Select Committee on Environmental Audit Minutes of Evidence

Memorandum from WWF


  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

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