responsible sourcing concerns over plans to scrap cfsh
The Code for Sustainable Homes was first launched in 2005 and ranks new homes based on their environmental impact and energy efficiency, on a scale of level one to six, with six being the highest achievable rating. Social landlords must currently build homes to at least level three to secure grant funding from the Homes and Communities Agency. In the recent Housing Standards Review consultation, the Government announced plans to scrap the Code for Sustainable Homes because it argues that the prescriptive rules are too complicated, frustrate house-builders and delay developments.
Instead, the Government aims to meet its 2016 target for zero carbon new homes by revamping Part L of the Building Regulations and introducing Nationally Described Housing Standards. The next update to the Part L regulations is due to take place in April 2014 and this intermediate step will see just a 6% increase in thermal efficiency compared with the levels set in the Part L revision in 2010. This means the final re-write of Part L in 2016 will need to make a significant leap to reach the zero per cent target unless the Government opts to extend the zero carbon target deadline beyond this date.
The proposal to scrap the Code for Sustainable Homes has been met with concern by an influential group of MPs in the Environmental Audit Committee, who believe this will reduce environmental standards in housing to the lowest common denominator. They argue the Code has been very successful in driving up housebuilding standards and has been instrumental in creating a sustainable construction industry in the UK.
However, at the same time senior construction industry professionals from the Home Builders Federation and the Federation of Master Builders have fought back against this group of MPs, saying that the Code for Sustainable Homes is out of date and overly complex and it is time to get rid of it altogether.
What will it be replaced with?
Whilst Marley can see the views from both sides, our main concern about the plans to scrap the Code for Sustainable Homes is the fact that it isn’t being replaced with anything to encourage builders and developers to use sustainable or responsibly sourced materials. There is a danger this could drive down the quality of design and construction and limit the investment manufacturers put into developing sustainable products.
Over time, manufacturers have invested considerable resources into improving the sustainability of products both through reducing their environmental impacts and adopting the responsible sourcing of the key raw materials. At the moment, the Code for Sustainable Homes helps to support this because there are two areas of credit for sustainability of materials, MAT 1 covers the environmental impact of materials and MAT 2 covers the responsible sourcing of the materials. This incentivises specifiers and house-builders to use products like ours that can both achieve an A+ rating in the BRE ‘Green Guide to Specification’ and are responsibly sourced in accordance with BES 6001. However, if the Code is scrapped, then the Government is proposing to exclude construction materials in the new Nationally Described Housing Standards that will be brought in alongside changes to Part L. However, non-housing developments will still be able to gain materials credits under BREEAM.
The Government argues that materials are adequately covered by existing standards but this isn’t necessarily the case. Indeed, the Construction Product Regulations introduced in July 2013 promote the use of Environmental Product Declarations (EPDs), where available, for the assessment of the sustainable use of resources and the impact of construction works on the environment. However, at the moment this is not mandatory and doesn’t incentivise anyone to choose a product with a better EPD.
What is the incentive?
It isn’t just about the standard itself – most environmentally conscious manufacturers will voluntarily meet a high sustainability standard. However, if the Code is scrapped, what is the incentive to choose a product with a high environmental rating over a cheaper, less sustainable product? It means organisations like the NHBC and local authorities would be more dependent on their own minimum standards and would need to ensure they require products to have an A+ rating, be responsibly sourced and have low embodied carbon. Indeed we have already seen a step in this direction with some local authorities asking for embodied carbon information for construction products.
Hundreds of thousands of new homes have to be built in the coming decades and we need to continue to encourage manufacturers, specifiers, house-builders and local authorities alike to continue the good work they have already done by making new homes more sustainable, and reducing the environmental impact of construction. The Code for Sustainable Homes made significant ground in encouraging the specification of more sustainable building materials, and scrapping it and not including materials in new housing standards seems to be a step backwards.