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Experts concerned over ‘disastrous’ London housing guidance


Leading housing architects have said new proposals to make homes in the capital more accessible could ‘cause chaos’

The plans, set out in draft housing guidance, would force all London homes to have step-free access regardless of what level they are on, removing the flexibility in the current building regulations.

A clause within the Mayor’s Draft Interim Housing Supplementary Guidance states that the ‘optional’ building regulation M4 should be applied to all new homes.

Professionals fear the proposals would see councils demanding that every housing developments over two storeys had a lift.

Although it would be possible for boroughs to relax the requirement, architects are worried the tone of the document will compel most councils to adopt the standard.

Head of housing for Levitt Bernstein, Julia Park, branded the requirement unachievable and untenable and said she had visited the Greater London Authority (GLA) to warn that it was already ‘causing chaos’.

‘The GLA has managed to create yet another policy that they know won’t always be achievable - or even desirable.

‘Our understanding is they are not expecting all homes to have step-free access and accept that some housing typologies, including small, low- rise blocks of flats and double stacked maisonettes remain extremely valuable, so are not being banned, despite the fact that they can’t support the capital or ongoing cost of a lift,’ she said.

Park, added: ‘It’s just a pity they don’t come out and say that instead of hiding behind an ambiguous ‘get out’ clause in the small print.’  

Frustrated with the proposed plans, housing architect Peter Barber or Peter Barber Architects, said: ‘If this goes through I’m giving up.’

He warned it would ‘sound the death knell for a lower-rise high-density approach to urban housing and neighbourhoods’ and was a ‘resounding endorsement of the generic corridor apartment building.’

Barber commented: ‘This is a Draconian, pointless, sledgehammer change to policy which has not been thought through.

‘It is policy which plays in to the hands of land grab London’s generic developer and his lazy architect. It will encourage the kind of lumpy middle and high rise apartment blocks which are currently being shoved up all over our city.

He added: ‘[It signals the end] for the kind of sociable street based high density lower rise (4/5 storey) urban neighbourhoods which we should be building in their place.’

Consultation ended on the plans in August.

Further comments

Teresa Borsuk, Pollard Thomas Edwards
‘I am old enough to remember the Building Regulations, when they set out in a compact buff coloured booklet, which was smaller than A4 and about an inch thick.  You could comfortably take it home and read at your leisure.  Today, you’d need a shopping trolley to do the same.  And it’s not only the increased volume – there’s commensurate complexity.

‘Part of the point of the new national standards is to simplify and regularise.  How we need that. To easily understand what’s meant to be done, where, would be extremely helpful in facilitating the already over complex process of procurement and delivery.

‘The Mayor’s Draft Interim Housing SPG seeks to encourage all the players in the housing market to think innovatively about how different housing models can meet a range of needs – including at different stages of life.

‘It carries forward housing design standards for London in the context of new national standards.  Building Regulation M4 (2) applies to all new homes in London.

This is more onerous than the former Lifetime Homes Standards

‘Step free access is required, so even low rise flats will need a lift. The entrance storey to a home requires a living space and WC – so the typology of “flats over garages” will not be allowed.  This is more onerous than the former Lifetime Homes Standards.

‘Is this a death knell for low rise housing? Perhaps not entirely.  Although it does challenge the quest for “different housing models for different needs” – the very thing it wanted to address.

‘The ‘get out of jail card’ is that, “Boroughs can consider the application of M4 (2) on a case by case basis – which may require ‘bespoke’ assessments of site specific circumstances”.

‘But more significantly it reintroduces ambiguity, uncertainty and debate - which will be entirely reliant on viability assessments and justifications; time and complexity we can ill afford.’

John Moore, HTA Design
‘In a nutshell 90 per cent of all new apartment blocks would need lifts, and houses would need future lift provision. There are also level access requirements for approaching the dwelling. This onerous requirement has been largely unheralded

‘The “level approach” and “future lift provision” in houses is already in LTH so no significant change there. Lifts (of a minimum 1,100 x 1,400mm size) within all multi-storey apartments will obviously add cost and area, both of which will discourage the use of small low build cost, low-storey apartment types, that fit in well with “suburbia” models, and tend towards larger block types.

‘Potentially an exemption for blocks under nine units and/or no more than four storeys might offset the disbenefits (allowing three units per core over three storey or twoi per floor over four). Alternatively smaller lift sizes could be made acceptable for smaller blocks to enable a wider and more affordable range of lift providers.’

Jerry Tate, Tate Harmer
‘Obviously we are concerned about the proposed guidance, we are working on a number of low rise residential schemes which simply would not be viable if we needed to include lift access throughout. If the rule were implemented it would fundamentally limit the range of housing we could provide, particularly on smaller ‘infill’ sites which are our bread and butter.’


Readers' comments (7)

  • Ben Derbyshire

    Lifetime Homes is no longer. Instead new Approved Doc M (effective Oct 2015) provides 3 categories of accessibility:
    1. Visitable Dwellings (basic provision, but not step-free)
    2. Accessible & Adaptable Dwellings (similar to LtH requirements)
    3. Wheelchair Use Dwellings (similar to Habinteg WHDG requirements)

    As to which category applies, this is should be established in the Planning Authority. Their consent should specify how many homes of each category are required. The local authority must not set unreasonable demands and must demonstrate evidence of actual need before requiring categories 2 or 3.

    Now whilst category 2 is similar to Lifetime homes, it differs in one significant way:

    2.6 The approach route should be safe and convenient, adopt the shallowest gradient that can reasonably be achieved and be step-free, irrespective of the storey on which the dwelling is located.

    This has understandably caused some consternation since it effectively means that even 2-storey flat blocks will now require lifts. We believe the industry has been lobbying and note that the indomitable Julia Park has already been up to County Hall to give them a piece of her mind!

    These measures certainly run counter to the general perception that this Tory-led government is not minded to burden the construction industry with more onerous regulation.

    Ben Derbyshire
    Managing Partner, HTA Design
    Chair, The Housing Forum.

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  • In the next 50 years, at the rate of today's current progress, medical research/robotics will have provided a 'cure' to very many disabilities. In the last few weeks we have seen a blind man being able to see again, and a paralysed man walking. Of course, I am not recommending that there should be no accessible future housing , but rather that a proportion of new housing should be, against a blanket regulation for all (which is how this will be interpreted)

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  • Supposed to be ground floor bathroom, not toilet, if you are giving full equality to all. Everybody needs a bath or shower.

    If they would just add a levy to building control fees (they manage to do that quite easily to planning charges) for every residential application, of say £50 per house, they could contribute to a central fund to let anyone who needs their house (old or new) modified to get full access to all floors for free, there would be no problem.
    A stairlift, a vertical cupboard lift, a ramp, a ground floor bedroom extension, all no problem.
    I say this in the big-picture sense that you have to weigh up how many new houses are built per year (circa 140k), and how many wheelchair users (1.7 million) there are.
    Far better to provide grants to modify existing housing stock, than some naive idea that in 12 years you would re-house every wheelchair-bound person across the UK, in a new over-sized bungalow with bathroom, kitchen, living room, bedroom all on ground floor.
    Put the money where the need is.

    Colin Mackenzie Architect

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  • Mikhail Riches are very concerned at these proposals. It would render many of the more innovative, small scale low rise flat typologies which we believe are a sustainable way of building in London, unlawful. Any flat above ground floor would require lift access. What about the Tyneside flat type? That would be a non starter now. Our scheme in Church Walk won several awards and ironically enough the London Mayors Housing Design Award in 2013, but it would not have been possible to apply this latest SPG without significant design compromise - as it was, we just managed to get planning before the Mayors Design Guide blanket ban on ceilings under 2.5m. This is all well intentioned, but hugely problematic in practice.

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  • Planners should avoid making new laws on the hoof. You need a regulatory impact assessment and weigh up the costs to change the building regs.

    Instead, how about taking a guide written for publicly funded housing (the Mayor's Design Guide) and apply it to all housing?

    Unsuitable and unaffordable, straight from the unaccountable.

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  • Planners should avoid making new laws on the hoof. You need a regulatory impact assessment and weigh up the costs to change the building regs.

    Instead, how about taking a guide written for publicly funded housing (the Mayor's Design Guide) and apply it to all housing?

    Unsuitable and unaffordable, straight from the unaccountable.

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  • Draft policy 2.1.13 states the LP SPG will ... ‘adopt’ the Govs nationally described space standards, which will apply to all homes and will apply ‘optional’ building reg. M4 (2) ‘accessible and adaptable’ dwellings to 90% of homes, and optional building reg. M4 (3) ‘wheelchair user dwellings’ to 10% of homes.....
    Building Reg. M4 (1) has been excluded in its entirety. The rationalisation & simplification of the Building Regs was meant to deliver more intelligence and sanity. But this is a total absurdity.
    All architects working in housing should respond to this consultation to highlight this issue.

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