Since I last wrote about apartment standards on this blog, a scattering of stories have shifted the debate away from construction costs as a defining factor in the purchase cost of houses. The SCSI have reported that a home with a construction cost of €150,000 will end up retailing for €330,000 in Dublin once the various other costs are factored in. These figures have got a good deal of coverage and have rather changed the tack of how the housing crisis in Ireland, and particularly Dublin, is being discussed.
However, even though construction costs are a small fraction of the overall cost of a home – which has made a mockery of the Department of the Environment, Communities and Local Government’s contention that it was Dublin City Council’s planning guidelines which were pushing up the cost – the debate about construction costs remains instructive. Recent suggestions – like lowering VAT, or development levies – are crude correctives which throw up bigger issues in the long term. Look at them in conjunction with the proposed ways of reducing construction costs, and this crudeness becomes a clear pattern. So below is an exercise in looking at the methods we’ve seen either proposed or implemented to date, and suggesting more equitable and effective ways of reducing cost without seriously reducing the quality of housing. To be clear, I think in the climate of land-hoarding and vulture funds that currently prevails in Dublin, this issue is something of a sideshow. However, it can be useful to see how well a sideshow is performing, if only because it gives you some clues about what you can expect from the main act. So below is a series of measures being considered by, or implemented by, the government and an alternative measure that would be as beneficial and would also be less damaging.
The government is considering: reducing VAT and development levies
An alternative: reform the Building Control Regulations
An obvious one to start. The immediate instinct to cut some of the government levies isn’t without merit, and I certainly can’t see why VAT should be payable on construction materials (which are pretty much essential goods). However, much of the discussion we hear about this tends to ignore the fact that removing levies is essentially a zero-sum game. Development levies go to funding Ireland’s councils. VAT goes to the central government. Reduce or remove these, and that money has to come from somewhere else.
Building Control is quite different; an expense that pays unwilling professionals to do work they don’t need to do, and to take on liability they shouldn’t have to take on. It has been endlessly talked about, both on this site and elsewhere, so I won’t dwell on it. The SCSI’s figures estimate total professional fees at €5500, which strikes me as extremely low and doesn’t include hidden costs (for example, architects are less likely to accept cheaper alternative products because of concerns over liability). Other estimates put the costs of proving compliance at around €30,000 (and let’s be clear – this isn’t the cost of complying with the regulations, it’s the cost of showing you’re compliant) which might be a little on the high side, and includes things like acoustic testing which should really be happening anyway. However, even allowing for this, a version of the UK model would reduce these costs to less than €1000 – quite likely knocking a five-figure sum off costs.
The government said: allow more bedsits
An alternative: enforce average sizes, not minimum sizes
Bedsits are awful. Let’s clarify that right now. Expecting someone to live in a single room, with a kitchenette and bathroom and nothing else, as a long-term option is ridiculous.
However, the concept of a small apartment is not, on its own merits, a bad one. After all, not every apartment has to be a long-term solution for families. The problem with this debate, though, is that apartment “minimum” sizes inevitably tend to also become the maximum. We have ample evidence that, once a minimum size is set, the market will deliver apartments exactly that size: the first instinct of a developer is to get as many units on-site as possible.
Is there a way of tackling this issue while also allowing smaller apartments where appropriate? Yes. Rather than having minimum sizes for each individual apartment, you give a minimum average size across a development for three-beds, two beds, and a combined category of one-beds and bedsits. So if you want to build some small bedsits, fine; however, you’ll also have to build larger-than-average one-bed apartments elsewhere in the development. In other words, you get a mix of large and small. This will give developers more flexibility when building apartments in awkward, confined sites – however it would also cause a shift in the entire way developers view apartments, as the larger ones would have to be targeted at people with more money will use them as a a home for decades.
The government said: reduce apartment areas
An alternative: correct deficient areas of the Building Control Regulations
I’ve already written about how apartments are disproportionately targeted by Ireland’s energy-efficiency regulations, and resolving this situation could knock a few grand off the cost of apartment construction without seriously compromising the energy use of the apartments (which have low energy use in any case).
But since the Department focused on floor area, it’s worth dwelling on another regulation: fire.
Have a look at the plans below. The apartment on the left is roughly based on the one I currently rent. The one on the right has exactly the same room areas, but is smaller by 5 square metres. Given that my apartment’s pretty small to begin with, this is a substantial gain, and it’s reasonable to assume more area savings would be possible with larger buildings. It works by circulating through the living area and saving on corridor space, which serves no real purpose.
However, under Fire Regulations, the layout on the right is or less forbidden.
Technical Guidance Document B (the document pertaining to fire safety) requires apartments to comply a British Standard (BS5588-1) that’s superseded. This old standard makes it more or less illegal for someone in a bedroom to have to escape through another room in case of fire (there are a few exceptions, but in very limited circumstances). This principle has been superseded, partly because fire detection and suppression technology has moved on hugely, but more importantly, it doesn’t actually work in practice. It requires all doors to the corridor to be self-closing, to keep the corridor safe – but door closers are annoying, so people tend to either disconnect them or wedge the doors open. Not only has the newer standard (BS9991) done away with closers as a waste of time, it has also allowed for open plan apartments – so long as they are properly alarmed and a domestic sprinkler system (these are cheap and simple) is installed.
So in short: because the Irish Guidance Documents refer to a standard that’s no longer current, they require developers to waste lots of area providing useless corridors. If the Building Regulations were rewritten to refer to current standards, it would be possible to reduce the area of apartments by a similar area to the DECLG’s enforced reductions – and all without reducing the actual size of accommodation at all.
This is an illustration, nothing more. I’m not suggesting every apartment should be open plan. However, it does show that just re-examining the structure of the building regulations can find cost reductions, without compromising the quality of the apartments at all.
The government said: reduce the number of lifts
An alternative: Regulate the lift provision in total, not by floor
Again, some backstory. Dublin City Council’s development plan stipulated a maximum of six apartments per floor for every lift. Government directives have increased this figure to eight – lifts are expensive, so the fewer lifts need to be provided in a development, the less expensive they’ll be.
However, regulating the number of lifts based on the number of apartments on each floor doesn’t make sense. Lifts don’t serve one floor, they serve every upper floor in the building. A lift serving a twenty-storey building doesn’t serve eight apartments, it serves one hundred and fifty-two: that’s nowhere near enough, and will lead to a long wait for the lift at busy times. In a two storey development, on the other hand, one lift is genuinely serving just eight apartments; in a three-storey, sixteen. This is on the extravagant side, especially since well over half the people in a low-rise building will almost never use the lift.
So lift provision should be done by the number of apartments using the lift in total. Low-rise buildings can have longer corridors, but the higher they get, the more lifts there should be. By changing the requirement to – say – “one lift per forty-five apartments in total or six per floor, whichever requirement is the greater” would enable a three storey building to have fifteen apartments per lift on each floor. The figure would then slide, so that only nine apartments per lift would be allowed for a five-storey building, and six apartments per lift would be the requirement for seven-storey buildings or more. Add in a maximum travel distance from the front door of an apartment to the lift, so buildings don’t end up with corridors the length of a football pitch, and you’ve got a solution that allows lower-rise buildings to reduce the number of lifts they provide, but still requires higher-rise building (with more profit margin) to provide a decent amount.
The government said: fewer dual aspect apartments
An alternative: specify daylight levels in rooms
The Dublin City Development Plan required 85% of apartments to be dual aspect: essentially, this means there should be windows in two external walls facing in different directions. Government directives have reduced this to 50%, allowing it as low as 33% in some circumstances. The problem is that dual aspect makes it difficult to circulate past an apartment, which limits the number of apartments you can have per floor.
However, what’s the dual aspect meant to achieve? It’s a crude-but-effective method of ensuring that apartments get reasonable levels of daylight over the course of a day – and dual aspect is not the only way of achieving this. To give a very obvious example, an apartment with floor-to-ceiling glazing facing in one direction will do better for light than an apartment with smallish windows in two walls.
Here’s the thing: you can simulate and measure daylight levels in a room. You create a computer model of the room, tell the computer its latitude, longtitude and orientation, and then mimic things like sunpaths over the course of a typical day; this creates a “map” showing natural light levels (measured in lux). Specifying minimum light levels is already pretty standard in schools, so we’re not talking space-age technology here. I’m not saying daylight modelling should be compulsory, but I am saying that the regulations could be rewritten to say that all apartments should be dual aspect, but to allow daylight modelling as an alternative to show the apartment has similar daylight levels to a dual aspect apartment if dual aspect isn’t possible.
This benefits everybody: instead of 50% of apartments in a development being badly lit, allowing for daylight modelling means every apartment will be lit properly; it also frees up a developer to have as many single-aspect apartments as they like, so long as they ensure those apartments achieve proper levels of daylighting.
The government says: consult with “stakeholders” on policy
An alternative: directly construct exemplar developments
One of the great truisms of our day is to contrast the leanness, ingenuity and inventiveness in of the private sector with the bloated, inefficient public sector. This is questionable as a principle in general – plenty of innovations come from university laboratories, for example – but for construction it’s particularly shaky.
Innovation involves risk, and developers are a risk-averse bunch. “Developer” has, a little unfairly, become a dirty word but I can’t say I blame them for this. Construction is a risky business. Yes, there’s a lot of money to be made from property development. However it also requires an investment of hundreds of thousands of pounds, if not millions – money that won’t see any return for at least a year, usually two or more, and could end up in a loss. Hardly surprising that most developers want tried-and-trusted, not innovative. Very few developers will permit an architect to come up with innovative solutions to, say, fire safety: if the Fire Authority don’t accept it, then that’s two months wasted talking to them and another four (at least) putting in a revised planning application, with all the costs that brings.
So innovation needs to be lead by the state. I don’t mean the state should build (say) social housing, although I think that would be a good thing and it’s a good thing to see it being discussed. I mean the state should construct some innovative apartment schemes, possibly quite small, that show different ways of building apartments. Hold competitions. Evaluate and peer-review each design stage – this is an experiment, not a rushed construction exercise. And then, when they’re finished, make every piece of data available to everyone. The designs and details; the costs, the savings, the overruns; the timescales; the successes, the problems, the failures. Everything. If some of these apartments lose some money, that’s OK: others will make money to compensate, and it’s as valuable to learn what doesn’t work as it is to learn what does. The private sector can use this resource, taking the elements that work, ignoring the elements that don’t. It could turn a profit for the state; it would provide much-needed housing; and it would enable the industry to become more knowledgeable.
So that’s six ideas. All but the last would be simple to implement. Some of them may not work; it’s a brainstorm rather than a tested set of proposals. And just to restate, I don’t think that construction costs are a very big issue anyway. What I’m trying to it do is illustrate the gap between how these issues can be thought about, and how they are thought about.
The least Irish people can (and should) expect is that standards, procedures and state actions to be put together carefully, knowledgeably and with thought. And yet the pattern in Ireland seems to be to just look at the provisions that are there and either beef them up or (as is the case recently) weaken them. What we see, consistently, is the most obvious, most reductive technique being applied. Minimum sizes are too big, so make them smaller; lifts are expensive, so have fewer of them; dual-aspect apartments are difficult to plan, so let’s have fewer of those too; VAT is a cost, so let’s get rid of it.
However anyone depicts this, it’s not “reform” of building standards, or anything even close to that. It’s just an accounting exercise: one that doesn’t bother to ask how best to serve Ireland’s needs. or how to make laws that work for the industry and for the people. Now there is a new Minister, with a new job title, and there’s more talk of reform. The problem is that, even now, there’s no evidence that competent “reform” is something within the capabilities of those in charge.