Jeanette Henderson

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					Jeanette Henderson
Sustainable Buildings Division
Communities and Local Government
Zone 2/H6 Eland House
Bressenden Place                                          Our Ref:   SC/CSH
London
SW1E 5DU
                                                          22 October 2007


Dear Ms Henderson

The Future of the Code for Sustainable Homes: Making a rating mandatory


The National Housing Federation represents 1,300 housing associations.                   Lion Court
Collectively our members provide 2 million homes for 5 million people across             25 Procter Street
England.                                                                                 London WC1V 6NY


Housing associations are currently responsible for delivering over 40,000 new            Tel: 020 7067 1010

affordable homes and other acquisitions a year – nearly one in four of all new           Fax: 020 7067 1011

homes built.1 Current housebuilding targets means that one third of all new homes        Email: info@housing.org.uk
which will exist in 2050 will have been built between now and then. This presents        Website: www.housing.org.uk

an opportunity for the housebuilding industry to make real inroads into cutting total
CO2 emissions, by progressively making new homes more sustainable. Carbon
emissions from domestic buildings account for nearly 30% of total carbon emissions
in the UK. In this respect, The National Housing Federation fully supports the Code
for Sustainable homes and its aim of providing a national building framework of
sustainable standards.

The housing association sector has the best track record of building to high
sustainable standards within the wider building industry. Current estimates identify
that 92% of housing association developments in the 2006/08 National Affordable
Housing Programme will achieve ‘very good’ or better using the eco homes
assessment criteria. Housing associations are achieving significantly more than the
odd exemplar scheme – our members are geared up to move across to level three
of the Code for Sustainable Homes (CSH). If fact the Housing Corporation
estimates that 39% of development partners already expect to achieve code level 4.
However we are not complacent with regard to the scale of what needs to be
achieved to further improve standards. By working together with the private sector
these pioneering standards are achievable for the whole housebuilding industry.

However, we believe the government needs to take a firmer approach with private
sector house builders. It is not sufficient that housing associations continue to go
first to ‘’demonstrate’’ to the building industry that it can be done, whilst the code
remains voluntary for the majority of developers who are to be building three in four
of the much increased targets for new homes.

We believe that the demonstration period for building sustainable homes has
already been proven through the response to the Eco homes standards which are
certainly more challenging than many aspects of level 1 or even 2 of the code. Our

1
 England’s Housing Timebomb. Affordability and supply 2206-2011. National Housing
Federation. 2006.
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sector can testify that it was able to achieve ‘very good’ Ecohomes ratings in a
relatively short period of time.

Recommendations

The National Housing Federation is urging the government the Government to
make the code for sustainable homes mandatory for all housebuilders to the same
timetable as housing associations, which would promote the development of new
technologies and produce supply chain benefits for all. The government must have
a significant role in kick starting and supporting the further development of
environmentally sustainable technologies.

The Federation also calls for land, including surplus public sector land, to be gifted
or discounted for affordable home builders in order that the increased cost of
achieving the code does not put them at a disadvantage when competing for land.

The Federation supports the inclusion of the Lifetime Homes Standard in the Code
for Sustainable Homes but wants the same requirements made mandatory on the
same timescales for the private sector.

As a concept the Federation supports the introduction of Energy Performance
Certificates. We would support the sensible integration of the EPC and the Code
rating.

The Federation believes that as an absolute minimum the code’s requirements for
level 3 for surface water run off in high risk flood areas be required for all
developments.

Making a rating against the code

The consultation ‘Making a rating against the Code’ which proposes that all new
homes must show to potential purchasers what levels of sustainability has been
achieved, is a small beginning, but the Federation believes will drive little market
change. Some developers are taking on the mantle but CLGs own figures state that
only 2% of private sector developments are reaching any level of sustainable
building.2 The current high level of cost in building to the code, means that there is
only a niche market for such homes in the private sector. A voluntary code lacks
teeth. We believe that without compulsion the vast majority of new homes will be
zero rated and there will be a missed opportunity in mainstreaming sustainable
building putting under threat the government’s own 2016 target.

This argument is supported by the findings of a recent Chartered Institute of
Building (CIOB) survey3, which states that 45% of senior construction staff say that
the market is not forcing them down the route towards zero carbon buildings, with
24% saying there is no financial incentive in building zero carbon buildings and
20.9% saying there is not enough market demand.




2
 The future of the Code for Sustainable Homes. Making a rating mandatory. P 35.
3
 CIOB. The Green perspective. A UK construction industry report on sustainability. Survey
2007.


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We believe that a zero rating against the code is unnecessary and would be
confusing. A customer would infer there had been an assessment against the code.
Code level 1 is not onerous and can be introduced with minimal cost, indeed it is
proposed that water usage is introduced at level 1 for all homes from April 2008
through revisions to building regulations.4

Building regulations revisions and mandatory requirements

The Federation believes that amending building regulations is the correct means to
underpinning the code for sustainable homes. However it is disappointed that the
current proposed revision will only encompass water usage in the home to
standards equating to level 1 of the code and that the longer term timetable is only
for revisions encompassing carbon emissions. These new mandatory requirements
are a missed opportunity to fully amend building regulations to encompass the code
in its entirety.

CLGs own risk assessment is that introduction of the code standards would only
have a minimal and short term adverse effect on supply. The Federation strongly
believes that until higher environmental standards become the norm for mainstream
building practices we will not effectively tackle climate change in this area, nor
produce long-term cost savings for potential house purchasers.

The CIOB report shows 67% of their respondents believe the Government should
now be compelling the widespread construction of low carbon buildings, through
tough building regulations.

If the code were also mandatory for the private sector, there would be two
significant effects. Firstly, the supply chain for products needed to achieve these
standards would be enhanced leading to significant reduction in the costs.
Currently, associations are disadvantaged due to poor supply chains increasing
costs when building to higher standards. In the case of building for affordable rent
the increased build cost must be borne by the association and balanced against
other priorities. When conducting scheme appraisals the increased build cost can
result in a disadvantage when negotiating land deals. The Federation is concerned
that when our members are consistently outbid on land deals by private developers
who have no requirement to reach even level 1 of the code it is inevitable that there
will be a knock on effect to the supply of new affordable rented homes. We
recommend that gifted or discounted land, including surplus public sector land,
must come forward for development as a means of increasing supply.

The second effect would be to stimulate the development of new technologies
resulting in more effective and efficient products. Whilst associations have been
leading the way an industry wide push would result in more rapid advances.
Government must play its part by providing a role in kick-starting the development
of such sustainable construction technology. It is by raising the volume for demand
for and increasing the range and consumer choice in technologies that will drive
down costs and alleviate the fear of the private sector that building to code levels
would affect supply.



4
    Water efficiency in new buildings. A joint DEFRA and CLG policy statement. July 2007.


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Energy performance certificates

As a concept the Federation supports the introduction of the EPC. We would
support the sensible integration of the EPC and the code rating. However, most of
the information required for an EPC is already held by associations and therefore
the current proposed method of producing certificates is another potential to draw
resources away from building and maintaining energy efficient affordable homes .

Lifetime homes

The Federation supports the inclusion of the Lifetime Homes Standard in the Code
but wants the same requirements made mandatory on the same timescales for the
private sector. The progressive introduction of the Standard at lower levels of the
Code will only be effective if the adoption of the Code to achieve specified levels is
made mandatory or that the requirement to achieve the Standard is introduced
through building regulations. It is proposed that the Standard is made mandatory for
all new homes built as part of the National Affordable Building Programme from
2011 subject to a proposed revision of the Standard and a new cost benefit
analysis. The previous cost analyses varied widely, with some of the costs
associated with the need to revise existing designs. If all homes were required to
include the Standard some of the design costs would be eliminated. The Federation
supports the proposed review.

Flood risk

The Government states that it will ensure that its objectives are met in terms of
directing housing development wherever possible away from high risk flood areas.
The Federation supports the government position that new housing development
cannot be avoided as a matter of course on areas at risk of flooding. Planning
authorities must require that necessary mitigation against flooding is put in place.
The Federation believes that as an absolute minimum the code’s requirements for
level 3 for surface water run off in high risk flood areas be required for all
developments.

In conclusion this letter sets out the National Housing Federation’s response and
highlights some key recommendations with regard to the future of the Code for
Sustainable Homes.

Yours sincerely



Sara Cunningham
Policy Officer
Neighbourhoods

Direct Tel: 0207 067 1078
Email: sara@housing.org.uk




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