Have changes to the code for sustainable homes guidlines ended the confusion?
Six weeks ago, three hundred pages of Technical Guidance were issued for the Code for Sustainable Homes. It was complemented by a schedule of changes, highlighting ‘minor’ and ‘major’ amendments, designed to make light work of understanding the changes.
There have been problems with the Code causing the path to zero carbon homes by 2016 to be somewhat shaky. Even the very objectives of the Code are far from being achieved in some areas. But why after 13 months is the Code still suffering from teething problems, especially as guidance suggests it is so similar to its well established EcoHomes predecessor?
There lies the crux of the problems; the link between the Code and EcoHomes, with terms such as ‘broadly similar’ being misleading and inaccurate. It is true that at face value they are ‘broadly similar’ but their detailed implications are fundamentally and intrinsically different. The Code is also vastly more expensive to achieve in construction and certification fees, and more importantly, the implications for the homeowner. Then there is the virtually unprecedented and unknown post construction review before any final Code Certificates can be issued.
My first hand experience of the difference between the two approaches, and the difficulty in achieving the Code over EcoHomes is highlighted in the Code case study assessment for new assessors. Those that have recently attended the Building Research Establishment’s (BRE) training course will be aware that the case study didn’t achieve a Code rating. This was predominately due to the mandatory energy credit not being achieved. At the same time as BRE were gathering their training information I was undertaking the real EcoHomes assessment on this same scheme. It achieved an EcoHomes Very Good rating.
Having now worked several Code Assessments it is evident that in practice the Code is very different to EcoHomes.
Another issue lies in the differing positioning of the EcoHomes and Code Technical Guidance documents. The EcoHomes document is for the sole purpose of assessors as a checklist by which they can gather the required information. This process is the same for the Code and yet it is essentially different in that the document is open to public scrutiny. This scrutiny is leading to more pressure on both Department for Communities and Local Government (DCLG) and BRE to make amendments.
In the same way that the Code Technical Guidance is being scrutinised, the Standard Assessment Procedure (SAP) energy model is also being interrogated in an unprecedented manner. And this in some cases provides unexpected answers. As a result, amendments and ‘bolt-ons’ are being required to the SAP model. Not until 2010 will SAP, Part L of the Building Regulation and the Code be harmonised. Once these are synchronised I believe the main bulk of the Code’s anomalies will be rectified.
Further issues relating to teething problems are to do with misplaced guidance on how to achieve the current national standard; Code Level 3, through insulation improvements alone. In some cases this just isn’t technically possible. The economic climate today and medium term projections may even derail the path to 2016 completely, rendering the whole Code unfeasible for a period of time. Only time will tell, and a trade off between environmental protection and housing at an affordable level will inevitably have to occur.
But these issues are correctable. Guidance changes in 2010 will hopefully deal with the energy side of things. And as the building industry finally get to grips with the Code, they too will realise, if they didn’t already, that those that say EcoHomes and the Code for Sustainable Homes are ‘similar’ are misinformed.
There are also concerns that in writing the Code, the authors were not completely aware of the full implications of the minor details within the Technical Guidance. The devil is very much in the detail.
It is this detail that I believe is missed in drafting the Code’s revision, and as a result the market place actions are not those intended, and strange glitches have occurred. Some glitches even undermine a leading principle of the Code; reducing the carbon dioxide emissions. Otherwise known as the ‘air source heat pump’ solution. Here, a dwelling can be fitted with an air source heat pump to achieve Code Level 3, yet emit higher CO2 emissions than a Building Regulation compliant gas heated dwelling. This surely was not the intended purpose of an environmental assessment method designed to address the issues of climate change.
This anomaly comes about through a calculation process based on a percentage methodology. This will always throw up inconsistencies compared with an actual target methodology.
It seemed that closing this loophole would be a sensible idea. And that is exactly what the third revision of the Technical Guidance did, recorded as a ‘minor change’ in the schedule of changes. Yet within days, rumours were abound that this change was due for a complete u-turn. The first I heard of it was through air source heat pump manufacturers. The fourth revision in 15 months is now pending.
Apparently, the change didn’t meet government policy for consultation. If the change was considered so minor, why were none of the ‘major changes’ also required to go through the consultation process?
What is clear is that the Code is now firmly on the radar of pressure and industry groups. Working with these industry groups and keeping the Code focused on climate change objectives is going to be a huge challenge for DCLG and BRE.
There are other issues relating to the Code that have come about through a lack of market testing, and rigorous prototyping of the various requirements. But there seems to be a few parallels here with other environmental movements, where the need for rapid action is leading to rather obvious counter productive results, rather like leaving the fridge door open to cool a room.
There can be no disputing that the overall aims and objective of this environmental assessment method are sound but that the detailed requirements in some areas compromise these. The building industry and supply industries, must adapt to the Code’s requirements and standards, and strive for more efficient and cost effective ways to achieve them. The water industry is a good example of this. They have adopted to the mandatory requirement of reducing internal water consumption in clever, and sometimes obscure ways.
The Code cannot have too many more mishaps and u-turns, as it will only undermine its objectives. Industry is already confused and frustrated, and advising clients has become a risky business as the goal posts are seemingly moving. DCLG and BRE must fully test any Code changes though a detailed evaluation and prototyping process and use industry groups to do this. Comprehensive and accurate guidance should then be available to enable industry to take up the Code and deliver real environmental improvements.
Michael Sturdy is lead code assessor at Richard Hodkinson Consultancy and member of the Code Technical Panel