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Abandon the current compliance process for Code for Sustainable Homes

Comment 15th July 2010

The Code sets out laudable aims for standards within new homes. However the compliance procedure is very beaurocratic and expensive.

A large part of the cost is hidden in that it is borne by contractors in the accumulation sorting and recording of evidence of compliance. Suppliers of materials are also bearing the cost of demonstrating compliance, including sometimes complex audit trails, which is being passed on in higher prices.

A very large proportion of the standards are subject to other legislation with much duplication of approval. For example energy, water usage, sound resistance between dwellings and domestic waste are all covered by the Building Regulations, site waste management plans are mandatory for projects over £350k. The standards escalator set out in the Code can be dealt with relatively simply by adjustment to the other regulations. The Code also has a number of areas which can be outside the developers control. For example: Density of development, particularly the number of storeys in a building, are subject to planning control with it being very difficult to achieve high levels of Code compliance in some geographical areas under local planning policies and their implementation.

Central Governments Planning Policy Statements could also assist. For example by making it clear that an insistance on single glazing by Conservation Officers is only appropriate on particularly sensistive buildings (Listed grade 1, possible grade 2*, for example).

Additionally under compliance with the Code a number of criteria have been 'fudged'. Heat pumps are efficient heat transfer systems but if the electrical power generation is taken into account they are no more efficient than a gas boiler (or offer lower CO2) but they enable a much higher thermal performance score to be achieved. Similarly larger dwellings score better than small ones as a consequence of geometry. Thermal performance should be based on the number of Kilowatt/years for each person that a dwelling is designed to accommodate, irrespective of heat source and building size.

Why does this matter?

The whole compliance procedure has been designed without any balanced understanding of building construction and usage or of the costs involved.

Removing the need for specific compliance and covering the matters in the appropriate alternative ways that already exist (Building Regulations, Health and Safety, Environmetal Health) would remove a costly element from the building of new homes. This can amount to several thousand pounds and tends to fall more heavily on smaller developments (one or two houses). The cost does not achieve anything that cannot be achieved through normal Building Regulation inspections and planning. It is an unecessary expense that sees no brick laid and inhibits development on marginal sites including those where low final sale costs can be expected or there are high initial costs associated with brown-field contamination. It affects all new houses, whether by large scale developers, self-builders or social housing providers.

If the Code were to be used as a guiding framework for Planning and Building Regulation development it would be more effective and much less expensive and inhibiting on provision of new homes.

Cutting up to ten thousand pounds, sometimes more, from the cost of each new home would allow more house building, particularly in these staightened times, with more jobs.

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