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ROUND TABLE REVIEW: WATER EFFICIENCY IN NEW BUILD HOUSING 49


around whether litres per person was the correct metric to be using in order to drive uptake of better solutions, rather than the fittingsbased approach which focuses on labelling of appliances on water efficiency to guide specifiers. A  ndustry iewfinder audience survey undertaken by Housebuilder and Developer saw a third of our survey sample saying that even restricting ‘as designed’ water use to 125 litres per person required ‘substantial’ levels of extra investment on their part. Actual ‘in-use’ consumption would be dependent on user behaviour over time. he ational etrofit ubs ohn Slaughter said the industry had embraced innovative solutions to reduce water use in properties, and there was a time lag with regulations having to catch up: “While the housebuilder can only deal in terms of the design specification,  think it’s probably likely that the norm is below 125. This is partly because if you look at the fittings ratings in art G for appliances, for washing machines and dishwashers, what’s available on the market is more efficient than what is listed in Part G.”


PART G REVISIONS: FITTINGS-BASED OR PER PERSON CALCULATIONS? Andrew Tucker of Thames Water confirmed that art  would see a new consultation on changes to update it in various ways in the coming months, which would be a positive move for water saving in new homes. He said that all water companies were “recommending to efra that they only use a fittingsbased approach, and ditch ‘litres per person, per day’ because the numbers are absolutely rubbish and are not needed, and a developer can’t measure them.” e also advocated aligning the fittings based approach with the water label (using mandatory water consumption labelling of products in the same way as current A-G energy consumption labels). This has been promised as a mandatory solution for a while, but Tucker says its introduction is now imminent, “for all basic devices that you currently see in the bathroom, and in the kitchen.” Slaughter said that “having a regulatory target is critical from a developer point of view, and having clarity about what the standard is, is kind of essential.” He said that with that accepted, it was more about ensuring regulations were “revised and updated” in a timely way, with the planned summer consultation on a new Part G having been scuppered by the snap election. Andrew Tucker said the range of consumption even between identical builds is “huge – one house uses 305 litres on average a day, and the one next


Andrew Tucker, Water Demand Reduction Manager, Thames Water


door uses seven and a half thousand litres a day.” He added: “You want to make it as simple as possible for a developer.” Danielle Michalska-Morris, representing the UK’s largest housebuilder Barratt Homes, said that “on paper, not in practice, [major] developers are below 110 litres per person,” and that Barratt and its sister firms edrow and avid Wilson “were all at 105 – on paper.” She alluded to the issue of ‘as-designed’ performance being fully dependent on ‘as-built’ and ‘as-operated’ performance to be fully borne out.


Michalska-Morris acknowledged that


“Part G is very outdated, and there’s new products on the market that we can achieve better with.” She added that in some authorities, particularly in London, they have been for some time driven to go below the regulatory 125 litres per person.” Tom Reynolds of the BMA asked if, in the light of the unified water label having “a really robust methodology,” including technical criteria, “why Defra would do it any other way.”


SOLUTIONS & FITTINGS-BASED CHALLENGES


Dan Lintell of event sponsor Triton Showers said that with whole-house approaches to water saving requiring architects to “balance a myriad of things,” the per-person measurement had a role as it was “very simple.” He asked Andrew Tucker what his alternative approach would look like. While Tucker admitted that the water sector didn’t yet know what the Part G consultation would contain, “all water companies have recommended that efra only use a fittings approach. Tom Reynolds of the Bathroom Manufacturers’ Association (after praising the round table as a “refreshing chance to have a really in depth conversation about water rather than energy”), said that his members were beginning to come around to the fittingsbased approach. “Historically,” he said, “BMA has been very defensive of the water calculation methodology, based on a defence of fleibility and choice for developers who


are effectively our end customers.” He added, however, “I think that position is changing among manufacturers, for a couple of reasons, firstly, as we look to the future and a necessary lowering of per capita consumption because of the looming threat of water scarcity, if we stick with water calculation alone, you’re going to end up with some really perverse behaviours, like people drilling overflows in baths at a really low level, and it will just drive dissatisfaction with bathroom manufacturers’ products.” Reynolds said the industry supported mandatory labelling, but appealed to the Government “not to reinvent the wheel” as they rolled out the new label. “There’s been an industry led scheme called the unified water label operating on a voluntary basis for many years, just make that a mandatory requirement.” Danielle Michalska-Morris of Barratt Homes said there were currently challenges in adopting the fittings approach: “We looked 12 months ago to go to it as our preferred method, but [water companies] come back and say, ‘but we need you to prove your litres per person per day.’” She added: “We’re still still having to do the water calculator; theres no issue with the fittings approach per se, it’s more that the per person measure is still around.” Tom Reynolds said that the regulations around water fittings are in a mess, because we’ve got Part G, we’ve got water supply and water fittings regs, and weve got the water quality regs, we’ve also got the Construction Product Regulation and now the Building Safety Act, which needs to be taken into consideration. And within the next few months, we will have water labelling regulations as well. All of these regulations are really hard for manufacturers to navigate, let alone our various stakeholders. And you know, there’s not always the synergies that you’d expect between these regulations. I think we could do with going back to the drawing board.”


“AS OF 1 APRIL, EVERY WATER COMPANY WILL HAVE TO INTRODUCE AN ENVIRONMENTAL INCENTIVE FOR EVERY HOUSEBUILDER”


ANDREW TUCKER, THAMES WATER WWW.HBDONLINE.CO.UK


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