Housing Standards Review (II)
For the past two years the Government has been working to rationalise the various technical standards and allied requirements that can apply to new housing projects. The proposed changes to the Building Regulations cover access, security, water and space standards. This consultation on draft technical standards, practical matters of implementation and proposed transitional arrangements closed on 7 November 2014.
Objectives of the consultation
The proposed requirements and national standards replace a variety of existing rules, each with different arrangements and costs for checking. Consolidating the requirements into the Building Regulations’ system, will bring a simple, single compliance process, reducing bureaucracy and cost.
The proposals include new “optional requirements”, which will form part of the Building Regulations but which local authorities will only be able to implement once they have demonstrated a justification for including such a requirement in their area, covering need and viability, through planning policy which will be subject to the normal examination process. Supplementary planning guidance alone will not be sufficient to implement the optional requirements.
Once the requirement is covered by the local authority plan, then it may be implemented through a planning condition on a scheme by scheme basis when planning permission sought. Authorities will be expected to set out as clearly as possible in their plan the circumstances under which they will apply the optional requirement. In the case of appeals, the usual route will apply.
The consultation describes how the new system will be implemented and the proposed transitional arrangements. It is intended that these proposals will be implemented during the course of 2015 once, subject to Parliamentary approval, the Deregulation Bill receives Royal Assent. This Bill contains provisions to amend both the Building Act (1984) and the Planning and Energy Act (2008) to enable the introduction of the new system of optional standards and requirements. The provisions add a new section to the Building Act covering the legal power to introduce optional requirements through Building Regulations, and the removal of the powers in the planning energy act relating to local authorities requiring renewable energy provisions for housing schemes. However, this latter provision will only come into effect once the zero carbon homes standards comes into effect, which is currently intended to be in 2016.
The consultation package included drafts of revised sections of the Approved Documents covering water efficiency, requirement G2, and solid waste storage, requirement H6. It also included a new Approved Document Q covering Security, with an optional requirement Q1 for Unauthorised Access. There was a Nationally Described Space Standard and new requirements for access for wheelchair users and others with reduced mobility. Finally, there was a Technical Consultation document describing the whole package, and an updated impact assessment. To download all documents follow the links below.
CIBSE response was developed with input from members of the Homes for the Future Group who met in late September and discussed the proposed changes. It was agreed that the questions in the consultation form were insufficient to address the full impact of the Housing Standards Review, therefore in addition to the questions asked CIBSE highlighted the following strategic impacts:
Access for operation and maintenance of building services installations - CIBSE recommended that specific mention is made to the need to provide adequate space for the installation, operation, maintenance, repair, removal and replacement of building services systems in any nationally recognized space standards that may be implemented.
Assessment of daylight - The total absence of any reference to daylight in the draft space standard is a serious concern and the Society of Light and Lighting, which is a part of the Institution, offered to meet with the Department to explore suitable ways to address this in the future.
Overheating risk – CIBSE recommended that technical standards are prepared to better evaluate overheating risk so that future designs can incorporate appropriate measures to reduce risk.
Enforcement of compliance - CIBSE recommended that greater attention be given to ensuring on site compliance with building standards, especially at a time when local authority resources are constrained and new skills in low carbon technologies are required for Building Inspection services, both for the public sector and private sector.
To read the full CIBSE response, please follow the link below.
Results of the consultation and next steps
Department for Communities and Local Government (DCLG) published the summary of responses to the HSR consultation on 27 March 2015. To download the summary report, please follow the link below.