All Change for Housing Standards – Have Your Say

The Department for Communities and Local Government (DCLG) is planning a major shake-up of the way local authorities can specify higher-than-baseline standards for housing built in their area.

If DCLG have their way, gone will be the freedom to apply, for example, Lifetime Homes, Space standards, Code for Sustainable Homes, and the Merton rule (often used to specify a certain percentage of renewable generation in a development) and in their place, a pared-down menu of standards that can be required locally, and all only allowed the basis of rigorous local “needs tests” and “viability tests”.

While the department is consulting on allowing local authorities to continue to be able to set local standards (or quotas) for accessibility, water efficiency and possibly space, they wish to end any local targets for energy and fabric efficiency (saying these are being taken care of by Part L and Zero Carbon). DCLG also want to debar planning authorities from setting requirements relating to for daylighting, sunlighting, or use of sustainable materials – all currently considered in the Code for Sustainable Homes.  At the same time DCLG is also consulting on proposals for Allowable Solutions (the “offsets” portion of the proposed Zero Carbon standards for 2016).

To help AECB members to respond to aspects which they feel strongly about, AECB is publishing some articles looking at the content of the consultations and some suggesting possible responses. The most detailed article is about the proposals for water, as AECB played a part in developing these proposals and of course we have our own Water Standard (see ‘AECB voice heard on water standards – but more pressure needed!’, see below).

Other articles include an overview of the DCLG Housing Standards Review proposals, an opinion piece from member James Livingstone (see ‘’Don’t let DCLG throw out the baby with the bathwater’, below), and to come, a brief overview of the Allowable Solutions proposals.

The articles can be viewed/downloaded here, and further contributions are due to be added, so please check again. You can also view or follow the @AECBnet to see notifications of new uploads

DCLG’s Housing Standards Review documents can be downloaded from the government’s website  and the Allowable Solutions ‘Next Steps’ document  from here

The Housing Standards Review consultation closes on 22nd October 2013, the Allowable Solutions consultation a week earlier on 15th October 2013.

AECB voice heard on water standards – but more pressure needed!

The AECB’s long-standing criticism of the Part L and Code for Sustainable Homes’ system for achieving water savings has at last borne fruit, and for the first time an appliance based standard is being proposed for demonstrating compliance with the Building Regulations.

The AECB’s criticism of the existing compliance method, the water calculator, is that it allows developers to install unnecessarily wasteful hot-water appliances and “offset “ them with very-low-use cold water appliances. It is for this reason that the AECB developed its own water standards, based on a fitting-by-fitting standard.

Screen shot 2013-10-02 at 17.44.13Thanks to the hard work of AECB member Cath Hassell, working alongside the Energy Savings Trust, this argument has now been taken on board by DCLG, who state in their current consultation on housing standards: “the inherent flexibility [of the Water Calculator] allows less efficient hot water using fittings to be offset by more efficient other fittings. In particular, more water efficient cold water fittings such as WCs are often specified to allow higher flow showers to be installed which has a consequent impact on energy use and ultimately household bills”. DCLG has published proposed baseline and higher-level appliance based water standards, to be introduced into the Building Regulations.


AECB was represented by Cath Hassell on the review board set up to advise DCLG on these proposals. While the introduction of an appliance-based standard was successfully agreed, a compromise arrangement means that DCLG still proposes to retain the option to use the water calculator, as an alternative. In addition, the baseline level of water saving proposed is no more stringent that the current part G.

Cath Hassell also points out that the Government has “changed the goalposts” quite dramatically since the review board finished its deliberations. The government appeared during the review board deliberations to accept that Local Authorities ought to be able to impose tighter water savings standards in their areas if they felt it was necessary – so AECB along with the rest of the working group developed both a baseline and a more stringent (and AECB believes, more desirable) water use standard for local authorities to use.

However, Now, DCLG is proposing that the requirement for a higher water efficiency standard within a local plan will only be allowed “after consultation with the local water supplier, developers and the Environment Agency” and only then if it is “consistent with a wider approach to water efficiency as set out in the local water undertaker’s water resources management plan.” In AECB’s view this will be prohibitively onerous and expensive for local authorities to implement, and as a result, they will be unlikely to manage it, and even areas of acute water stress may find they are having to relax water standards, compared to those they are currently requiring, through, for example, the Code.  (Similar difficult conditions are proposed in the Housing Standards Review for other “voluntary” local standards, such as space and accessibility, see ‘All change for housing standards’, above)

AECB will be challenging DCLG on their proposals in its response to the consultation, which closes on October 22. In order to get the best chance for meaningful new water standards to come out of this review, Cath Hassell has written a guide to the DCLG proposals, including the AECB’s responses to the questions on water, and members are urged to read this and put in their own responses. AECB’s response to the DCLG consultation questions on water efficiency can be viewed or downloaded from here along with other information and opinion about the Housing Standards Review.