The Government has published a set of design requirements and guidance in a new Healthy Homes Standard (HHS), to be used by Homes England and its delivery partners on schemes funded under the Affordable Housing Programme. This blog outlines a brief review of the standard.
A missed opportunity
In general, the Standard is something of a missed opportunity. It currently fails to recognise that our homes do not function in isolation as determinant of health – health benefits are derived from how they are planned, designed, built and maintained within the wider context of the neighbourhood and communities where they are situated.
Five key themes
What the Standard does do is compile existing building regulations and design guidance – some mandatory and some advisory -around five key themes: inclusivity, amenity, efficiency, comfort, and control.
It also explicitly links housing design to people’s health outcomes, which is currently only implicitly addressed in the National Planning Policy Framework (NPPF) and Building Regulations. Nine specific criteria appear to go further than current regulatory requirements. Notably, the standard applies Building Regulation Part M4(2) on accessibility for all new homes, which goes beyond current national requirements. Similarly, it requires new homes to meet Energy Performance Certificate A and undertake a Whole Life Carbon Assessment (WLCA).
Campaigning for Healthy Homes
Since 2019, the Campaign for Healthy Homes has advocated for a more comprehensive and proactive approach to built environment standards, an approach which aims to positively promote residents’ health. The campaign outlines 12 Healthy Homes Principles, each of which seek better health outcomes from new housing developments.
The 12 Principles for Healthy Homes
The below table examines the overlap and gaps between the TCPA’s Healthy Homes Principles and Homes England’s Healthy Homes Standard (HHS).
| Healthy Homes Principle | Addressed by the Healthy Homes Standard (HHS)? | Does the HHS go beyond existing regulations? |
| Fire safety | Yes – Aligns with Building Regs. Part B (Fire safety) and the Fire Safety Act. | No – Reiterates existing requirements without additional measures. |
| Liveable space | Yes – Promotes adequate internal space and storage as well as requiring all homes to meet the Nationally Described Space Standards (NDSS). | Yes – All homes must comply with the NDSS, although other standards remain optional through local planning policy. |
| Inclusive, accessible and adaptable | Yes – All new homes to meet Building Regs. Part M4(2) on accessibility and the HHS also encourages neurodivergent-friendly homes and designing for diverse cultural requirements. | Yes – M4(2) standards are required as a minimum under the HHS (although possible subject to local planning policy – where adopted) |
| Access to natural light | Partially – there are references to daylight, out- look, and good design for health and wellbeing, but quantitative daylight standards are not required. All homes to be designed to be ‘dual aspect’ where ever possible and at least one habitable should receive direct sunlight during the daytime. | Partially– Uses language ‘At least 1 habitable room within a healthy home should receive direct sunlight during the daytime’ and ‘Healthy Homes should be designed to be ‘dual aspect’ wherever possible’ |
| Cut carbon emissions | Yes – the HSS reinforces Building Regs. Part L (Conservation of fuel and power) and requires homes to achieve EPC A rating or equivalent and undertake a Whole Life Assessment (WLCA). | Yes – requires EPC A and a WLCA for homes and wider development infrastructure following RICS WLCA version 2 (2023). |
| Access to amenities, nature and transport | Partially – requires to be in line with Building for a Healthy Life (BHL) recommendations to provide private outdoor space such as a balcony, terrace, or garden to each home. References active travel, green spaces and community facilities but notes they are covered separately in BHL guidance. | Partially– consistent with existing NPPF policies but does require all homes to provide a private outdoor space. |
| Safe from crime | Yes – requires compliance with the Building Regs. Part Q (Dwelling security). Also encourages new homes to meet the requirements in Secure by Design. | No – reinforces existing policy and voluntary design standards. |
| Climate resilient | Partially – requires new homes to have a maximum estimated daily water consumption of 125 litres per person per day (Building Regs. Part G). Also states strategies should ‘analyse and take into account’ the use of renewable energy systems. | No – relies on current regulatory thresholds; no new requirements. |
| Prevent air pollution | Partially – requires compliance with Building Regs. Part F (Ventilation) to ensure indoor air quality. But no measures to address outdoor ambient air pollution. | No – builds on existing ventilation standards without new limits. |
| Limit light and noise pollution | Partially – requires compliance Building Regs. Part E (Resistance to sound). Refers to guidance for noise levels in BS 8233:2014. No clear reference to limiting light pollution. | No – reflects existing good practice guidance. |
| Ensure thermal comfort | Yes – requires compliance with Building Regs. Part O (Overheating) and Part F (Ventilation). Suggests that ‘indoor temperatures do not exceed 25°C for more than 10% of the year.’ | No – suggested temperature limits (e.g., 25°C for <10% of the year) are good practice examples, not regulatory requirements under the HHS. |
| Genuinely affordable and secure homes | Partially – the standard will be applied to the Affordable Housing schemes so will include some socially affordable homes | No – it does not define genuinely affordable housing based on average incomes. |
How to strengthen the Healthy Homes Standard
Based on this initial review, there are some key opportunities to strengthen the HHS, in particular:
- Access to amenities, nature and sustainable travel: schemes built to Healthy Homes Standards need to connect people to social infrastructure, prioritising wellbeing by linking homes to: i. Essential services, such as the GP and schools; ii. Neighbourhood amenities, including nature, shops, sports and recreation, safe doorstep play and outdoor play spaces; iii. Inclusive active travel and sustainable public transport options.
- Climate resilience: Healthy Homes will need to be built to be future-proofed to be resilient to increasing risk and uncertainty of extreme weather events associated with climate change, including storms, heatwaves and flooding.
- Healthy local environment: Healthy Homes need to contribute to ensuring people are living in a healthy local environment – including: i. Outdoor air quality – through minimising exposure and mitigating features such as natural hedgerow buffers; ii. Limiting exposure to noise pollution and artificial light pollution – balancing the need for safety (via lighting) while avoiding sensory overload; iii. Clean and efficient water supply and sanitation – linked to both energy efficiency and climate resilience, efficient and clean water use, including rainwater harvest systems and biodiverse Sustainable (urban) Drainage Systems (SuDS) need to be built-in to schemes.
Missing details
Importantly, unlike other industry standards, such as Building with Nature and BREEAM New Construction Residential v6.1, the HHS says very little about process. Such as how the plans and design of a site is informed by local health and housing needs.
Or – importantly – how community engagement and co-production will be integrated into the design and delivery of new housing schemes. Criteria ‘a.4 — Designing for diverse cultural requirements’ touches on this, but the standard makes no reference to mechanisms that will support resident involvement and accountability. This will help ensure schemes are being delivered as outlined and in helping to build-in opportunities for learning, refinement and long-term stewardship.
A move in the right direction
Overall, the Healthy Homes Standard can be described as a consolidating framework for Homes England and its partners. It pulls together existing regulations and some guidance under a single standard, with a limited number that go above current mandatory requirements.
However, when reviewed alongside the Healthy Homes Principles, and indeed other standards, the HHS misses some crucial opportunities that would positively promote people’s health in new housing schemes.
The TCPA welcomes this standard as a move in the right direction, but without enforceable health-based standards, the HHS cannot yet be considered a transformative approach to designing the healthy homes and neighbourhoods of the future.
