Select Committee on Environmental Audit Written Evidence


Memorandum by The Royal Society for the Protection of Birds (RSPB)


  1.  The RSPB is Europe's largest wildlife charity with over one million members. We manage one of the largest conservation estates in the UK with more than 180 nature reserves, covering more than 100,000 hectares.

  2.  The RSPB's policy and advocacy work covers a wide range of issues including climate change, energy, education for sustainable development, marine issues, water trade and agriculture. The RSPB's professional conservation and planning specialists make representations on over 400 items of planning casework each year throughout the UK, including national planning policy guidance, regional planning, development plans and individual planning applications and proposals. We have considerable planning experience. For example: we worked with the Sustainable Development Commission on the new sustainable development duty in the Planning and Compulsory Purchase Act 2004; and have been involved in the Office of the Deputy Prime Minister's Planning Advisory Group in relation to the development of Planning Policy Statement 1.

  3.  The RSPB is the UK member of the BirdLife International Partnership, a global alliance of independent national conservation organisations working in more than 100 countries worldwide. The RSPB was actively engaged with the World Summit on Sustainable Development (WSSD) and are now working to ensure sustainable development is central to policy, decision making and action at all levels.


  4.  The RSPB is concerned about the impacts that the location and design of house building will have on wildlife and the environment. We agree with a recent report for Defra (2004) that if EcoHomes are built, more houses can be accommodated at less cost to the environment. To demonstrate the efficacy of this, we estimate a cost-benefit ratio for higher energy standards for new housing.


  5.  The RSPB is concerned that the conclusions and implications of the Barker Review are potentially incompatible with the general principles of sustainable development and the Government's own sustainable development objectives. Neither the Barker Review, nor the Government's Sustainable Communities Plan, has been subjected to any kind of sustainability appraisal or strategic environmental assessment. Therefore, an overarching national strategy, which is subject to a proper and rigorous assessment, is needed to ensure that the environment is at the heart of any building programme and that the outcome would be beneficial for society.

  6.  The planning system is currently undergoing major change. It is essential that it remains robust enough to ensure that the environmental implications of building projects are fully taken into account. Although there is a new statutory requirement for all Regional Spatial Strategies and Local Development Documents to be subject to sustainability appraisal, we are concerned that this may not be sufficiently rigorous to identify fully the environmental impacts of major house building programmes in the South East of England or elsewhere. We are particularly concerned about the Office of the Deputy Prime Minister's (ODPM) proposals to incorporate the requirements of the Strategic Environmental Assessment Directive within the sustainability appraisal process; further guidance on this has not yet been published by the ODPM. All environmental impacts need to be properly considered and mitigated for where necessary, not "traded off" against economic or social objectives.

  7.  Such assessments should identify priority environmental issues. For example:

    (i)  Water shortages vary across English regions; sustainability appraisal of regional or sub-regional strategies should identify the most water stressed catchments, so that the highest water efficiency standards can be pursued in those areas.

    (ii)  A proposed new housing development at Holton Heath in southeast Dorset was rejected at public inquiry in 2002 due to the intolerable pressures it would have placed on designated wildlife sites of international importance. Any strategic assessment of house building or other development proposals should identify the cumulative national impacts on designated wildlife sites.

  8.  The Barker Review could have serious negative impacts on the environment and society, not only through a significant house building expansion, but also through the wider infrastructure and development that will accompany it. Many of these significant environmental impacts will be external to the market. Regulation must be used to minimise these externalities, for example, on issues like water supply and flood risk, to prevent loss of "functional green infrastructure"[22] and to improve the wildlife value of developments.[23] If such factors are not mitigated by genuinely sustainable development, society will face higher costs in the long term. This is why sustainable use of natural resources makes sense for current and future generations.

  9.  However, regulation cannot provide all the solutions. Therefore, the use of economic instruments is essential to encourage the efficient use of natural resources, minimise impacts on the environment, and drive technological change.

  10.  Sustainable development policies have been in place, and recognised as an issue within the construction sector, for a number of years. However, there remains inertia in the industry to delivering improved environmental performance, for example due to skills barriers. Policy objectives and voluntary approaches have clearly not brought sufficient change. Therefore, regulation and economic instruments are justified and essential to drive improvements in the environmental performance and standards of the industry; owing to the longevity of the housing stock, its output will form a significant part of the world we pass on to future generations. Improvements to the environmental performance of new buildings are known to be feasible and affordable; if we fail to achieve them, we will fail future generations and the environment.


  11.  The RSPB believes that building regulations should be strengthened to ensure much better environmental performance from new housing. We believe this is our obligation to future generations and the environment, and is justified in terms of current costs and benefits.

  12.  An analysis of costs and benefits of house building standards is possible using reports from Defra (2004) and the Housing Corporation (2002). These studies were not designed for direct comparison, so analysis should be undertaken with caution. For simplicity, only comparison of the costs of energy efficiency measures and carbon savings has been made. The comparison is based on the BRE EcoHomes "excellent" standard, and the scenario in the Defra study that represents the expansion requirements outlined by the Barker Review.

  13.  The costs of achieving EcoHomes "excellent" standard have been estimated at around £1,760-£3,000 per home. This represents just 1.2%-2% of the average house price. However, the work for the Housing Corporation identified additional costs for social housing of the energy efficiency measures necessary within this standard of just £130 per home. The benefits of reducing carbon emissions are estimated in the Defra (2004) study at £19 per tonne, which the RSPB considers to be a very conservative figure. The costs and benefits are discounted at 3.5%, and are compared in the table below.

Total homes built per year
Cost of EcoHomes "Excellent" energy standard on all new homes over 15 years
Damage avoided over 30 years, from carbon emissions reductions
Benefit: Cost Ratio

£466 million
£2,900 million

  14.  The benefits, from reduced energy use, of building to EcoHomes "excellent" standards are six times greater than the costs. The RSPB believes that higher estimates of the potential future damage from climate change can be justified, and if these are adopted, the case for greater energy efficiency becomes even stronger. Even if a discount rate of 10% is used, the ratio stays above 4.5:1. The case for strengthening building standards is overwhelming.

  15.  In addition to climate change, housing produces significant environmental impacts in the form of land take, waste generation, resource consumption (eg aggregates and timber) and water use. Cost-benefit analyses of each of these impacts are required to justify the increased consumption of resources implied by the Barker Review. The RSPB believes that tighter resource use standards are justified, and will produce social as well as environmental benefits. For example, simple technologies, such as dual/low flush toilets, mixer taps, water butts, and low flow showers, can save 23 litres per occupant per day (5% of water use) (Environment-Agency OFWAT, 2001). This can reduce the average household water bill by £43 in the first year.

May 2004

22   Described in the ODPM plans for the Thames Gateway at: Back

23   Eg: RSPB Good Practice Guide for Prospective Development (RSPB, 1997), Biodiversity Impact (RSPB, 2001) Working with Wildlife Pocketbook (CIRIA, 2004), all available through the RSPB. Back

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