Conclusions and recommendations
1. We
have never disputed the need to address the problem of housing
affordability and we accept that this will inevitably result in
more new homes being built, but we are concerned that consideration
of the environmental impacts of these new communities ranks below
a significant number of other economic and social factors. (Paragraph
7)
2. We were interested
to see that ODPM has provided an explanation for what it means
by sustainable communities but we remain deeply concerned at the
very limited and superficial reference to the environment. For
example, we would have liked to see explicit reference to the
need for the homes within these communities to be built to high
environmental standards, including energy and water efficiency.
(Paragraph 11)
3. The resignation
of one of the key players on the Steering Group tasked with developing
the Code seemed to bode ill on the likelihood that critical consultation
responses would be given real consideration. While we welcome
the fact that ODPM has issued a press release saying that it will
strengthen the Code, and Yvette Cooper has written to us, bringing
this to our attention, ODPM still has a significant uphill battle
to regain credibility, for the Code, the consultation process
and itself. (Paragraph 17)
4. The fact that ODPM
judged that the question of whether or not to make increased levels
of energy and water efficiency compulsory, needed further assessment,
and so should be part of the consultation, is surprising. Given
the desperate need to off-set the impact of the proposed increased
numbers for new homes, the likely cost of energy in the immediate
future and the dire state of the water resources in the South
East of England, there can be no question that these should be
compulsory. (Paragraph 21)
5. We are pleased
to welcome, therefore, ODPM's latest decision to set minimum standards
of energy and water efficiency for every level of the Code but
we are anxious to know exactly what these standards will be and
when they will come into effect. ODPM must make these details
available at the earliest opportunity. This should include an
assessment of the cost and practicality implications of setting
minimum standards for each level, reflecting one of ODPM's original
concerns, as well as an assessment of the energy and water efficiency
savings attached to each standard. (Paragraph 22)
6. It remains unacceptable
to us that Level One of the new Code for Sustainable Homes is
not consistent with the BRE Ecohomes "Very Good" standard
and is, at best, little better than the existing Building Regulations.
This questions the value of the many months the Senior Steering
Group spent developing the Code and surely flies in the face of
the original intentions of the SBTG. (Paragraph 24)
7. we do think that
the Code for Sustainable Homes should require flood risk measures,
such as door gates, flood resistant under-floor vents and high
level electrical sockets, to be included as standard in all homes
built in areas where the Environment Agency has identified a reasonable
risk of flooding. (Paragraph 26)
8. We recommend ODPM
include a requirement for legal timber to be used in all buildings
at Level One. (Paragraph 27)
9. WWF has said that
all that is necessary to bring them back on board the Senior Steering
Group for the Code for Sustainable Homes is, "quite simply,
a statement that whatever results from the consultation period,
the final code will be demonstrably stronger and go further than
existing Government commitments". We believe that if ODPM
is to enjoy the confidence of the environmental world, consumers
and the construction industry then this must not simply be a statement
but a commitment that is delivered without further delay. We do
not believe that the measures announced by ODPM on 9 March represent
a significant step forward. (Paragraph 28)
10. we are so concerned
that, despite the so-called "strengthening" of the Code
for Sustainable Homes, it is still not adequate and we would urge
ODPM to take some time, properly to assess the consultation responses,
and to think very hard about some of the crucial elements missing
from the Code. As it stands it will still fall far short of what
is needed to ensure that future housing development is sustainable.
(Paragraph 29)
11. It is entirely
unsatisfactory that for those building in the private sector,
the Code is intended only as a voluntary measure. (Paragraph
30)
12. The reality must
surely be that the effectiveness of the levels and standards set
out in the Code become increasingly diminished if the Code itself
can be largely ignored by the Private Sector, the sector directly
responsible for the vast majority of new builds in England, because
it is voluntary. (Paragraph 31)
13. if the Government
regards the Code as a form of draft Building Regulations, as Ministers
have suggested, then ODPM must set out a clear timescale in which
Code standards will be adopted into Regulations. (Paragraph 33)
14. the whole basis
of the widespread scepticism with regard to compliance with a
voluntary Code is that there is little incentive for developers
to raise their standards and build to the Code. Time and again
we have been told that developers will do only what they are required
to do. (Paragraph 36)
15. We are concerned
that houses have already been built, and will continue to be built,
without sufficient regard to strong environmental standards.
Reliance on developers to gradually begin to "do the right
thing" we believe is misplaced and is symptomatic of a fundamental
lack of urgency in the Government's approach to ensuring that
new housing and new communities are truly sustainable. We do
not believe that this can be left to chance and we look to ODPM
to provide strong leadership, not only across government, but
in respect of developers and Local Authorities, who need greater
support and guidance to ensure that there is no delay in introducing
strong environmental standards. (Paragraph 36)
16. The experience
of Crest Nicholson and George Wimpey UK, who are regarded as "market
leaders", offers no support for the argument made by Ministers
that developers will want to follow the Code because it gives
them an advantage over their competition and a favourable selling
point with their customers. Not only this but it shows little
basis for Yvette Cooper's opinion that use of the Code will make
homes more desirable to buyers. (Paragraph 38)
17. one of the Home
Builders Federation's concerns about the Code for Sustainable
Homes is that it might, at some point in the future, become mandatory.
This does not promote any confidence in either the willingness
or the ability of most housing developers to adopt a voluntary
Code. (Paragraph 39)
18. We very much welcome
the fact that Defra seems to have engaged much more closely with
ODPM on some issues relating to the creation of sustainable communities,
such as the Sustainable Buildings Task Group. However, the fact
that the draft Code for Sustainable Homes is such a poor document
does lead us to question exactly how much influence Defra was
able to exert on the Code before it was put out for consultation.
(Paragraph 40)
19. It was disappointing
and frustrating to find that there had been no significant improvement
in either compliance or enforcement of the Building Regulations.
We call upon ODPM urgently to review the resources and methods
of enforcement in order to ensure greater compliance. (Paragraph
41)
20. We do not believe
that the fear that developers will find the Code too difficult,
and so not comply with it on a voluntary basis, is any reason
not to make it mandatory, in fact quite the opposite. It would
surely suggest simply that time is being wasted in taking the
voluntary approach. (Paragraph 43)
21. We cannot stress
how important it is to get it right with regard to the existing
housing stock. The number of new homes built each year is dwarfed
by the numbers of existing housing stock in excess of 20 million
homes. The Government is missing a huge opportunity to reduce
the carbon emissions from those homes if it fails to grasp the
nettle now and extend Part L of the Building Regulations to include
the existing housing stock. (Paragraph 44)
22. Whilst we accept
that the German programme to bring its pre-1978 housing stock
up to contemporary energy standards is "extremely ambitious",
as Elliot Morley points out in his supplementary evidence to us,
we believe that this represents the kind of ambitious, strategic
thinking and planning that is so badly needed in the UK but which
is so sadly lacking. (Paragraph 44)
23. Despite our disappointment
at the limitations to the revisions made to Part L of the Building
Regulations, we applaud ODPM's decision to force early compliance
with them and see this move as evidence that ODPM can react with
a sense of urgency on occasion. By acknowledging that the impact
of climate change takes precedence over long lead-in times to
allow the building industry to get its house in order, we believe
this also sets the precedent for ODPM to move much more quickly,
not only to strengthen the Code for Sustainable Homes, but to
apply equally tight timescales for compliance with it. (Paragraph
45)
24. When we launched
this inquiry we asked whether the Government should be introducing
fiscal measures to reward higher building quality and greater
environmental performance. The overwhelming response to that
question was yes. (Paragraph 50)
25. We believe that
a vicious circle currently operates in the property market. Not
only are there currently no incentives for home buyers to want
to buy properties built to high environmental standards, but there
are also no incentives to encourage developers to build them.
Trying to address this problem through voluntary codes or publicity
campaigns alone is simply not enough. Fiscal measures which offer
either real savings or significant penalties have to be introduced.
(Paragraph 55)
26. We recommend that
HM Treasury should consider reducing both Stamp Duty and Council
Tax for those homes built to high environmental standards. Any
necessary consultation process these proposed reductions might
prompt should be completed in advance of the 2007 Spending Review
so that cross-Government discussions can be better informed. (Paragraph
59)
27. we recommend that
HM Treasury revises the current VAT rules concerning both new
build and refurbished homes built to high environmental standards.
Once again, any consultation process should be completed in advance
of the 2007 Spending Review so that cross-Government discussions
can be better informed. (Paragraph 61)
28. We recommend that
HM Treasury should examine the scope for a reduction of the rate
of Planning Gain Supplement to be offered to developers who build
homes to high environmental standards. This work should be done
in advance of the 2007 Spending Review so that cross-Government
discussions can be better informed. (Paragraph 62)
29. We find the Treasury's
desire to be "proportionate" and its reluctance to impose
"a high administrative burden on Government agencies",
not only strategically short-sighted but woefully inadequate.
It would also appear to contradict the Prime Minister's views
on tackling climate change. (Paragraph 64)
30. The German approach
to fiscal incentives contrasts sharply with the lacklustre way
in which ODPM, Defra and the Treasury have responded to the question
of fiscal incentives, which not only speaks volumes about the
real level of importance and commitment afforded to this issue,
but also paints a very depressing picture of complacency and apathy
which we believe is all too evident in these departments. (Paragraph
66)
31. if it is the case
that the Treasury has the final decision on whether or not any
fiscal incentives should be introduced, then the response of the
Treasury to this inquiry, suggests to us that any roundtable discussions
that do take place are very unlikely to result in even a commitment
to consider seriously the suggestions we, and many others have
set out. We can only hope that the conclusions of the Stern Review,
when published, will result in a much needed change of attitude.
(Paragraph 67)
32. We consider that
with only ten years left before the Government's own deadline
of 200,000 new homes per year by 2016, to delay discussing how
to fund the infrastructure for much of that development until
the Comprehensive Spending review in 2007 represents a massive
planning failure. (Paragraph 70)
33. Given the Government's
intention to build 200,000 new homes per year by 2016, and the
often very long lead-in times needed for any significant infrastructure
to be completed, there would seem to be a fundamental problem
with relying too heavily on the Planning Gain Supplement as a
method of funding. (Paragraph 71)
34. The answer to
the problem of homelessness, overcrowding or indeed, helping people
get their feet on the first rung of the housing ladder, is not
to throw up badly constructed houses in areas which are poorly
supported by essential infrastructure. To do so would be ignoring
the Government's own definition of sustainable communities as
"places where people want to live and work, now and in the
future". (Paragraph 72)
35. We remain deeply
concerned that ODPM is determined to build new homes first and
then worry later, if at all, about how the supporting infrastructure
can be provided. The communities that are created as a result
of such a short-sighted policy will be anything but sustainable.
(Paragraph 73)
36. We do not believe
that there is a cure-all solution to the water supply issues in
the South East and if existing, as well as new, homes are to enjoy
a secure water supply, and if the regions rivers and water courses
are not to be decimated by the increased demand, then much rests
on the water companies ability to meet that demand, reduce the
amount of water lost through leakage, and raise awareness of the
water efficiency measures people can adopt at home. (Paragraph
82)
37. However, the fact
that the Environment Agency is now warning that standpipes and
rota cuts may be necessary this summer, creating a real risk that
water customers will have their access to water rationed in some
way, would seem to suggest that current water company plans are
in danger of failing. As climate change bites in the South East
we can expect to see these weather patterns repeated more frequently
and we cannot help but be deeply worried about the South East's
ability to cope with the increased water demands as a result of
the Government's intention to build 200,00 new homes per year
by 2016. (Paragraph 84)
38. Thames Water have
told us that from start to finish a new reservoir would take 20
years to plan, develop and then build. This presents a fundamental
difficulty given that Thames is responsible for a significant
proportion of the water which will have to be supplied to many
of the new communities planned for the four Growth Areas. If ODPM
remains wedded to the target of building 200,000 new homes per
year by 2016 then it seems clear to us that some of the necessary
water infrastructure will not be ready in time. (Paragraph 86)
39. If Folkestone
and Dover water company can make a successful application for
"water scarcity status" on the basis of concerns about
meeting demand over the next ten years, then most of the water
companies in the South East of England can, and will, make similar
cases. Whilst this is not an issue for those buying new homes
in the four Growth Areas, as their homes will have meters anyway,
it will certainly impact on existing residents in those regions
who will have water meters imposed on them. We are certain that
this possibility will not have occurred to many living in these
regions and ODPM and Defra will need to work quickly to address
the many questions people will have. (Paragraph 90)
40. people suffering
from serious difficulty in paying their bills should be helped
through the benefits and tax credit system. we welcome Elliot
Morley's commitment to "pay particular attention to the sensitive
introduction of meters to households and to the effects on customer
bills, especially of those least able to pay." (Paragraph
91)
41. The fact that
so much water is still being lost through leakage is also unacceptable.
Whilst we accept that water companies are working to reduce leakages,
and we acknowledge that some of our water infrastructure is old,
it is clear that unless real progress is made in dealing with
the unacceptable levels of water lost through leakage, it is going
to be very difficult to justify imposing restrictions on use,
or introducing compulsory water meters. (Paragraph 92)
42. Whilst loss of
water through leakages continues at unacceptable levels it is
going to be very difficult to convince consumers that the water
companies are doing their part in saving water. (Paragraph 92)
43. there is little
doubt that if we are to address seriously the rising trend in
the demand for water, a number of the options available to us
represent a significant challenge and will only be achieved as
the result of major behavioural change. We support the Environment
Agency's "twin track approach" to balancing the social,
environmental and economic needs of housing growth. (Paragraph
93)
44. Despite the media
coverage of the current and prolonged drought in the South and
South East of England, despite the pictures of half full reservoirs,
and despite the increasing awareness of the impact of climate
change on the South and South East of England, public awareness
of the extent to which individual households are both part of
the problem, and the solution, is very poor. (Paragraph 94)
45. the fact that
Folkestone and Dover Water have won the right to impose compulsory
water meters on its customers will certainly concentrate the minds
of consumers and raise awareness of the issues around water supply
and the possibility that other areas of the country may yet have
to have compulsory water meters too. This growing awareness must
be exploited by Defra to really raise the profile of water supply
issues. (Paragraph 95)
46. once existing
consumers in the South and South East of England begin to realise
just how dire the current situation is, how much climate change
is going to impact on their daily lives in the future, and that
the Government's continued commitment to build 200,000 new homes
per year by 2016 will only exacerbate the problem, the Government
is going to have to work very hard to win over public opinion
(Paragraph 96)
47. The Water Savings
Group is still in its infancy and has much ground to cover in
what we suggest should be a very short time. Given the urgent
need for action with regard to water supply and demand management,
we expect to see evidence of positive and early action emerging
from the Group. (Paragraph 97)
48. The need to build
new homes is seen as an absolute imperative and is used by the
Government as a mandate to sweep aside any concerns that people
may have about the environmental impacts of those plans. We find
it deeply worrying that there is no appetite within ODPM to take
on the building sector and guarantee that these homes will be
built to sufficiently high energy efficiency and environmental
standards. What we find reprehensible is the clear signal from
Government that it really does not matter that these homes are
going to be built before supporting infrastructure is in place.
And we reject the implication that the people for whom these
new communities are intended will be so grateful to have a home
that they will be prepared to put up with substandard communities
rather than sustainable communities. (Paragraph 98)
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