HBF has consulted widely amongst its membership on the various proposed changes to Building Regulations Part E.
BUILDING REGULATIONS PART E - RESISTANCE TO SOUND
HBF has consulted widely amongst its membership on the various proposed changes to Building Regulations Part E and has forwarded a response to DETR, attaching a list of observations and suggestions for amendments to the draft Regulations and Approved Document.
HBF members are generally supportive of the aim to ensure that adequate levels of sound insulation are provided between attached dwellings. Many anticipate building a large proportion of houses and flats designed to meet the call for high-density urban living accommodation heralded by current planning guidance, creating an environment where neighbours will be living closer together than ever before.
This said, HBF members have expressed a number of concerns about the proposals for post-construction testing contained within the consultation document and have recommended that these be dropped in favour of `robust standard details` (as are being developed to support the new Part L proposals). Full reasons for this are given in our response (click here to view). The main problems include:-
* costs (which are under-represented in the consultation papers);
* the number of units required to be tested (this is also underestimated);
* the scope for building control inconsistency;
* uncertainty (high early failure rates likely - unknown cost of remedial works);
* impracticality (works will be complete, with skirtings and covings fixed and, for floors, carpets laid, before testing can be carried out); and
* availability of testing equipment (given that the numbers to be tested are likely to be higher than DETR has estimated).
Other `technical` issues about which HBF made adverse comments include:-
* the absence of `deemed-to-satisfy` examples of wall and floor constructions within the draft document (robust standard details would address this);
* a number of conflicts with Part L are unresolved, especially at wall/wall and wall/floor junctions (again, robust standard details would provide the solution);
* intermediate floors within houses (even detached houses) will have to be insulated; and
* wet plaster is recommended for masonry party walls (notwithstanding skills shortages; and conflict with Part L, Egan, NHBC `standards and finishes` etc.)
In short, HBF accepts the need for regulatory change but favours investment in the structure and fabric of new homes rather than the funding of a new control regime.