2013 Response to Housing Standards Review (October)

RESPONSE to QUESTIONNAIRE

Introduction

This consultation paper deals with several technical issues regarding the design and implementation of Housing Standards, many being more relevant to the house-building industry than potential house owners. The sixty-four questions cover a wide range of problems, some not relevant to existing home-owners. Our members are mostly home-owners though there is a substantial minority who are tenants seeking one day to purchase their homes. They all have clear views whether the dwelling they occupy meets their needs, and it is this aspect that has led to the answers to those questions that relate to residents.

The most serious housing problems facing UK citizens are first the unfortunate level of house price inflation - a consequence of past cheap finance - and secondly the failure to provide affordable rented accommodation for those unable to become home-owners. The profit that developers expect from the building of dwellings is of the order of 20%, so with the high price of land for development it is not surprising that on the one hand dwellings have become smaller and on the other hand rented properties are not popular because the developer's capital is then tied up in the property.

To ensure that new dwellings including new-build and property conversions are adequate, it is essential that housing standards are suitably appropriate to meet the needs if not the demands of the public. Underlying this strategy is the need to consider where the finance is to be found. If the standards are too high and the developers still expect a high profit margin, houses - whether for purchase or for renting - will not be built. If they are too low, we shall be saddled with the slums of the future. Dwellings only fit for childless couples will deteriorate rapidly when children arrive unless there are appropriate dwellings available for families. NORA members see the need for housing for a balanced community is a prime necessity. This is partly a housing standards matter but most importantly also a planning policy matter.

Accordingly NORA members are concerned that the recommended housing standards may well be determined more by commercial viability than by necessity. Our response is aimed at defending the need for dwellings that meet the needs of the time and the place, and it is hoped that our answers to the questions relevant to occupiers are helpful in guiding the governmental decisions.

Chapter on Process

Q1 Which of the options (A, B, or C) set out above do you prefer? Please provide reasons for your answers.

NORA members prefer Option C

It would be unnecessarily complex to have a set of recommended Housing Standards as well as a separate list of Building Regulations. Who would monitor the two systems?

Option B - by deferring the final decision - only delays the introduction, and in the interim the standards will fail to be fully implemented. It may take longer to include them in Building Regulations, but once completed, it would be certain.

Q2 Do you agree that there should be a group to keep the nationally described standards under review? Y/N.

Yes.

It is wiser to have a responsible team available to make changes quickly when needed.

Q3 Do you agree that the proposed standards available for housing should not differ between affordable and private sector housing? Y/N. Please provide reasons for your answer.

Yes.

It would be invidious and discriminatory to have a lower standard for 'affordable housing', which would include rented accommodation. It would also be shaming and most undesirable for market housing to be built with less space than that in social housing, which happens in some Local Planning Authorities (LPA).

Q4 We would welcome feedback on the estimates we have used in the impact assessment to derive the total number of homes incorporating each standard, for both the 'do nothing'and 'option 2' alternatives. We would welcome any evidence, or reasons for any suggested changes, so these can be incorporated into the final impact assessment.

No comment

Chapter on Access

Q5 Do you agree that minimum requirements for accessibility should be maintained in Building Regulations? Y/N.

Yes

Q6 a) Is up-front investment in accessibility the most appropriate way to address housing needs, Y/N. if Yes,

b) Should requirements for higher levels of accessibility be set in proportion to local need through local planning policy? Y/N

Yes to both questions.

Conversions of upper floors cannot always comply with accessibility needs regardless of public demands.

Q7 Do you agree in principle with the working group's proposal to develop development of a national set of accessibility standard consisting of a national regulatory baseline, and optional higher standards consisting of an intermediate and wheelchair accessible standard? Y/N.

Yes

Q8, 9, 10 & 11

These questions deal with costings and NORA members are not competent to answer them.

No comment.

Q12 To what extent would you support integration of all three levels of the working group's proposed access standard in to Building regulations with higher levels being 'regulated options'? Please provide reasons for your answer if possible.

a) Fully support.

b) Neither support or oppose.

c) Oppose.

Fully support since this is more efficient.

Chapter on Space

Q13 Would you support government working with industry to promote space labelling of new homes?

Yes.

It is extra-ordinary that a simple matter of including the net floor space of a dwelling in the prospectus of a dwelling for sale or for renting is not mandatory. It is rarely included in planning applications unless the LPA insists on its inclusion. Architects all use computer driven programs for design and always know the square metrage of the dwellings proposed. It surely should be mandatory both in planning applications and in advertisements. The inclusion of the square metrage of properties for sale and for rent in continental EC is almost universal, and it is a key element in decisions taken by prospective residents. NORA members see no reason for it not to be mandatory in England & Wales now.

Q14 Do you agree with this suggested simple approach to space labelling? Y/N.

Yes.

Q15 If not, what alternative approach would you propose?

No answer

Q16 Would you support requirements for space labelling as an alternative to imposing space standards on new development? Y/N

No.

NORA members see no reason for space labeling to be an alternative to imposing space standards. Both could apply. Potential residents could compare what is being offered with what is the statutory minimum standard. Housing Standards should be mandatory and national, and this would ensure that they were not constrained by viability issues or local variability.

Q17 Would you support the introduction of a benchmark against which the space labelling of new properties is rated? Please give reasons for your answer.

Yes, provided it is allied to mandatory minimum space standards.

Potential residents could the compare what is being offered with the minimum standard.

The need to establish benchmarks is overwhelming. Too many poky one and two bedroom apartments have been produced in our towns and cities without adequate space for furniture, storage of clothing, food and waste and for work facilities at home. The abandonment of Parker-Morris standards has led to the downsizing of new dwellings, so much so that householders may need to seek new accommodation whenever their family increases in size. This cannot be conducive to community stability.

A return to minimum space standards such as Parker-Morris standards is vital, and some indication of the desirable square metrage of the various sizes of dwellings must be produced. They would enable planners and prospective householders to assess what is offered. Without standards as a target, developers will never meet the needs and hopes of householders.

Q18 Which of the following best represents your view? Please provide reasons for your views.

a) Local authorities should not be allowed to impose space standards (linked to access standards) on new development.

b) Local authorities should only be allowed to require space standards (linked to access standards) for affordable housing.

c) Local authorities should be allowed to require space standards (linked to access standards) across all tenures.

NORA members support the view expressed in 'c' because it is equitable. The standards should be mandatory, otherwise developers will continue to produce poky and inadequate sized dwellings if there is no obligation to meet specified standards.

Q19 Do you think a space standard is necessary (when linked to access standards), and would you support in principle the development of a national space standard for use by local authorities across England? Y/N

Yes.

And the standard should be mandatory.

Q20 Do you agree with the proposed limiting of the scope of any potential space standard to internal aspects only? Y/N

Yes.

In many instances there may not be any external space or it may so limited in extent that standards could not be applied. On the other hand when external space is available, provided it is not visible from the street, its use for storage of waste must be considered.

Q21 Do you agree that Space Standards should only be applied through tested Local Plans, in conjunction with access standards, and subject to robust viability testing?

Yes.

But the question of 'robust viability' is an issue for developers not for planners or building regulators.

Q22 & 23 These deal with costings and NORA members are not competent to answer them.

No comment.

Q24 & 25 We also need to verify how many local authorities are currently requiring space standards, and what those space standard requirements might be. Can you identify any requirements for space standards in local planning policies? Please provide evidence or links where possible.

NORA members do not have this information.

Q26 What issues or material do you consider need be included in H6 of the Building Regulations, in order to address the issues identified above?

NORA members fully support government wishes to ensure that proper space is provided for the storage of waste.

Q27 Do you agree with this approach to managing cycle storage? Y/N.

Yes

NORA members support the need for appropriate space for cycle storage, but it is expected that the minimum space standards will also ensure adequate space for the storage of other goods such as food, clothing, household goods, push-chairs, Too many poky dwellings have been built since the Parker-Morris standards were revoked, so that such storage facilities are inadequate for everyday family use.

Chapter on Security

Q28 Do you support the view that domestic security for new homes should be covered by national standards/Building Regulations or should it be left to market forces/other?

a) national standards/Building Regulations

b) market forces/other

Where possible, please provide evidence to support your view?

NORA members consider that, since the risks of burglary are so variable and depend so much on the style of dwelling and the design of the estate, it is not feasible to produce standards that would cover all these variables. The best guidance is likely to be provided by the relevant police safety officer, and the decision on the nature of any domestic security left to the householder.

Accordingly there is a place for national standards that would provide objectives as guidance for both planners and developers to consider appropriate domestic security measures where it is indicated.

Q29 Part 1: Do you think there is a need for security standards? Y/N .

Yes.

Part 2: If yes, which of the approaches set out above do you believe would be most effective to adopt (please select one only)?

a): Option 1 - A baseline (level 1) standard and a higher (level 2) standard.

b): Option 2 - A single enhanced standard (level 2) for use in areas of higher risk only.

Option 1 is preferred since all properties need some security to cover doors and windows, but higher levels would be appropriate in areas of high risk.

Q30 If the level 2 standard is used how do you think it should be applied;

a) On a broad local basis set out in local planning policy? Or

b) On a development by development basis?

Option 'b' is sensible, because it provides room for negotiation between developer, planner and householder.

Q31 Do you believe that there would be additional benefits to industry of integrating the proposed security standards in to the Building Regulations as 'regulated options'

Yes.

Q32 If security standards are integrated in to the Building Regulations, would you prefer that;

a) level 1 and level 2 become optional 'regulated options' for use by local authorities? Or

b) level 1 be required as a mandatory baseline for all properties with level 2 a regulated option for use by local authorities?

Provided level 1 is minimal, option 'b' is preferred, because it ensures that some basic protection is provided.

Q33 - Q39 

No comment on costs and designs

Chapter on Water Efficiency

Q40 Do you agree a national water efficiency standard for all new homes should continue to be set out in the Building Regulations? Y/N.

Yes

Q41 Do you agree that standards should be set in terms of both the whole-house and fittings-based approaches? Y/N.

Yes

Q42 Do you agree that the national minimum standard set in the Building Regulations should remain at the current Part G level? Y/N. (see also Question 43)

Yes

Q43 Do you agree that there should be an additional local standard set at the proposed level? Y/N.

No

Q44 Do you agree that no different or higher water efficiency standards should be able to be required? Y/N.

Yes

Q45 Would you prefer a single, tighter national baseline rather than the proposed national limit plus local variation? Y/N.

Yes

Q46 Do you agree that local water efficiency standards should only be required to meet a clear need, following consultation as set out above and where it is part of a wider approach consistent with the local water undertaker's water resources management plan? Y/N.

Yes

Q47 Should there be any additional further restrictions/conditions? Y/N.

Yes

It is to be hoped that, where there are clear indications that the water supply or the drainage facilities are highly likely to be prejudiced by new development, the LPA will exerts its power to refuse planning consent, so that the question of 'further restrictions/conditions' would not arise. Sadly many LPAs grant consent for developments knowing there are problems with water supply or drainage adequacy and pass the buck to the relevant Water Authority and the Environment Agency to solve, even when the agencies have expressed alarm at the proposals.

Q48 & Q49 deal with costs and NORA has no data to offer.

No comment.

Q50 Do you currently require through planning that new homes are built to a higher standard of water efficiency than required by the Building Regulations through:

a) a more general requirement to build to Code Level 3 or above? Or

b) a water-specific planning requirement? And

c) are you likely to introduce or continue with a water-specific water efficiency standard (beyond the Building Regulations) in the future?

Planners should refuse planning consent when water supply is inadequate and drainage facilities are insufficient to cope with more effluent.

Chapter on Energy

Q51 The government considers that the right approach is that carbon and energy targets are only set in National Building Regulations and that no interim standard is needed. Do you agree? Y/N. If not, please provide reasons for your answer.

NORA members agree that no interim standard is needed.

Q52, Q53, Q54, Q55 & Q56

These questions are too technical for NORA members to have a view.

Chapter on Indoor environmental standards

Q57, Q58, Q59 & Q60

These questions are too technical for NORA members to have a view.

Chapter on Materials

Q61 Do you agree that materials standards are best left to the market to lead on? Y/N.

Yes. The choice of materials best used for the style and design in the construction of new dwellings is best left to the architect, the builder and the potential householder. New materials are being produced all the time, and tastes and needs change continually, so set standards are inappropriate.

In some situations, however, such as Conservation Areas and sites adjacent to listed properties, the choice of external materials needs to reflect the presence of neighbouring properties.

Chapter on Process & Compliance

Q62 Which of the above options do you prefer (1, 2, or the hybrid approach)? Please provide reasons for your answer.

NORA members prefer the 'hybrid option'. If the ultimate set of standards is defined at the start, and then introduced in stages, it does mean that developers, planners and building regulators know what the ultimate is to be. If the standards are being developed as time passes, no doubt standards will be determined more by convenience and by viability than by a need for excellence.

Q63 Do you think that moving to a nationally consistent set of housing standards will deliver supply chain efficiencies to home builders? Y/N.

If yes, can you provide estimates and evidence of the level of efficiency that could be achieved?

This is a technical question, but the principle of establishing a consistent set of housing standards must lead to efficiencies in design and material supplies.

Q64 Do you think that moving to a nationally consistent set of housing standards could help reduce abortive or repeated costs during the construction stage of home building? Y/N.

If yes, can you provide estimates and evidence of the level of efficiency that could be achieved?

Yes.

NORA members see that a consistent set of housing standards must improve the efficiency of the house-building programme, though they have no data to confirm this common-sense view.

October 2013                                                Alan B Shrank - NORA chairman