The Local Housing Delivery Group – Standards, Standards, Standards – what a poor report #NPPF
The second output of the Local Housing Delivery Group
set up in 2011 to respond to the Government’s challenge to boost the delivery of new homes, to simplify housing standards where possible, and to support growth and high standards in home building by helping local authorities and developers find agreed ways in which they can fulfil their obligations under the new National Planning Policy Framework (NPPF).
Unlike the other report on viability – which produced a finished usable out of the box product this report is just a report on problems (‘an interim report’) and seems poorly informed.
I note that no-one on the delivery group seems to be a designer of homes so it is no wonder sad to say, though there were a couple of architects on the standards working. group.
Grant Shapps had earlier proposed a muddles and unworkable ‘local standards framework’
conceived as a clearly costed menu of standards from which planning authorities would be able to select priorities, the overall intention being that the effect on viability of individual developments would be more transparent and more widely understood.
But as many standards will immediately come off the price of land or enable major savings in energy this effort would have been meaningless.
the proposal for a costed menu as originally conceived was rejected due to a lack of support.
The report indentifies the 10 most common standards and then focuses on four areas for further work. The interaction of the standards was identified as a key cause for concern.
It became apparent from the submissions made by the standards’ owners that they have often been developed for good reasons in response to specific needs or concerns. However some did appear to us to have been created in isolation and without regard to other initiatives. There is criticism of the way in which some standards have been developed, operated and maintained, and the way in which the same requirements may need to be ‘ticked off’ more than once to satisfy multiple standards.
On the subject of accessibility they propose a two or three-tier accessibility model to replace lifetime homes etc. The group seems unaware of the considerable work on a British Standard for accessibility which would do just that. No disability reps on the group which would have told them that immediately.
On Energy it proposes to replace the Merton rule – about time too as it conflicts with the direction of travel of building regulations and has encouraged counterproductive tokenist interventions like microgeneration on roofs which create far more carbon in their lifetime than they will ever recover. No mention though of the massive work done through the Zero Carbon hub to replace the CSH. Again no expert on the working group – why not someone from BRE?
On Security the report is rightly critical of the Secured by Design Approach as they can conflict with good spatial design. But again the report fails to recognise that the DCLG commissioned a design guide to replace secured by design and integrates with good urban design, as it was written by some of the same people that did the Urban Design Compendium. Again no specialist. We are building up to an omnishambles here.
On Water efficiency it sensibly recommends that part G have varying standards depending on local water stress. But again no Environment Agency Rep.
The bibliobiography is full of holes, no evidence base identified for car parking standards. Err what about the major report on this commissioned for the DCLG and several other private research programmes.
What needed to be done is for the government to set out its policy objectives and then commission a firm piece of research identifying how these could best be delivered through an integrated set of standards – whether b regs planning, funding whatever. Practically I think this would require an integrated design manual as well as the two areas are so closely linked. The model here is the London Housing Design Guide and Levitt Bernstein’s ‘Easi-Guide to Good Housing Practice’. Then a firm work programme should have been set out including key stakeholders by regulatory sector integrating with in a programme management approach parallel initiatives such as the Zero Carbon Hub.
This report is a classic example of how you shouldn’t expect House builders to regulate themselves. They have no incentive to build sustainable, roomy, accessible homes. The report is shoddy, poorly informed and has already pissed off many many bodies such as the UK Green Building Council. It also shows how the ‘light touch’ approach to regulation by DCLG is a failure. What was the DCLG rep doing at the meeting their seems to have been no attempt to steer it back on course. We expect better from our taxes.