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A Reformed Decent Homes Standard for Social and Privately Rented Homes Consultation

A Reformed Decent Homes Standard for Social and Privately Rented Homes Consultation

 

Executive Summary

 

  • CIBSE are in support of the general direction i.e. 1) upgrading standards, and 2) aligning expectations in the social and private rented sectors i.e.:
    • the social rented sector would now be subject to MEES; the current requirement (EPC F!) is wholly inadequate to reduce fuel poverty and provide healthy and comfortable homes.
    • the private rented sector would now be subject to the DHS. 
  • We agree that the fabric criterion should be used (out of the several proposed new EPC metrics), to reduce fuel poverty risk. In the detail, CIBSE’s support to applying MEES in the social rented sector is conditional to our points made in the EPC consultation, including the fact that the proposed fabric metric, FEES, is highly theoretical and not measurable: we recommend alternative metrics should be used to effectively drive fabric performance [l https://www.cibse.org/media/fpccujez/reforms-to-the-epbr-cibse-response-rev1-submitted.pdf ]. We would also point to the work of the National Retrofit Hub on MEES and how they could deliver health, fuel poverty and comfort outcomes [https://nationalretrofithub.org.uk/resource/delivering-for-tenants-what-is-needed-from-the-minimum-energy-efficiency-standards-to-deliver-the-health-fuel-poverty-and-comfort-outcomes-needed-for-renters/ ]. In particular, we support their points to CIBSE’s on the need for ambition and monitoring outcomes.
  • CIBSE support the inclusion of new damp and mould requirements, in principle. However, these will rely on the HHSRS, which has not been updated for two decades. We recommend that more information is provided, possibly with a further review, to ensure that the HHSRS bands, and therefore the DHS requirements, are based on the latest evidence. We would also recommend liaising with the UK Centre for Moisture in Buildings, for the latest evidence and information on assessment techniques.
  • CIBSE recommend more attention to air quality and ventilation (beyond the measures that may be implemented in relation to damp and mould):
    • We welcome the addition of mechanical ventilation systems in the list of items that must be kept in a good state of repair, but recommend that 1) this is expanded to all ventilation systems (e.g. including local extract fans), and that the definitions are expanded to ensure a good state of operation, not just basic state of repair (e.g. a system may switch on but still provide inadequate ventilation). This should contribute to reducing the risk of damp and mould, but will also contribute to broader air quality, and possibly summer thermal comfort.
    • The standard should ensure that adequate ventilation is provided (not just that ventilation systems are in a good state where they are already present).
  • CIBSE recommend more attention is placed to the standards required of electrical systems, which have evolved significantly in the two decades since the DHS was last updated.
  • CIBSE support the introduction of requirements for window safety, but would highlight the following:
    •  the need to avoid increasing overheating risk if restrictors are not well thought-through and excessively restrict air flow, and
    • the opportunity, through measures that improve window safety, to also improve ventilation and/or reduce overheating risk e.g. if these measures also allow secure openings (i.e. against external intrusion), and/or provide shading. 
  • We strongly recommend to review the reliance on the HHSRS to limit overheating risk, and the option to strengthen DHS requirements. As pointed out by MHCLG themselves in relation to damp and mould, the HHSRS is a backstop when things go wrong, but prevention and mitigation measures should be considered instead, especially passive ones which provide resilience and do not create a risk of increased energy costs and fuel poverty. This is particularly important given evidence that overheating is more prevalent in households living in social housing, with low incomes or with members aged over state pension age [Lomas at al, 2021[1]]

    [1] K.J. Lomas, S. Watson, D. Allinson, A. Fateh, A. Beaumont, J. Allen, H. Foster, H. Garrett,

    Dwelling and household characteristics' influence on reported and measured summertime overheating: A glimpse of a mild climate in the 2050's, Building and Environment, Volume 201,

    2021, 107986, ISSN 0360-1323,https://doi.org/10.1016/j.buildenv.2021.107986.

    (https://www.sciencedirect.com/science/article/pii/S0360132321003905)

     

    This consultation closed on the 10th September. You can see the CIBSE response here.Email Towards a new London Plan lin
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