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1. Andy von Bradsky, 'One year on, is the Code for Sustainable Homes working? - YES', 'Debate', Building Design, 20 March 2008, p 9, posted on

2. Mark Brinkley, 'One year on, is the Code for Sustainable Homes working? - NO', 'Debate', Building Design, 20 March 2008, p 9, posted on

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The Code for Sustainable Homes is broken

The Code for Sustainable Homes is broken, even as it becomes mandatory in Building Control applications.

That will not stop the British government, who bought it that way from the Building Research Establishment, from selling the CSH on to other governments around the world eager to look like they have green housing programmes. That will suit British consultants looking to expand their fee earnings from abroad. For Andy von Bradsky, Chairman of PRP architects, the British CSH '... will become a highly exportable tool that would allow other countries to adapt the Code to suit their needs, guiding their construction industries towards more sustainable development.' A consultant like PRP, willing to promote the broken Code, will be likely to enjoy '... a marked advantage in overseas markets'. (1)

Some consultants will do very well out of the Code, to the extent that selling the ideology of "zero-carbon" housing is decisive. It is also entirely possible to technically make houses and flats designed to meet the performance criteria in the CSH, at a price. Neither the British government, nor the consultants unwilling to challenge the "zero-carbon" nonsense, will care that the social cost of building to the Code may be to render the resultant housing uninhabitable by anyone who is not prepared to live the ideology of a "zero-carbon" existence.

They know that sufficient people will live sufficiently as the Code requires for the regulation to be deemed a success. Other countries will want to emulate the regulatory policy. If those other governments are like the British government then they too will not be prepared to invest in a prototyping programme. To demonstrate, before it becomes regulatory, that a complex matrix of weighted categories and extendable lists of issues can be synthesised on a national scale by commercial builders.

That lack of preparation in pursuit of an ideology never bothered Britain's biggest builders either. Housing consultant Mark Brinkley, himself sold on the idea of sustainability, complains the Code is '... playing into the hands of the large house builders and developers'. (2) The larger commercial builders well understood that the ideologically driven and technically unresolved pursuit of "zero-carbon" would further consolidate their market in the ever more complex winning of planning approvals. So did the British government. Yet this comes as a surprise to Brinkley, who thinks the Code should consider small builders and self-builders.

The Code was meant to commercially break the multitude of smaller builders who will look to Mark Brinkley for advice, unable to afford Andy von Bradsky's consultancy. Yet while it has helped to consolidate their business the Code is broken for the publicly uncritical large house builders and developers too. The CSH is broken because it:

Frustrates pre-planning Type Approvals processes in the Building Regulations, by insisting that post-planning and site specific issues be considered in every "Dwelling Type"

Forces a two stage assessment for every site variation on typical designs, as a job creation scheme for Code Assessors, paying the Code authors a percentage of all fees

Fails to aggregate research and development expenditure across popular house types, while expecting every "sustainable" home to perform like the Halley VI Antarctic Research Station

Forgets the Standard Assessment Procedure 2005 is too insensitive to handle U values of 0.1 W/m2K and air tightness of 1.0 m3/hr/m2, while agreement on an improved SAP 2009 is not obvious

Fudges the issue of space inside and outside the home, squeezed by the cost of land, the share of gains from planning, the policy of densification, and temporarily falling market valuations

Facilitates moralistic environmentalists to meddle with the business of volume house building, to change weightings, extend issues, and fiddle with Environmental Profiles that the BRE currently monopolises

The CSH is completely FFFFFF… broken.

Yet it will be persisted with, and some of these problems will not prove impossible to overcome in architecturally freakish ways, making wild assumptions about household behaviour.

It matters, however, that the Code for Sustainable Homes will make the Building Regulations into an eco-wish-list in which behaviour within and about the home becomes more of an interest to public policy makers.

It matters, too, that the CSH makes reconciliation of Building Control with the Development Control processes of the planning system less possible than it was under the unexplored Local Development Order provision of the 2004 Town and Country Planning Act.

It matters, most, that housholds will have their behaviour irrationally constrained, and possibly monitored, perhaps, and I am quite sure some green FFFFFF... zealot is thinking about this, even as a retrospective condition on planning approval. Failure to live on 80 litres of water per person per day, or through the ageing photovoltaic panels on the roof, meaning withdrawal of planning approval.

The Code for Sustainable Homes is meant to be a green restriction of the local reallocation of the national denial of development rights.

It looks likely that annual housing production will be retreating from meeting the simultaneous target of 240,000 homes a year by 2016, thanks to the exhaustion of the inflationary housing market spiral that this government has done so much to encourage through the financial and planning systems. The exhaustion may be temporary and house price inflation re-established with a vengeance. For in 2016 the CSH takes the Building Regulations beyond the super-insulation of Code 5, and supposedly permanently into the ideological "zero-carbon" Code level 6.

By then we will know the answer to the following question:

How many £240,000 home buyers want to rely on "greywater" in a rainy country with mains utilities, or make their own electricity expensively?

If living in one of these new homes is the only way of getting into the inflationary housing market up to 2016, people will be unlikely to oppose the CSH, but will instead accept the ideology, and then make a virtue of living in eco-rationed housing.

No-one will then care that the Code for Sustainable Homes was broken in December 2006, and broken when it became mandatory in 2008.

Ian Abley 19.03.2008 - added to on 24.03.2008

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