Memorandum submitted by the Environment
Agency
SUMMARY
The residential sector consumes significant
levels of resources. Homes use two-thirds of water put into the
public supply network. They use 30% of energy and are responsible
for 24% of greenhouse gas emissions. We need to improve the environmental
performance of buildings and neighbourhoods. In particular:
— the quality of new housing, particularly
the standard of environmental performance, must be part of any
proposals for accelerating household growth;
— the Government must deliver its commitment
to the introduction of minimum water efficiency standards;
— the environmental performance of
existing housing stock must be addressed;
— buildings need to be located in the
right place. We welcome consultation on draft PPS25 Development
and Flood Risk;
— we need long term planning and funding
for necessary environmental infrastructure to support housing
development;
— we look forward to the public consultation
and forthcoming delivery of the Code for Sustainable Buildings
by April 2006. The Code for Sustainable Buildings is one part
of the package necessary to deliver sustainable communities; and
— fiscal measures should reward higher
building quality and improved environmental performance. We would
welcome incentives for industry and residents to take action.
1. INTRODUCTION
1.1 We are the Government's leading advisor
on the environment. We work with national, regional and local
government to ensure that current levels of planned housing growth
are sustainable and that the environmental risks of development
are clearly understood and addressed.
1.2 Through the planning process we:
— contribute to national, regional
and local planning frameworks to ensure planning policies are
in place to protect the environment, mitigate impacts and increase
the potential for environmental improvement;
— contribute to the sustainability
appraisal of planning policies, including their Strategic Environmental
Assessment;
— highlight to local authorities the
environmental risk—including flood risk—of individual
planning applications; and
— provide guidance to developers on
avoiding and reducing the environmental impact of their proposals
and on maximising environmental benefits.
1.3 We also advise the Government on the
adequacy of Water Company Water Resources Plans, regulate the
treatment of contaminated land and the treatment and disposal
of waste, and are responsible for the strategic planning, management
and delivery of flood risk infrastructure.
2. INQUIRY ISSUES
The Code for Sustainable Buildings—can a
voluntary Code possibly deliver the degree of change needed?
2.1 The Code alone will not achieve the
degree of change needed. If housing growth is to be sustainable,
the impacts on critical environmental factors such as water supply,
sewerage systems, waste disposal facilities, greenhouse gas emissions,
biodiversity and flood risk must be identified and addressed as
an integral part of delivery plans. The Government has acknowledged
this in its manifesto. All these factors fall outside the scope
of the proposed code.
2.2 However the code is an integral part
of a necessary package of measures. It will:
— deliver high (above Building Regulations)
standards for all new homes funded through public private partnerships;
— signal to industry the direction
Building Regulations are taking;
— make the industry more familiar with
innovative approaches and techniques.
2.3 Alongside the Code there should be :
— improved standards of resource efficiency
for all new and existing homes;
— arrangements put in place to ensure
houses are not built in areas of environmental risk;
— the timely provision of the necessary
associated infrastructure.
Building Standards
2.4 The residential sector consumes significant
levels of resources. Homes use two-thirds of water put into the
public supply network. They use 30% of energy and are responsible
for 24% of greenhouse gas emissions. We need improved minimum
standards of building delivered nationally through regulation
to achieve the level of change needed.
2.5 The demand for water created by new
and existing homes could be substantially reduced through improved
standards of water efficiency. Our work shows that water efficiencies
of up to 25% per household can be gained by ensuring pipework,
fittings and appliances maintain standards of performance and
use less water. The cost of these efficiencies is modest. In some
cases the cost of efficient units is less than conventional or
standard items.
2.6 High water efficiency standards applied
to all the one million new homes currently planned for south east
England could save more than 60 million litres a day—enough
to supply water for 500,000 people. But voluntary initiatives
will not create the step change necessary. We urgently need the
review of Building Regulations (Part G) to deliver national minimum
standards for water conservation in all new homes. The code should
stretch standards, signpost likely future changes to Building
Regulations, and encourage innovation. It should, as the Government
intends, be the minimum required for all publicly funded housing.
2.7 We need to encourage local authorities
to apply code standards to private homes. We are currently unsure
how the Government intends to take this forward.
2.8 We also need high standards for flood
resilience and resistance in homes that are vulnerable to flooding.
This means they should be:
— designed to manage flood water on
the site, for example using parks and green spaces for temporary
storage;
— safe for occupation and use during
flood, with safe access in and out for occupiers and emergency
services, including if defences were to overtop or fail;
— flood resilient (for example use
of stone floors that do not need to be replaced after a flood)
or resistant (that is, where water is prevented from entering
the building);
— not dependent primarily upon the
construction of new, or improvement of existing, flood defences
to manage the risk;
— where technically possible, use sustainable
drainage systems to reduce risks.
2.9 We are currently working with ODPM on
how to establish flood resilience in Building Regulations.
Adequate enforcement
2.10 Over 30% of new homes do not comply
with the Building Regulations. To achieve the required resource
efficiencies the Regulations must be adequately enforced.
Retrofitting
2.11 About 75% of the current housing stock
will be around in 2050. A reduction in the environmental impact
of existing homes could release some "environmental headroom"
for new houses. For example, improving the efficiency of water
use in the existing housing stock could offset the demand for
water that is created by new housing. Our preliminary research
shows that retrofitting existing housing with water efficient
devices could provide around 40% of the extra demand.
2.12 The majority of households could save
up to one quarter of their current water use—between 8%
and 16% by simply retrofitting toilets. Houses over five years
old are likely to present highest water efficiency opportunities.
2.13 In September, ODPM Ministers announced
a review of incentives for improving the efficiency of existing
stock. This review will cover both water and energy efficiency.
We look to this study to provide clear recommendations to encourage
residents to take action to improve the environmental efficiency
of their homes.
Location
2.14 Depending on where they are located
and the standards to which they are built, planned new housing
has implications for water resources, water quality, and flood
risk, as well as waste management and air quality.
2.15 Flood risk is a critical location issue
that needs to be addressed. Over five million people and two million
homes and businesses are currently at risk from flooding in England
and Wales. Recent floods, storms and drought have shown how vulnerable
we are to the weather. The floods this summer in Europe and the
events in New Orleans illustrate this very well.
2.16 We have made significant progress in
flood risk management through increased investment, both in defences
and flood warning, and in mapping the risk of flooding, but the
additional risks and costs could be reduced if new building in
high flood risk areas is carefully managed. The Government's Foresight
Future Flooding report highlighted that, in the face of climate
change, the risk of flooding over the next 30-100 years increases
significantly, and the damage could be very costly if flood management
policies remain unchanged. It also concluded effective land-use
planning to manage flood risk could reduce the aggregate cost
of flood defences from £52 billion to £22 billion until
the 2080s.
2.17 Research by the Association of British
Insurers has shown that one-third of designated development sites
(up to 108,000 homes) in the Government's south east growth areas
are located in the floodplain, and 10,000 properties may be built
in areas with significant flood risk.[8]
Spatial planning must direct homes to places where exposure to
environmental risk is least. The review of PPG25 on Development
and Flood Risk (and the intention to give clear advice to local
authorities on the need to avoid development in areas of flood
risk) is therefore welcome.
2.18 Spatial planning should also flag up
where new facilities—like waste handling facilities and
sewage treatment works are needed and signal where these types
of infrastructure are a precondition of housing growth (see section
D on infrastructure).
Is the Government doing enough to promote the
code, with the industry and the general public, ahead of its imminent
introduction early in 2006?
2.19 It is unfortunate that there has been
a delay in the publication of the draft code for consultation.
The construction industry would have benefited from an early indication
of the scope of the code and how it will work in practice. However,
once it is in place the code will be a pre-condition of any housing
development involving public funds so the construction industry
will have to respond quickly.
2.20 If the code is to have wider application,
and we believe that it should, it will need to be actively promoted
by national, regional and local government and be underpinned
by incentives or made a planning requirements. Developers have,
in the past, indicated that they are unlikely to adopt voluntary
standards. Their preference is for an unambiguous regulatory floor.
Should the Government be introducing fiscal measures
to reward higher building quality and greater environmental performance?
2.21 Yes. There is a place for fiscal measures
alongside other instruments (for example information, such as
labelling schemes and the Home Information Pack, regulation and
standards, the code, and Government led procurement) to reward
and encourage better environmental design. Fiscal measures, such
as council tax or VAT reductions, could drive up standards, particularly
in existing housing. Government should investigate the creation
of incentives for investment in technologies and integrated approaches
to environmental infrastructure that deliver multiple benefits.
These could include grants, loans or fiscal incentives such as
Enhanced Capital Allowances.
2.22 The affordability of a home includes
both its initial cost and its running costs. Higher environmental
standards in new homes will make houses more affordable, and more
comfortable, to live in, particularly for those on lower incomes.
Our research has shown that a house designed to be 25 per cent
less wasteful in water, energy and waste delivers savings of £138/year
to run. Even if the householder were to pay the full additional
cost of these measures (about £800) they would get their
money back in six years. With an appropriate fiscal incentive
the householder will be repaid in less time.
Infrastructure—is the Government doing enough
to secure sufficient funds for the timely provision of infrastructure?
2.23 Accelerated development in the south
and east of England, in particular, will stretch the capability
of some environmental infrastructure to cope. But a great deal
more of the nation's existing environmental infrastructure is
also in need of investment. There has been a historic legacy of
under investment and maintenance in public and private sewerage
infrastructure resulting in leakage, collapse, overloading and
sewer flooding. The need to reduce waste going to landfill requires
waste minimisation and major investment in alternative waste treatment.
2.24 The Government needs to secure sustained
investment, from private and public sources, for the environmental
infrastructure to overcome the predicted environmental impacts,
climate change and deliver good basic services in water, waste
and flood protection. This investment needs to be planned ahead
and in some cases will need to be a precondition of growth.
2.25 Tomorrow's infrastructure may look very
different to yesterday's. For example smaller scale, more decentralised
facilities that provide multiple benefits. Funding and institutions
need to be more flexible to support innovation.
Water quality, sewerage and waste water
2.26 Concentrated housing growth in some
places will mean that the capacity of sewers will have to be extended
if residents are to benefit from acceptable levels of waste and
foul water drainage and we are to meet current and future water
quality standards.
2.27 We estimated that up to 80 sewage treatment
works will need to be upgraded in the south east to service the
demand from existing and new housing being discussed in the draft
south east plan. This figure could be much higher if there is
a step change in housing growth to meet affordability goals.
2.28 Demand management can reduce the need
for capital investment in costly infrastructure. For example,
the use of Sustainable Drainage Systems (SUDs) can reduce the
need for more traditional forms of wastewater facilities.
Waste
2.29 Building new homes creates waste. We
estimate that plans for new homes in the south and east of England
could result in between 10.12 and 13.33 million tonnes a year
of construction demolition and excavation waste. Up to 20% of
this could be hazardous waste. We estimate that up to seven incinerators
or 50 waste treatment facilities will be required to deal with
waste from new homes in the South and East of the country.
2.30 We need to drive down waste arising
from construction through: better on-site sorting, storage and
management of materials and waste; re-use of excavated inert waste;
on-site remediation; and the use of sustainable construction techniques.
Water resources
2.31 For water resources, traditional resource
side options, such as reservoirs, are generally expensive, inflexible
and have high social, economical and environmental costs. Large
infrastructure projects may take up to 20 years to develop—committing
customers and society in general to an ongoing high energy/cost
solution.
2.32 Some new reservoirs may prove to be
necessary. (We currently think four or five in the east and south
east in the next 15 years.) But this must be balanced by lower
cost, flexible opportunities to secure more efficient use of the
existing water resource. Demand management is key to establishing
an appropriate mix of schemes and should mitigate or at least
defer the need to develop some new resources. This twin track
approach is essential to balance the social, environmental and
economic needs of housing growth. It will depend on:
— more rapid household metering penetration;
— higher water efficiency standards
in new housing stock;
— the development of incentives to
encourage retrofit of existing stock;
— water labelling of fixtures, fittings
and appliances;
— market transformation strategies
to accelerate adoption of more efficient products in the do-it-yourself
and retrofit markets.
Energy
2.33 Alongside energy efficiency, local
and small-scale generation of low carbon heat and power will play
a far larger part in meeting the needs of communities in future.
Building-integrated systems and local sources of heat and power
can reduce overall emissions of greenhouse gases, contribute to
security of supply, help provide affordable warmth, and promote
competition in the energy economy. We support adoption of microgeneration
in ways that are sensitive to the local environment as an obvious
component of sustainable building and communities.
Funding
2.34 New development puts pressure on existing
infrastructure and may require new infrastructure to be built.
While better demand management (for example through better water
efficiency) can reduce the levels of infrastructure that will
be required, we are concerned that adequate funding for environmental
infrastructure may not be forthcoming. Funding for these types
of infrastructure is complex. There will be a mix of private and
public investment, funded through consumer charges, developer
contributions and general taxation. Existing charging structures
for water, flood risk management and waste mean that the homeowner
or occupier does not pay the full costs of these pressures. Estimates
for infrastructure per house are around £35,000-£45,000.
In some places, like the Thames Gateway, it could be as high as
£65,000 per house. We believe that there is a case for developers
to contribute more in some cases.
2.35 The proposed Planning Gain Supplement
is one vehicle that could be used to meet some of these costs.
Whatever form of planning contribution is created in the future
(for example Section 106, revised section 106, Planning Gain Supplement,
Development Tariff etc) it should provide sufficient funds for
essential environmental infrastructure. We need better recognition
of the role of the developer in designing out the need for expensive
and unsustainable infrastructure, especially for flood defences,
and take into account the impacts of climate change over the lifetime
of the development.
Are the water companies doing enough to secure
the supply of water resources to the four Growth Areas? And is
concern about security of water supply, in the South East of England
in particular, a valid one or simply a knee jerk reaction to a
few hot, dry summers?
2.36 Our research shows that Water Companies
have underestimated by 20% the level of housing growth in their
water resources plans. This is not an immediate problem but will
need to be addressed in future strategic planning cycles. Government
policy is for water resources to be met through a combination
of demand management and investment in new resources.
2.37 Southern England has just had its driest
ten months since 1976. River flows and groundwater levels are
low across southern England, causing environmental problems such
as distressed fish, damage to wetland bird breeding grounds, algal
blooms and loss of habitats. Water companies plan for droughts
like this, but the high population density and the low rainfall
mean that the water available for each person in south-east England
is lower than in many parts of Mediterranean Europe.
2.38 We are concerned about continued security
of water supply in south-east England. This is the driest part
of the country. The water environment is particularly valuable:
chalk streams and rivers are rare and some of the best in Europe
are in south-east England. Population is growing and individual
demand for water is also increasing. This adds to the pressure
on the water environment in areas where there is little additional
water available for abstraction.
2.39 There are options for further water
resource development in the south east. Water companies have identified
sites where new reservoirs could be built or existing reservoirs
could be extended. There is also scope for more water to be transferred
from other parts of the country. However, all of these developments
are costly and have a detrimental effect on the environment. They
also take between 10 and 20 years to construct.
2.40 Water resources can be made available
for growth areas in the south east, but at a cost. We are concerned
to make sure that this is properly planned so that any new development
has the lowest possible environmental and social impact. Managing
demand in new and existing homes and businesses can help to minimise
these effects and make the best use of the limited volume of water
we have.
2.41 Metering can make a significant contribution
to the management of water resources in England and Wales. It
raises customers' awareness of how much water they are using and,
providing appropriate tariffs are charged, encourages them to
reduce their water use. Emerging research suggests metering can
reduce demand by between 8% and 21%.[9]
Suitable safeguards are required to protect the vulnerable groups.
2.42 All new properties are metered and
water companies have several opportunities to meter existing households.
But there are large differences in metering coverage between water
companies—from 5% to 60%. The current annual rate of progress
in meter installation ranges from 0.79% (Thames Water) to 4.95%
(South West Water). Five companies project metering coverage of
less than 50% by 2030. Two of these are in the south of England.
We need to encourage more rapid and widespread metering of household
water supplies, with more sophisticated tariffs.
Is there sufficient effort being made by the Government,
the Environment Agency and the water companies to educate people
about water efficiency?
2.43 The Environment Agency is actively
engaged in the Government's Water Efficiency Group, which has
been established to take forward and deliver water efficiency
in homes and businesses. In addition we are engaged with:
— Public awareness campaigns. As part
of our drought plans, we work with others on public awareness
campaigns on water efficiency.
— Water Efficiency Awards. The fourth
Environment Agency Water Efficiency Awards were held in March
2005. Sectors covered include leisure and tourism, building and
construction, industry & business, public sector, education
and community work.
— World Environment Day. The Environment
Agency has promoted United Nations World Environment Day for 2004
and 2005. Saving water has been a major feature of the campaign
in both years and is certain to be a major issue in 2006 too.
We estimate that 114 million litres of water would be saved directly
from the promises made.
3. CONCLUSIONS
3.1 We need improved the environmental performance
of buildings and neighbourhoods. In particular:
— the quality of new housing, particularly
the standard of environmental performance, must be part of any
proposals for accelerating household growth;
— the Government must deliver its commitment
to review Part G of the Building Regulations and the introduction
of minimum water efficiency standards;
— we must tackle the environmental
performance of existing housing stock;
— buildings need to be located in the
right place. We welcome consultation on draft PPS25 Development
and Flood Risk;
— we need long term planning and funding
for necessary environmental infrastructure to support housing
development;
— we look forward to the public consultation
and forthcoming delivery of the Code for Sustainable Buildings
by April 2006. The Code for Sustainable Buildings is one part
of the package necessary to deliver sustainable communities but
it is not enough on its own;
— fiscal measures should reward higher
building quality and improved environmental performance. We would
welcome incentives for industry and residents to take action.
November 2005
8 ABI, Making Communities Sustainable p 7 http://www.abi.org.uk/display/File/Child/554/Making-Communities-Sustainable-housingsummary.pdf Back
9
Impact effect of metering-UK evidence summary (draft). Herrington,
2005. Back
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