THE ENTEC REPORT
28. In April 2004 Entec, an environmental and engineering
consultancy, published a report, Study into the Environmental
Impacts of Increasing the Supply of Housing in the UK, which
had been commissioned by DEFRA's Rural and Resource Economic Division.
It was commissioned as a desk study to be delivered within six
weeks and the Barker Review's final report was published, although
it was published after this and consequently includes a supplementary
note summarising the relevant aspects of the Review's final report.[26]
29. According to DEFRA the timetable "was
extremely tight" for the study. DEFRA also stated that
because of this "the figures included in the report are
indicative and require substantial qualification and interpretation".
Therefore it "remains the view of Entec, not DEFRA".[27]
According to Entec (in the introduction to its report), the time-scale
"imposed limits on the depth of the technical work, which
could have been carried out more robustly and with greater breadth
over a longer period of time". Despite its shortfalls,
the Entec Report is very useful. It gives some insight into the
type and scale of environmental impacts than can be expected from
building dwellings at the rates set out in the SCP and as proposed
by the Barker Review.
30. The publication of the Entec Report on the
environmental impacts of increasing housing supply, though belated,
was welcome as a very important step in the right direction. It
is, however, lamentable that a report on such a key area of policy
had to be carried out in just six weeks. This suggests that DEFRA
was slow to realise the potential impacts of the Barker Review.
31. The Entec study found that by far the biggest
environmental impact from increasing housing supply was the significant
increase in CO2 emissions that result from their construction
and use. The external costs from such emissions outweighed the
costs of any other damage by a factor of ten. In addition the
study found that the use of higher environmental standards in
construction would significantly lower the environmental impacts
of housing over 30 years. The study also found that contrary to
received opinion, building at higher densities could result in
higher environmental impacts. However, the report acknowledges
this may not be a valid conclusion as it was not possible, due
to the limited time-frame, to take the benefits of more environmentally
sustainable transport associated with higher density development
into account. Further work to clarify the issue should be carried
out as a matter of urgency.
32. DEFRA expressed its concerns to us regarding
the approach used by Entec. It highlighted that the scenario in
the report that resulted in the highest environmental costs (£8.3bn
over the next 30 years) used as a baseline no house building at
all over that period. The implication of this is that the impact
of homes being built at current completion rates, and as part
of the SCP, should be assumed and therefore should not be taken
into account. DEFRA indicated that the baseline for determining
environmental impacts should be taken as current build rates.
This approach would result in the maximum figure for costs to
the environment in the Entec Report being nearly halved to £4.3
billion. It would seem that DEFRA is suggesting that it is unnecessary
to determine the unarguable environmental impacts of the 140,000
new homes that are being built each year, or those proposed in
the SCP, and that it is only important to determine the impact
of the extra homes, up to 120,000 a year, proposed by the Barker
Review. However, DEFRA in adopting this strategy has chosen to
ignore the environmental impact of existing house building programmes.
We note that the ODPM Select Committee in its inquiry, in April
2003, into the SCP called for an independent and comprehensive
review of the environmental impact of the proposed housing development
in the Growth Areas. We regret that no thorough review of this
kind has yet been carried out.
33. We urge ODPM and DEFRA to ensure that any
future study on the environmental impacts of increasing housing
supply in England takes as its baseline no growth over the next
thirty years. It is vitally important that the impacts of all
homes that are to be built over this period are determined, so
as better to inform the decisions on how and where they should
be built, and this is the approach that ODPM and DEFRA should
take. This is the only credible way of determining the overall
impacts of increased house building. For the avoidance of doubt,
we are not arguing for zero growth, simply for the impacts of
all growth, even growth that is already expected, to be fully
considered so as to be better placed within the overarching context
of environmental limits and to enable proper mitigation against
its environmental impacts.
34. It is therefore with concern that we see, in
the final memorandum to us from ODPM, that together with DEFRA,
it is commissioning joint research, a sustainability project,
into "the effects of additional housing on sustainable communities".
We seek reassurance from both ODPM and DEFRA that any research
commissioned by departments into the environmental implications
of the proposed house building shall be a continuation of the
work initiated by Entec. The terms of reference for this research
must be made public as soon as they have been agreed.
Taking the Review Forward
35. In evidence to us Kate Barker significantly qualified
the views and recommendations set out in her Report. Not only
was she much less forthright in her views when giving evidence
on how to increase housing supply and improve affordability, she
also made clear that there should be an assessment of the environmental
implications of her proposals.[28]
She also expressed significant reservations regarding the quality
of available information on which housing policy decisions were
being made, telling us that "careful reading of the report
would suggest that the confidence based in the absolute figures
is not high".[29]
Indeed, the third recommendation from the Review states that "further
research should be undertaken to improve the evidence base for
housing policies". The present evidence base for
the Government's housing policies is inadequate and it is imperative
that the Government ensures that work is carried out to rectify
this. We recommend that no proposals are taken forward to further
increase housing supply without ensuring that there is a sufficiently
strong evidence base to support them.
36. Giving evidence before us for the second time,
Lord Rooker reiterated his earlier position that ODPM would not
be able to pronounce on the Review's recommendations until the
end of 2005, at the earliest, and that in the meantime it would
not be possible to give any indications of what particular recommendations
the Department would be taking forward.[30]
We were told in the ODPM's supplementary memorandum that "given
the large number of recommendations in the Barker report, and
the differing timescales within which they need to be addressed,
the Government does not intend to publish a single response".
Instead, "as proposals are developed to address specific
recommendations, they will be subject to consultation in the normal
way".[31] However
it was still possible for the document to set out the work that
was being carried out to implement many of the Review's recommendations
and included was a timetable for the forward programme regarding
the recommendations from the Review. According to this timetable
work should already be underway to develop a methodology for a
national market affordability goal with the aim of consulting
on a draft national affordability goal and indicative regional
targets by December 2005 (Recommendation 1). The Government will
also be reaching conclusions on the Review's proposal for a Planning
Gain Supplement (Recommendation 26) by that date and setting up
a new arrangement for offering independent advice on housing numbers
to the merged Regional Planning Bodies and Regional Housing Boards
(Recommendation 6). The Department for Transport has already announced
the creation of a Community Infrastructure Fund (CIF) with funding
until 2008 (Recommendation 22). Furthermore, in her supplementary
memorandum Kate Barker told us that the Government was carrying
out work and planning to consult on various areas that "cover
the most significant recommendations which apply to Government".[32]
We find it astounding that Lord Rooker can categorically say that
it will not be possible to give a response to the Barker Review's
recommendations until the end of 2005 when there is clearly already
significant work going on within ODPM to take forward many of
the Review's recommendations.
37. It should be entirely possible, and indeed would
be desirable, for a position statement on the Review's recommendations
to be published by the Government. The implication from ODPM that
it is not possible to state which of the Barker Review's recommendations
are being taken forward without having reached a decision on exactly
how to implement those recommendation it accepts is disingenuous.
Whilst there may be some awareness amongst those sectors closely
involved in taking the Barker Review's recommendations forward
of what Government views are there is nothing in the public domain
that makes this clear. This is unacceptable. ODPM and HM Treasury
should publish a substantive response to the Barker Review as
a matter of urgency. This response should set out which recommendations
are being taken forward, which are being considered as options
and which have been discarded. It should also include details
of what work is currently underway on the various proposals from
the Review.
9 HM Treasury Press Release, 'Delivering stability:
securing our future housing needs',17 March 2004 Back
10
HC Deb 17 March 2004 c322 Back
11
HC Deb 28 April 2004 c309-10WH Back
12
Barker Review of Housing Supply: Delivering Stability: Securing
our future housing needs, Final Report, March 2004 Back
13
Ev3 Back
14
Barker Review of Housing Supply: Delivering Stability: Securing
our future housing needs, Final Report, March 2004, box 2.1 Back
15
Q 544 Back
16
Ev287 Back
17
Q83 Back
18
Ev42 Back
19
Q443 Back
20
Ev123 Back
21
Barker Review of Housing Supply: Delivering Stability: Securing
our future housing needs, Final Report, March 2004 Back
22
Q365 Back
23
QQ 423-4 Back
24
Q580 Back
25
Ev136 Back
26
The Entec report looked at aspects related to housing construction
and occupation. To asses the impacts of construction it considered
the embodied energy (in terms of CO2) of building materials
and elements, construction waste and aggregates. It also considered
the following impacts resulting from occupation: primary energy
use (in CO2 terms), domestic waste production and water consumption.
It did not, however, consider other pollutants from energy use,
transport impacts or lifecycle impacts of materials used in construction. Back
27
Ev112 Back
28
Q 463 Back
29
Q 430 Back
30
Q 857 Back
31
Ev84 Back
32
Ev138 Back