Memorandum from WWF
INTRODUCTION
Through its One Million Sustainable Homes campaign,
WWF is working to bring sustainable homes from the fringes of
the housing sector to the mainstream. At the start of the campaign
WWF initiated a stakeholder dialogue to identify the barriers
to sustainable homes. We consulted over 350 stakeholders from
a wide range of sectors and as a result were able to identify
six key barriers:
— A lack of fiscal incentives.
— Current Planning and Building Regulations
do not promote sustainable homes.
— A perceived lack of investor support.
— A perception of extra cost.
— A lack of consensus around the definition
of a sustainable home.
— A perceived lack of consumer demand.
Since the launch of the campaign in August 2002,
WWF has been working with key partners to implement strategies
to overcome the perceived barriers. For more information about
the campaign please see the enclosed briefing.[19]
Key activities to date include:
— WWF was the only NGO represented
on the Egan Review of Skills and the Sustainable Buildings Task
Group, both of which have recently submitted their reports to
Government.
— WWF is pleased that, upon our specific
recommendation, Andrew Stunell MP has introduced a Sustainable
and Secure Buildings Bill (a Private Members Bill) to parliament.
This important Bill seeks to amend the existing Building Act to
allow sustainability to be addressed for the first time.
— WWF and Insight Investment, the asset
manager of Halifax Bank of Scotland (HBOS) benchmarked the sustainability
performance of the top 13 FTSE listed house builders to help overcome
the perception that investors are not interested in sustainable
homes.
WWF therefore feels ideally placed to answer
the EAC's questions concerning sustainable housing.
1. Are the conclusions of the Barker
Review compatible with the general principles of sustainable development
and the Government's own sustainable development objectives?
The overriding message of the Barker Review
was that we need to build more homes to help meet demand for housing
that is affordable, and to increase stability in house prices.
WWF recognises that in some areas of the country there is a need
for more homes. However, our homes and communities have significant
environmental impacts: nearly 30% of the UK's CO2 emissions come
from the domestic sector, and 55% of the timber used in the UK
goes into our homes. Homes also have significant impacts in terms
of the use of other natural resources including water and aggregates
and in helping to determine resident's lifestyle choices such
as how they to travel to work. WWF was very disappointed that
the Barker Review did not pay adequate attention to the need to
ensure that all new developments reach the highest standards of
sustainability. In WWF's view, it is essential that quality must
go hand in hand with quantity.
In June 2003, WWF produced a report, One
Planet Living in the Thames Gateway[20]
which examined the environmental, social and economic costs of
the development of 200,000 new homes in the Thames Gateway to
different building standards: current Building Regulations, Building
Research Establishment's (BRE) EcoHomes "Very Good"
standard and "zero energy, zero waste (Z2) standard".
The findings showed that developing to EcoHomes "Very Good"
standard could achieve a 32% reduction in CO2 emissions, a 39%
reduction in water use and up to a 25% reduction in household
waste sent to landfill compared to current building regulations.
Developing to "Z2" standard could achieve a 99% reduction
in CO2, a 65% reduction in water use and a 76% reduction in household
waste sent to landfill. The report shows that these improvements
could be delivered for 2% additional build cost for meeting EcoHomes
"Very Good", and 10% for Z2. However, these extra costs
could be partly offset through planning gain (a mechanism whereby
developers can increase development in exchange for meeting environmental
targets) and partly by residents paying slightly more for their
homes. The study shows that these increased mortgage repayments
would be compensated for by the savings from reduced running costs
and that living in sustainable homes would result in lower household
expenditure in addition to the environmental benefits.
The report highlighted that if the Government
is serious about meeting its own sustainable development objectives,
it must ensure that all new homes and communities meet the highest
sustainability standards, not only in terms of the buildings themselves
but also in terms of enabling residents to reduce the environmental
impact of their daily lives.
2. 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?
WWF strongly believes that Government must ensure
that the environment is at the heart of any building programme.
As stated in the WWF/Town and Country Planning Association (TCPA)
report Building Sustainably[21]
WWF believes that the current frameworks that govern how and where
new homes and communities are developed, the planning system and
the Building Regulations, are woefully inadequate when it comes
to addressing sustainability issues. One of the key problems is
the confusion amongst planners and building control officers about
which sustainability issues are covered by which regulatory framework.
WWF would welcome an overarching national strategy to ensure that
the environment is at the heart of any building programme, but
we believe it would be vital to ensure that such a strategy complements
and enhances the current regulatory frameworks, rather than adding
to the confusion amongst practitioners.
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?
As stated above, WWF does not believe that the
current planning system is robust enough to deliver sustainable
homes. WWF welcomed the recent consultation on PPS1 and the Government's
proposals to make sustainable development the "purpose of
the planning system". However, as stated in WWF's response
to PPS14, a significant problem with the current planning system
is the inconsistent interpretation of national policy by regional
and local planners. Clarity of purpose at the national level is
vital to ensure that practitioners understand that all applications
must be considered in the context of sustainable development.
PPS 1 should give planners unequivocal power
to refuse consent if applications fail to address sustainability
issues adequately. Equally, it is essential that developers receive
a clear message from central Government that they must submit
proposals that contribute to sustainable development, and that
they will be denied planning consent if they fail to address these
issues seriously. WWF fully supports the Sustainable Buildings
Task Group's (SBTG) recommendation in their report, Better buildings—better
lives[22]
that PPS 1 should be clearer about the extent to which the planning
system can require more sustainable building practices as opposed
to merely encouraging or promoting them.
The Barker Review recommends improvements to,
and a streamlining of, the planning process primarily to speed
the process up. WWF has consistently promoted reform of the planning
system to ensure that it facilitates only the development of sustainable
homes. We believe sustainability need not be a brake on supply
and as stated in our response to PPS1, WWF supports the SBTG's
view that there is great scope to consider sustainability issues
through pre-application discussions on planning applications.
As recommended in the WWF/TCPA report, and again
by the SBTG, WWF strongly believes Government must produce a best
practice guide to accompany PPS 1. This guide should explain the
complementary roles of the building regulations and planning system
and promote better co-ordination between the two. It should include
a detailed list of sustainability criteria that should be addressed
through the planning framework to complement the Building Regulations.
WWF believes the BRE Sustainability Checklist for Developments[23]
provides a comprehensive list of issues which should be covered
in such a guide.
With 50% ODPM funding, WWF, BRE and SEEDA (South
East England Development Agency) are working with the other RDAs
to produce regional sustainability checklists relevant to regional
circumstances and concerns and provide case studies of examples
of best practice. The SBTG and the Egan Review have both endorsed
the BRE Checklist and the SBTG has welcomed the Government's support
for WWF to develop the Checklist for all regions. WWF believes
the Checklist should be used as a basis for the best practice
guide.
4. Is it possible to ensure materials
and resources used, and waste produced, during building do not
have a harmful impact on the environment?
WWF believes it possible to ensure that building
processes minimise harmful impacts on the environment and indeed
in some cases that it is possible for development to have some
positive environmental impacts, for example by increasing biodiversity.
WWF believes that the Building Regulations should require that
materials used in construction have a low environmental impact—an
area where considerable progress can be made should the Sustainable
and Secure Buildings Bill receive Royal Assent. For example, the
Bill specifically seeks to promote the recycling of materials
from construction demolition. Best practice sustainable developments
have already demonstrated that it is perfectly feasible to use
more environmentally friendly materials such as recycled and reclaimed
materials and timber from independently certified, well-managed
sources.
WWF fully supports the SBTG's recommendation
that the "Construction Products Association (CPA) and the
DIY suppliers in consultation with the Government's Advisory Committee
on Consumer Products and the Environment (ACCPE) look at the feasibility
of introducing an Environmental Product Declaration scheme for
sustainable construction products and materials that is applicable
to both the consumer and professional market and is relevant at
both product and building level. Such a scheme should be based
on ISO 14020 in order to be internationally acceptable. In addition,
the Group believes that Government needs to consider introducing
some incentives to encourage uptake by customers."
WWF also believes the Building Regulations should
require much higher standards in terms of water and energy efficiency,
the use of renewable energy and the minimisation of waste both
during construction and occupancy (eg through the provision of
recycling facilities).
5. Are the building regulations as they
stand capable of ensuring that new housing is truly sustainable
in the long term?
As outlined above, WWF does not believe that
building regulations in their current form are capable of delivering
sustainable homes in the long term, which is why WWF fully supports
the Sustainable and Secure Buildings Bill. Should the Bill receive
Royal Assent, WWF will be working to ensure that ODPM starts work
immediately on reviewing the Building Regulations in the context
of sustainability. WWF fully supports the SBTG's view that should
the Bill fall, Government should legislate at the earliest possible
opportunity to ensure that the legislative objective is achieved.
Clearly, given that the majority of an individual's
environmental impact comes from their lifestyle choices such as
the way they travel and where their food comes from, housing can
only ever contribute towards sustainability in the wider context.
As WWF's One Planet Living in the Thames Gateway report demonstrates,
the role of planning in creating the necessary infrastructure
to enable people to live in an environmentally friendly way is
absolutely essential.
6. How could they be improved? Could
greater use be made of existing environmental standards for housing?
The WWF/TCPA report made clear and specific
recommendations about how the Building Regulations should be improved.
The report was welcomed by the Building Regulations division at
ODPM, and they have since been fully supportive of the Sustainable
and Secure Buildings Bill. There are a number of specific issues
where the Building Regulations could be improved including: consideration
of the environmental impact of materials, the requirement for
greater energy and water efficiency, the use of renewable energy
and the requirement for storage space for segregated recyclable
waste.
WWF believes that existing environmental standards
such as BRE's EcoHomes are crucial in that they provide a stepped
approach to enable developers to improve performance beyond minimum
regulatory requirements. They also point to how the Building Regulations
should be improved in future revisions. The new Code for Sustainable
Building as proposed by the SBTG would seek to build on BREEAM
(BRE Environmental Assessment Method)/EcoHomes standards. WWF
believes the Government must act upon the recommendations of the
SBTG to ensure that compliance with the Code becomes a requirement
of "doing business" with Government as well as incentivising
take up by the private sector. In this way Government as a construction
client can help to bring sustainable developments into the mainstream.
This will be beneficial not only in terms of bringing costs down
through economies of scale, but also in terms of helping to educate
and forewarn the construction industry about future minimum regulatory
requirements.
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?
The Planning system is the only tool to have
the flexibility to promote sustainable development in a holistic
manner and in ways that are sensitive to local needs and circumstances
(unlike the Building Regulations which are prescribed centrally).
WWF therefore believes it is vital that the planning system considers
the wider impacts of design and development on the global as well
as the local environment. As the WWF report One Planet Living
in the Thames Gateway demonstrated, the majority of an individual's
"ecological footprint" is made up of their lifestyle
impacts in terms transport, food and waste disposal. It is essential
that new development and the regeneration of existing communities
facilitates sustainable lifestyle decisions for residents and
enables individuals to reduce their impact on the planet through
the provision of local amenities and services. For example, providing
local infrastructure and amenities can reduce the need to travel
by personal car and allows residents to reduce their environmental
impact whilst also improving their quality of life.
Another key challenge is that Government spending
on housing, transport and other infrastructure/services is currently
spread across different Government departments. The Treasury must
encourage "joined up budgeting" to facilitate the development
of affordable, sustainable communities.
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?
The WWF/TCPA report highlighted that there is
a lack of skills among planning and building control officers
to deliver sustainable communities and that practitioners need
training to enable them to become champions of sustainable development.
The house builder sustainability benchmarking study that WWF recently
carried out in partnership with HBOS, demonstrated that the majority
of the top 13 FTSE listed house builders are failing to address
sustainability issues adequately, thereby indicating a similar
shortage of skills in the private sector. To help address this
issue, WWF and BioRegional are running "One Planet Living"
continued professional development courses for a range of construction
professionals. These courses have been very successful and consistently
oversubscribed.
June 2004
19 Not printed here. Back
20
http://www.wwf.org.uk/filelibrary/pdf/thamesgateway.pdf. Back
21
http://www.wwf.org.uk/filelibrary/pdf/buildingsustainably.pdf. Back
22
http://www.dti.gov.uk/construction/sustain/EA-Sustainable-Report-41564-2.pdf. Back
23
www.wwf.org.uk/sustainablehomes. Back
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