There is a lot of detail to work through in the consultation document and supporting material, which we will discuss with members in formulating our consultation response.
The government confirms that it wishes to move to reduce the number of non-Building Regulations technical standards applying to house building to a minimum (“fewer than 10”) based on the detailed work under the Review.
At a high level the central question posed in the consultation is where, once as many current local and other standards relating to dwelling design and performance as possible have been removed, any remaining nationally accepted standards not currently within Building Regulations should sit. In this respect, the consultation document says:
“The government welcomes views on the following strategic options;
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 [other] technical standards would remain.
It is stated that “the government’s preference, subject to consultation, is option B. We will take your views into account alongside the other questions posed in this consultation document. These will help inform how the system could be shaped in the medium to longer term.”
HBF has argued strongly that option C is the right approach and we will continue to do so, but will need to support our case and consider how such a transition would work in responding to the consultation.
The government also sets out its approach to preventing a future wave of new local technical standards being developed by local authorities. It proposes “that a policy statement issued alongside the outcome of this consultation is likely to be the most suitable means to this end. The statement will make it clear that, going forward, there is a national policy expectation that local planning authorities limit the use of discretionary standards in future to those which are proposed by the Review.” Local authorities would also be encouraged to bring their local plans up to date to align with the new standards.
For the future the government also proposes that the nationally described standards set agreed as a result of the Review “is kept under scrutiny by a group of key partners, who will be tasked with keeping the standard set relevant.” It adds that “If, as a result of this consultation, the government decided to move the standards wholly into the Building Regulations, either now or in the future, the Building Regulations Advisory Committee would fulfil this function, as now.”
For future clarity – and to complement the Taylor Review on planning practice guidance – the government “proposes to host the nationally described standards, if taken forward, on a central portal enabling [this] ease of access and use.”
The consultation seeks views on the specific recommendations emerging from work on specific standards areas under the Review – relating to Accessibility, Space, Security, Water efficiency, Energy, Indoor environmental standards, Materials and Process and Compliance.
The single most contentious area on specific standards relates to Space – where HBF has argued consistently that there is no case for minimum internal space standards to be applied to new build homes for market sale.
The government says on Space that it “does not have a preferred approach on space standards at this time, or how they would operate exclusively with access standards, and takes the view that further work will be necessary to develop improved analysis if a space standard is to be taken forward including further exploration of areas which impact on the cost of affordable housing.
“In consulting on this issue, government is making no commitment to the introduction or use of space standards and will consider responses to consultation before deciding how to proceed.”
It also states that:
“Overall, it is clear that in many respects the market is performing well in the absence of national space standards and government’s preference remains for market led solutions. Therefore, given the views of the review working group we are keen to consult on whether an industry-led voluntary space labelling scheme could sufficiently address stakeholder concerns or whether a baseline standard may be necessary and what that standard should be.”
The consultation goes on to seek further views on whether space standards are necessary or desirable and, if so, to which tenures they should apply and how they should be formulated. The consultation additionally seeks views on whether any specific standards relating to accessibility requirements that might be agreed should also be expressed in terms of minimum space standards.
On Energy the consultation proposes that in future “carbon and energy targets are only set in National Building Regulations and that no interim standard is needed”.
Finally, the ground covered by the Review also raises the question of the future of the Code for Sustainable Homes. The consultation document does not approach this question as a specific headline topic, but the overview does state (paragraph 40) that:
“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. We will put in place transitional arrangements to ensure that contractual commitments under the Code can be properly covered.”
HBF will be organising member meetings to discuss the Review recommendations and to help formulate our response to the consultation and will be in touch about this separately. We would also encourage members to respond in due course to the consultation in their own right based on the general line developed through our member meetings.
To unsubscribe, simply click the following link: Unsubscribe
Please do not reply to this email. It has been sent from an email address that does not accept incoming emails. To contact us please email firstname.lastname@example.org