Select Committee on Environmental Audit Written Evidence


Memorandum from ecoSE


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).

    —  Countryside Agency.

    —  Southern Water.

    —  Mid Kent Water.

    —  Pavilion Housing.

    —  WaterVoice.

    —  Woking Borough Council.

    —  Energy Savings Trust.

    —  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.


2.1  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.

    —  Green Mortgages.

    —  Energy Grants.


    —  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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