Memorandum submitted by Chartered Institution
of Water and Environmental Management (CIWEM)
A: THE CODE
FOR SUSTAINABLE
BUILDINGS
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?
It is difficult to judge the extent to which
the code will be voluntary once introduced. Neither is it easy
to judge the likely impact of the code without a clear indication
of its content. Statutory requirements will be delivered via the
Building Regulations. CIWEM understands that the Code for Sustainable
Buildings (CSB) will act to inform the industry of the likely
future direction of Building Regulations, encourage developers
to build to standards higher than the minimum requirement, as
well as being a pre-requisite for those developments in receipt
of public funding. In many ways, this seems logical and reasonable.
However, we remain concerned that for the vast majority of developments,
there will be little or no incentive for developers to do anything
other than meet the minimum requirements of the Building Regulations
(that is assuming these will be properly enforced).
In an interim report, the Chairmen of the Sustainable
Buildings Task Group stated that "we believe that the construction,
development and house building industries do not subscribe to
much of the sustainability agenda, and have not been persuaded
of its long-term benefits". This does not suggest that the
building industry is likely to willingly embrace a voluntary code.
It could be that there might be a discretionary element to the
CSB, wherein planning authorities may choose whether to require
compliance or not. Such a situation may again seem reasonable,
but would in all likelihood create a scenario whereby compliance
with the CSB would be required in areas under high development
pressure, and not in those areas where development and regeneration
were being encouraged. From a sustainability point of view this
would do no-one any favours in the long term and promote polarisation
of development quality between affluent and more deprived areas.
CIWEM considers that central to the delivery
of sustainable development is the establishment of not only stringent
efficiency and other sustainability standards for developments,
but also of a level playing field for developers, which does not
place those developers who embrace higher standards at a competitive
disadvantage in the marketplace. This might not be an issue, were
greater sustainability credentials a strong selling point for
buildings. However, currently we do not consider this to be the
case and it is something that the Government must work hard on
in terms of educating the public.
CIWEM broadly welcomes the development of the
CSB. However we do not consider it will be sufficient to deliver
the degree of change described. For this to happen, the buying
public and the business community must value the environmental
performance of buildings far more highly than they presently do.
This will require the Government to deliver a package of statutory
measures, financial instruments and widespread education. We would
also suggest that the CSB should be subject to regular review,
say every five years (in conjunction with the Building Regulations)
with regular translation of CSB content into the Building Regulations.
2. Is the Government doing enough to promote
the Code, with the industry and the general public, ahead of its
imminent introduction early in 2006?
Awareness of the CSB amongst organisations in
the construction industry appears to be good, although we cannot
comment on the extent to which it has been communicated to developers
"on the ground" with any authority.
In terms of wider awareness, there appears to
be little information available over and above a brief introduction
of the Code on the ODPM website. There is no readily available
information about the kind of aspects which will be covered in
the CSB, to whom and where it will apply, and how it will relate
to the statutory regulations. This is perhaps not surprising if
the Code is still in gestation. Nevertheless, we would suggest
that the information currently available from ODPM should be accompanied
by detailed and persuasive information about why the Code is important,
and supporting the sustainability arguments it aims to underpin.
There has been little in the mainstream press on the subject since
it was officially announced in 2004, nor any visible Government
campaign to promote the interests of the Code. Therefore, it may
be argued that not enough is being done to promote the Code ahead
of its launch.
3. Should the Government be introducing fiscal
measures to reward higher building quality and greater environmental
performance?
As an Institution with sustainability interests
at its core, CIWEM considers that fiscal measures which would
encourage greater building quality and overall environmental performance
would be a welcome component in the delivery of greater public
demand for such features. CIWEM has long championed the use, for
example, of universal, intelligent water metering allied to rising
block tariffs and seasonally varying tariffs in order to change
the public perception of water as a resource and to reduce demand.
Other fiscal measures such as the removal of VAT for materials
used in building renovation, reduced (or removal of) stamp duty
for dwellings meeting certain environmental performance, or even
mortgage relief or similar incentives would be welcomed.
We would also like to see the use of warnings
and notices on products which are particularly harmful to the
environment, drawing attention to factors such as higher than
average energy consumption for a product, or that outside lighting
may have adverse effects on wildlife. If the value set of the
public is to be changed to recognise the environmental performance
of buildings, then it is likely that a range of measures will
be needed including fiscal ones.
B. SUSTAINABLE COMMUNITIES:
HOMES FOR
ALL
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?
CIWEM considers that Sustainable Communities:
Homes for All does appear to give greater emphasis to certain
environmental aspects of the Sustainable Communities Plan. There
is a dedicated chapter on "Enhancing the Environment",
which deals, in particular, with the density of the proposed housing
and the Government's commitment to building on at least 60% previously
developed land.
Energy efficiency of new buildings, as well
as renovation of existing stock is also discussed. We are pleased
to see commitment to such improvements, but sustainability in
new mass housing projects requires maximisation of insulation,
passive solar heating, solar hot water systems and heat exchange
ventilation, all of which may only be provided easily in new build.
This would at the present time require compulsion as it constrains
street design for the best effect at high density.
The discussion of the issue of construction
waste is to be welcomed, and there is a commitment to ensure that
the CSB is complied with for Public Private Partnership projects
as well as a promise to pilot the CSB in the Thames Gateway (although
with no explanation of what such piloting will involve).
The importance attached to the provision of
public open space is also welcomed. It is important that adequate
provision of public open space is fully integrated into new developments.
We are pleased that the Government is considering housing density
issues but this should not come at the expense of well designed
greenspace and garden provision which is important for urban biodiversity
as well as infiltration of rainfall.
CIWEM is disappointed, however, that there is
minimal mention of water efficiency in new dwellings bar a mention
that water efficiency will be considered when the building regulations
are updated, nor of the potential impact on water resources of
large-scale developments in the South East. There is also no consideration
of greywater recycling/water reuse in the plan. We consider that
water issues, which we discuss in further detail below, are of
a significance that is not reflected in the five-year plan.
Similarly there is no mention of the impact
of new developments upon the load on existing sewerage networks.
Large parts of such networks are combined sewers and many are
at, or near capacity, or already exceeding their capacity in storm
conditions. Development such as that in the Thames Gateway would
increase frequency of CSO discharges as well as increasing the
risk of sewer flooding. It is therefore imperative that new build
in the area has adequate soakaway capacity for rooftop and hardstanding
drainage, incorporating sustainable drainage systems (SUDS). Provision
to adequate levels may impact on housing density, depending on
local infiltration capacities. Nevertheless, sustainable drainage
and wastewater capacity is an essential consideration for the
proposed growth areas.
Also of concern is that the impact of new development
in flood plain areas is not given appropriate weight, particularly
in the context of the South East, and especially the Thames Gateway.
Climate change will increase the risk of flooding in most areas
and it is not sustainable to continue building on areas at significant
risk of flooding. It is possible to defend to a certain level
but that level can always be exceeded by floods greater than the
design of the defences. In addition, future generations will be
faced with having to upgrade these defences in the light of climate
change or abandon the communities at risk. This is hardly sustainable
in the long term (it is not clear what the envisaged lifetime
of these new communities is, nor is there much evidence that this
has even been considered). It is hoped that the emerging PPS25
will adequately address this issue.
There are, therefore, areas where we consider
environmental impacts receive fair consideration, but we remain
disappointed by the overall lack of recognition, and admission
by the Government, that the Sustainable Communities Plan will
have significant environmental impacts, which must be minimised
through detailed planning and design.
CIWEM recognises that ODPM is mandated to deliver
large-scale housing expansion, and most of the aims of the Plan,
in attempting to deliver far more "user friendly" developments
for society are laudable. We continue to feel, however, that the
use of the term "sustainable" is not yet justified,
and is defined in more social and economic terms than environmental
ones (there should, of course, be a balance of all three). The
Government has failed within this plan to publicly recognise the
threats posed by flooding in the Thames Gateway and other growth
areas (despite increasing concern being expressed by sectors such
as the insurance industry). Nor has it discussed the implications
of extra demand on water resources in an area where they are under
pressure. To do so, and to demonstrate a clear commitment to identifying
and addressing these threats in partnership with all relevant
stakeholders, is necessary before CIWEM can be satisfied that
the Government is affording the environment sufficient consideration
on all fronts.
C. INFRASTRUCTURE
5. 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?
Infrastructure to offer alternatives to the
car will be needed, though cars must still be adequately accommodated.
From an air quality point of view parking cars at ground level
under housing and having only utility activity at front ground
level can enable close building to high density travel routes
of any mode, provided walking and cycling routes are also included.
We are concerned that water infrastructure appears
to be considered rather separately to other infrastructure by
the Government and that the innovation in funding infrastructure
through, for example, Local Delivery Vehicles, is not matched
by similar funding innovation for water service provision. We
are also concerned that in the rush to secure infrastructure funding,
local authorities may not be aware of the implications of any
funding agreements for water services.
6. 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?
CIWEM considers that Water Companies, the Environment
Agency and Ofwat have shown some commitment to addressing the
needs of water resources for the sustainable communities growth
areas. This is endorsed by the fact that funding has been made
available in the last Ofwat determination for feasibility and
environmental studies that will be undertaken by several Water
Companies and the Environment Agency over this five-year period.
Concern will always be raised in the press and
the media as and when restrictions are introduced. This is largely
because there is a lack of understanding that most Water Companies
are only funded to provide a certain level of service to their
customers, which allows restrictions to be put in place at a given
frequency, approved by the Environment Agency and funded by Ofwat.
That appeals and restrictions were needed in 2005 should not be
regarded as constituting a problem. Appeals and restrictions are
part of the water industry's operating machinery for managing
droughts, and we should expect them to be used when significant
rainfall deficits put pressure on the ability of water resources
systems to meet the unrestricted demands of people, so as to avoid
unacceptable damage to the environment.
This said, CIWEM considers that there are medium
to long-term threats to security of supply when the current freshwater
resource base is set against contemporary projections for future
water supply needs.
Broadly speaking, household demand is expected to
rise at the rate around 0.5-1% p.a. of current demand (which is
about 150 l/h/d on average in England & Wales, and around
160 l/h/d on average in the South East). Demand volumes (as opposed
to per capita or per household rates) will rise most in resource
zones targeted for population increases and housing increases,
including the growth areas of the Sustainable Communities Plan.
Demand is expected to become higher under climate
change scenarios. Central scenarios of climate change indicate
the need for the nation's water planners to plan increasingly
for greater swings in water resources availability between wet
spells and dry spells. It appears that the resource and the demand
effects of climate change are likely to become problematic after
rather than before 2020. This is not to say that such effects
will not be present until then; merely that they are likely to
fall within the band of variability previously experienced under
natural variation.
The proposed developments in the Sustainable
Communities growth areas will have a water efficiency saving target
of >25% compared to normal homes, >20% compared to other
new (and therefore metered) homes, which CIWEM considers a welcome
step. However, such savings amont to reductions of around 50 l/h/d
compared to a normal (unmetered) household, and around 30 l/h/d
compared to a new (metered) household. Evidence from the savings
achieved from water efficiency programmes implemented to date
indicates that such savings will not be achieved easily. Even
if these efficiency gains are achieved, the Sustainable Communities
Plan will still lead to a large increase in demand in areas already
under strain to supply (75% of 160 l/h/d = 120 l/h/d x 200,000
new homes with an occupancy rate of say 2.3 persons per household
= 55 Ml/d = a large reservoir or 50 small boreholes). It is clear
that savings will be needed from all households in the targeted
regions, not just in the new build, to reduce the need for new
resource schemes, or increased use of existing water schemes.
In addition to increased demand, deployable
outputs will be reduced in some parts of the South East through
sustainability reductions invoked under the Habitats and Water
Framework Directives, unless proper provision is made for the
replacement of lost output. There are also threats to groundwater
yield from diffuse pollution. The combined reduction in output
may be as high as 3,000 Ml/d, or 16.6% of the amount of water
delivered daily in England and Wales.
There is no escaping that the growth areas of
the Sustainable Communities Plan have been assigned to those parts
of the country which are driest, have the greatest water demand
and are most vulnerable to the impacts of climate change in this
context. The imposition of ambitious water efficiency targets
on new developments in these areas may mitigate the problem, but
doesn't remove it, as the achievement is only a reduction in the
overall increase in total demand.
Water companies could quite conceivably supply
much greater volumes of water than they currently do in order
to head off any threats to security of supply. Across England
and Wales an average of 10% of the available resource is used
for water supply, although there are regions where this amount
is as high as 59% of the available resource. To increase supply
will involve additional cost not only to the water consumer, but
also to the environment, and requires a long planning period.
We would like to see more discussion of the
feasibility of introducing water reuse/greywater recycling in
certain developments, as well as on a larger scale in catchments.
Greywater recycling is now commonplace in certain parts of the
world, where greywater is treated to a standard below that required
for potable use and used for irrigation or toilet flushing. CIWEM
considers that more needs to be done to realise the benefits of
recapturing what is still largely a lost resource, whilst at the
same time recognising that there must be strict definition and
control of water reuse for the sake of public health. Returning
appropriately treated wastewater from treatment works located
near the tidal limit of rivers to upstream reaches of the same
river is also an idea whose time has surely arrived.
7. Is there sufficient effort being made
by the Government, the Environment Agency and the water companies
to educate people about water efficiency?
It is essential that the profile of water efficiency
in the community (domestic, business and leisure users) is understood
in terms of the value of the product, the environment in which
it exists and how to make best use of it. To this end CIWEM welcomes
the recent creation of "Waterwise", though we would
still like to see the creation of a government supported Water
Saving Trust which would have wider representation than the water
companies and therefore be better placed to co-ordinate messages
and actions on water efficiency.
Demand can be managed more effectively by making
individuals in society aware of the true value of water and the
opportunity costs associated with excessive or imprudent consumption
of those resources. Education and awareness might achieve substantial
reductions in demand from the average consumption of 150/litres
per day in England and Wales. More water efficient appliances
can help, as can the use of more drought tolerant plants and gardens.
In the end, though, it is creating the mindset that we need to
become "low water-using people" that will make the difference.
People should expect to be supplied with good,
wholesome water for essential needs (for drinking, cooking and
washing), whatever the weather; but they should not expect to
be able to draw water without restraint for non-essential uses,
like garden watering, when rivers, lakes and aquifers are prejudicially
low (or at risk of being so at some point in the future of a drought
event).
The pricing mechanism can encourage individuals
to be more prudent in their use of water resources. This would
require metering on a larger scale than the 26% penetration that
currently exists in England and Wales, allied to much more frequent
reading than is practice at present (which typically entails reading
of meters only at six monthly intervals) so as to enable tariffs
to be targeted appropriately to the task of saving water in areas
of shortage and in periods of shortage. Rising block tariffs and
seasonally varying tariffs can achieve these ends in circumstances
where individuals respond to the costs of the resource that they
consume. On the other side of the coin however, research shows
that those individuals living in metered households can take the
view that since they pay directly and pro-rata for the water they
consume, it should be made available to them in whatever volumes
they require. Thus metering can reduce the response of customer
to appeals for restraint by water companies.
The whole matter of metering and its potential
demand reduction benefits needs to be placed in the context of
(a) the cost of metering—which increases incrementally,
on a unit cost basis—and (b) the fact that the cost of water
and wastewater services in England and Wales amounts to something
in the order of only 2% of average household income. Pricing may
not be as effective an incentive to household water consumption
as it has been in industry, where the cost of water supplies and
wastewater treatment and discharge services can constitute a significant
part of the total operational cost of the enterprise. That said,
the requirement (under the 1999 Water Industry Act) that water
scarcity status must be declared before water companies are able
to compulsorily meter properties is a hindrance in enabling companies
to introduce economically-justified metering of high water-using
customers (noting that properties with swimming pools, and all
new properties, are already subject to compulsory metering). Socio-economic
needs must of course be considered, but perhaps as part of welfare
policy rather than water management policy.
CIWEM does not, therefore, consider that the
Government, Environment Agency or water companies are ignoring
the issue. However, all three could, and must do far more. Such
an effort should be on a united front endorsed by all three, rather
than each undertaking their own promotion/educational programmes.
A concerted national promotion would carry far more weight than
if one party only were to the message forward.
OTHER COMMENTS
Buried assets
CIWEM would like to see far greater consideration
of the way in which buried assets (eg pipe networks) are planned
and developed. Currently in the UK we employ a very expensive
way of supplying clean water and removing sewage, not to mention
gas and electricity, ie pipes and cables buried under the road.
Digging these up for repairs and new connections uses large amounts
of consumables and involves a large number of traffic movements
and disruption, often made worse through poor coordination of
works. Despite this there is no discussion of whether the situation
can be improved to deliver a better way of managing such services.
We consider that service provision should be thought about at
the earliest stages of design, but it is almost invariably only
added as an afterthought. Readily accessible service routes, preferably
within large service channels, with easily removable covers should
be required for new build sustainable housing.
Just as a gap in appreciation of water efficiency
has been identified, CIWEM considers that there is a lack of understanding
about the responsibilities of water supply to individual properties.
Water companies are generally responsible to the boundary of the
property—there are a number of exceptions but these tend
to be historic and complicated. For new developments, it would
be helpful if owners understood their responsibilities and for
building standards to ensure the choice of pipework is fit for
purpose. Increasingly there is a trend of local contamination
incidents occurring with petroleum type products permeating through
plastic pipes. Petrol can arise from owner/occupier activity or
vandalism activities. With the increasing number of vehicles around
and the use of plastic pipe, consideration should be given to
enhancing the pipework standards to materials such as "protectaline"
which has a metallic sleeve and prevents organic materials permeating
plastic.
November 2005
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