APPENDIX 20
Memorandum from Wilson Bowden plc
1. INTRODUCTION
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. POSITION AND
RESPONSE OF
WILSON BOWDEN
PLC TO
THE BARKER
REVIEW
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. WILSON BOWDEN
PLC RESPONSE
TO THE
REQUEST FOR
INFORMATION
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. CONCLUSION
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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