Lifetime Homes - CONSULTATION
PRELIM PAPER - for RIBA HOUSING GROUP
WMA Nov.’09
REMIT
The remit for this paper is to draw together the concerns of architectural practitioners in the RIBA Housing Group with the current Lifetime Homes (LTH) Standards, in response to their potential adoption as mandatory standards in 2013.
The points drafted in this paper have in the available time and by necessity been made without recourse to any other current rounds of consultations on LTH, Code for Sustainable Homes etc. with. Building Regulations Advisory group (BRAC), CLG or others.
Having examined some of the overriding issues, this paper has been extended to include a series of summary proposals and recommendations that provide an appropriate alternative to the currently confused system in which we are all mired. This allows for embodying principals which are universally valued, deleting redundancies and streamlining out the current systemic inefficiencies.
The summary proposals are followed by the detailed critic (largely abstracted from the RIBA Housing Grp Paper of Sept.’08) and an evaluation of the Scottish Standards recently redrafted after devolution, which provide an extremely valuable counter-point.
SUMMARY PROPOSALS
In principal it is proposed that-
· the Lifetime Homes Standards as independent regulatory standards are abolished.
· a new building regulatory framework is adopted with clear separation of dwellings from all other building types.
· the regulations are reworded into plain English, with a clearer format, well illustrated in colour, and edited to remove obfuscation, contradictory, obsolete, and redundant standards; and to provide a structure which can allow for future change, extension, adaptation and innovation,
o The level of clarity to be achieved should be easily accessible and readily communicable across the entire construction industry without specialist knowledge.
· those standards from LTH which are deemed universally beneficial for adaptable and inclusive housing, are embodied within this new structure after comprehensive editing and redrafting, so that there expression is entirely consistent with core building regulations.
· There be a clearer methodology for appraising which of the existing LTH standards should be universally adopted into any new mandatory standards to practically and efficiently provide cost effectively for more adaptable and inclusive general needs housing providing benefit for, and without detriment to, universal needs.
Upon devolution the new Scottish assembly set about a redraft of their construction regulations. These were first published in 2004 as the Scottish Building Standards. (Ref:- www.sbsa.gov.uk/tech_handbooks/). If you are unfamiliar with them they are an eye opener. They started from the same UK regulatory base but now provide a model precedent which incorporates the above proposals.
Their standards provide a robustly constructed regulatory framework that is compact, clearer and simpler than anything we have here. Their format, many aspects of the contents and their underlying principals are recommended to Housing Group. Some key aspects of the Scottish Standards are described below (a synopsis of some other pros and cons of these standards will be presented at the meeting).
It is furthermore proposed that:-
· LTH standards which relate specifically to the space requirements of service and circulation areas should only be adopted as mandatory were they are directly linked to the provision of space standards for all other areas within a dwelling.
· In the manner of contracts where clause options can be optionally selected or deleted, the regulatory structure for any new English Housing Standards should be framed with a core of mandatory standards under parliamentary act, supplemented by optional standards (under different section headings monitored by BRAC), permitting incorporation of Code for Sustainable Homes at their different levels, Secure by Design, etc.
o This would provide greater consistency and clarity, streamline the current mire, provide flexibility and choice at the briefing stage to clients, funders, and authorities etc. whilst also permitting variance by project size and region etc.
o It would allow for future change and adaption, through the incorporation of specific new standards in a ‘test bed scenario’ that could lie beyond mandatory adoption under parliamentary act.
o Assessed and monitored through a single standards system, this would deliver a considerably more efficient and comprehensible system than the present.
· In striking a reasonable balance between universal need and specialist provisions standards should only be permitted at a mandatory level where sustained by rigorous research and be evidence based with regards to the wider benefit and economic cost, not based on assumptions or opinions.
· LTH standards which don’t deliver efficient practicality be appended within the new proposed standards as clauses to be optionally selected.
BACKGROUND
The moral principal that buildings should be adaptable, flexible and inclusive, to make all dwellings usable to the wider population at different periods of their lives and through different stages of physical capacity, is one which is welcomed and widely supported by the profession. Over the years the underlying principal of LTH has been successfully communicated to become equally well understood and supported by clients, government agencies, public authorities and funders. LTH has strong ‘brand recognition’ and wide ‘in principal’ support. By 2013 the government intend to make LTH mandatory.
· The appropriateness of the LTH standards, their economic cost, the detail implementation of these standards, the clarity of definitions, the prioritisation of some specific standards over other factors and overall impact on dwellings, the erosion of choice, their enduring sustainability, flexibility, and utility - are all matters however which raise genuine concern and questions among most housing practitioners.
There appears to be no research base on which prevalent disabilities, in this age, it is most cost effective to address. (what about dementia, the prevalence of arthritis, loss of sight, and the growth in obesity etc.) Are there new standards which should be supplanting some of the existing and which afford universal benefit? And which have the most significant dis-benefits, through impact on density, incur the greatest build cost, and have least take up. Should there be a clearer definition between wheelchair housing and LTH.
· Given that there is competition for limited resources what balance should be struck?
Some believe that the mandatory adoption of LTH standards will be a further erosion of personal choice, lead to even more conformity and box ticking, and that its proscriptiveness is completely inappropriate given the lack of real feedback from the houses actually designed around these requirements.
· To most practitioners the application of Lifetime Homes Standards as it stands is fundamentally flawed, grossly inefficient and constraining.
The building regulations are seen throughout the industry as the core directive in determination of minimum standards in construction. Historically these have been perceived as being exclusively technical standards.
· If a sensibly efficient unitary system of standards is to emerge this will need to change
A significant number of other innovative single issue standards to improve the performance, quality and utility of dwelling construction have developed over recent years in response to changing demands and perceived shortcomings in the core technical regulations. In residential construction many of these independently drafted and assessed supplemental standards are now applied by authorities/commissioners/developers/funders, or being considered for adoption as mandatory standards. Other than LTH incl. Code for Sustainable Homes, Mandatory Space standards, Secure by Design, Building for Life, along with various independent local, regional or national directives, etc. This issue is systemic.
· The strategy proposed in this paper reinforces the position of the National Building Standards as the core directive, whilst providing a structure and framework which permits deletion of many of the current plethora of supplements, and their (stripped & edited) embodiment within a clearly constructed framework that can be better understood universally, be more easily implemented and deliver choice.
ECONOMIC COST OF LTH
LTH specifically incurs considerable economic cost and the current framework is not economically efficient..
Construction Cost.
· The context in which LTH standards are applied incurs additional construction cost (across different projects, scales and typologies). But there is a significant additional cost in all cases; although a precise range of value is disputed.
However the minimum cost of applying LTH standards can not be expressed simply as the additional build cost incurred in the construction of dwellings to meet the standards set.
· With a fixed budget, expenditure incurred on the incorporation of LTH standards is made at the cost of other choices that confer attributes to a dwellings standard, quality, performance and utility. Where these attributes might contribute to a development delivering better individual or universal benefit and/or more sustainable construction, such expenditure is a direct and systemic economic loss.
If LTH standards are universally adopted as a mandatory standard significant examples of this direct loss would include:
o in strategic planning, the constraint on any form of internal stair access dwellings, rendering many FOGS (flats over garages or shops) a development impossibility.
o in internal planning the emphasis on the space standards for circulation and service spaces, enforced at the expense of habitable room areas which provide fundamentally more universal benefit.
Process/ Management Costs.
· Add the national economic cost of sustaining separate institutions throughout the construction industry charged with the drafting, monitoring, assessing and/or publication of independent standards. And with each institution go clear vested interests which sustain entrenched views often at odds with others, or any wider perspective.
· Add the time/cost to all others within the construction industry (outside the architectural profession) of the requirement for comprehension of a multitude of frequently contradictory, supplemental and independent standards, each expressed in their own genre, along with their own requisite monitoring and auditing.
· Add the familiarity most practitioners will have with the economic cost of cross auditing standards under the current contrary system with its impenetrable definitions, as well as the cost of assessments undertaken at different periods within an individual projects development, whether by the designers or others within project teams.
· Add the cost of staff induction and training in familiarity with the current multitude of different sources of standards, their descriptions and interpretation, when many, particularly LTH are written with the definition and clarity of some obscure cabalistic tome.
Some of these costs go largely unaccounted and unreported. Typically these uneconomic costs are absorbed, and/or at the expense/time on the delivery of better designs, and/or the output of more economic works and/or with greater profitability.
The current regulatory framework is neither logical nor a clear expenditure of resources for the delivery of its objectives and should be jettisoned
These factors in particular impact upon RIBA members. This is systemic stupidity, a tickbox nightmare and totally inefficient.
· This paper recommends that Housing group and the RIBA should object to any redraft of the current regulations and LTH in particular which does not adequately respond to these concerns.
PRACTITIONERS DETAILED CRITICISM OF CURRENT LTH STANDARDS
(Abstract from RIBA Briefing Paper to Housing Group Sept.’08). These examples manifest a generally universal state of confusion in the structure and interpretation of the current standards.
· Can a two or three storey apartment block which does not have a lift be considered to meet the standard? Standard 5 states that ‘... where homes are reached by a lift it should be fully wheelchair accessible’. Developers are reluctant to install lifts in blocks of under four storeys due to the cost of installation and the ongoing maintenance, which can lead to disproportionate service charges.
· The need for clarity on standards for three storey homes and the location of bathroom(s) within them - an interpretation of the standard is that there is nothing to stop the only bathroom being on the third storey
· Clarification that the standards apply to all homes irrespective of tenure
· The need for clarification on whether a straight stair is required in order to be able to allow for a stair lift in the future.
· Need for guidance on the definition of ‘reasonable’ in the context of identifying a reasonable route for a hoist.
· general concern that habitable room sizes are being squeezed to allow for adequate circulation space - and the quality of living space reducing as a result.
· Building Regulation objection to bathroom doors that open out into the corridor space
· A concern that the requirement for car parking spaces, where provided, are designed so that they are capable of being made larger, serves as a disincentive to providing car parking spaces
· The need to provide window cill heights at 800mm above floor level means that Building Regulations require the glass to be to a certain ‘toughened’ standard, which adds to costs.
· Floor drainage is clearly a big issue above ground level; pumped solutions should be accepted on occasion – with the need to publicise the effectiveness of specification of and installation details for pumped solutions
· The inclusion of dimensioned illustrations in the standards and guidance as provided for in the BSI Draft Code of Practice (DD266:2007)
· The overall additional costs to LTH was estimated by Joseph Rowntree Foundation to be £300. However, other estimates have put these nearer to £5000. There is a need to investigate this further.
· Concerns that bathroom layouts are not dimensioned and that available guidance on bathroom design is ambiguous. Specific queries with regards to Habinteg guidance on bathroom design include:
· No specific requirements are given about access beneath basins or access to baths. Fig. 7, suggests that no access is necessary beneath a basin in the ‘ease of access’ bathroom, though diagrams of ‘fully accessible’ layouts imply the need for some leg-room.
· Diagrams also suggest that access to bath taps is not a requirement.
· Diagrams show a mix of inward and outward opening doors (including inward opening to fig. 9 ‘fully accessible’). Notwithstanding the need to comply with Part M, are there requirements or preferences about door swings?
· Placing the WC side transfer space between the bath and WC would give good access to the bath too, but would typically mean that the WC was not adjacent to a wall. Is this a problem in terms of future grab rails and would there be requirements about the distance between the basin and the WC as a result?