Eos Architects Director Jaime Moya ponders the grey area that remains over the status of Notional Floor Areas.
04 Sep 2015
As many consultants and housing professionals involved in the design and delivery of affordable housing in Wales will be aware, there has been long standing confusion over the status of the ‘Notional Floor Areas’ (NFAs) listed in the Welsh Government Acceptable Cost Guidance/On Costs for Use with Social Housing Grant Funded Housing in Wales document published in 2012. This confusion arose from the fact that whilst Annex D scheduled a list of NFAs for various house types no other reference was made to the NFAs or their status within the document.
Although Eos Architects’ own informal communications with the folk at the Welsh Government Housing & Regeneration department confirmed that the NFAs had no prescriptive status and that the important thing was that homes should be designed to comply with the standards prescribed by Development Quality Requirements – Design Standards & Guidance (DQR) published in July 2005, some clients were still understandably nervous about design proposals that, whilst complying in all respects with DQR, fell short of the NFAs listed in the 2012 document.
As a result, we had two groups of clients within the same sector that each interpreted the regulatory guidance in a fundamentally different way. One group of clients wanted us to use our expertise in this guidance to design highly efficient homes that delivered the DQR standards within the smallest possible and, therefore, most cost effective footprint, whilst the other group considered the NFAs to be a minimum standard to be achieved in addition to DQR in order to be assured of Social Housing Grant funding for their projects.
Thankfully this confusion has been largely cleared up with the latest incarnation of the Welsh Government document on the subject. Published in April 2015, the new guidance includes explanatory notes that were not present in the 2012 document and they confirm that the “NFAs are not a minimum size as the main criterion should be all designs comply with DQR…” The notes go on to state that whilst house and flat designs that demonstrate full DQR compliance are possible with floor areas below the NFAs, the same cannot be said for designs with floor areas that are described as being ‘significantly’ larger than the NFAs. These may be considered as not representing value for money by Welsh Government, which could elect to cap the SHG input for the project as a result.
Apart from this, the list of NFAs is unchanged from the 2012 document, with the exception that the Shared Abbeyfield type has been omitted and the notes also helpfully provide clarification on the method of measurement to be used for calculating floor areas.
So that’s it then; the confusion over NFAs has been cleared up. Well, sort of. The fact that the trigger point at which oversized dwellings would be considered as not representing value for money (and therefore at risk of having the SHG input capped) has not been clearly specified means that an element of uncertainty over funding remains on any project with dwellings above the NFAs.
Whilst it was possibly not the intention of Welsh Government, this simple omission means that the NFAs may actually become the de facto maximum floor areas for DQR compliant designs for the foreseeable future.
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