits of DCLG's proposed approach compared with maintaining
and evolving the CSH.
1 DCLG, Housing Standards Review, Consultation description (August 2013) Back
DCLG, Housing Standards Review, Consultation (August 2013), para 3 Back
DCLG, Housing Standards Review, Consultation (August 2013), para 1 Back
National Housing Federation (CSH 032) para 3.1 Back
Alliance for Sustainable Building Products, Home Builders Federation,
Wienerberger Ltd, National Federation of Roofing Contractors,
Local Government Association Back
Environmental Audit Committee, Fifth Report of Session 2005-06, Sustainable Housing: A Follow-up Report, HC 779 Back
Building Research Establishment (CSH 025 BRE) Summary Back
DCLG, Code for Sustainable Homes Case Studies: Volume 4 (August 2013), para 10.2 Back
DCLG, Housing Standards Review, Consultation (August 2013), paras 38 to 39 Back
DCLG, Housing Standards Review, Consultation (August 2013), para 40 Back
DCLG, Business Plan 2012-2015 (May 2012), para 5 Back