Future Homes Hub                            ESH0091

 

Supplementary written evidence submitted by

Ed Lockhart, Chief Executive, Future Homes Hub

 

Follow up to points from the oral evidence session of 15 January 2025 for the inquiry on Environmental Sustainability and Housing Growth

 

Introduction

The Future Homes Hub was set up in 2021 as an independent body to support the housing sector meet its long-term environmental goals. The Hub’s ethos is to promote collaboration on shared objectives and all its members are committed to working in partnership with each other to achieve the key goals. However, it is also recognised that there are a number of areas where improvement in policy design and implementation would help to deliver both more homes and the desired environmental outcomes simultaneously. This note provides more detail on such delivery issues in response to questions raised by members of the Committee during the evidence session. 

Examples of regulations that are difficult to comply with – Question 10

I mentioned in my oral evidence the difficulty for developers in complying with a multiplicity of different requirements on energy efficiency from different planning authorities across the country.

There are similar issues and challenges for developers on environmental objectives such as Biodiversity Net Gain (BNG), water efficiency and embodied or whole life carbon, where individual planning authorities seek to introduce their own policy requirements in addition to any national standards or requirements that exist.

Such varied requirements across areas undoubtedly complicate and delay housing delivery, a problem that can be compounded by the lack of Local Planning Authority resource and expertise to implement their own adopted policies. This is a real issue, if for example, a local environmental policy requirement is the subject of a planning condition which the LPA then has difficulty in discharging.

But difficulties can also arise in implementing national standards where these have not been fully thought through or properly prepared. A good recent example of such a problem concerns the 2021 change in Part L of the Building Regulations. In seeking to implement this in their designs, developers found that there were difficulties in integrating Part L with the requirements of Part O of the Building Regulations on overheating and with Part K on protection from falling, collision and impact. The Future Homes Hub gathered evidence on these problems from developers and discussed solutions to resolve them with the responsible Government Department, MHCLG.

In the case of Part L 2021, a further problem was that the SAP software that is used by developers to model designs to meet the regulatory requirements was not available in sufficient time at a satisfactory level of reliability for developers to be able to model efficiently new dwelling designs that would comply.

That unsatisfactory experience with the 2021 Part L-related revision of SAP, has directly contributed to MHCLG’s agreement to work with the industry through the Future Homes Hub to ensure that the new Home Energy Model compliance assessment tool is fully functional before the Future Homes Standard is implemented. This joint approach is being overseen by the Future Homes Standard Implementation Board, which is jointly chaired by a senior figure from the industry and a senior MHCLG official.

A further issue for securing nature and other environmental objectives such as the provision of blue and green infrastructure (For example, SuDS and water reuse systems) in new development – is the need to find a suitable model for long term stewardship and maintenance. Given the concerns raised by the Competition and Markets Authority about private estate management arrangements in new development, there is a need to agree models for adoption and maintenance of nature-based assets. Developers themselves are not equipped to provide this, local authorities have stepped away from adoption and maintenance of open green space and other assets and other bodies such as water companies currently face some regulatory barriers to adopting assets.

Overall, this is a substantive problem which needs resolution. Without agreed models that work for Government and stakeholders, the uncertainties relating to adoption and maintenance will undermine the implementation of policies and disincentivise developers from pushing the boundaries on sustainable development.

 

Examples of regulations that might be removed or strengthened and the role of national level regulation – Questions 11, 27 and 28

It is not the Hub’s view that there are particular regulations that should be removed or strengthened as such.

The issue is much more about how regulations are designed and implemented, whether there is a clear roadmap or pathway for future regulation, whether the combined impact of regulations that interact with each other has been thought through and whether the impact on particular types of development or developers has been properly considered.

Uncertainty about the nature and requirements of likely future regulations creates significant challenges for developers and the supply chain, for example:

A good way to avoid such problems would be for the Government to publish roadmaps for proposed changes to regulations over a 5 to 10 year period ahead. This would enable developers, contractors, product manufacturers, planners, skills providers and others to invest in innovation and capacity in a timely way with reduced commercial risk.

It was for this reason that the Hub in its 2024 “Water Ready” report recommended to Government that it should adopt a 10 year roadmap for changes to Part G of the Building Regulations on water efficiency, with planned increases in water efficiency requirements in 2025, 2030 and 2035.

In its publications Future Homes, One Plan” - Future+Homes+One+Plan_Future+Homes+Hub+Prospectus-+FINAL+WEB.pdf - and One Plan: Scaling up delivery” - Scaling_Up_Delivery.pdf – the Hub has also set out how industry stakeholders can work together and with Government to achieve key environmental objectives for new housing at scale in the period to 2035 and beyond. We believe having this sectoral roadmap is an invaluable way to ensure everyone is on the same page and working towards shared goals in an agreed way.

Given the need for clear and workable pathways, it is also desirable to avoid individual regulations being introduced on a siloed basis at different times without considering the bigger picture of how things might be best joined up and synergies between different individual objectives encouraged. A siloed or fragmented approach to new regulation can result in:

Government should therefore look carefully at the relationships and linkages between different regulations when considering changes to them, or the introduction of new regulations, to ensure that unintended consequences and undesirable complications or tensions between different regulations are avoided.

One idea the Hub has proposed to achieve better outcomes in future is that there should be a co-ordinated review of all the Building Regulations every 5 years rather than piecemeal revisions of individual Parts of the Building Regulations over an uncertain timescale.

Differing requirements between different layers of Government – national and local – should also be avoided. The Hub believes that national regulatory standards - such as the Building Regulations - should have primacy and that a patchwork of different local additions to these through local planning policies should generally not be allowed. This would create a much clearer and more certain climate for developers and the supply chain to focus on delivering the best solutions to meeting regulatory policy objectives. Where there are particular factors which may require different standards in some areas, this could be provided for in national regulations. This is already the case, for example, with Part G of the Building Regulations which provides for a more demanding water efficiency standard in areas which face water stress.

An important cross-cutting or generic issue is that complex or sub-optimally designed regulation is particularly difficult for SME home builders to implement. Small companies do not often have the in-house technical and environmental expertise to deal with complicated regulatory requirements. Some requirements may also be more difficult to implement on the small sites that SMEs develop. This needs to be recognised and the implementation of regulatory requirements for SMEs made as simple as possible to avoid adding to the pressures which have seen too many SMEs leave the industry over the last 30 years. Simplified compliance regimes, including the provision of deemed to comply technical or design solutions is one way in which regulatory implementation can be made more practical for SMEs. Ways of making implementation easier for SMEs should be considered when designing and considering all new regulation and revising existing regulation for the housing sector.

Other steps which could improve the delivery of housing to sustainable standards as well as the business climate would be for infrastructure bodies to be engaged at an earlier stage in new policy development and for statutory bodies to stop introducing new requirements after development principles for projects have been agreed.

Map of Future Homes Standard pilot projects – Question 23

The Hub’s map of these projects is at:

Future Homes Hub UK

Examples of things at neighbourhood level which actively deliver better outcomes for nature, the environment and carbon – Question 24

Well-designed green space, incorporating SuDS, the provision of Biodiversity Net Gain and retaining and adding to trees within the overall envelope of the development would be a good example of how nature, environmental and carbon objectives can be advanced in a mutually supportive way. Such high-quality design also delivers a good standard of placemaking, with the social and wellbeing benefits that provides.

The Hub has also developed the Homes for Nature initiative The Homes for Nature commitment will see a bird-nesting brick or box installed for every new home built, as well as hedgehog highways as standard on every new development taken through planning from 1st September 2024 for participating companies.

With 28 homebuilders, who build more than 100,000 homes a year, already signed up for the voluntary commitment, the move represents a major step towards providing the minimum of 300,000 nesting bricks and boxes thought to be required to support swift populations and many more bird species across the country. The number of signatories and, therefore, committed nesting brick installation continues to grow.

In addition to integrated nest bricks, boxes and hedgehog highways, homebuilders are encouraged to incorporate additional features, such as bat roosts, insect bricks and hibernacula. Away from the home, nature-led sustainable urban drainage systems and pollinator-friendly landscaping help to make even more homes for nature on new developments.

 

April 2025

 

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