APPENDIX 8
Memorandum by The Royal Society for the
Protection of Birds (RSPB)
INTRODUCTION
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.
SUMMARY
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.
SUSTAINABLE DEVELOPMENT
AND THE
ENVIRONMENTAL IMPLICATIONS
OF HOUSE
BUILDING
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.
COST-BENEFIT
ANALYSIS OF
HIGHER ENVIRONMENTAL
STANDARDS FOR
HOUSING
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
|
|
| High | 301,000
| £466 million | £2,900 million
| 6.2:1 |
|
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: http://www.odpm.gov.uk/stellent/groups/odpm-communities/documents/page/odpm_comm_026908-06.hcsp 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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