Memorandum from the House Builders Federation
INTRODUCTION
1. The House Builders Federation (HBF) is
the principal trade association representing private house builders
in England and Wales. The HBF has some 300 members, ranging from
the largest national house building companies, through regional
firms to small local builders. Collectively our members build
more than 80% of the new homes constructed each year.
2. The HBF has sought for some years to
raise awareness of the need to improve national housing supply
and welcomes the thorough analysis and positive proposals for
action to tackle this important issue set out in the report of
the Barker Review. The Committee's inquiry is therefore of very
direct relevance to the issues on which the HBF is working.
EVIDENCE RELATING
TO THE
QUESTIONS THE
COMMITTEE IS
CONSIDERING
Are the conclusions of the Barker Review compatible
with the general principles of sustainable development and the
Government's own sustainable development objectives?
3. Yes. The Barker report does not advocate
that a response to the housing supply crisis should be at the
expense of other Government policy objectives. The report specifically
acknowledges that its proposals for change and reform of the planning
system should ensure that planning decisions continue to take
account of the social and environmental as well as the economic
benefits and costs of new developments. Its thrust is to propose
a more efficient and effective planning system that can deliver
the necessary increase in housing supply consistent with the overall
objectives of the Sustainable Communities Plan.
4. The Barker report has also been written
in full knowledge of the parallel work of the Egan Review on Skills
for the Built Environment and the Sustainable Buildings Task Group.
The recommendations of all three reviews and other relevant work
need to be considered together in assessing how future house building
can be realised sustainably.
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?
5. Such a framework is already available
in the Government's proposed Planning Policy Statement 1 (PPS1)—"Creating
Sustainable Communities". The HBF broadly supports the proposed
PPS1 which will promote sustainable development by balancing social,
environmental and economic objectives and including the important
questions of design of the built environment and urban renewal
within its scope.
6. We note that the Sustainable Buildings Task
Group in its report published on 18 May has recognised the importance
of PPS1 in promoting sustainable development and the Task Group's
recommendation that particular attention be given to drawing up
a clear best practice guide for implementing PPS1, including clarifying
the respective roles of Building Regulations and the planning
system. HBF will participate actively in discussions on drawing
up any such best practice guidance.
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?
7. Yes. While the planning system is not
the sole mechanism relevant to the achievement of sustainable
building and should not duplicate other mechanisms such as Building
Regulations, its role should be to pull together all relevant
legislation to produce sustainable development. The recommendations
of the Sustainable Buildings Task Group already mentioned recognise
the role the planning system, informed by the proposed PPS1, can
play in this regard.
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?
8. The planning system is designed to balance
the need for new housing and other development against potential
alternative uses of land, amenity values and risks such as flooding.
Where on balance it is decided that new housing should proceed
the system can also provide for necessary safeguards and risk
mitigation measures to be incorporated within development plans.
9. The house building industry has already
responded positively to relevant Government policy by building
more than 60% of its homes on brownfield sites and increasing
housing densities. The industry can continue to respond positively
to sustainable development objectives given open dialogue with
Government and other stakeholders on ways in which such objectives
can be delivered effectively.
Is it possible to ensure materials and resources
used, and waste produced, during building do not have a harmful
impact on the environment?
10. Yes. This can be achieved via the Building
Regulations. Part L of the Regulations already ensure that new
homes built today are four times more energy efficient than those
built 30 years ago. HBF and the house building industry are also
actively discussing the current proposals to further improve the
energy and water efficiency of buildings through Building Regulations.
11. If passed the current proposal for the
Sustainable and Secure Buildings Bill will expand the potential
scope of Building Regulations further to more fully encompass
the objectives of sustainable development. The HBF will engage
positively to discuss any new Building Regulations that may in
future be proposed under such powers. It will be important to
ensure that there is a proper partnership between the regulatory
authorities and the industry in discussing any such proposals.
Key to successful progress in promoting sustainable construction
is identifying the means by which particular objectives can best
be delivered in ways that both meet public policy objectives and
are practical in commercial terms.
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?
12. Yes, subject to the additional points
made in the answer to the preceding question.
13. The recommendations of the Sustainable
Buildings Task Group also need to be taken into account. Overall,
given the strides already made in the performance of new homes
in important areas such as energy efficiency, HBF additionally
believes that much greater attention needs to be focused on how
the performance of the less well performing existing housing stock
can be improved. Unless the performance of the existing stock
is sufficiently addressed it will be difficult to meet the relevant
proportion of the UK's overall environmental objectives solely
through action on new built homes.
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?
14. A positive long-term planning policy
for housing would provide the certainty needed about future house
building plans to enable complementary planning and investment
decisions to be made about related infrastructure requirements.
Uncertainty and incremental short-term decisions in the planning
system are an important obstacle to the effective delivery of
infrastructure that would support sustainable development objectives.
15. The Barker Review considers these issues
and identifies the need for improvements in decision-making and
investment mechanisms in this field.
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?
16. There is recognised to be a need for
further work to improve skills across many professions and occupations
in order to deliver sustainable communities for the future.
17. The Barker, Egan and Sustainable Buildings
Task Group reviews have all considered skills issues from their
own perspective. Their relevant recommendations are complementary
and HBF and the house building industry will be actively participating
in work to take their findings forward. We believe that many developers
already have considerable knowledge and skills on the achievement
of environmental objectives—for example through the planning
system and Building Regulations requirements. The challenge of
further improving sustainability and regenerating many of our
urban areas will nevertheless call for a widening and deepening
of relevant skills. We are working with Government and key stakeholders
towards this end.
June 2004
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