CIC Blog: 2019
Jane Simpson Access
If the purpose of introducing Optional Categories 2 and 3 into Building Regulations Part M for England was to simplify and expedite the design and construction of accessible housing, then it has failed. More worryingly, the Home Builders
More worryingly, the Home Builders Federation (HBF) has objected to fifteen draft local plans outlining targets for accessible housing. I remember the campaign to save the doorstep!
We have all seen the cases of homes with inadequate storage, tinned food stored in car boots and nowhere secure or safe to store cycles, pushchairs or scooters and bizarrely garages too small for cars. The changes were introduced in 2015 and the industry should be ensuring that homes are fit for purpose. Eight years ago the RIBA’s Case for Space campaign identified issues; three bedroomed homes in London were 36m² larger than in Yorkshire; in May 2017 they are now only 25m² larger. Can we trust the actions of the BHF? Regulation is needed now more than ever.
So what needs to change?
The terminology applied to M4(2) Accessible and Adaptable and M4(3) Wheelchair Adaptable or Accessible does nothing to clarify; it is confusing! This results in too many architects and developers in London assuming that the requirement is for 100% M4(2) and to show that 10% can be adapted to M4(3); this is not correct. The 10% requirement is for M4(3) housing to be built.
The only mechanism now is for English local authorities to specify a percentage of accessible residential units on a new development by means of a planning condition. But there has to be proven evidence of local need. Many local authorities cannot afford the expense of such a study. My own local authority in northern England recently lost 40% of its budget, how can they justify the expense?
Another flaw is the removal of a Local authorities’ power to dictate accessible housing standards when converting non-residential properties. This results in still fewer accessible dwellings being created.
The obligation remains for existing dwellings to be no less compliant than prior to building work taking place, but only when the work is a material alteration. Confusion about this is evident on popular programmes such as Homes under the Hammer, in which the removal of the downstairs WC to an upstairs bathroom is regularly applauded. Sorry, don’t you want you granny or granddad to visit and are you happy for your toddler to use a potty on the kitchen floor?
Confusion persists amongst:
- Prior to 2015 Local Authorities had developed their own accessible housing standards and many are under the false impression that they can insist upon them; no they can’t.
- If they don’t specify the percentage of Category 2 and 3, there is nothing for Building Control to check against.
- Category 3 requirements are not met by a Category 2 that can be amended if needed to become Category 3. You build to either Category 3 adaptable, or accessible. A Category 2 cannot provide the space needed for a Category 3, whilst retaining the same numbers of bedrooms.
- Certain key elements such as pre-emptive works for level access showers are misinterpreted, despite the definitions in Appendix A of the Approved Document being very clear.
The future of Part M
Meanwhile, it is well-documented that we are an aging population with bed-blocked hospitals because homes are unsafe or unsuitable for people’s needs.
Let’s hope that the forthcoming revisions to Approved Document M Volume 1 will allay some of this confusion and encourage housing to suit our ever-changing population. Habinteg estimate an increase of £521 built cost and £1,387 extra space cost for a three bedroomed house; weigh that against the cost of a day in hospital £683 or a week in residential care typically £560-660.
Surely the extra cost would soon pay for itself by the reduction in hospital bed-blocking alone.
- The minimum standard to be Category 2 nationwide for all new build.
- A more simplified fit for purpose guidance, reduce confusion.
- Redefine Category 3 to Wheelchair housing. All homes need to be adapted to suit an individual anyway.
- Remove the blanket exemption for conversion of non-residential properties.
- Enforce regulations where homes are undertaking non-compliant alterations, reducing accessibility.
Contributor: Jane Simpson is an architect and NRAC registered Access Consultant. www.janesimpsonaccess.com
Senior Enforcement Officer (Heat Networks)
Office for Product Safety and Standards
Heat networks are shared heating systems which provide a more energy efficient alternative to domestic boiler heating systems. They incorporate systems where water is heated or chilled at a central source (such as a boiler or plant room) and then channelled to customers through a pipe network for heating, cooling or hot water use. There are two types of heat network. Communal networks serve a single building containing multiple customers, such as a block of flats or offices. District networks serve multiple buildings, such as a housing estate or university campus.
Heat networks are very popular in northern Europe but currently supply only around 2% of homes and offices in the UK. However, the government is promoting this technology as an important contributor towards its carbon-cutting targets. The sector was largely unregulated until the publication of the Heat Network Regulations, which seek to establish some uniformity among operators in the way they bill customers (i.e. according to their actual consumption of heat) while also giving customers an incentive to reduce their consumption. The Regulations are also being used to create the first detailed picture of heat networks in operation throughout the UK.
The Regulations are enforced by the Office for Product Safety & Standards (OPSS), part of the Department for Business, Energy & Industrial Strategy. They place duties on heat suppliers, defined as anyone who supplies and charges for the supply of heating, cooling and/or hot water to customers through a heat network. In a domestic setting, customers are those with the exclusive use of a bedroom, bathroom and kitchen within their home. In a non-domestic setting, customers are those with the exclusive use of a partitioned space. Heat suppliers must: inform OPSS of the details of their networks; install heat meters to measure customers’ consumption (where it is cost-effective and technically feasible to do so), and; use those meters to bill customers by actual consumption.
Heat suppliers should inform OPSS of their existing networks as soon as possible, using the official ‘notification template’. This asks for information such as the number of buildings and customers on those networks as well as, for metered networks, the amount of heat generated and supplied. New heat networks should be identified on or before the date they become active. A fresh notification form must be completed within every four-year period thereafter. Heat suppliers will in future be required to use a cost-effectiveness tool to determine whether or not they should install heat meters. The cost-effectiveness tool will be released following a planned consultation. Where the tool gives a positive response, heat suppliers will be expected to install meters and begin billing customers by actual consumption as soon as the meters have been installed. Where the tool gives a negative response, heat suppliers will be required to re-use the tool every four years thereafter.
The Regulations apply across the UK and are enforced by OPSS on behalf of the devolved governments. The enforcement approach taken by OPSS is always to help heat suppliers achieve compliance, although there are criminal penalties for wilful non-compliance. The ‘notification template’ is available at www.gov.uk/guidance/heat-networks. This webpage contains guidance on the types of heat networks considered to be inside and outside the scope of the Regulations. It also contains a list of FAQs and a ‘heat estimator’ tool to help with heat generation and supply calculations. The email address to which completed notification forms should be sent is email@example.com.
Contributor: Fergus McEwan is a Senior Enforcement Officer (Heat Networks) at the Office for Product Safety and Standards which is part of the Department for Business, Energy & Industrial Strategy (BEIS).