Age Concerns response to The future of the Code for Sustainable Homes making a rating mandatory

Transcription

1 Ref: 4007 Age Concerns response to The future of the Code for Sustainable Homes making a rating mandatory October 2007 Gillian Connor gillian.connor@ace.org.uk Policy Unit, Age Concern England, Astral House, 1268 London Road, London SW16 4ER. Registered charity no

2 2 About this consultation The Government is consulting on whether to make the Code for Sustainable Homes (introduced in April 2007 for new-build homes) mandatory. If this goes ahead, developers would be required to indicate to a buyer whether a home had been assessed against the Code. The Code aims to give buyers of new homes better information about the environmental impact of their home and its potential running cost. Homes are awarded a 1 to 6 star rating based on nine sustainability criteria. The essential sustainability criteria in the Code are: Energy/CO2; Water; Materials; Surface Water Run-off; Waste, household and site waste. The optional sustainability criteria are: Pollution; Health and well-being (including Lifetime Homes); Management; and Ecology. In addition, the consultation seeks views on whether to make the Lifetime Homes standard a mandatory element of the Code (on a phased basis). At present, a home can score the highest rating, six stars, but still not be built to the Lifetime Home standard. The standard comprises 16 criteria and aims to make living in a home as easy as possible, for as long as possible, through thoughtful design. About Age Concern Age Concern is the UK s largest organisation working with and for older people. Four national Age Concerns in England, Northern Ireland, Scotland and Wales and a federation of over 400 local organisations work together to promote the well-being of all older people. Our work ranges from providing vital services to influencing public opinion and government. Every day we are in touch with thousands of older people from all kinds of backgrounds enabling them to make more of life. The Age Concern England Policy Unit develops public policy proposals on ageing and older people with respect to England and UK-wide policy. We influence Government, public bodies and professional organisations by commissioning and undertaking research, responding to consultations, liaising with decision makers, holding policy events and developing partnerships with other organisations. Most of our policy responses and summaries are available to download on our website: All rights reserved. Third parties may only reproduce this paper or parts of it for academic, educational or research purposes or where the prior consent of Age Concern England has been obtained for influencing or developing policy and practice.

3 3 Policy Unit, Age Concern England, Astral House, 1268 London Road, London SW16 4ER. T: E: Registered charity no Key points and recommendations In summary, Age Concern believes that: the best way of implementing the Lifetime Home standards is to incorporate it into building regulations until it is possible to do the above, the Code for Sustainable Buildings should be mandatory and Lifetime Homes standards should be essential criteria of the Code, as suggested in the consultation paper the Lifetime Home standard should be introduced as essential criteria at a much lower rating of the Code than proposed. The Government s pledge to build three million new homes by 2020 represents an opportunity to build many new homes to the Lifetime Homes standards. We recommend that: Implementation of the Code, and specifically the Lifetime Homes criteria, needs to be monitored closely to gauge its effectiveness, especially as the Lifetime Homes standards are not necessarily a priority consumer concern at present The Government needs to ensure that builders/developers clearly set out the level at which they meet the Code rather than make generic statements about building to the Code Local authorities should be encouraged to use the Code to lay down minimum criteria for planning permission for new residential developments, and legal assurances may be needed to encourage this Up to date published research and good practice on the costs of building to Lifetime Homes is needed to ensure there is an informed debate about the cost of building Lifetime Homes.

4 4 1. Introduction Age Concern welcomes the opportunity to respond to the consultation on Lifetime Homes. We, like other organisations concerned with the housing of older people and people with limited mobility, are very pleased that accessible housing and the Lifetime Homes standards are beginning to prompt Government action. We also welcome the wealth of evidence in the Code pointing to the benefits of Lifetime Homes, which we do not repeat here. We have therefore tried to keep our general comments brief and have tried to consider each of the questions posed in the consultation in turn. However, we must stress that we see the inclusion of Lifetime Homes within the Code as an interim measure only. We believe that the most effective way of increasing the number of homes built to this standard is to incorporate the Lifetime Home standard into building regulations. Indeed, the Government pledged in 2005 that it would seek to do just this 1. We have outlined briefly why we think the Code is not the most effective means of implementing the Lifetime Home, and of implementing them correctly. But if the Code proposals do go ahead then we have indicated our preferred way forward and we would be very keen to be involved and consulted on any further Code developments. 2. General comments Overall comments Age Concern believes that the best way of implementing the Lifetime Homes standards is to incorporate them into building regulations until it is possible to do the above, it would be helpful in the interim if the Code for Sustainable Buildings was mandatory and if Lifetime Homes standards become essential criteria of the Code as above the Lifetime Homes standard should be introduced as essential criteria at a much lower rating of the Code than proposed. If they are not essential criteria of level 4 of the Code until 2010 and level 3 until 2013 then very few homes are likely to be built to the Standard in the next few years. This represents a missed opportunity in terms of the house-building programme proposed for the next decade. 1 Opportunity Age, Department for Work and Pensions, 2005

5 5 Issues not covered elsewhere in our response implementation of the Code, and specifically the Lifetime Homes criteria, needs to be monitored closely to gauge its effectiveness. The Lifetime Homes standards is not necessarily a priority consumer interest concern at present. Environmental issues can resonate with consumers especially when there are cost savings associated with energy efficiency. The benefits of Lifetime Homes are less likely to be felt in the immediate future. It is important to test how well consumers respond to this element of the Code. potential buyers need very clear information on the Code and on Lifetime Homes so that they can make informed choices. The Government needs to ensure that builders/developers clearly set out the level at which they meet the Code rather than make generic statements about building to the Code which could risk misleading the consumer if the home has only been built to level 1 of the Code, for example. We would welcome clarity on whether local authorities would be legally permitted to use the Code to lay down minimum criteria for planning permission for new residential developments. We would welcome this. However, we have heard of some local authorities, for example LB Southwark and Cambridge City Council, who have attempted to make Lifetime Home standards a pre-requisite of planning permission being over-ruled by the Planning Inspectorate. We would like to see up to date published research and good practice on the costs of building to Lifetime Homes. We believe the question of cost has not been given adequate attention in the paper and that it suggests that higher cost and space standards are automatically associated with Lifetime Homes. 3. Our responses to the specific consultation questions Q1: Do you agree that a rating (not an assessment) against the Code for Sustainable Homes should be mandatory for all new marketed homes from April 2008? Yes. We agree a rating should be mandatory. This would help to promote awareness among consumers. We recommend that an assessment should also be mandatory, so as to encourage builders to build all new properties to at least some of the Code s requirements. We note that current take up represents only around 2% of private new homes built each year. A mandatory assessment could help to create a level playing field in the building industry and could be phased in according to an agreed and workable timescale. If the Government is serious about our ageing society, it should not leave the responsibility of ensuring more sustainable homes to the market, and to developers.

6 6 Q2a: Do you agree that where homes are not assessed against the Code for Sustainable Homes, potential buyers should be given a document which clearly states that it has not been assessed? Yes. This would at least alert the buyer to the fact that a Code exists and that the builder has chosen not to be assessed against the Code. If an assessment against the Code is not made mandatory then we suggest that buyers should be able to request an assessment themselves before they proceed with a sale. Buyers should be explicitly made aware of this right, although we recognise that the cost would probably fall on the consumer. Q2b: Would you prefer that this document is: a) a zero star certificate; or b) a standard letter? Age Concern believes that a zero star certificate (option a) is probably preferable if an assessment against the Code is not made mandatory. Again, we feel this would act as an incentive to developers to build homes to at least some of the Code s requirements. Q3: Do you agree that, before we make rating against the Code mandatory, we should require that all Code assessor organisations (or self-employed individuals) are able to provide Code and EPC services as a single package? Yes. We believe the system should be as straightforward as possible for the consumer. Q4a: Do you agree that the Home Information Pack would be an appropriate mechanism for ensuring homebuyers are provided with a rating against the Code for Sustainable Homes? If Home Information Packs are to be made a legal requirement for all marketed homes, as intended by the Government, then this seems to be a sensible way to raise awareness of the Code among buyers. Q4b: Do you think it is necessary to have legislative powers to ensure that both design stage and post-construction certificates are given to homebuyers? Yes. Certainly in relation to the Lifetime Homes standards, we are aware that actual implementation is not always consistent and that the standard is subject to interpretation. In London, for example, despite a planning target of 100% Lifetime

7 7 Homes, we understand from the Greater London Authority and London boroughs that post-construction inspection indicates the final home does not always conform to the standards. Q5a: Do you agree there should be a transitional period for the introduction of a mandatory rating against the Code? We would prefer that the Code is made mandatory as soon as possible for all new homes but we recognise there may be practical issues to consider in doing this. Q5b: If there is a transitional period, should this come into effect for new homes that either: See Q5a. apply for planning permission after April 2008; or reach the Initial Notice, Full Plans or Building Notice stage of the building control notification process after April 2008? Q6: Do you agree with our analysis of the likely demand for assessments and that there will be sufficient Code assessors available? Age Concern does not feel qualified to comment on this matter. Q7a: Do you agree with the principle that the Code for Sustainable Homes should be changed to reflect the changes to the building and other regulations? Yes, we agree that this seems sensible and that it would be a sign to consumers that the developer is striving to do more than is legally expected of them. Q7b: Do you agree that the Code for Sustainable Homes should be revised in light of changing Building Regulations in 2010? Yes, we agree for the above reasons. Q8a: Do you agree that Lifetime Homes standards should be mandatory in the Code? Yes. We argued in response to the initial consultation on the Code that Lifetime

8 8 Homes standards should be made mandatory within the Code. We have always viewed incorporation into the Code as an interim step as we believe that Lifetime Homes standards should be incorporated into Building Regulations. We are concerned that CLG believes that the Code over time, [will] make it the norm to do so without resorting to additional regulatory intervention. We are not convinced that consumers appreciate the potential (sometimes long-term) benefits of Lifetime Homes. Unlike energy efficiency measures, the benefits of Lifetime Homes are less likely to be felt in the immediate future. We therefore believe that mandatory standards are necessary. Q8b: Do you agree that Lifetime Homes standards should be mandatory at progressively lower levels of the Code starting with level 6 in 2008, level 4 in 2010 and level 3 in 2013 No. We do not think there should be a staged introduction, particularly as so many new homes will be built between now and 2020 and our population is ageing (for example, the number of older people aged 85 and over is to increase by 2/3 by 2026 alone). If the Lifetime Homes standard is not an essential criteria of level 4 of the Code until 2010 and level 3 until 2013 then very few homes are likely to be built to the Standards in the next few years. This represents a missed opportunity in terms of the huge house building programme proposed for the next decade. GC/October 2007