Memorandum submitted by Crest Nicholson
ENQUIRY ISSUES—WRITTEN ANSWERS TO QUESTIONS
PROVIDED
1. Additional question
How did Crest Nicholson achieve it leading position
on sustainable development (CSR)
(PND)
Crest Nicholson started to differentiate itself
in the home building sector before 2000 with a business strategy
that included core values of building communities, quality construction
and high standards of customer service. ODPM Gold and Silver "Building
for life awards" at flagship developments such as Ingress
Park (Thames Gateway), Port Marine (Bristol) and Park Central
(Birmingham) were the beginning of putting into practice the delivery
of high quality, high volume, mixed use, viable community renewal
developments. The Board established a Committee for Social Responsibility
and Group Environment Manager position in 2002. A review of the
social and environmental aspects of the company's activities,
products and services was undertaken to create a relevant Sustainable
Development policy. This policy allowed integration of social,
economic and environmental aspects of the business into existing
management practices or procedures from land buying through design
and build to Sales and Marketing. Environmental and social performance
data was collected and benchmarked. Strengths and weaknesses were
identified. Improvements were made to increase performance on
an annual basis. Our Corporate Responsibility report is published
and verified annually following global and national guidelines.
A: CODE OF
SUSTAINABLE BUILDINGS
(RP)
1. Can a voluntary code possibly deliver
the degree of change needed in the building industry to achieve
well-designed, energy efficient sustainable buildings which have
minimal impact on the local environment?
A1.
R.P. Experience shows that voluntary
sustainability measures are not generally implemented by the speculative
housebuilding industry largely because of the need to maintain
the levelness of the competition playing field throughout the
process of change. It only responds reliably to mandatory legislation.
A concern in this case is the degree to which
the Code will be voluntary. The Government commitment is quoted
as "From April 2006 all new housing receiving government
funding will meet the new Code for Sustainable Buildings and we
will encourage local authorities to apply similar standards to
private houses."
P.T. Promotion in the private house-building
sector where Government funding is not involved will rely on voluntary
participation in the hope that product differentiation, competition
and marketing will convince house-builders to participate.
The more enlightened house-builders who already
consider sustainability and environmental policy at the core of
their business will embrace the Code but it is hard to see a commitment
from smaller or less enlightened house-builders where the Code
will add additional cost (£608 per dwelling) to achieve even
a one star rating. Often they are delivering price sensitive homes
at the lower end of the market. There is more awareness of sustainability
issues amongst the public but anecdotal evidence would suggest
affordability for first time buyers is still more of an issue.
Real change to achieve well designed, energy
efficient sustainable homes would require mandatory compliance
and it is difficult to see why this cannot be delivered through
enhanced Building Regulations or Planning. Of the six essential
elements four are already covered in part by Building Regulations,
leaving site waste management and water. New Planning Policy Statements
(PPS1, PPS3 and PPS22), Sec 106 agreements, Local Development
Frameworks, Regional Spatial Strategy, Development Plans and Sustainable
Checklists; a whole plethora of planning documentation and initiatives
make reference to design codes and the delivery of sustainability.
Planning authorities are already using their powers to invoke
change. There is a contradictory message if the Code remains voluntary;
the burden of regulation on house-builders is already there, there
needs to be consolidation and clarity.
It seems a pity when Ecohomes was establishing
itself as the building industry standard for environmental labeling
that a new Code for Sustainable buildings has been newly invented,
especially when it remains voluntary. With Housing Corporation
and English Partnerships amongst other agencies being directed
to use the new Code it is hard to believe Ecohomes can survive
beyond the transitory period after 2008.
2. Is the Government doing enough to promote
the Code, with the industry and the general public, ahead of its
imminent introduction early 2006?
A2.
R.P. A related reason why the industry
has not conscientiously adopted voluntary sustainability measures
is because customers are not generally prepared to pay for them.
For them to become so there needs to be a much heightened public
awareness of the crucial importance of sustainability issues,
sufficient to justify the introduction of and payment for commendable
but expensive mitigation measures.
As far as the general public is concerned I
do not think that the Government is doing enough either to raise
the level of understanding of the problem or to promote the Code
which is designed to address it.
(It is possible however that as fuel prices
rise to critical levels, market forces will do the job for it.)
The industry is aware of the imminent introduction
of the Code, and is currently considering a consultation paper
for which the deadline for responses is 6 March 2006. The Code
itself is due to take effect in April, which barely allows sufficient
time for the consultation responses to be adequately considered
before its introduction.
This apart however, the promotion of the Code
has so far raised a number of doubts and uncertainties which the
ODPM should be doing more to resolve or eliminate, viz:
— The Building Regulations are a Statutory
Instrument and Eco-Homes is steadily (albeit slowly) becoming
the industry standard. In sustainability terms the Code broadly
covers the same issues as they do, so how exactly will it relate
to, complement, or replace them?
— The consultation paper for the Code
acknowledges its debt to Eco-Homes upon which it has been closely
modelled, although it will have a different name, structure and
scoring system. Why? Wouldn't it be simpler to adapt the next
issue of Eco-Homes to a suitable level? Why increase the confusion
by introducing another document?
— How voluntary will the Code be? The
consultation paper introduces significant ambiguities as follows;
— ". . . all new homes built by
RSLs (or others) with Housing Corporation funding will comply
with higher levels of the Code . . ."
— ". . . we will require new dwellings
developed by these bodies to be at least as sustainable as the
Eco-Homes Very Good standard, which means they will meet our level
three."
— The Government will ". . . encourage
local authorities to apply similar standards to private homes."
— "That does not mean however
that we intend that building to meet Code standards should become
a condition of planning consent."
— So, will LPAs be able to enforce
compliance with the Code or not, and if so at what level?
P.T. Within the industry there has been
adequate consultation and awareness although the timescales are
tight, the consultation period ends in March2006.
Ecohome assessors were asked to comment on
the document towards the end of 2005. It should be noted that
the BRE organisation for Ecohome assessors will be re-trained
in the use of the new Code. Training has not commenced yet the
Code is to be rolled out and implemented in the early part of
2006.
With regard to the general public there does
not seem to be much promotion ahead of its imminent introduction.
Any marketing differentiation strategy used by House-builders
will rely on increased public awareness of the new Code and significance
of the rating system. The roll out of the Home Information Packs
in June 2007 seems to have had better promotion; the opportunity
should not be missed to link levels of sustainability and energy
efficiency between homes achieved by the new Code and the standards
achieved by the second hand homes market.
3. Should the Government be introducing fiscal
measures to reward higher building quality and greater environmental
performance?
A3. Yes
R.P. There is already some ambiguity
about the relationship between the Building Regulations and compliance
with the Code at entry level, particularly if through planning
the Code becomes effectively mandatory. Assuming (and suggesting)
however that levels above entry compliance do remain voluntary,
and given that the industry has hitherto been prepared to adopt
mandatory measures only, the idea of fiscal incentives to reward
higher attainment would seem well worth exploring.
P.T. There is more of a case to introduce
fiscal measures to reward higher building quality and greater
environmental performance if the scheme is to remain voluntary.
If it became mandatory there is less of a need unless it is an
incentive to take dwellings beyond just a minimum standard. This
could be reduced stamp duty rates for purchasers or reduction
of company taxation for those companies willing to go beyond the
minimum.
Planning gain and Sec 106 agreements could be
another area of reward, where the planning gain package could
favour high levels of sustainability and lessen other contributions
eg affordable housing, transport, etc.
There should be the continuation and increase
of subsidy and grant to assist in greater use of renewables when
trying to attain carbon neutral homes (5star rating).
B: SUSTAINABLE
COMMUNITIES
4. Does the ODPM Five Year Plan, Sustainable
Communities: Homes for All demonstrate a greater recognition of,
and greater commitment to tackling, the impact of increased house
building on the environment or does it merely pay lip service
to it?
PND
The ODPM five year plan (Section on the Environment,
Chapter 8) does not go into detail on how sustainable communities
will be developed by joined up thinking. It refers to the Code
for Sustainable Buildings which relies heavily only on one of
the BRE rating tools, the BRE EcoHomes rating system, which deals
mainly with the environmental aspects of homes. As new sustainable
communities of the future will rely heavily on guidance/regulation
linking each step in the whole development process then the code
has an excellent opportunity to sit above and link up:
Sustainable land buying/
Land selection and planning—www.Sustainabilityworks.org.uk
Housing Corporation;
BRE Sustainability check list
Regional variations of BRE checklist eg, SEEDA
Climate Change Partnership, Checklist for developers
Architecture—Urban Design Code.
Design—BRE EcoHomes + BREEAM for Offices
+ Retail + Hospitals etc.
Specification—BRE EcoHomes + BREEAM for
Offices + Retail + Hospitals etc.
Supply chain—BRE EcoHomes + BREEAM for
Offices + Retail + Hospitals etc.
Build/construction—Constructing Excellence
KPIs + DTI Waste Management plan.
Sales and marketing—Creating sustainable
home buyers and the markets.
Customer care—Providing Home Information
Pack (HIP) including SAP certificates (Energy efficiency of building
notices), EcoHome certificates and sustainable life style manuals).
Although there may be other excellent guidance/rating
tools, their use should be made part of planning regulation/mandatory.
In order to gain optimum sustainable development improvement they
should be linked up through out the whole development process/cycle
in order to create sustainable communities.
Once their use is mandatory under the Building
Code then the BRE (and/or others) could collect the data and benchmark
annually to draw a baseline for improvement across the industry
setting realistic and manageable targets.
5. To what extent does the Five Year Plan
address the environmental implications of the geographical distribution
of demolition versus new build?
The plan does not appear to "address the
environmental implications of the geographical distribution of
demolition versus new build" in detail.
There may be a need for a more early strategic
planning guide, under the new sustainable building code, going
beyond the listed building grades, to aid developers and take
into account relevant environmental criteria. The tool should
be able to evaluate and balance the social, economic and environmental
criteria of areas within a renewal or regeneration region for
the most sustainable outcome being either renovation or demolition
and rebuild.
C: LPS2020
6. The Government has consulted on the new
construction standard for dwellings (LPS2020). On the basis of
that consultation is it possible to determine whether the new
standard will be a positive force for change and add value to
the construction process?
C6.
R.P Innovative construction techniques
offer a key mechanism to shorten constuction times and by so doing,
to reduce costs; and consequently they are seen as of crucial
importance in the programme to address the current housing shortfall.
However non-traditional construction systems have not had an entirely
successful history so a confidence gap has developed within the
consruction industry itself, in its customers, and in its insurers
and lenders.
In order to regain their confidence the BRE
is developing The Standard for Innovative Methods of Dwelling
Construction, LPS (Loss Prevention Standard) 2020, with the help
of industry stakeholders including The Association of British
Insurers, Council of Mortgage Lenders, NHBC and HBF. It will provide
a route to certification for innovative building systems, sub-assemblies
and elements which are not wholly covered under current recognised
standards and codes for dwelling construction, and which have
a limited track record of service in the UK. It will also cover
performance in use, particularly in the face of disaster (fire,
flooding, exceptional storm etc), the ease and practicality with
which repairs can be carried out and their cost, ease of adaptation
and extension, and behaviour when subjected to everyday use eg
having things fixed to it (such as hanging baskets etc) or chip
pans going up in flames.
I have today spoken to Oliver Novakovic at BRE
Certification Ltd who advised that the standard has been prepared
and that the consultation period is over. Responses were very
supportive, the Certificate has been drafted and that calibration
of the standard is now under way. This effectively means that
a trial assessment is being carried out on five candidate systems,
whose manufacturers have paid for it.
Once the final approved standard is published,
manufacturers and suppliers will be able to apply to BRE Certification
and its licensees for the certification of their systems and components
against it.
On the basis of the consultation, which was
very positively supportive, it is reasonable to expect that LPS2020
will perform as designed, to instil confidence in Modern Methods
of Construction so that they can fulfil their potential and add
value to the constuction process.
P.T. The new Loss Prevention Standard
(LPS) 2020 has been developed by BRE Certification Ltd and major
stakeholders at the request of insurers, mortgage lenders, regulators
and manufacturers. The standard will provide a means to assess
the performance and design of new methods of construction that
do not have an adequate track record in the UK.
The new standard will be a positive force for
change as the demand for Modern Method of Construction increases,
partly from the pressures of Government and partly from commercial
pressures to deliver volume. The standard should give confidence
to the institutions and purchasers alike and dispel some of the
historic prejudices and concerns about MMC from the past.
It will add value to the construction process
providing innovation, higher quality within shorter time scales
of construction giving equal treatment for insurance and lending
as given to conventional dwellings.
The new standard will give confidence and control
in choosing innovative building systems.
D: INFRASTRUCTURE
(INCLUDING FACTUAL
INFORMATION, REFERRALS
TO WATER
COMPANIES AND
RECOMMENDED ACTIONS
FOR GOVERNMENT
OR OTHERS)
7. Is the government doing enough to secure
sufficient funds for the timely provision of infrastructure, such
as transport links, schools and hospitals in the four Growth areas?
Not answered.
8. Are water companies doing enough to secure
the supply of water resources to the four Growth Areas?
1. Milton Keynes and the South Midlands
2. The London-Stansted-Cambridge corridor
3. Thames Gateway
4. Ashford
8A. Some Water Companies are not active players
in the planning process until the later stages when unexpected
changes to the programme can cause major delays. These delays
may involve a development company having to make significant financial
contributions to the construction of a water reservoir or additional
sewage treatment. Although regional experiences differ, there
is an opinion that Water Companies are most comfortable with supplying
traditional services that include, sewage treatment, supply leakage
repair and metering services.
8B. Sustainable Urban Drainage Systems (SUDS)
have been proposed at an early stage in planning to recharge rivers
and aquifers at a natural rate, as an alternative to traditional
storm run off sewer diversions that can deplete natural ground
aquifers and contribute to floods. SUDS meet local planning requirements
and are often cost effective. These sustainable plans may be rejected
at a later date due to the EA, Water Company or Planning Authority
not wanting to adopt a SUDS drainage system. If the Planning authority
does adopt the system, then they may apply heavy commuted sums
which makes it prohibitively expensive for the developer. This
impedes progress. Some frustration is expressed by our strategic
land planners that after lengthy periods of debate the development
plans then receive a "no commitment" decision in the
later stages.
8C. Hence where developers seek to utilise best
environmental practice and exploit the natural drainage characteristics
of a site in response to their Sustainable Development policy,
the ongoing responsibility for the scheme should be defrayed to
an adopting Authority. This should not require large amounts of
commuted sums being paid to a Local Authority. A significant change
in planning policy and relationships between Local Planning Authorities
and the EA is required to ensure that there is a national framework
for the assessment, implementation and final adoption of efficient
water management systems on all sites against flood risks or drought
conditions.
8D. Water UK Briefing (November 2005)—New
sustainable water resources need to be planned by the EA and water
companies in line with the planned residential and mixed-use growth
areas to maintain secure public supply. Investment is required
in developing sustainable water resources such as:
— Increased storage—expanding
existing reservoirs;
— Increased natural storage eg, wetlands,
restoring floodplains, lakes;
— Coastal desalination; and
— Improving the management of catchments.
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?
8E. Crest Nicholson has a Sustainable Development
policy (2002) and is aware of the global environmental pressures,
in particular Climate Change, and how this may impact our industry
at a national/local level. We are also aware of the overwhelming
scientific consensus that the UK's climate is changing and the
Southeast and East of England is at the forefront to this change.
The Water UK supply outlook for 2006 is "normal for the UK
but serious in some parts of the Southeast where for a year rainfall
has been well below average. Long-term prospects are good as long
as the management of water resources is fully recognised in development
planning. To the water industry this means making sustainable
development the first priority."
8F. Crest Nicholson has participated (November
2004) in the consultation stages of the Three Regions Climate
Change group's "Adapting to climate change: a checklist for
development" by The Sustainable Development Round Table for
the East of England, the London Climate Change Partnership and
the South East Climate Change Partnership. Documents such as this
should also be taken into consideration in building policy development,
if not already taken into account.
9. Is there sufficient effort being made by
the Government, the Environment Agency and the Water Companies
to educate people about water efficiency?
9A. The efforts being made by Government
to educate people about water efficiency appear to be less at
present than the efforts being made to raise awareness and educate
the public about climate change, carbon emissions and energy efficiency
(via the Carbon Trust and/or the Energy Saving Trust). This is
evident from advertisements on television, in the press and in
public places. The emphasis on carbon emissions is understandable
considering the significance negative impact this may have on
the survival of future generations. In times of drought there
have been memorable reactive efforts to educate people through
publicity on water efficiencies such as hose pipe bans and the
use of showers for bathing. Perhaps there needs to be a consistent
and prolonged publicity programme for water efficiency through
a Water Trust. The Commission for Architecture and the Built Environment
(CABE, WWF & HBOS, July 2004) communicated a report on the
"Attitudes and Decision Making among Home Buyers". Quantitative
research on the environmental aspects of design, found that 48%
of those surveyed thought that water efficiency, as assessed by
EcoHomes, was very important. At local government level Crest
Nicholson and other stakeholders were invited and gave evidence
to the KCC Strategic Planning Policy Overview Committee: Select
Committee—"Water and Wastewater, particularly in Ashford"
on 13 July 2005. Questions were regarding water efficiency and
new housing developments (the management of 31,000 new homes and
the rise in water demand and wastewater output. Numerous councils
are communicating their sustainable development guidance and plans
to developers and the public that includes good water efficiency
practices
9B. The Environment Agency (EA) is making
an effort by conducting a stakeholder consultation on "water
infrastructure for new developments" (December 2005). Crest
Nicholson has contributed written answers to their questionnaire
on decentralised and/or innovative water infrastructure solutions
as envisaged under the Government's Sustainable Communities Growth
Areas. This consultation discusses technical options and barriers
to such infrastructure implementation. The EA web site section
on "Water Resources" is a passive form of education
for people in general about water efficiency on how to save water
in the home, garden and at work. There are sub-sections on "Water
Efficiency Awards" and "Water Company resource plans
which focus on mains supply water leaks, households metering,
abstraction targets and drought plans. Innovative water efficient
technologies appear to be being encouraged through annual awards
on a voluntary basis. There appears to be a need for the EA, Planning
authorities, Water Companies and developer to come to an agreement
on how to prepare for sustainable new development scale water
resources (supply and treatment).
9C. Some regional Water Company web sites
(supply and sewage treatment) have sections to educate people
about how to save water in the home, garden and at work. Their
annual Sustainable Development and/or Environmental Reports also
communicate wider water service issues. However, there is a need
for them to communicate and educate their closest stakeholders
and the wider public concerns on their plans for secure innovative
and sustainable water resource supplies to address the needs of
the planned urban renewal expansion.
January 2006
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