Memorandum from the Department for Environment,
Food and Rural Affairs
1. This memorandum is in addition to that
submitted by ODPM, which explains the wider Government policies
on Sustainable Communities. This note focuses on the environmental
aspects of housing growth.
SUSTAINABLE COMMUNITIES
2. Defra supports the five strategic priorities
for creating Sustainable Communities:
— Delivering a better balance between
housing supply and demand.
— Ensuring people have decent places
to live.
— Tackling disadvantage by reviving
deprived neighbourhoods and tackling social exclusion.
— Providing better public services.
— Promoting development of English
Regions by improving their economic performance so that all reach
their full potential.
3. The Government will shortly be publishing
a refreshed Rural Strategy which will set out how the vision of
Sustainable Rural Communities set out in the 2000 Rural White
Paper will be delivered in the next three to five years. The Strategy
will set out action that will support the creation of sustainable
rural communities, including in relation to sustaining economic
development, ensuring fair access to public services and affordable
housing, and valuing the countryside as an asset. The Strategy
will include the Government's response to Lord Haskins report
on Modernising Rural Delivery.
4. Defra also works to increase the supply
of affordable housing in rural areas through supporting ODPM and
the Housing Corporation in rural proofing their policy and programmes.
This includes agreement of the Housing Corporation's rural target
for settlements below 3,000 which over 2004-05 to 2005-06 is set
to approve a total of 3,500 homes. At a local level we fund the
Countryside Agency to deliver the Rural Housing Enabler programme
which provides funding for the employment of 40 specialists in
30 counties/unitaries across England to work with local rural
communities and identify housing need and ways of meeting that
need.
5. Kate Barker's review of housing supply
reinforced the evidence of undersupply of housing and the adverse
consequences this has on economic and social development, particularly
in the supply of housing for key workers. House building in 2001
was at its lowest level since World War II. Defra recognises the
need to provide extra housing to resolve these problems. Our aims
are: to ensure that new communities are as sustainable as possible,
particularly in eco-efficiency terms; to promote sustainable infrastructure;
and to minimise the adverse environmental consequences. The Sustainable
Communities Plan provides a significant opportunity to develop
better standards and practices.
6. Defra strongly supports other elements
of the Plan, which promote wider sustainable development, in particular
the emphasis on using brownfield land for housing, and increasing
density rates. ODPM figures published last month show that 66%
of all new building is now on brownfield land (exceeding the target
of 60%), and that the density of building has increased to 30
dwellings per hectare compared to 25 in 1996. Green belt has increased
by 19,000 hectares since 1997 with a potential for a further increase
of around 12,000 hectares proposed in emerging local plans.
ENTEC REPORT
7. Defra commissions extensive economic
research from external researchers on all areas of its policy
interests to provide independent analyses to inform the development
of policy. The purpose of the Entec study, "The Environmental
Impacts of Increasing the Supply of Housing in the UK",
was to provide an objective initial assessment, quantified as
far as possible, of the environmental impacts of proposals in
the Barker Report for increasing housing supply so as to meet
a range of housing affordability targets. The study looked at
the impact of proposed housing increases on Defra policy concerns,
to provide an indication of the nature and potential orders of
magnitude of the associated environmental costs and benefits and
to provide recommendations on the ways to take these forward,
thus allowing them to be reflected in decision making. The timetable
for this work was extremely tight, and the study was conducted
as a short desk based exercise, to enable advice to be timely
and to contribute to the wider government debate on housing issues.
8. The report was received by Defra on 23
April, and given an initial review by officials including those
from other Departments and then placed on the Defra website on
7 May. Entec sent to a copy to the Environmental Audit Committee
secretariat on 26 May. We regret this delay and have set in hand
action to improve our presentation of Defra commissioned research.
As the report itself makes clear the work was a scoping study
and does not represent a definitive analysis of the problems.
The figures included in the report are indicative and require
substantial qualification and interpretation. Because of this,
it was not published as a Defra document and the report remains
the view of Entec, not Defra.
9. The researchers consider a number of
possible scenarios in terms of the annual number of dwellings
built, average housing densities and occupancies and standards
of environmental design. Thus there is a very wide range in their
estimates for the aggregate environmental impact—from +
£1.6 billion to - £4.3 billion compared with their baseline
assumption. The £8.3 billion figure quoted in the press is
the highest figure for gross environmental costs in the worst
case scenario ie it is effectively a comparison against a scenario
of no house building at all for the next 30 years. The increased
cost of the extra housing over the baseline of current build rates
is just over half this figure at around £4.3 billion. However
in a best case scenario which takes account of potential mitigating
factors such as improved building standards, the environmental
costs can be substantially curtailed in both absolute terms and
over the baseline. And not least, it should be pointed out that
the figure quoted is a present capitalised value over some 30
years, it is not an annual monetary cost.
10. As the researchers point out, there
are large degrees of uncertainty over both the estimation of the
scale of the environmental impacts, and in attaching monetary
values to them. Only a limited range of impacts were considered
in the time available and some appear calculated on a gross basis,
ie they do not take account of the fact that the occupants of
new housing would be creating environmental impacts in their current
housing. Both under and over estimation of some figures is likely
and further work may be necessary to explore these issues and
refine the estimated environmental impacts.
OTHER INITIATIVES
11. In addition to the Entec review, which
looked at the broad-brush impacts of housing, Defra is taking
forward its extensive work on the detailed policy areas. Defra
has contributed to two important initiatives which are relevant
to the Committee's enquiry.
12. First the Egan Review on Skills for
Sustainable Communities which was published in April. Defra
welcomes the emphasis on advance and holistic planning of infrastructure
alongside housing, and the proposals for improving and broadening
the skill base for delivering new developments.
13. Second, Defra strongly supported the
establishment of the Sustainable Buildings Task Group and welcomes
its report "Better Buildings- Better lives" (submitted
to Government on 17 May) as a valuable and timely contribution
to the sustainable buildings agenda. The report recommends specific
improvements in the environmental performance of buildings, for
both new buildings and refurbishment, across the country, which
industry and Government can look to deliver in partnership in
the short and long term. The report recognises the importance
and urgency that must be attached to driving up the sustainability
of buildings and the ongoing work across Defra to help deliver
these improvements. The report reinforces the need for the highest
environmental standards (in terms of energy, waste, water, and
the sustainable use of timber and other construction materials)
to be applied more widely to our new and existing building stock
if we are to deliver the Government's vision of a low carbon economy.
These issues are brought together in the recommendation for a
Code of Sustainable Building which the Group suggests is based
on BREEAM and incorporates clearly specified minimum standards
in key resource efficiency criteria. Other headline recommendations
include "that the Government review the advisory bodies concerned
with sustainable buildings to simplify and consolidate them",
and "enshrine a 25% saving over average per capita water
consumption in regulation by 2005 [and] a 25% energy efficiency
improvement under Part L." Defra, Dti and ODPM Ministers
are urgently considering the SBTG's recommendations and are looking
to respond in due course on the most suitable options for implementation.
14. The Government's Strategy for Combined
Heat and Power to 2010, published in April 2004, reconfirms
the Government's commitment to its 2010 target of 10 gigawatts
of installed Good Quality CHP capacity. It sets out a framework
to support the growth of this sustainable energy technology and
reports on a range of market interventions to help achieve this.
Among these interventions is the exploration of ways to encourage
the take up of CHP and other low carbon technologies in the Building
Regulations revision announced in the Energy White Paper, thereby
building on the CHP guidance included in the 2002 edition of the
Regulations. The Strategy additionally reports on the Community
Energy programme's commitment to promoting community heating and
its provision of reduced heating and electricity costs to households
and public buildings.
15. As far as energy efficiency is concerned,
the Government set out an Action Plan for cutting annual carbon
emissions by 12 million tonnes through energy efficiency over
the next six years. These savings will need to be made across
the whole economy, but a significant proportion will come from
the built environment. This is reflected in the Action Plan, which
contains a number of key policies and measures directed at this
sector. Two important examples are the proposals for changes to
the Building Regulations, which will raise standards of new and
refurbished buildings from 2005; and a doubling in the level of
activity under the Energy Efficiency Commitment from 2005 through
to 2011, subject to a review in 2007. The combined product of
the energy efficiency measures in the Action Plan will contribute
roughly half the overall carbon savings in the Climate Change
Programme, and save households and businesses over £3 billion
per year on their energy bills by 2010.
16. Government is committed to ensuring
that the growth areas are equipped with the water and sewerage
services and infrastructure necessary to guarantee the long-term
health of these communities. To achieve this we recognise the
importance of involving the respective water undertakers and environmental
regulators at an early stage in the development of proposals
17. Discussions were held with water companies
by the consultants who undertook the studies leading to the identification
of the growth areas. Further discussions have taken place since
publication of the Sustainable Communities Plan and these continue
involving the individual water companies concerned, the Environment
Agency, relevant growth area delivery vehicles, DEFRA, ODPM, Water
UK and OFWAT. ODPM are funding a project by the Environment Agency
in the Ashford Growth Area to determine an integrated water management
strategy covering water supply, wastewater treatment and flood
management and alleviation. The strategy will be a crucial element
in putting together the masterplan for future growth in the Ashford
area. Water utility companies have just submitted plans for the
next 25 years on demand and supply, which are currently being
assessed by the Environment Agency, which will report to Defra
Ministers in July.
18. In respect of flood risk management,
Defra is committed to ensuring that development in the growth
areas takes fully into account current and future flood risk.
Whilst we recognise that some development in areas of flood risk
is unavoidable, such developments have to be designed and sited
in such a way as to mitigate as far as possible any potential
flood risk, and allow defences to be maintained/replaced in the
future. Such an approach is vital if we are to ensure that the
new communities are truly sustainable. ODPM's Planning Policy
Guidance Note 25 sets out the approach that planning authorities
should adopt when considering applications for development in
flood risk areas, including where necessary that a flood risk
assessment is undertaken. The recent Foresight Flood and Coastal
Defence Project highlighted the increased risk of flooding posed
by climate change and socio-economic factors, particularly in
coastal areas of the South East, and the importance of planning
authorities thinking carefully about the longer term risk to developments
on the floodplain. Defra and the Environment Agency are closely
involved in detailed planning decisions in Thames Gateway to ensure
that flood management measures are designed into new developments.
ODPM and DEFRA are represented on the steering group for the Environment
Agency's "Thames Estuary 2100" study of flood risk management,
which will consider which flood defence measures are needed for
the next century. All ODPM-funded projects and partnership vehicles
in the Thames Gateway are required to produce an appropriate flood
risk assessment.
19. Through ODPM the planning system ensures
that the need for new facilities is incorporated into waste local
plans. Defra is working closely with ODPM to ensure that the growth
areas assess the amount of waste likely to arise and plan for
the waste facilities needed to deal with that waste.
20. As mentioned above, Defra recognises
the importance of the increasing use of brownfield sites for housing
developments, the protection of valued open spaces, and increases
in the amount of Green Belt which has been achieved through ODPM's
land use planning policies. The most important biodiversity sites
have statutory protection, but Defra is also working to ensure
that new developments respect locally important sites, and take
the opportunity to enhance the provision of greenspace for access,
recreation and biodiversity. To this end, Defra supports the local
biodiversity partnerships which have defined biodiversity priorities
within the Growth Areas. In London and the South-East, these partnerships
have established schemes to ensure benefits for biodiversity are
designed into developments, especially new housing. Defra is also
working with ODPM on the revision of Planning Policy Guidance
Note 9 which will help to ensure that new developments respect
locally important sites for nature conservation.
21. In addition, Defra and ODPM jointly
funded the Thames Gateway Greenspace Strategy. This provides overarching
guidance to local delivery vehicles on integrating greenspace
into development plans, and will be followed up by local implementation
plans. Part of this strategy involves the "Greening the Gateway
Action Plan" currently being developed by ODPM and Defra,
which concentrates on managing the greenspace in the Thames Gateway.
One of the main objectives of this plan is to ensure that all
recreational green spaces are easily accessible and that the benefits
of accessing greenspace to health are promoted.
22. The Forestry Commission supports the
development of urban forestry especially through the 12 community
forests. The Countryside Agency also worked with ODPM on the allocation
of £11.5 million of green space funding for the new growth
areas.
CONCLUSION
23. The Sustainable Communities Plan provides
an opportunity for realising many benefits, in particular for
developing and improving new environmental standards for housing.
June 2004
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