Don’t Let Them Put Our Environmental Standards on the Red Tape Bonfire!

The Department of Communities and Local Government has published proposals to slash the options for housing construction standards to be set above and beyond the Building Regulations. Lined up for the executioner’s bullet are the Merton Rule,  Code for Sustainable Homes, Lifetime Homes and more.  In this Soapbox James Livingstone laments the threatened loss of opportunities to drive up building standards, and urges fellow AECB members to join him in lobbying government not to throw the ecological baby out with the bureacratic bathwater.

I was asked to get on a soapbox on the subject of the Housing Standards Review .  Well, an invitation like this brings out the best and worst – so here goes!

The Housing Standards Review

What is it ?

As a part of the ‘bonfire of red tape’  the government has proposed trying to streamline the miscellany of discretionary  standards that Local Authorities , Housing Associations , the HCA and others request of housebuilders,  over and above the Building and Planning Regulations .

The standards specifically mentioned in the Review include  Housing Quality Indicators , Lifetime Homes, the Code for Sustainable Homes , Secured by Design , the Merton Rule, the London Housing Design Guide  and local space standards.


Being generous to its intentions, it might be described as Government’s attempt to reduce duplicated and unnecessary complications from the housing development process.

Being less generous,  it might be described as another hamfisted attempt of a deaf government to remove all obstacles to housebuilders having their way in determining shape, size and standards of their developments, emascualting local discretion and aspiration,   and  yet another  backtrack on being ‘the greenest government ever’.

The Effect 

Now I wouldn’t argue that there are overlapping and sometimes contradictory standards applied to housing development,  and despite being a ‘defender’ of the Code for Sustainable Homes,  I would agree that  there are bits of it that are no longer relevant and other bits that are pretty much unworkable – especially on small developments .

But this does not justify or explain the proposed  dismantling of all of the discretionary enhancement standards that have done so much to improve the environmental credentials of mass housing  in the last ten or so years .

So, in this area  the  Review proposals include:

  • doing  away with the Code for Sustainable Homes and the Merton Rule
  • relying only on Building Regulations for energy and carbon reduction standards
  • offering no replacement  for the enhanced  sustainability standards offered by the Code, including materials sourcing and ecological enhancement
  • and relying  on ‘the free market’ for ensuring that embodied energy of materials  is considered in procurement.


So,  under the proposals, environmental  standards for housing are being cut ,  housebuilders are being empowered,  the  aspirational and discretionary powers of local authorities in this area are being done away with,  and the absolutley crucial pathfinder roles of the Code and other standards are being actively discouraged.

Now I know this will come hard to a lot of AECB members – some of whom routinely dismiss some  housing standards  as a ‘mere box ticking exercises’,  but the Code for Sustainable Homes and the Merton Rule have not just been  really  important  trailblazers for housing environmental standards,  but have  been responsible for more carbon savings and ecological enhancements in housing  than -for example – Passivhaus standards will ever will be.  And it’s not just about energy you know…

The standards for mass housing are crucial. We ‘caring environment types’ mustn’t just ignore mass housing in total favour of the exciting (and arguably elitist) exemplar projects that are so much fun to do.   And  it seems  important that local government are not disallowed from giving  expression to local  needs, and to those that voted them into power, by applying appropriate planning conditions, that may exceed national standards. After all , they understand the needs of the  locality best.

Take a stand

So,  I ask you to lobby and join the consultation process.

Please defend  the use of enhanced standards  in ecology , water use and  materials sourcing that the Review looks to dismantle.

Please protect the discretionary powers of Local Authorities to aspire to better local standards, and please resist the loss of an important benchmark for individuals to measure their aspirations against.

© 2013: James Livingstone and AECB (for Terms and Conditions click here)


James LivingstoneJames Livingstone and Norfolk Building and Energy Associates  work in East Anglia, the Midlands  and London on design, surveying for retrofit, planning, low impact materials and standards for new build. Further information at



The Housing Standards Review consultation documents can be downloaded from the DCLG web pages here: The deadline for responses is 22nd October.

An overview of the proposals in this Review is due to be published on the AECB website at the start of October, to assist members who want to respond to the consultation. Do also contribute your views on the AECB forum here. (All can view, members only can post, please ensure you are logged in). You might want to share your opinions on these questions:

  • What respective roles do you believe regulation, independent standards and the free market play in delivering good housing?
  • Has the government sidelined issues that  should be benchmarked or even regulated?
  • Can excellent but one-off dwellings contribute anything to raising standards more generally?
  • Are aspirational standards and/or local policies a good way to drive up quality in mass housing, or should this all be under central control?

If you would like to respond to this Soapbox with another article, or would like your consultation response to be published on these pages, please contact .