Written evidence submitted by Leku Environmental Ltd.

We are a small consultancy that specialises in Code for Sustainable Homes assessments for the larger national house builders in the South West of England. I have worked in mass housing for over 16 years as an architectural technician and as a technical coordinator, very much at the implementation end of the industry.

Setting aside the obvious conflict of interest (the end of the Code would/will have a huge impact upon our business) I would like to make the following comments:

1.              House Builders will always build to the absolute statutory minimum. Whether it is SAP or CSH, Developers will always look to achieve the absolute minimum above what is required. If Code is removed, then overall standards will drop.

2.              I feel it is reasonable to have a mechanism where some sites are built to a higher standard than others – to mitigate perhaps building on a green field etc. Hanham Hall (http://www.barratthomes.co.uk/new-homes/south-gloucestershire/H439401-Hanham-Hall/) is a great example of this.

3.              House Builders employ professional people very capable for dealing with complex issues. The current Housing Standards Review implies that the regulations should be simplified or ‘dumbed down’. The major House Builders all use standard specifications and housetypes that are already compliant with minimal changes between sites.  

4.               How will the removal of the Code allow more houses to be built? It will allow House Builders to make more money (all seems to be reporting healthy profits at the moment) but I struggle to see that more units will be built to address the housing shortage. Certain sites will always be more challenging to build for different factors and regardless of adherence to Code requirements. Also the increase of house prices outstrips the financial cost of Code implementation.

5.              Given that a house should last at least 80 years, any improvements made at inception result in the maximum benefit. Lowering quality to achieve a short-term gain seems very shortsighted and will have a long-term negative impact. We should be building dwellings that are more sustainable and efficient for the future, not less.

6.              We must not forget the people who will live in these houses, be they the purchaser, tenant or future occupier. Any reduction in statuary requirements will result in poorer quality homes being built and it will be the inhabitants who pay the price, not the developers. There are over 100,000 Code accredited units now in Britain to the benefit of all who live in them.

7.              The Code for Sustainable Homes has been set up to fail. When it was controlled by the BRE (and EcoHomes before it) it was updated every 6 months to ensure it kept pace with Regulations and best practice. Many of the criticisms of the Code could be easily dealt with by updating it timely.

2 October 2013