APPENDIX 14
Memorandum from ecoSE
1. INTRODUCTION
1.1 Who are ecoSE?
ecoSE is a key strategic partnership in the
South East of England, consisting of a range of organisations
from the public and private sector. The current membership comprises
representatives from the following organisations:
— Environment Agency (Southern and
Thames Regions).
— South East England Regional Assembly.
— Government Office of the South East
(GOSE).
— South East England Development Agency
(SEEDA).
— Woking Borough Council.
— Town and Country Planning Association.
1.2 Why are we submitting a memorandum?
The Environmental Audit Committee's inquiry
into Housing: Building a sustainable future is of direct relevance
to the work and objectives of ecoSE, and is strongly commended.
The ecoSE partners have a common objective to ensure that housing
development in the South East takes place in a carefully planned
manner; one which will allow sustainable economic growth, will
create a better quality of life through addressing social issues,
and will both protect and enhance the environment.
1.2.1 The partnership was formed in a direct
response to the significant environmental pressures that already
exist in the South-East, such as scarcity of water resources,
increasing energy use and waste production, increasing flood risk
etc., which may be exacerbated by the current growth forecasts
for the South-east.
2. EVIDENCE RELATING
TO THE
ISSUES OF
CONCERN TO
THE COMMITTEE:
COMMITTEE QUESTIONS
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?
2.1.1 ecoSE is committed to working towards
a prosperous region that understands the need to balance social
environmental and economic issues. Therefore the suggestion from
the Barker review that economic considerations of new housing
may have to "over-rule" environmental objectives is
of potential concern.
2.1.2 Social, economic, or environmental
objectives are not mutually exclusive. Sustainable development
should ensure that progress is achieved without negatively impacting
on any of these objectives and, wherever possible, utilises opportunities
to enhance them.
2.1.3 A balanced and integrated approach
to housing development is therefore required. ecoSE believes that
through high quality design of communities, raised housing construction
and design standards, retrofitting of older housing stock, and
working together to establish new skills and financial mechanisms,
the needs of sustainable development can be addressed in a positive
way.
2.1.4 The economic benefits of unsustainable
housing development also need to be seen in the context of any
resultant accelerated climate change, more frequent water shortages,
more waste management facilities, increased flooding, higher household
bills and potential EU infraction proceedings against the UK for
infringements of numerous EU Directives. This will impact upon
the social and economic prosperity of the South East and thereby
the UK.
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?
2.2.1 The current review of the National
Sustainable Development Strategy could be used to set the overarching
principles that should ensure that the environment (including
water resources, flood risk, and water quality) is considered
in conjunction with social and economic issues. It is then important
that a requirement is made for this guidance to filter down to
all government guidance and initiatives, including building programmes.
2.2.2 ecoSE supports the use of high quality
design and building standards and the use of best practice. Whilst
this does not represent an overarching strategy they are essential
elements to the delivery of any 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?
2.3.1 The Town and Country Planning system
regulates the development of land across England and Wales. It
is designed to balance competing objectives and is ideally placed
to address issues of sustainable development and sustainable construction.
2.3.2 ecoSE sets out recommendations for
changes to the planning system at National and Local level under
its manifesto Issue 3, section 3.2 (see Appendices). These include
updating the Planning for Sustainable Development (1998) document,
as well as developing a criteria based approach to appraising
planning applications. Local development frameworks, permitted
development rights and supplementary planning guidance should
clearly address policies covering sustainability and sustainable
design and construction.
2.3.3 With regard to Regional spatial strategies,
planning policies should require that all developments achieve
a standard which is equivalent to BRE EcoHomes "very good",
or in SPG develop an equivalent local standard which includes
additional local issues and concerns. This is necessary to help
address the significant environmental challenges in the South
East highlighted in the ecoSE Manifesto Issue 2, section 2 &
3. (see appendices).
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?
2.4.1 In the South-East there exists many
pressures not only on the environment but socially and economically
as well. The challenge is therefore to build not only in the right
place but to produce developments of a very high quality and design
so that there are minimal impacts on the environment and optimum
benefits to the quality of life of those living in the South East.
2.4.2 With regard to flood-risk, the design
of projects should be such as to minimise risks to inhabitants
through innovative flood risk management techniques, building
in resilience, and locating types of development appropriate to
the risk. To reduce the impacts of development on flood risk,
particularly in the face of climate change which will serve to
increase risk in the south-east, sustainable urban drainage systems
should be incorporated in new and regenerated developments wherever
hydro-geologically appropriate.
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?
2.5.1 ecoSE would encourage the construction
industry to take responsibility for the waste it produces. Within
the South East the industry generates an estimated three million
tonnes of waste, including excavated soil and clay, through house
building. Incidents of fly-tipped construction waste are also
increasing as landfill taxes and transportation costs rise. The
industry can reduce the waste it generates and better manage resources
by adopting the waste hierarchy.
2.5.2 ecoSE's Manifesto Issue 2 section
2&3 (see appendices) proposes further details on how to reduce
the impact of construction waste, and encourages the raising of
construction standards for all new buildings, regeneration and
maintenance to achieve high levels of water and energy efficiency
coupled with waste minimisation. This highlights the benefits
in use of best practice in improving environmental performance
and reducing harmful impact.
2.5.3 The incorporation of these standards
is not however enough in itself and there should also be emphasis
put on ensuring the construction industry has the right skills,
as well as those working in the other elements of the development
process including developers, planners and commissioning bodies.
(see manifesto Issue 5 section 1 in apendices).
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?
2.6.1 To address sustainability through
the Building Regulations requires a change in primary legislation.
This may take some time to implement and there are more direct
means of introducing sustainability requirements into new construction
projects.
Options include:
— Advantage should be taken of the
significant opportunities for updating existing regulations beyond
the forthcoming review of Part L.
— Existing regulations should be upgraded
to keep in line with UK sustainable development targets.
— A revised Building Regulation Approved
Document relating to materials should be introduced. This should
require the use of materials with low environmental impacts and
reused/recycled materials.
— More onerous performance targets
for homes should be imposed through the Building Regulations system.
— Additional funding, resources and
training (where required) should be provided to local authorities
to allow more stringent enforcement of existing and future housing
standards.
2.6.2 ecoSE want to see all development
in the SE undertaken to ecohomes "very good" standard,
but also achieving optimum deliverable water efficiency savings
as set out as part of the ODPM/DEFRA "Better Buildings Summit"
and the Energy Savings Trust Best Practice standard for energy
efficiency.
2.6.3 A rating of "very good"
or "excellent" requires developers to consider all of
the issues (energy, water, pollution, materials, transport, ecology
and land-use, and health and well being) and ensure that housing
has a high all round performance without being overly prescriptive.
Specifying a rating of PASS or GOOD could allow developers to
cherry-pick the issues which they could easily deal with whilst
neglecting other areas.
2.6.2 ecoSE also draws the committee's attention
to the Government's Energy Efficiency Action Plan (April 2004)
which deals with the huge opportunities for improving energy efficiency,
estimated at around 30% across the economy using established technology.
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?
2.7.1 New development across the South East
will place greater pressures upon already stretched infrastructure
and environmental resources. In many cases this will require substantial
infrastructure investment, although the design and construction
of each development, and how people subsequently use them, will
largely determine the scale of these pressures and thus required
investment. This demonstrates the importance of high quality design
and build to minimise the impact on existing infrastructure.
2.7.2 The pressures on infrastructure can
also be substantially reduced by a major programme to encourage
the retrofitting of existing stock; raising energy and water efficiency
to EcoHome "very good" standards. This is addressed
in the ecoSE Manifesto Issue 4 (see appendices) and includes proposed
efficiency standards.
2.7.3 A transport assessment is included
in the Ecohomes standard and therefore represents one element
of ensuring sustainable transport infrastructure. Good design
of communities, that reduces travel distances and reliance on
the private car by providing local community social infrastructure,
is also essential in influencing the scale and type of transport
infrastructure required. (see Manifesto issue 1 section 4 in appendices)
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?
2.8.1 See para 2.5.2, and ecoSE Manifesto
Issue 5, section 1, which focuses particularly on working together
to establish new mechanisms and ensuring that industry has the
right skills.
2.8.2 If we are to implement best practice
and make the very most of new technology, we must equip our workforce
to harness the gains that technology can bring to sustainable
development. Investment in skills will be needed to support the
sustainable construction of new developments and retrofitting
of existing development.
2.9 Other Issues
2.9.1 Financial Incentives. ecoSE recognises
that to achieve improvements in building standards and design
within a sustainable development framework, whereby economic,
environmental and social considerations are addressed, financial
incentives may be required. These are covered in ecoSE Manifesto
issue 5, and include:
— Abolition of zero percent VAT rate
for new residential build.
— Reduced VAT rates for accredited
supplies.
— Product charges on non-sustainable
building materials and equipment.
— Subsidies for the installation of
sustainable equipment.
— Stamp duty relief for sustainable
homes.
— Capital allowances for expenditure
on the conversion of premises into "sustainable" dwellings.
3. APPENDICES
ACCOMPANYING MEMORANDUM
— Manifesto and ecoSE Mission Statement.
— Manifesto issue 1: Ensuring that
the highest quality of design in new developments and their surrounding
communities is achieved, creating spaces that can meet people's
changing needs, minimise the impact on the environment and are
places where people want to live and work.
— Manifesto issue 2: Promoting and
encouraging the raising of construction standards for all new
buildings, regeneration and maintenance to achieve high levels
of energy and water efficiency coupled with waste minimisation.
— Manifesto issue 3: Raising the design
standards of new homes, by encouraging the following groups to
adopt ecohomes "very good" as a minimum standard.
— Manifesto issue 4: Promoting and
encouraging the retrofitting of existing stock to raise energy
and water efficiency to EcoHome standards "very good".
— Manifesto issue 5: Working together
to establish new mechanisms, ensuring the industry has the right
skills, and promoting financial incentives to encourage better
housing design, construction and "retro-fitting" to
secure the environmental improvements needed.
May 2004
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