CIH response to DEFRA’s Review of Water Efficiency Standards in the Building Regulations 2010 (Part G)

CIH has responded to DEFRA’s consultation on updating Part G of the Building Regulations, which sets the water efficiency requirements for new homes. 

Consultation questions

10.Do you agree that the ‘mandatory water efficiency standard’, should be amended from 125 l/p/d to 105 l/p/d?  

Agree. 

We agree with this proposal for the reasons described in the consultation document. 

We would note that one of our members suggested an alternative approach, which would set water efficiency standards in new homes based on anticipated occupancy. This could be achieved in different ways, for example by setting different standards for homes with one, two, three, four, and five plus bedrooms, or by setting different standards linked to bandings based on total floor area size. This would mean that smaller homes, e.g. those designed for single occupancy, have a lower l/p/d standard than homes designed for large families. However, if this suggestion was taken forward by DEFRA, it  would need to be carefully considered to ensure it does not introduce any distortions or drive unintended outcomes, such as smaller homes on some developments automatically not being able to have baths or en-suite bathrooms. 

Relatedly, our members noted that updating water efficiency standards for new homes should not detract from the need to consider how we reduce water consumption in existing homes. CIH welcomed the proposal in the government’s Decent Homes Standard consultation to produce non-statutory best practice guidance on improving water efficiency in the rented sectors. However, given the levels of water stress and scarcity anticipated in the future, there may be a need to go further in the coming years. In addition, the updated Decent Homes Standard will apply only to rented housing, and there are fewer policy levers to improve water efficiency in the owner-occupied sector. Ultimately, a holistic approach is required that formulates additional policy proposals for reducing water demand across new and existing homes. 

Lastly, our members emphasised that a link needs to be made between the water demand implied by the proposed changes to Part G, and broader strategic planning for new homes. CIH has contributed to NESO’s ongoing work on the Strategic Spatial Energy Plan (SSEP) and Regional Energy Strategic Planning (RESP), and as part of this we have stressed that essential infrastructure planning – whether energy networks or water networks – must be aligned with local housing plans and the demand these plans will place on the energy and water networks. CIH supports the government’s target of building 1.5 million new homes this parliament, but for this to take place, strategic housing, water, and energy planning must be aligned at the national, regional, and local level. 

11.Do you agree that the ‘optional technical water efficiency standard’, should be amended from 110 l/p/d, where there is a clear local need such as in areas of serious water stress, to 100 l/p/d?  

Agree. 

The suggestion by one of our members on linking the efficiency standard to number of bedrooms or total floor area size also apply here. 

19.Do you agree that local planning authorities and local building control and registered building control approvers have effective procedures to deliver water efficiency measures through the Building Regulations? 

No. 

In our engagement with our members on this consultation, we have been informed that challenges with building control are linked to wider resource pressures experienced by local planning authorities. There are currently shortages in the planning, construction, and ecological expertise that is required for housebuilding, and our members expect the ability of local building control approvers to be affected by wider capacity challenges in local planning authorities and the ongoing uncertainty of local government reorganisation and devolution. This could result in a lack of the expertise and technical knowledge required to ensure Part G is being adhered to in the future, especially if the changes proposed in the present consultation result in the wider installation of new, more unfamiliar systems like black water harvesting. 

To ensure that all new homes are built to a good quality, and to the minimum specifications set out in the Building Regulations, local planning authorities and local building control must be adequately resourced to perform their functions. 

QA. To what extent do you agree or disagree that government should pursue wider reform of the water efficiency standards in Part G of the Building Regulations?  

Agree. 

QD. Do you consider that reuse systems should be required through the Building Regulations 2010? 

Yes. 

We have answered yes to this question, but this should be seen as heavily caveated; the barriers and possible unintended consequences of doing this must be properly considered.  

We believe that all homes should be sustainable, climate friendly, and futureproofed. Ensuring homes maximise their water efficiency is a critical part of this, and we support the possible requirement for reuse systems to be mandated in new homes in the future. However, we do not have a view on exactly which forms of reuse system should be required, and there are several barriers to their more widespread adoption. We have expanded on these barriers in our response to Question E below, and they must be carefully considered and addressed before an attempt is made to mandate reuse systems through the Building Regulations. 

QE. If you answered yes to ‘Do you consider that reuse systems should be required through the Building Regulations 2010?’, what systems or enablers in your opinion are required: e. Please provide information to explain your answer. 

Cost remains a key barrier, especially as the cost of installing reuse systems will likely push up the total cost of building a new home. The Housing Forum have previously questioned whether the cost of reducing overall water usage in new homes could also be addressed by other methods. They have suggested government should take action to do this so that the cost of reducing average water demand per home is not placed solely on housing developers. Our members have suggested the possible use of rising block tariffs to incentivise lower water use in homes, which could charge a higher price per litre for every litre consumed above the average. However, this would need to be carefully considered to ensure no detrimental outcomes occurred for households with a medical requirement for above-average water consumption. Our members also suggested that government could look to introduce policy mechanisms to restrict the manufacture and supply of high-flow devices. 

There are further concerns about the safety of reuse systems. Our members expressed concerns that householders or plumbers without sufficient training may attempt to adjust reuse systems, which could result (e.g.) in greywater accidentally contaminating drinking water. Reuse systems could also simply be switched off by householders if they do not understand their purpose or see their benefit. If reuse systems were to become more common, there would need to be improved advice and support to households regarding their purpose and safe use.

More generally, the wider installation of reuse systems will require the upskilling of plumbers, repairs and maintenance operatives, and other trades that work on domestic homes. CIH members working in social housing, both for stock-holding local authorities and housing associations, have observed that their repairs and maintenance teams would require significant upskilling to properly understand the complexity of reuse systems, as well as how to repair, maintain, and replace them safely. This would be a challenge because of the considerable pressure currently being placed on repairs and maintenance services in social housing from repair backlogs and new regulatory and legal requirements, as well as the wider skills shortages in these areas. Any requirement to install reuse systems in new homes would need to be accompanied by collaborative working between government and the housing sector to upskill a large, diverse workforce to maintain them properly over their full lifespan. 

QF. Please provide links to any relevant evidence that you have used to inform your views for this consultation. If there’s anything else, you’d like us to know or consider please add it here. We’re particularly interested in information around:

• Any risks and mitigations of contaminated potable water supplies associated within a development that relies on reuse systems of cross connection, backflow, microbial growth on plumbing and therefore risk of contaminated potable water supplies.
• Any risks and mitigations that industry is not yet ready to safely install and monitor reuse systems to run effectively and safely.
• Any associated costs to householders for maintenance of reuse systems, as well as higher operating costs and energy costs.
• Evidence that increased uptake of water reuse systems would require upskilling and training requirements for plumbing, electrics and groundwork.
• A further review of (AD-G).
• A review of Approved Document H.
• Customer expectations and enjoyment of water in the home.

To inform our views for this consultation, we consulted with CIH’s Supply and Development group, a group of senior housing professionals working mostly in social housing on the development of new homes. We would welcome the opportunity to host officials working on the Part G review at this group in the future, should it be helpful.