Supplementary memorandum from WWF
Response to specific questions from the Environmental
Committee following WWF's Oral Evidence Session, 16 July 2004
1. Are there any standards, other than
EcoHomes, for sustainable housing that you have looked at? If
so how do they compare to the EcoHomes standard?
At the start of the One Million Sustainable
Homes (OMSH) campaign, WWF initiated a stakeholder dialogue to
identify the barriers to sustainable homes and ways to overcome
them. WWF consulted with around 350 stakeholders from across a
wide range of sectors. One of the key barriers cited by respondents
was the perceived lack of consensus around a definition for sustainable
homes.
WWF asked stakeholders, which, in their view,
was the current "best" standard available to assess
sustainable homes, and the result was resounding support for the
EcoHomes standard. WWF received clear feedback from respondents
that the OMSH campaign should build upon EcoHomes, which was already
well established and recognised by the industry, rather than adding
to the confusion by developing a new standard. Respondents indicated
that EcoHomes is not perfect, but they felt that one of its most
important features is its commitment to an annual review by a
multi-sector steering group. Therefore it undergoes refinement
and improvement every year.
There are a number of tools which make partial
assessments of sustainability including Arup's SPeAR, National
Green Specification (NGS) and Leadership in Energy & Environmental
Design (LEED) in the US. However, in the UK EcoHomes is the most
holistic environmental assessment method for homes currently available.
2. You have expressed satisfaction with
the outcome of the Sustainable Buildings Task Group. This has
concluded that a new Code for Sustainable Buildings (CSB) should
be based on BRE's existing standard (BREEAM and EcoHomes). In
your view is this because it is undoubtedly the best approach
for setting standards for construction, or is partly due to the
fact that it is already in existence and therefore a relatively
easy option?
WWF believes that the new CSB should be based
on BRE's BREEAM and EcoHomes standards and that the minimum requirement
for all public procurement of housing should be equivalent to
EcoHomes "Very Good" standard. Anything less would be
no different from the status quo, and would defeat the
purpose of having the CSB in the first place.
WWF believes BREEAM and EcoHomes is undoubtedly
the best approach for several reasons. Firstly, the Government,
construction industry and BRE have invested heavily in the development
of the BREEAM standards over many years and the result is a suite
of well-researched tools which measure environmental performance
in a holistic way. The tools are based on practical experience
and implementation, and are supported and widely used by the construction
industry.
Secondly, many organisations including those
in the public and private sector are already committed to the
use of BREEAM/EcoHomes on all developments. These include Countryside
Properties, SEEDA (South East England Development Agency), Housing
Corporation, English Partnerships, and Office of Government Commerce.
Many developers have now used the BREEAM/EcoHomes
standards and are increasingly familiar with them, and have invested
in resources and capacity to help them deliver (eg they have in-house
EcoHomes trained assessors). WWF believes it is vital that the
industry is provided with a "level playing field" and
given clear and consistent messages about the standards they will
be required to meet. Developing the CSB in line with BREEAM/EcoHomes
will build upon the requirements of the agencies listed above,
and ensure that the industry is not asked to learn about and deliver
an entirely new set of requirements.
Thirdly, BRE has developed a comprehensive training
and assessment programme to ensure the delivery and quality assurance
of the BREEAM standards. It is difficult to imagine how Government
will assess the CSB if it is required to set up a completely new
system of training, assessment and certification. It is important
to note that making use of the BREEAM assessors will avoid burdening
already over-stretched planning and building control officers
with extra responsibility for checking compliance with the CSB.
Therefore to invent a completely new standard
would be "reinventing the wheel" and would add unnecessary
financial cost and inconvenience to the development and implementation
of the CSB. Indeed, to invent a new standard would, in our view,
be a serious waste of resources and a major set back in terms
of time.
3. What improvements would you like to
see in the proposed CSB, in comparison to EcoHomes?
WWF would support the recommendations of the
Sustainable Buildings Task Group that the CSB should require minimum
standards to meet in certain key areas, particularly resource
efficiency criteria. WWF would like to see the timber credit improved,
based on the outcome of the independent assessment of different
timber certification schemes being undertaken by the Central Point
of Expertise on Timber (CPET). WWF would also welcome the expansion
of the health and well-being section to include assessment of
endocrine disrupting chemicals in building materials and furnishings
where possible. WWF has discussed with BRE the need for a review
of the weightings of EcoHomes to ensure they are based on objectively
verifiable priorities.
4. You also agreed to send us any information
you have on what percentage of housebuilders' costs are represented
by 106 agreements.
Unfortunately, given the short time available,
WWF is not able to provide the above information. We would recommend
consulting house builders and local authority planning departments
on this issue.
July 2004
| 
