APPENDIX 2
Memorandum from Sustainability Works
1. OUR ORGANISATION
AND ITS
RELEVANCE TO
THE COMMITTEE
1.1 Sustainability Works (www.sustainabilityworks.org.uk)
provides a free web-based sustainable housing tool, hands-on training
sessions, expert consultancy and assistance for housing associations,
local authorities, consultants and developers needing guidance
on how to develop housing in a sustainable way.
1.2 Based around a 2,000 page library of
expertly researched, regularly updated information on sustainable
housing, the on-line tool enables registered users to write a
sustainable development policy for their organisation, set sustainability
targets and check progress throughout the development process
on individual projects, as well as compare projects against recognised
standards such as the Building Research Establishment EcoHomes
and Housing Quality Indicators.
1.3 Funded by the Housing Corporation until
April 2005, Sustainability Works has two years proven success
with over 1,000 registered users from all sectors of the housebuilding
industry, plus an ongoing training programme comprising sessions
on how to gain maximum use from the on line tool as well as bespoke
training and consultancy on sustainable development for individual
organisations.
1.4 The Sustainability Works on-line tool
offers a set of recommendations guiding organisations to build
up their own holistic framework for sustainable housing—this
is of direct relevance to the EAC consideration of how any future
building programmes can be made truly sustainable and take full
account of environmental objectives as well as social and economic
ones—our remit is to give guidance to housing organisations
on exactly these issues. Sustainability Works also understands
the concerns and priorities of the UK housing industry through
regular contact with its registered users' database and face to
face contact through training and consultancy.
1.5 Sustainability Works has responded to
the issues of specific concern to the Committee in 2 below.
2. ISSUES OF
SPECIFIC CONCERN
TO THE
COMMITTEE
2.1 Are the conclusions of the Barker Review
compatible with the general principles of sustainable development
and the Government's own sustainable development objectives?
The general principle of sustainable development
is to meet basic needs and improve the quality of life, while
ensuring that natural systems and resources are maintained and
enhanced both for the benefit of existing and future generations.
Put simply—passing on the planet in good shape to our children,
grandchildren and beyond. The Government's own sustainable development
objectives are for social progress recognising the needs of everyone,
effective protection of the environment, prudent use of natural
resources and high, stable levels of economic growth and employment.
The conclusions of the Barker Review suggest that the rate of
housebuilding ( particularly affordable housing) must dramatically
increase to meet demand and to reduce the cost of UK housing.
In order to achieve this massive increase in housebuilding, greenbelt
designation should be revisited and the planning system changed.
A large programme of new housebuilding would
not necessarily be in conflict with the principles of sustainable
development. Making housing more affordable and having a housing
stock which was medium to high density with good access to open
spaces which fostered biodiversity, free from crime, sited in
cohesive, inclusive communities which were involved in the development,
management and maintenance of their homes, built from environmentally
friendly materials, energy efficient, well designed with sustainable
infrastructure, good public transport, local jobs and services
all nearby—all this would be in line with the objectives
of sustainable development and an asset to be handed on to future
generations.
Also, for housing to be sustainable in the long
term it is necessary for it to be designed and constructed to
be adaptable to changing needs and expectations. Residents should
have a role in the design and management of their homes. This
implies a shift in the housing market towards stakeholders having
a significant role in decision-making and away from housebuilders
having the overwhelming say in what gets built.
So yes—the Barker review conclusions could
be compatible if new housing adopted a holistic approach with
stakeholder involvement and higher environmental standards than
those currently implemented by the house building industry. Conversely,
if the housebuilding industry's reaction was to produce more of
the same, but in greater quantities—it would be a lost opportunity
and not an asset for the future.
2.2 In view of the Barker Review is there
are need for an overarching national strategy to ensure that the
environment is at the heart of any building programme?
We think that there is already a good sustainable
development strategy in place—"A Better Quality of
Life" so a new national one would not add anything further,
plus sustainable development requires local and regional solutions,
not a "one size fits all" approach. What is lacking
is any "teeth" to the implementation of sustainable
development- better planning control and building regulation is
needed which incorporates the sustainable development agenda,
plus the requirement for any new development projects to have
a holistic environmental strategy.
2.3 Is the current planning system robust
enough to ensure that the environmental implications of building
projects are fully taken into account? How can the planning system
be used to increase the building of more sustainable housing?
Would the proposed changes to the planning system in the Barker
Review have a positive or negative effect on the environment?
We think the current planning system is not
robust enough at present. As it stands the planning system confines
itself to land use issues, requiring minimum densities of 30-50
dwellings per hectare (we think higher minimum densities may be
appropriate for the majority of sites ), planning encourages mixed
use, the sequential approach to previously developed land, and
the percentage of affordable homes (usually dealt with by Section
106 agreements.) Some local authorities have Supplementary Planning
Guidance which asks for a sustainable development checklist to
be submitted, which covers a broader range of sustainable development
issues. In some authorities there is also a requirement for the
scheme to be submitted for a BRE EcoHomes assessment, but this
practice is not widespread. Local authorities are often worried
about discouraging developers from investing in their area, so
are loathe to impose more onerous requirements than neighbouring
authorities. Environmental Impact Assessments are only required
on some sites and even then are submitted after planning permission
has been granted.
We think that the remit of planning needs to
be widened beyond issues like density and the use of previously
developed land to include other environmental aspects. Any new
scheme should be considered in a holistic way—land use issues
should be seen as inseparable from issues such as the potential
for sustainable infrastructure, renewable energy generation etc
on specific sites. Planning has the potential to look at these
issues in the local context (rather than a one size fits all approach),
which is essential to sustainability. All applications should
be required to have a sustainability checklist assessment of some
sort. The division between planning and building control should
be remedied—this is recommended in the TCPA's Sustainable
Housing Forum Report called "Building sustainably" October
2003.
The proposed changes to the planning system
in the Barker review include changes to the decision making process
governing the allocation and release of land at local level, as
well as assessing land according to its relative value to society
(which is a radical way of considering land value).
The environmental implication which is causing
concern in some quarters is that greenbelt land will need to be
released in certain areas where there is worsening market affordability
and where brownfield land is difficult or slow to develop. Any
developments which resulted in urban sprawl would be contrary
to the principles of sustainable development, but it is true to
say that some urban fringe land offers very little environmental
benefit, as does agricultural land which is intensively cultivated
and does not foster biodiversity. Any relaxation in greenbelt
designation and loss of agricultural land would need to compensated
for by rigourous environmental standards being insisted upon,
such as efficient use of land, high ecological value landscaping,
sustainable transport and infrastructure provision. Only if the
release of greenbelt was seen as an opportunity to built projects
to higher environmental standards than the norm, would there be
an overall environmental benefit.
2.4 Where will the proposed new housing be
built? What are the implications for land-use and flood risk of
the large-scale proposed building projects?
New housing will probably be built in the growth
areas identified in the Sustainable Communities Plan. Some may
be built on urban fringes or agricultural land, particularly in
areas where brownfield land is difficult or costly to develop
due to land contamination or land assembly problems and delays.
Any redesignation of the green belt should have sustainable development
strings attached—eg higher density/mixed use/local public
transport/local facilities and services/local energy generation
etc all provided by the developer.
A large amount of the development proposed in
the Thames Gateway is at potential risk from flooding. So new
developments will effect flood risk. The use of permeable surfaces,
local retention ponds etc should be mandatory for new developments.
Flooding may become particularly problematic with adverse weather
conditions predicted due to climate change—a precautionary
approach should be taken.
2.5 Is it possible to ensure materials and
resources used, and waste produced, during building do not have
a harmful impact on the environment?
It would be possible to significantly reduce
the impact on the resource use and waste from housebuilding by
adopting the use of environmental assessment methods including
Life Cycle Analysis, Green Specification for Housing and Environmental
Preference Method. These methods assess the environmental impacts
of the air and water pollution produced by the extraction, transport,
manufacture and disposal of materials. The Building Regulations
do not currently cover the environmental impacts of materials.
BRE EcoHomes currently assesses a limited range
of impacts, from the use of timber for example, and could be extended
to cover the impacts of construction as a whole. The market for
low impact materials and products is relatively small at the moment
and many materials are imported or expensive or both and increased
regulation in this area would create a competitive market for
green products.
2.6 Are the building regulations as they stand
capable of ensuring that new housing is truly sustainable in the
long term? How could they be improved? Could greater use be made
of existing environmental standards for housing?
Ensuring that new housing is truly sustainable
requires amongst other things that the Building Regulations are
extended to include higher standards of energy conservation, the
conservation of water and the environmental impacts of construction.
However, the Building Regulations cannot of themselves ensure
that new housing will be sustainable; this requires a sustainable
approach to planning issues which include density, transport and
access to facilities.
2.7 How will it be possible to ensure a sustainable
infrastructure, including transport and water supply, which will
be necessary to support any extensive house building, is put in
place?
The technology for providing sustainable forms
of infrastructure exists; the problem will be persuading developers
to implement it. Again, better building control and planning regulation
which insists upon a holistic approach will be necessary.
A more imaginative use of section 106 agreements
might include developers funding or contributing to sustainable
public transport systems, local water supply and renewable energy
generation for example.
2.8 Do those involved in housing supply, both
in the public and private sector, have the necessary skills and
training to ensure new housing meets environmental objectives?
If not, how can the knowledge base of those involved in the planning
and building process be improved?
No, in our experience there is a general lack
of skills and awareness, particularly in the private sector. We
have trained around 250 people involved in housing development
in the last 18 months, mostly from the HA sector but increasingly
from private housebuilders, consultants and local authorities.
Our training and dissemination programme has
shown that housing associations are starting to address the environmental
agenda due to the Housing Corporation's requirement for a sustainable
development strategy and for all new schemes to achieve an EcoHomes
"good" rating. The result is general awareness raising.
Most housing associations are working up their own sustainable
development policy and there is currently some really innovative
work coming from the HA sector.
Also, there are isolated attempts from housebuilders
who are becoming more environmentally aware and who realize its
potential as a marketing strategy. The publicity and coverage
surrounding Bedzed and Greenwich Millenium Village for example
has been immensely positive in this respect. But there is still
a general lack of knowledge and skills amongst the majority of
clients, housebuilders and consultants.
There are various tools available to improve
the knowledge base, including the Sustainability Checklist, BRE
EcoHomes, Green Street (a Sustainable Homes initiative)and our
own Sustainability Works. All of these tools have benefited from
seed funding but actually need continued funding and support,
as well as endorsement from central and regional government to
ensure that organisations continue to use them. In our case, we
only have guaranteed funding until 2005 from the Housing Corporation
to continue to run the website and carry out our subsidised training
programme.
A critical element of knowledge base improvement
is regular monitoring and self review. We emphasise on our training
courses that it is not sufficient to just set a sustainable development
policy, but the policy must filter down to individual development
schemes and be monitored through the life of the project, plus
lessons learnt fed back into future developments.
May 2004
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