| 1. | The environmental impacts of the proposed increase in house building deserve much greater consideration than they have yet received from Government. Whilst we accept the need to improve housing supply, we believe that housing policy should be set within the overarching context of environmental limits. All new housing should be built to standards that minimise environmental impacts. There is a serious risk that, as matters stand, the principal beneficiaries of housing growth will be property development companies, whilst the principal loser will be the environment. (Foreword)
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| 2. | Large scale house building demands prudence, properly joined-up government, thorough environmental appraisals, a respect of environmental limits, local engagement, and improvements in skills, knowledge and awareness. We need sustainable communities and new sustainable housing, but unless they are environmentally sustainable they will never be truly sustainable at all. (Foreword)
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| THE BARKER REVIEW OF HOUSING SUPPLY
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| 3. | The Review's proposal that a set of predetermined market indicators should be used to bring land forward automatically for housing development would be a direct attack on the principles underpinning the planning system. It would establish the principal role of planning as being simply to meet market demand, without regard to any other considerations, including democratic accountability. (Paragraph 20)
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| 4. | It was disingenuous of Kate Barker to insist that there was no geographical dimension to the Review's recommendations when it is obvious to us, and to many others, that any measure that aims to build more where the housing market is stronger will inevitably result in increased building in the South East. It is important that the Government acknowledges and addresses this before taking any steps towards implementing the measures put forward by the Review. (Paragraph 21)
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| 5. | It is a matter of great regret that Kate Barker failed to take full advantage of the remit of her Review in relation to sustainable development. It is also extremely disappointing that the Review did not address how fiscal measures could be used to improve the efficiency of the housing industry and reduce its environmental impacts, as Kate Barker has since told us should be the case. (Paragraph 26)
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| 6. | We urge ODPM and HM Treasury to acknowledge the shortcomings of the Barker Review and to ensure that the concerns Kate Barker has subsequently expressed regarding the environmental impacts of increasing housing supply inform the Government's approach to considering her recommendations. (Paragraph 27)
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| 7. | 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. (Paragraph 30)
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| 8. | 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. (Paragraph 33)
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| 9. | 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. (Paragraph 34)
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| 10. | 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. (Paragraph 35)
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| 11. | 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. (Paragraph 37)
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| THE SUSTAINABLE COMMUNITIES PLAN
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| 12. | It is clear that the Sustainable Communities Plan does represent a positive change in how the Government approaches growth and regeneration. However, we are disappointed not to see set out explicitly in the key requirements for a sustainable community the need to comply with the principles of sustainable development; and we deplore the absence of any reference to environmental protection, or the need to respect environmental limits. (Paragraph 40)
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| 13. | We would like to know if or when ODPM intends to publish its definition of sustainable communities. This definition must give a clear indication of exactly how sustainable development underpins sustainable communities; and should explicitly give the environment equal footing with social and economic goals. (Paragraph 44)
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| 14. | The belated effort by ODPM to explore how sustainable development is linked to the Sustainable Communities Plan is a stark example of the failure of Government to place sustainable development at the heart of policy making and of how environmental considerations remain a bolt-on rather than a primary concern. (Paragraph 45)
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| 15. | It would appear to us that many of the efforts directed towards achieving sustainability within the SCP are little more than a window-dressing exercise. This is unsatisfactory and bound to have severely detrimental consequences in the long term. (Paragraph 52)
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| 16. | Sir John Egan was of the view that it will be very difficult, and probably detrimental to the economy, to focus too much effort on developing northern regions when there is such a draw to the South East from all over the country and from the rest of Europe. He implied that these other regions would develop of their own accord if they had the potential. Whilst this argument may make some sense from a purely economic perspective, it has few merits from a social or environmental one. It is alarming to us that a senior Government advisor should express such views: we believe them to be wrong and would like to hear from Government to what extent it supports them. (Paragraph 57)
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| 17. | ODPM and HM Treasury must make clear at what stage they will judge the South East region to have reached its growth limits and what options they have considered to assist social and economic development within sensible environmental limits elsewhere in the country. (Paragraph 58)
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| 18. | The SCP simply predicts growth in the South East and sets out to provide for it. This predict and provide approach makes no attempt to rebalance housing demand and economic development in the country as a whole. Given the limited ability and willingness of the South East regions to absorb further growth, this reflects a short-term approach from the Government to what is a long-term problem. The undoubted result of the acceptance of such an unequal model of growth can only be to exacerbate regional differences in prosperity, to the detriment of the country as a whole. (Paragraph 61)
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| 19. | It is astounding that despite the clear need for an assessment of the environmental impacts of the proposals for the Growth Areas as a whole, nothing has been done to date by ODPM or DEFRA to address this issue. (Paragraph 63)
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| 20. | It is not satisfactory that there seems to be a degree of confusion within the Environment Agency as to the environmental impacts of further large scale development in the South of England. Ministers should take steps to ensure that any remaining concerns within the Environment Agency are fully explored; and the Agency itself clearly has a responsibility to make sure that it is offering frank and consistent advice. (Paragraph 65)
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| 21. | Development as proposed in the Thames Gateway will result in a long commuter corridor, where most residents will travel to London to work, unless every effort is made to create jobs in the area, provide local infrastructure and ensure a significant proportion of new housing is affordable. (Paragraph 70)
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| 22. | The proposals for growth, particularly in the Thames Gateway, are likely to result in a dramatic increase in the number of properties being flooded unless the Environment Agency's advice is heeded. We support ODPM's proposal that the Agency should become a statutory consultee for applications in areas notified as at risk of flooding or likely to add to flood risk. In the meantime, local authorities should be strongly encouraged to notify the Agency of the outcome of applications to which it had objected on the grounds of flood risk. (Paragraph 72)
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| 23. | There is disturbing evidence that the sum so far allocated for infrastructure funding will not be anything like sufficient to meet the requirement generated by the Growth Areas. The Government should revisit this issue as a matter of urgency and make clear exactly what level of public funding for infrastructure it intends to make available in the Growth Areas over the next twenty years, and assure us and the public that this will not result in other parts of the country suffering a lack of resources as a result. (Paragraph 75)
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| 24. | Lord Rooker's statement that there would be no growth without infrastructure was welcome. However, if this is so then the Government needs to make clear how it intends to ensure timely development of infrastructure to keep pace with housing construction. This does not yet appear to be happening. (Paragraph 76)
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| 25. | The focus in the Sustainable Communities Plan on improving and protecting the local environment is a positive step; however there is as yet no clear understanding of the impacts of development on the wider environment and this has to be urgently addressed. There is a pressing need for a thorough environmental appraisal of the Sustainable Communities Plan. (Paragraph 77)
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| 26. | It is imperative that something as significant as the Sustainable Communities Plan should be assessed for its environmental and other impacts on the country as a whole, not only for its impacts on the areas where growth and investment are planned. With this in mind, the Government should strongly consider a National Spatial Framework similar to those already in place in Scotland and Wales. (Paragraph 80)
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| SKILLS |
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| 27. | We welcome the Egan Review's work, which despite the fact that it was not part of the original brief, makes some progress towards a definition of what a sustainable community might be and which gives greater prominence to the environment than anything as yet put forward by the Government. (Paragraph 82)
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| 28. | It is imperative that the Government addresses the lack of skills and need for training, identified by both Egan and Barker, in all those professionals involved in delivering sustainable communities and regeneration, including outside agencies and consultancies. (Paragraph 84)
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| 29. | Whilst we welcome the creation of the National Centre for Sustainable Communities this will not be enough to address the problems at hand. There is a need for a large-scale training programme for those professionals and officials at all levels already involved in delivering sustainable communities. (Paragraph 85)
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| 30. | If the shortages of skills are not properly addressed as a matter of urgency it is increasingly likely that we will end up with a large number of badly built houses in poorly designed communities with limited transport infrastructure that have severe environmental impacts, rather than the "sustainable communities" that are the Government's stated aim. (Paragraph 86)
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| 31. | As an audit committee we would be very interested to hear from the Government how it intends to measure its success at creating sustainable communities and how it intends to, if at all, compare communities' achievements without the use of a common set of indicators for sustainable communities. (Paragraph 88)
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| PLANNING AND SUSTAINABILITY
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| 32. | We are surprised to see the proposed PPS1 title "Creating Sustainable Communities", given that there is as yet no clear understanding of what sustainable communities are. The final version PPS1 should make very clear how sustainable communities and sustainable development relate to each other and not treat them as interchangeable concepts. (Paragraph 90)
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| 33. | Nowhere in the draft Planning Policy Statement 1 is recognised the need to ensure development occurs within environmental limits, or the need to adopt a precautionary principal with regard to what those environmental limits might be. This is a serious failing and should be rectified by ODPM. (Paragraph 91)
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| 34. | It is imperative that the final version of PPS1 adopted by ODPM, together with the promised guidance on its implementation, makes clear that minimal environmental standards of new houses, and all other buildings, together with their wider environmental impacts, should become material considerations for planning decisions. (Paragraph 94)
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| 35. | In order to limit the amount of undeveloped land being built on to meet housing targets, ODPM should use every effort to maximise both development on brownfield sites and housing densities. (Paragraph 98)
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| 36. | It is vital that the increased pressure for development in the South East of the country does not lead to a gradual erosion of Green Belt land. Neither would it be acceptable for the Green Belt boundaries to be moved increasingly further out to compensate for urban encroachment. (Paragraph 101)
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| THE ROLE OF DEFRA |
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| 37. | The Secretary of State for DEFRA, The Rt Hon Mrs Margaret Beckett MP, has a duty to ensure that sustainable development, which is a vital component of the Department's responsibilities, is properly considered across Government. As a Committee we strongly support Mr Morley's efforts to champion sustainable development within Government and we regret that in the case of housing the Department seems to have been sidelined. (Paragraph 103)
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| 38. | DEFRA is the department with responsibility for taking forward the Government's policies on sustainable development. We therefore find it highly unsatisfactory that when embarking on the Sustainable Communities Plan and the Barker Review - both of which clearly have major implications for the ability to meet sustainability targets - the Government did not feel it necessary to give DEFRA a more prominent role. (Paragraph 105)
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| 39. | Environmental considerations and sustainable development are central to land use and planning policy and it is inexplicable that responsibility for these areas was separated into different departments. It is a matter of urgency that they are once again integrated into a single Government department at the earliest opportunity. (Paragraph 106)
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| HOUSING CONSTRUCTION |
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| 40. | We are alarmed at the apparent ease and possible extent of non-compliance with part L of the Building Regulations. We call on ODPM to carry out a thorough review of the extent of the problem. This should include consideration of how the number of local authority building inspectors can be increased and their skills improved; and examine the feasibility of setting local authorities targets for the number of inspections carried out. We would be concerned about any proposals for extending self-certification schemes without a proper assessment first being made of current levels of compliance with existing self-certification schemes. (Paragraph 116)
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| 41. | Unless significant measures are put in place to reduce emissions from the housing sector from their current level of around 40MtC a year they could constitute over 55% of the UK's target for carbon emissions in 2050, nearly doubling the current 30% contribution. This is clearly unsustainable. (Paragraph 125)
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| 42. | Expected emissions from the housing sector are in themselves a cause of concern, but appear even more worrying when viewed in conjunction with other areas, such as aviation, where emissions are projected to rise dramatically. These increases will significantly affect the UK's ability to meet its targets for reducing carbon emissions. DEFRA recently admitted that on the basis of current policies alone it will not be possible to achieve the 2010 UK domestic target of a 20% cut in carbon dioxide emissions. Our figures show that on current trends exactly the same can be said for the 2050 target of cutting yearly emissions by 60% to 65MtC. (Paragraph 126)
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| 43. | We urge the Government to explore all avenues for reducing emissions from existing housing and for the construction of new housing, given the levels of carbon emissions from this sector. This should include considering the introduction of fiscal measures to encourage improved energy efficiency in homes, in particular the introduction of a reduced rate of stamp duty for all homes that achieve set standards. (Paragraph 127)
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| 44. | There is an urgent need for the Government to review how sustainable construction methods are researched and developed in this country. The current approach is fragmented and the funding so low as to be practically insignificant. (Paragraph 130)
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| 45. | The Government should consider setting up a body specifically charged with encouraging and co-ordinating research and development in the areas of sustainability and construction. (Paragraph 131)
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| A CODE FOR SUSTAINABLE BUILDINGS
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| 46. | We are alarmed to see that yet again ODPM has committed itself to a course of action aimed at increasing the numbers of new houses built without considering the wider implications for sustainability. It is imperative that research is carried out to determine the long-term implications of the significantly increased use of Modern Methods of Construction currently being encouraged by the Department. (Paragraph 133)
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| 47. | We very much welcome the work of the Sustainable Buildings Task Force and agree that there is a real urgency for change and reform in how buildings are designed and constructed. We generally support the approach of the Task Force, although as its proposals stand they will result in a Code for Sustainable Buildings that will not be as stringent or cover as wide a range of areas as we would like to see. (Paragraph 137)
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| 48. | Simply taking the Building Research Establishment's standard forward in the proposed Code could result in a missed opportunity to achieve the step change that is required in construction practices to reduce the environmental impacts of all buildings, including houses (Paragraph 138)
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| 49. | We do not see how ODPM and other departments can claim to be making credible efforts to improve the environmental performance of buildings when they set a target of what will effectively be six weeks or less for the outline of the Code for Sustainable Buildings to be agreed. (Paragraph 139)
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| 50. | We would like to hear further details from the Government on the expected levels of uptake of the Code and how, other than the various demonstration projects that have been mentioned, it will be encouraging uptake by house builders. (Paragraph 141)
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| 51. | The Task Force proposed that the Building Regulations should require 10% of materials in the construction of new building to be recycled. We welcome this, although we would prefer to see a higher figure. In addition, we would like to see the Code include a requirement for any new materials used in construction to meet minimum recylability standards. (Paragraph 143)
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| 52. | The Task Force recommended the Code should be set up to work in conjunction with the Building Regulations. We agree; and ODPM must make clear that the requirements of the Code are precursors to more stringent Building Regulations. It would also help the building industry if the Department set out a clear timeframe for the standards in the Code to be met or to be translated into the Regulations. This is the only way a voluntary Code will have any significant impact on house builders. (Paragraph 147)
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| 53. | The best practice guide for PPS1 called for by the Task Force should give clear indications as to how the Code could be used by local authorities to require improved standards from developers. (Paragraph 148)
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| THE HOUSE BUILDING INDUSTRY
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| 54. | The Government should set out a clear timetable for achieving zero carbon emission homes through the proposed Code for Sustainable Buildings. (Paragraph 149)
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| 55. | While we are encouraged by the attitude of some house building companies the majority are nowhere near achieving the kind of record with regard to environmental performance we would consider acceptable. (Paragraph 156)
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| 56. | The emphasis placed by ODPM on using a few developments as examples of best practice is clearly not enough when we are told that builders are already quite willing and able to meet higher environmental standards when forced to do so. More needs to be done by ODPM to address this. (Paragraph 157)
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| 57. | The apparent reluctance within the House Builders Federation to acknowledge the need drastically to improve the environmental performance of the building process and of new houses is a matter of serious concern. It is particularly worrying that the current political drive for a significant increase in house building coincides with a shortage of skills in the industry. In the absence of commercial pressure to raise the industry's environmental performance we believe that the Government has a duty to intervene ensure adequate environmental standards. (Paragraph 159)
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| 58. | It is unclear to us how increasing the supply of land available to private developers, as proposed by the Barker Review, would in any way compel them to bring forward proposals for smaller dwellings, at higher densities, to reverse the trend in reduced affordable and social housing supply. (Paragraph 162)
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| 59. | The Government should make it clear that it will oblige the housing industry to address the way it functions if there is no clear and significant improvement in housing quality and affordable housing supply by 2007, at the latest. The housing industry as a whole will do very little unless forced to, which the Barker Review has failed to recognise. Unless the industry improves its standards it should expect to be required to operate in an enhanced regulatory environment. (Paragraph 164)
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