Select Committee on Environmental Audit Written Evidence


Memorandum from Wilson Bowden plc


  1.1  This paper provides the Environmental Audit Committee (EAC) with the response of Wilson Bowden plc to its Request For Information (RFI) in support of its enquiry entitled Housing: building a sustainable future. Our understanding is that this enquiry by the EAC will examine the role, competition, capacity, technology and financing of the house building industry and the interaction of these factors with the planning system and the Government's sustainable development objectives. We also recognise that this enquiry is taking place against the background of the publication of the final report by the Barker Review on housing supply in March 2004.

  1.2  This submission sets out the general position of Wilson Bowden plc in relation to the Barker Review as well as providing the EAC with the company's response to the specific questions set out in the RFI.


  2.1  Wilson Bowden plc believe that the Barker Review, which looked at the constraints on UK housing supply, represents a seminal moment in the development and implementation of housing policy in this country. The Review itself, established in April 2003, provided a real opportunity to carry out a comprehensive analysis of the problems constraining housing supply in the UK and to put forward substantive recommendations for resolving the current housing crisis.

  2.2  Wilson Bowden plc welcomed the Interim Report from the Barker Review when it was published in December 2003. We believed that it provided a comprehensive analysis of the housing market and accurately identified the underlying causes of constrained supply. In our view, the subsequent final report, published in March 2004, also provides a blueprint, which if followed by the Government, the house building industry and all stakeholders involved in the housing market, could result in the alleviation of these constraints. Furthermore, it could lead to the production of an economically viable and environmentally sustainable supply of housing.

  2.3  Wilson Bowden plc therefore believe that this blueprint, if implemented in full, offers the potential for significant improvements in the economic and social conditions which have arisen as a consequence of constrained housing supply. In order to ensure this happens, we believe Government, the house building industry and all stakeholders will have to meet the challenges and obligations laid out in the final report. This will require a partnership-based approach by these stakeholders.

  2.4  However, Wilson Bowden plc recognise that the recommendations of the Barker Review amounts to a "quid pro quo" with the house building industry. In putting forward the recommendations the Review has created the potential for the constraints on house builders operating environment to be alleviated in return for a significant increase in housing supply. But the Review also appears to be looking for companies like ours to meet a number of challenges in the way we operate our business.

  2.5  In responding to this, Wilson Bowden plc is committed to working individually and with the rest of our industry and the Government to do the following, (in no particular order):

    —  build not just houses but sustainable communities;

    —  respond to environmental challenges in the way we run our business and the type of housing that we build;

    —  provide more mixed use developments;

    —  ensure good design is at the heart of our business model;

    —  respond to customer requirements;

    —  improve our embrace of Modern Methods of Construction;

    —  enable society to more clearly identify the benefits of development; and

    —  increase investment in skills and training.


3.1  Overview

  3.1.1  Wilson Bowden plc strongly believes that the implementation of the recommendations proposed by the Barker Review must be set in the context of the national and international agenda for environmental sustainability. The principles of sustainability, which underpin this agenda, are an integral part of any national housing policy in the UK. It is right that implementation of the Barker recommendations is done in a manner consistent with these principles. As far as Wilson Bowden plc is concerned, we have already sought to incorporate the principles of environmental sustainability into our business planning and operational practices.

  3.1.2  However, whilst the principles of sustainability are vitally important in the delivery of the Barker recommendations they must not be manipulated, as they have on occasions in the past, to prevent the development of new housing. Instead, the principles of sustainability and the wider environmental agenda should be incorporated into the delivery of the package of recommendations put forward by the Barker Review and used to guide and inform the development of a national housing strategy.

  3.1.3  Inevitably this will mean taking some very difficult decisions and setting some tough priorities in relation to where and how new housing development should take place. But the Interim Report of the Barker Review clearly identified the consequences, in both economic and societal terms, of an inadequate supply of housing.

  3.1.4  Therefore, the sustainable environment agenda must be used positively and proactively to inform and guide development, rather than stifle it. All stakeholders involved in housing development must respect this agenda and the principles that underpin it. If this happens, the Barker recommendations for increasing housing supply can be delivered in an economically viable and environmentally sustainable manner.

  3.1.5  In the sections below, Wilson Bowden plc sets out its detailed response to the questions contained in the Environmental Audit Committee RFI.

3.2  Are the Conclusions of the Barker Review compatible with the general principles of sustainable development and the Government's own sustainable development objectives?

  3.2.1  The Government set out four aims for sustainable development in "A Better Quality of Life, a Strategy for Sustainable Development in the UK" (CM4345, May 1999). These are:

    —  maintenance of high and stable levels of economic growth and employment;

    —  social progress which recognises the needs of everyone;

    —  effective protection of the environment; and

    —  the prudent use of natural resources.

  3.2.2  Clearly these four aims need to be addressed in an integrated way and that is precisely what is proposed in the Barker Final Report. Indeed the general principle underlying the Report's recommendation is that policies need to consider the environmental costs, alongside the social and economic benefits of new housing. In other words a better means of assessing the costs and benefits of development and land use is required and Wilson Bowden fully support this.

  3.2.3  In terms of detail, the Barker Review makes a wide range of recommendations covering planning, taxation and the house building industry. The Government has indicated it's acceptance of those recommendations. These recommendations have the potential to recalibrate the economics of the housing market and ensure that the forces of supply and demand achieve a better balance. In turn, this should lead to the optimal delivery of the type and levels of housing that is required. The Government has now embarked upon a consultation exercise with stakeholders on the best way to deliver the Barker recommendations with a view to reviewing progress in achieving the Report's objectives in the summer 2005. Wilson Bowden plc look forward to working with the Government and all other stakeholders interested in solving the current housing crisis throughout the implementation phase.

3.3  In view of the Barker Review is there a need for an overarching national strategy to ensure that the environment is at the heart of any building programme?

  3.3.1  The environment has been at the heart of the Government's plans for sometime. Indeed the ODPM Sustainable Communities—Delivery Through Planning document, dated July 2002, states that policy should "deliver in a sustainable way" the key Government objectives for housing, economic development, transport infrastructure and rural regeneration "whilst protecting the environment".

  3.3.2  Furthermore PPG3-Housing requires housing needs to be met in the most sustainable way possible and advises local planning authorities, in preparing their local plans, to adopt a systematic approach to assessing the development potential of sites and the redevelopment of existing buildings, when deciding which are the most suitable for housing and the sequence in which that development should take place.

  3.3.3.  More recently, the deliberations over an 18 month period on the new Planning and Compulsory Purchase Act which received Royal Assent on 13 May has again demonstrated the importance of aligning the planning system to underpin the provisions of sustainable communities. As an example, the requirement to provide design statements for both outline and full planning permissions will detail how the proposed development relates to the wider environment. The elements to be considered in such documents are: massing, layout, relationship to public open space, density, building heights, access and movement, landscape strategy, mix of use and response to context.

  3.3.4  In addition, it is clear from the Consultation Document on PPS1 (published on 24 February 2004) that the final version will place sustainable development at the heart of the planning system. It reiterates the 1987 Brundtland definition of sustainable development and the Government's four aims, set out in its 1999 strategy (CMD4345) for sustainable development, as:

    —  High and stable level of economic growth.

    —  Promotion of social inclusion.

    —  Protecting and enhancing the environment.

    —  Prudent use of natural resources.

  3.3.5  Accordingly, regional and local plans should be prepared to contribute to the achievement of sustainable development. Indeed local planning authorities should seek outcomes that enable economic, social and environmental objectives to be achieved together—something Wilson Bowden have supported and argued for in both of the company's submissions to the Barker Review. However, in certain cases, a planning authority may consider that extra weight should be given in its policies to a particular economic, social or environmental objective. This is acceptable as long as the reason for doing so is made explicit and the consequential impacts are either avoided or mitigated.

  3.3.6  Following on from the above, it should be noted that there is also a plethora of legislation and regulations that are already in place which effectively ensure the environment is fully protected in any development scheme. These range from the protection of areas of major conservation significance such as National Nature Reserves, Sites of Special Scientific Interest, Ramsar sites, along with SPA's and SAC's, through to the protection of individual species. There are also various legislative provisions for protecting areas of landscape policy such as National Parks, Areas of Outstanding Natural Beauty and Areas of Great Landscape Value. Similarly, historic and heritage landscapes are also protected, as are areas believed to contain archaeological interest. More broad-brush protection is also provided by Greenbelt policy where coverage has been increased by 19,000 hectares in the period 1997-2003. Finally there are provisions relating to controlling development in floodplains and within close juxta-position to hazardous installations, airports etc.

3.4  Is the current planning system robust enough to ensure that the environment 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?

  3.4.1  As noted in our response to the previous question there is an existing robust legislative system in place that ensures environmental implications of projects are fully taken into account when applications for planning permission are determined.

  3.4.2  Under current legislation the need for an environmental impact assessment has to be assessed for every planning application, on the basis of whether the proposed development is likely to have significant effects on the environment.

  3.4.3  These provisions are soon to be extended by the Environmental Assessment of Plans and Procedures. These new regulations which will come into force by 21 July 2004. These Regulations implement the European Directive 2001/42/EC which is designed to ensure that significant environmental effects are assessed much earlier in the process, ie during the preparation of development plans or programmes, and before decisions are taken on key issues such as alternative development sites. Authorities responsible for preparing the plan or programme will therefore be required to compile an environmental report. This will identify, describe and evaluate the likely significant environmental effects of implementing the plan or programme and of the reasonable alternatives available.

  3.4.4  The above guidance is relevant to both the existing planning system and that proposed under the new Planning and Compulsory Purchase Act. It also applies to other areas such as energy, industry, transport, waste and water management. Resources have been made available to planning authorities to help them comply with the Directive. In addition, other bodies that have key roles in strategic environmental assessment, such as the Environment Agency, are actively preparing for their new role.

  3.4.5  This same Directive will also have an impact on the development of sustainability appraisals, which will be made mandatory for local development documents and regional spatial strategies, under the new planning system. In the long run, it is anticipated that strategic environment assessment will be fully incorporated into sustainability appraisals. In the meantime ODPM's guidance shows how a Strategic Environmental Assessment can be expanded into a sustainability appraisal and how the differences between these two types of analysis can be reconciled. All in all, this advance will help the integrated treatment of economic, environmental and social issues which is a key principle of the Government's sustainable development strategy.

  3.4.6  Apart from the previously mentioned normal development control procedures other mechanisms are now being tested and deployed to ensure the environmental implications of development projects are taken fully into account. One of the prime examples is the use of "design coding", as tested by English Partnerships on their Upton project in Northampton and now being rolled out to their site's at the former RAF base at Bracknell and the Winfrith Technology Centre. This process centres on involving stakeholders in intensive "inquiry by design" workshops which establish the ground rules for the master planning and design of a scheme. Such has been the success of this approach that ODPM has launched the first of six pilots for testing design codes at—Cirencester, Rotherham, Newcastle, Aldershot, Hastings and Ashford. This will provide the means to evaluate various models and approaches for the developing, adopting and implementing design codes in the new planning regime. The test will also establish if the use of such design codes can accelerate the delivery of housing whilst ensuring good quality design. Clearly any scheme subject to such a coding practice will still be subject to approval through the planning system in the normal way.

  3.4.7  Finally, good planning is all about positively managing development. As a result, the proposed changes to the planning system, proposed by the Barker Review, will in our view fulfil sustainable development objectives.

3.5  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?

  3.5.1  On 5 February 2003 ODPM launched the Communities Plan—Sustainable Communities Building for the Future. Within that document four principle growth areas were identified to accommodate the lion's share of the identified additional housing. Those areas were the Thames Gateway; Milton Keynes and South Midlands; the London/Stanstead/Cambridge corridor (latterly extended to incorporate Peterborough) as well as Ashford. Actual development locations within these broad areas will be the subject of review and identification in the relevant regional spatial planning strategies.

  3.5.2  The above initiative was subsequently complimented by the identification of a Northern Growth Corridor along with Market Renewal Pathfinder areas. The latter are primarily concentrated in the Midlands and North of the country.

  3.5.3  Housing requirements elsewhere in the country would either be located in a small number of strategic locations, or more likely on sustainable brownfield sites within urban areas.

  3.5.4  In terms of land use, the Government remains committed to the provisions of PPG3 Housing and in particular the search sequence for locating new development, ie brownfield development before greenfield releases, and Wilson Bowden continues to support this approach. To compliment this, the encouragement given to building at high densities will continue to prevail. Indeed, it has been estimated that the Government's Density Direction in the South East will save 4,000 hectares of land from development by 2016.

  3.5.5  If Central Government are committed to the regeneration of Thames Gateway, then they will need to allocate sufficient resources to ensure that proper flood defences are installed prior to commencement of major housing development.

  3.5.6  As to flood risk aspects, the Environment Agency is due to issue local planning authorities with flood zone maps in the summer of 2004. These will show the different zones of flood risk as set out in PPG25. The maps will be incorporated into the flood map on the Agency's website in the autumn of this year. Updates to the flood map (which also includes information on flood defences) will be provided to local planning authorities every three months.

  3.5.7  Local delivery vehicles in the Thames Gateway and presumably elsewhere, will be required to produce flood risk assessments for their areas in order to ensure that appropriate siting and design of development is considered. Furthermore, where ODPM is funding individual projects directly, this will be conditional on an appropriate flood risk assessment being carried out.

  3.5.8  At the more general level the planning system itself should be able to support better water management, such as the introduction of sustainable urban drainage systems and ensure policy seeks to minimise flood risk through the implementation of existing statutory requirements.

3.6  Is it possible to ensure materials and resources used, and waste produced, during building do not have a harmful impact on the Environment?

  3.6.1  The use of effective supply chain management, combined with a comprehensive waste management regime, will minimise the environmental impact of build programmes.

  3.6.2  With the reduction in the number of landfill sites across the country capable of taking "active" waste and the increase in landfill tax from the current rate of £15 per tonne to £35 per tonne by 2008, there is a significant economic argument to reduce the amount of waste material being produced. Accordingly, a robust waste management policy that employs on-site remediation of active waste, as well as the segregation and re-use, wherever possible, of inert material in the build programme makes environmental and economic sense. Wilson Bowden plc has successfully trailed this approach in one of its house building regions and is currently in the process of rolling the programme out to the rest of the Group.

  3.6.3  The above also has implications for the supply chain, as effective partnering arrangements with suppliers can minimise wastage in both the product preparation process and the build programme. Initiatives such as recycling of material with the supplier, combined with the sourcing of material from renewable resources, or joint working to introduce innovations in both product and working practices, can all pay dividends. In this context Wilson Bowden now actively engages with its main suppliers and enters into two-way dialogue with them at specialists' forums which it organises.

  3.6.4  As noted in our response to the question on the role of the planning system in sustainable housing, improved building regulations, with the introduction of a new sustainable building code, will encourage recycling and a minimisation of waste during the construction process. In addition, the publicity afforded to Corporate Social Responsibility Indices together with "sustainability awards" will also assist. With regard to the latter, a recent example is the Sustainable New Homes Awards which were announced in October 2003. These are run by the House Builders Federation and the World Wildlife Fund. Criteria for the Award includes energy efficiency and the use of renewable energy; how development has protected and/or enhanced bio-diversity; the minimisation of waste from both construction and the lifestyles of residents; water efficiency and recycling; sustainable urban drainage; urban pollution levels and use of toxic chemicals.

3.7  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?

  3.7.1  As currently drafted the building regulations are not capable of ensuring that new housing is truly sustainable in the long term. Perhaps in recognition of this fact the Government is supporting a Private Members Bill to allow building regulations to be made for new purposes, ie furthering the protection or enhancement of the environment, facilitating sustainable development and furthering the prevention or detection of crime. As an example, Part M of the building regulations currently require all new homes to be more accessible. Whilst we are broadly supportive, these could be strengthened by introducing the "lifetime homes" standard to allow older people to remain in their homes for longer, or to facilitate adaptation of homes to reflect changed circumstances, thereby meeting longer term needs.

  3.7.2  It is also worth noting that all new homes funded by the Housing Corporation are required to achieve a "pass" rating under the Building Research Establishment Eco Homes Standard as a minimum condition. This standard effectively grades the sustainability of a house design and development into four sections, all of which are higher than currently exits in the building regulations. It is understood that the Corporation is proposing to raise the requirement to the Eco Homes "good" rating from April 2005.

  3.7.3  Similarly, the English Partnership's Millennium Communities Programme highlights how major schemes can combine innovation and sustainable development. Indeed each of their schemes must meet environment performance and constructions efficiency standards that go beyond the current building regulations.

  3.7.4  Clearly, the above noted range of initiatives can cause confusion and need simplifying. To this end the Sustainable Building Task Group, set up by the Government at the Better Building Summit last October, has submitted its report to ODPM. It proposes a code for sustainable buildings that would be based on the Building Research Establishment Environmental Assessment Method (BREEM) which measures the environmental impact of any buildings and rates the performance on a scale of pass to excellent. All ratings are above existing statutory requirements and cover: management; operational energy; transport; health and well being; water; materials; land use; ecological value and pollution. It is believed the "Code" would provide a level playing field for quality building control. It would be dynamic, respond to innovations through annual updating and offer a series of standards from a regulatory base right up to advance practice.

  3.7.5  ODPM, DTI and DEFRA have now agreed to start work on the main principles for a "sustainable buildings code". Its proposals are expected to emerge in changes to the building regulations in 2010 and beyond. When implemented the new Code will replace and consolidate the current confusing array of existing environmental standards for the construction industry, and as such it is to be welcomed.

  3.7.6  As an aside, it is also worth noting that British Research Establishment have worked with mortgage lenders to develop a new certification approach for manufactured housing. This resulted in a launch of LPS1272-System Build Standard on 26 April 2004 which provides manufacturers of prefabricated building systems with a recognised bench mark against which they can test and certify their product. In addition to normal building performance criteria, it covers insurance and mortgage lenders requirements such as durability, reparability and identification.

3.8  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?

  3.8.1  Inadequate infrastructure provision lies at the heart of many local housing supply problems. The Barker Interim Report quoted a figure of 40,000 new homes held up by inadequate infrastructure provision in the South East alone. Clearly central Government funding must therefore be put in place for physical and social infrastructure to pump prime the necessary development which will meet the Government's primary objective of increased housing provision. In this respect the Barker Final Report recommends that all Government Departments take account of planned housing and population growth when making spatial allocations for infrastructure funding and that the Prime Minister's Committee on Housing and Growth in the South East should be expanded to cover delivery in general and be used to facilitate cross department co-operation.

  3.8.2  In addition, to minimise delays, infrastructure providers (such as the Highways Agency and Water Companies) should be involved from an early stage in developing both the Regional Spatial Strategies and the Local Development Plans. This will ensure that regional and local planning housing targets are based on realistic assessments of infrastructure funding and provision. Having said that, restrictions must be placed on the infrastructure provider's ability to object to development. In addition, greater use should also be made of area based special delivery units, including Urban Development Corporations, to drive housing development forward where land acquisition, servicing and infrastructure provision problems are identified.

3.9  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?

  3.9.1  It is probably fair to say that existing skills and training provisions, in both the public and private sectors, need to be improved. To examine this in more detail, the Deputy Prime-Minister announced on 8 April 2003 the Egan Review of Skills. Its primary focus was to consider the skills that built environment professionals needed to help deliver the vision set out in the "Sustainable Communities Plan: Building for the Future". That Report has now been published and identified over 100 skills involved in the development, implementation and maintenance of sustainable communities. More specifically it recognised there were shortages of staff in the core groups and a lack of generic skills overall. It recommended the establishment of a National Centre for sustainable community skills which should be up and running by early 2005. The focus of the latter would be on developing generic skills such as leadership, communication, teamwork, project management and understanding sustainable development.

  3.9.2  In contrast, the actual promotion of trade skills themselves could be tackled by other existing mechanisms that are already in place. However, if skills constraints are not adequately being addressed within a prescribed timeframe, the Government should conduct a review of the effectiveness and impact of CITB-construction skills in the house-building industry. Having said that it is believed that house-builders, sub-contractors and suppliers working together can deliver the skilled trades needed to produce the required increase in homes.


  4.1  Wilson Bowden plc believe that the Barker Review has established a positive platform for alleviating the constraints on housing supply, in an economically viable and environmentally sustainable manner, which will lead to a significant increase in housing volumes.

  4.2  As we have made clear in this submission, and the ones made to the Barker Review itself, the principles of sustainable development and the wider environmental agenda are already embedded in the existing system. Wilson Bowden plc, along with our industry colleagues, are already responding to these principles and agendas. We believe that good progress has already been made but we recognise that as part of the "quid pro quo" for the Barker Review, we will need to do more.

  4.3  Furthermore, we believe that the principles of sustainable development can be incorporated into the delivery of the Barker recommendations for increasing overall housing supply. There is no reason why they should be seen as mutually exclusive. As we have suggested in this submission, this means that the principles are proactively and positively used to guide and inform how and where new housing development takes place. But we do add the caveat that the principles must not be manipulated in a way that stifles this development.

  4.4  We strongly believe that all stakeholders, and this should include house builders, Central & Local Government, housing and homelessness organisations, and environmentalists, who are genuinely interested in alleviating the constraints on housing supply now have a responsibility to ensure that the recommendations put forward by the Barker Review are implemented. A crossroads has been reached in national housing policy and we have a real opportunity to develop an implementation strategy that delivers the level and type of housing required but in a way that is both economically viable and environmentally sustainable. For our part, Wilson Bowden plc intends to meet the challenge which has been set down.

June 2004

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