Memorandum submitted by Bedfordshire Councils
Planning Consortium
INQUIRY ISSUES
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?
I do not believe that a step change in the building
industry providing energy efficient, well-designed dwellings,
which have a minimal impact on the local environment, can be achieved
under a voluntary code. A statutory document or code of practice
is required. The house building industry will only provide dwellings
to suit market forces and will always look to maximise profits
and sales. This results in the industry always looking to provide
dwellings at the cheapest possible cost but to sell at the maximum
possible price. The base line cost will obviously depend on many
factors, land prices, labour and material costs and anticipated
returns on investment. The selling price will generally depend
on the style of dwelling, size, the attractiveness and desirability
of the area and the maximisation of profit margin. Therefore the
quality of dwellings will always be in jeopardy in any voluntary
code. As will the use of brownfield land, as the purchaser of
the land has a duty to rectify (and pay) for any clean up operations.
This government's heavy application of landfill taxation has also
exacerbated this problem.
There is considerable pressure on developers
to produce the funding from section 106 agreements to pay for
schools, affordable houses, transport, green infrastructure etc.
Unless there is a statutory code for energy-efficient buildings,
sustainable building will be offered as one of the items on shopping
list that a local authority or Local Delivery Vehicle can demand
from the developer. Affordable Housing can have a large impact
on this. The issue of how much of the affordable housing is paid
for by the housing corporation and how much is paid for by the
section 106 agreements is unresolved, and is difficult to discover.
As far as I am aware the planning authorities have show that they
have negotiated with the developers before they can go to the
housing corporation. It is only if there is not enough money to
deal with the infrastructure needs and the affordable housing
that the housing corporation will contribute. If the section 106
agreement has to pay for the affordable housing it can seriously
lessen the amount of money for items such as sustainable housing.
Considering that many authorities believe that there is an infrastructure
deficit it is likely that money from section 106 will be put towards
remedying existing deficits rather than sustainable building standards.
A voluntary Code relies upon the attitude of
the local councillors which might be good or might be very poor.
There is not sufficient marketing and publicity to explain to
new house buyers how much money will be saved in bills from sustainable
housing and the contribution that it makes towards climate change.
As a result of this developers and councillors are able to say
that there is not the market demand and as a result they would
have to raise the house price and no one would buy them.
There is a huge difference between the standards
of local councils as regard sustainable housing. In South Bedfordshire
District Council, which has to build 26,000 new homes by 2021
as part of the MKSM growth area there is no insistence on Eco
Home standards. In response to a question from South Bedfordshire
Friends of the Earth to a full District Council meeting in October,
as to whether the council would insist on Eco-Homes "very
good" Standards for all new development, Cllr Nicols answered
in the negative, saying that "the council was not in a position
to force the achievement of higher standards through the planning
system as this was a national policy matter and needed to be addressed
primarily through building regulation changes." However,
English partnerships which are operating in Milton Keynes have
a policy that all the new build under their direction, both as
the landowners and as planners, has to be Eco Homes, "Very
Good" and they are also asking for and agreeing that 10%
of the new build should be "Eco-Homes Excellent".
There are serious concerns that many new houses
do not meet the standards of the existing building regulations.
Indeed according to an article in The Guardian 18 September
2005 The Building Research Establishment in Watford says that
60% of new buildings do not conform to the existing building regulations.
Councils do not have the resources to police the regulations.
If the existing statutory code is not followed it gives little
hope for a voluntary code. It is therefore essential that legislation
is in place to force constructors to include energy efficiency
and minimising impact on the environment in their house building.
We are concerned that a new code is being considered,
rather than using the BREAM standards of eco- homes "very
good "and "excellent". We believe that these standards
are the minimum and we believe that the standard required for
the present environmental challenges is the new standard of Z-squared
which has been developed by the World Wildlife Fund with BedZed.
Z-squared is a carbon neutral standard which
is based upon the development in by BedZed in Wallington South
London. There are plans for 2,000 new homes to be built to this
standard in the Thames Gateway. The Z-squared standard could achieve
a 99% reduction in CO2 emissions, 65% reduction in water use.
And a 76% reduction in household waste sent to landfill and of
course enormous savings in bills to the homeowner. There is no
point in building affordable houses if they are unaffordable to
live in. Considering not only the challenges of climate change
but also the rising costs of water and energy for house-owners,
it seems extraordinary that the Sustainable Communities Plan does
not insist upon this standard throughout. The Housing Corporation
is insisting that all their new build is now "eco homes very
good". Why cannot these standards be applied to developers?
Consideration also needs to be given to how
the governments target for 60% of development to be built on "brownfield"
land can be achieved thereby ring fencing the 40% target for Greenfield.
At present the ratio is fairly arbitrary as to its effectiveness
and is left purely to the Planning Authorities to attempt to achieve.
The result is that the target is applied nationally rather than
to each individual Planning Authority area and the thrust appears
to be that it matters not where the target is achieved, as long
as nationwide it is achieved. This is not a sustainable philosophy,
as it will ensure that in the areas with limited Greenfield availability,
more will be developed on that Greenfield land to the detriment
of that locality. The target must be applied locally and each
individual locality must be legislated to achieve the ration.
The expression 60% brownfield first and then 40% Greenfield to
follow should be considered. If these targets cannot be met then
it should be mandatory that development allocations should be
scaled back proportionally. We are concerned that research done
by George Krutcher of South Bedfordshire District Council, which
was laid before the MKSM EIP shows that due to the existing situation
and ratio of brownfield/greenfield only 26% of the new build can
physically be on brownfield which goes completely against the
governments targets. We have sent in a copy of this evidence.
3. Should the Government be introducing
fiscal measures to reward higher building quality and greater
environmental performance?
Yes, as without some incentive to the construction
industry "more of the same" will always be built for
the reasons as in item number 1. There is an urgency and a need
to make emissions taxable. If the government is to fulfil its
Kyoto targets it has to seriously consider the impacts of household
emissions and their construction. According to the Environment
agency the energy used in constructing, occupying and operating
buildings represents approximately 50% of greenhouse gas emissions
in the UK. Construction and demolition waste alone represent 19%
of total UK waste. The environmental efficiency of buildings in
the UK remains lower than in many other European countries. An
increase in the number of single person households, together with
rising domestic waste production and water consumption, means
that increases in environmental efficiency are needed just to
limit the impact of existing buildings. Also the money that is
released from spending on household bills will benefit other parts
of the economy. Also it is a chance for the UK to develop the
expertise and skill base in this area, which will, in the near
future be in demand across the world economy.
Tony Blair stated in a speech to "the 10th
anniversary of the Prince of Wales's business and the environment
programme in September 2004" that "Just as British Know
how brought the railways and mass production to the world so British
scientists, innovators and business people can lead the world
in ways to grow and develop sustainably" If there was an
established code of Z squared for all new building then it could
provide a huge boost to the "green industries" and thereby
the whole economy. Therefore fiscal measures should be brought
in order to reward higher building quality.
There are fiscal measures which should be changed.
VAT is still charged on converting existing buildings into smaller
dwellings, whereas it is not charged on new building. It is far
more sustainable considering the increase in single person households
to increase the number of conversions and improvements, particularly
than to build from new. This also gives more space for more dwellings
in town centres rather than on the outside of towns.
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?
The ODPM five-year plan only pays "lip
service" to it for the reasons as follows
B4.1 The overall scale of house
building required.
Is it essential to build new housing
while promoting sustainable development?
There is currently an empty housing
stock of some 900,000 houses in the UK. The utilisation of this
asset would decrease the requirement for new development, promote
urban regeneration and utilise already existing infrastructure.
Infrastructure would need to be expanded to cope, but would be
far less financially demanding on public resources than creating
new infrastructure for new development. Initiatives of urban regeneration
have been proved to be successful in the past creating sustainable
evolving communities in urban areas and decreasing "slum
areas". Consideration should be given to either removing
VAT on refurbishment of housing stock and/or the introduction
of VAT on to new house building. This would have the effect of
equalising the provision and make it more attractive for landlords
to bring housing stock back into the market place for either sale
or rent. Although we support the New Empty Dwelling Management
orders referred to in paragraph 5.30 of Homes For All we
believe that the government should be doing much more in order
to bring empty homes back into occupation.
B4.2 The proposals are unlikely
to significantly reduce house prices
House prices nation-wide only generally
fall in times of recession. In certain specific areas prices may
fall when that type of property becomes undesirable due other
opportunities of new development thus creating slum areas. House
prices in the southeast, even during the eighties, did not fall
to the extent of negative equity as experienced by other areas
in the UK. We live in a market driven economy, house prices in
the SE and surrounding areas will reflect comparables and land
prices and will continue to rise at a higher rate than the rest
of the UK, and this is where the majority of the proposed new
development will be. We are currently in a situation in the SE
whereby local people and those on salaries of less than £40,000
p.a. cannot afford to live in the towns and villages they consider
"home" or even within a reasonable travelling radius
of their work environment. The median wage in South Bedfordshire
is £21,575 (National Office of Statistics) and average house
prices in the area are currently £109k for a flat, £148k
for a terraced home and £174K for a semi-detached house (reference
BBC News Online December 2004).
Will the new housing actually answer
the demand?
According to Homes for All,
the ODPM's Five Year Plan published in January 2005, a main reason
for the need for increased dwellings is the rise in single occupancy.
On page 15, paragraph 2.5 states that: "Over one million
more households were formed between 1996 and 2003, an increase
of more than 5% compared with a population rise of just 2%".
Homes for All predicts that
this trend will continue and that by 2021 "the total number
of households is expected to increase from 21 to 24 million—almost
190,000 new households each year."
Significantly firm policy statements
are lacking on the type of accommodation which is built. Homes
for All talks of meeting the assessed needs for affordable
housing, but there is nothing to show that developers will be
building single occupancy homes, which, according to ODPM is where
the demand is, rather than three, four and five bedroom executive
homes, for those who can afford to buy on the open market.
Indeed the Sustainable Communities
Plan states that "too many large homes are being built, when
the demand is mainly for small households. In recent years more
than one in three homes built in the SE have been larger four
bedroom houses." (page 9)
A response to the growth in single
person households would be to encourage conversions of existing
buildings as this would use up less energy, create less carbon
emissions and use less land. However VAT on conversions makes
it more expensive for a developer to convert than to build from
scratch
It is far from clear that new house
building on the scale planned, and without clear sense of the
type of dwellings to be built, will deal with the real housing
need, which we regard as meeting the needs of people on existing
waiting lists and those with the genuine need for affordable housing.
On 30 October 2005 The Observer
newspaper reported back on promises by Gordon Brown in May to
The Observer that shared ownership would help huge numbers
onto the housing ladder. The article reporting that the shared
ownership scheme "will take a year to start operating and
aims to help only 20,000 purchases a year nationwide."
The same Observer article also
examines the affordability of the shared ownership scheme. In
a shared ownership scheme for one person flats in south London,
the combined mortgage and rent amounts to £625 per month,
an amount which is out of many people's reach. (Ref: Gareth Rubin,
The Observer, 30/10/05)
Will the Government be able to afford
to build enough social housing for those who cannot afford to
be on the schemes for home ownership, yet whose jobs are vital
for a functioning economy?
There are certain problems with the
supply of affordable social housing that are only hinted at in
these documents but which should be in the forefront of the debate.
The 1980s Right to buy initiative has helped many people; it has
also depleted stocks of social housing. Indeed paragraph 1.22
of Homes for All states that the right to buy is "expensive
for the Taxpayer" and that "since 1980 we have lost
1.7 million council homes and 100,000 housing association homes."
Further, in a speech on affordable
rural housing and available on ODPM's website, Keith Hill MP,
the former ODPM Minister, said: "The Right to Buy has helped
boost homeownership, which we think desirable, but it has meant
the loss of 1.8 million homes from the public sector at an estimated
cost of £40 billion in discounts."
This situation has added to the difficulty
faced by people on the housing waiting lists seeking accommodation.
The scheme is still continuing although it is now part of the
Home-Buyer scheme. The result is that although many people will
be helped into home ownership, it will be very difficult to achieve
a net increase in the social housing stock in the region. Indeed
there could be a net fall in the amount of social housing.
Paragraph 1.15 of Homes for All
states that this means that, "despite massive increases
in investment since 1997, the number of new affordable homes being
built is below that of the mid 1990s". Paragraph 2.11 adds
that "More new social homes are now being built, but sales
of local authority and housing association properties mean the
total stock of social housing is still falling".
B4.4 The geographical distribution
of new housing, including plans to concentrate development in
the South East in four growth areas, Milton Keynes, the Cambridge/Stansted
corridor, Ashford and the Thames Gateway.
The main area of concern we have with
regard to the areas targeted is the lack of infrastructure/ the
inability of the current infrastructure to cope with demand. New
development will create a need for new infrastructure, which will
take up large areas of greenfield. If infrastructure is not in
place prior to housing the current facilities will become even
more overloaded, the transport routes could experience gridlock
syndrome and schools and hospitals will not be able to accommodate
demand.
Transport routes East to West ie Milton
Keynes to Stansted are already unable to cope with the demands
placed upon them.
Unemployment is currently very low
and this is encouraging commuting, not a sustainable practice!
Areas proposed for development are
in a very small overall geographical region, where new development
is initiated along main transport routes (while awaiting new infrastructure)
ribbon development will occur causing coalescence of the whole
region. Urban sprawl over the south east of England.
All the growth areas proposed are "commuter
belt" areas for London and will encourage transport/travel
into and out of the city thus increasing the already seriously
overloaded transport infrastructure.
B4.5 Whether the proposals will
promote high quality sustainable communities whilst avoiding poorly
designed urban sprawl.
This will depend totally on the planning
permitted, timescales allocated, infrastructure available and
methodology of development.
Initial new development trends towards
existing infrastructure, this will create ribbon development as
opposed to new communities. As land is generally at a premium
along these routes they will be financially prohibitive to the
lower financial classes and very acceptable to commuters. Commuting
is not the basis of sustainable development and does not encourage
"community" development. If areas are developed piecemeal
by different developers with no overall area development plan
then where is the community?
In the interests of sustainable development,
are subways and cycle paths to be a requirement for development?
If they are then land usage will be more extensive resulting in
higher house prices to compensate developers for the cost of land.
B4.6 The balance of new development
between housing for sale and social housing.
The concept of social housing is one
that everyone approves of but when does social housing loose its
meaning? When the cost is not affordable to the people it is meant
for. All new development over a certain size has to provide a
proportion of social housing, but the cost of that housing is
comparable to the price of housing stock in the rest of the development
which includes the balance build out cost for the property developers'
profit margin. In the South East cheaper does not mean affordable.
If social housing is initially released
at "affordable prices" it could have the effect of corralling
residents as they will be unable economically to move further
up the property ladder, therefore not releasing the social housing
thus creating the demand for more social housing. An upward spiral
effect of demand for social housing is then being created. One
possible solution to this would be a tiered system of social housing
with price structures and grant aid designated by Government according
to demand and cost in individual areas.
Regeneration of existing housing stock
in existing urban areas could be economically more viable for
social housing needs. It would also be more acceptable for those
requiring the housing as amenities such as schools and doctors
already exist and the need for transport is less.
B4.7 The extent to which decisions
relating to housing, including numbers, tenure and density should
be taken by central and local Government.
Local government decisions regarding
development are based wherever possible on an understanding and
knowledge of demand as opposed to a perception or generalised
statistical need as seen by central government. From this point
it would seem appropriate for information from local government,
who recognise requirement, know what housing stock is available
and understand the type of housing needed, to be the basis for
development.
Local Government decision-making with
regard to development would reduce the problems of planning applications,
as they would be giving local people what they want and need.
Large businesses do not budget from
the top down; they ask individual departments to send their budgets
up to be analysed and discussed, a proven business principle.
B4.8 Impacts upon the environment
overall.
Our present lifestyle in the UK is
having a considerable negative impact upon our environment both
locally and globally, yet the urgent need for large scale change
in our lifestyle, although seemingly recognised by some parts
of government, does not seem to be recognised by the SCP.
Tony Blair said in March 2005 "Climate
Change represents a potentially catastrophic threat, but it is
within our control to address it—and address it we must".
Around this time the new UK Strategy for Sustainable Development,
Securing the Future was published. This is much stronger than
the 1999 Strategy and embodies the principle of "living within
environmental limits". Around the same time PPS1 was published
which states in paragraph 13 (i) "Development Plans should
ensure that sustainable development is pursued in an integrated
manner, in line with the principles for Sustainable Development
set out in the UK Strategy".
However the "Sustainable Communities
Plan" does not seem to follow these principles and aims and
we are concerned that the ODPM does not recognise the significance
and implications of the principles of Sustainable Development.
This was particularly clear in the "overview" of "Sustainable
Communities, Building for the Future, 2003" which defined
sustainable communities in the following seven points:
1. Accelerating the provision
of housing.
3. Tackling homelessness.
4. Low demand and abandonment.
7. Protecting the Countryside.
However these points were very different
from the four aims of the 1999 UK Strategy for Sustainable Development
which were:
1. Social progress which recognises
the needs of everybody.
2. Effective protection of
the environment.
3. Prudent use of natural resources.
4. The maintenance of high
and stable levels of economic growth and employment.
There is a complete difference of approach
and underlying aims between the definition of Sustainable Communities
and that of Sustainable Development. One is seriously concerned
with the local, national and global environment, the other is
concerned with decent homes and creating places where people want
to live. This becomes much more marked with the publication of
PPS1 and the new UK Strategy for Sustainable Development, Securing
the Future.
The new document "Homes for All"
shows that ODPM is now aware that there are serious issues concerning
sustainable development. In appendix 1 it states that "Sustainable
Communities embody the principles of Sustainable Development .
. . Meet the needs of existing and future generations". However
it continues to describe sustainable communities in eight sections
talking about the needs of the community. In these eight sections
that fill over two sides of A4, the stress is not on "living
within environmental limits", but on "minimising climate
change", and on promoting a lifestyle that "minimises
negative environmental limits".
"Minimising climate change"
and being "environmentally sensitive" is not the same
as showing a commitment to the Kyoto protocol and the government
target, deemed very necessary by many scientists, of cutting CO2
emissions by 60% by 2050 .
THE IMPACT
OF INCREASED
HOUSE BUILDING
ON THE
ENVIRONMENT AS
REGARDS BIODIVERSITY
The SCP could have a considerable negative effect
upon biodiversity in the region. This is an area where "Homes
for All" says very little about biodiversity. In Appendix
one it mentions "protect and improve wildlife habitats"
Otherwise it talks merely about "greener communities"
in chapter 8 these phrases give a totally false impression of
the base line conditions.
This does not reflect the seriousness of the
existing threat to our biodiversity nor any indication of the
pressures that it might be placed under if development of this
scale goes ahead. Since the 1970s there has been a considerable
decline in biodiversity. Farmland birds have declined by 60% since
1970. Some common bird species have declined in numbers by 80%
since 1970 and according to the RSPB, a third of the UK's most
important habitats and a quarter of our most threatened species
are still declining. In other words our children today can enjoy
significantly less wildlife than those of us who were children
in the 1970s. Indeed such is the problems that the aims of the
government are not to massively increase biodiversity but merely
to try to reverse and to halt the decline. This is shown by Government's
Public Service Agreement target reverse the decline in farmland
birds by 2010.
There is no acknowledgement in Sustainable Communities
of the impacts of large scale development on biodiversity. This
is mirrored by the latest ruling against the UK from the European
Court. The European Habitats Directive 1992 is a very important
piece of legislation. The introduction to the habitats directive
states that "natural habitats are continuing to deteriorate
and an increasing number of wild species are seriously threatened."
And as a result measures have to be taken to protect Special areas
of Conservation and protected species. The new ruling from the
European court on the Habitats Directive says that in many ways
the UK government is not properly implementing this vital piece
of legislation. In particular they refer to the effects of water
abstraction and land use planning. The ruling on land use planning
is very significant. The Habitats Directive in article 6 requires
that the indirect implications off development nearby on the protected
site are seriously considered. The scale of development in certain
regions in the SE is such that it will cause light disturbance,
noise disturbance, habitat fragmentation and many other indirect
effects upon protected sites.
Regional Planning Statements are not site specific
and therefore although they now have to do a Strategic environmental
assessment, they do not look at the effects on individual Strategic
Areas of Conservation of which there are several in the East of
England Region and the South East. However the European court
has ruled that this attitude cannot continue. In paragraph 56
of the judgement it says "It thus follows from the foregoing
that, as a result of the failure to make land use plans subject
to appropriate assessment of their implications for SACs, Article
6(3) and (4) of the Habitats Directive has not been transposed
sufficiently clearly and precisely into United Kingdom law."
There are considerable concerns about protected
species, such as bats. There has been such decline in these species
that there is considerable protection in the Habitats Directive.
In Article 12 section 1 D of the Habitats Directive it states
that the "deterioration" of roosts or breeding gounds
is prohibited. The Conservation (habitats etc) Regulations 1994
have made it a criminal offence to remove or destroy a bat roost
but they do not mention the idea of deterioration. You can leave
the tree with bats roosting in it. However if you concrete over
the semi wild habitat upon which the bats in the roost are feeding
from and create noise and light pollution which will disturb the
bats, then you are causing the deterioration of the roost and
you are harming the population levels of this protected species.
The scale of building in the SE is such that unless there is a
step change in attitude there will not be enough semi wild habitat
left to support the existing bat population.
It is important to stress the role that farming
has had in destroying semi wild habitats. Indeed farming can often
be far more of a culprit than new housing development. Housing,
if designed with biodiversity at the heart of land use could create
habitats within the rural area and create enough semi wild areas
to support and enhance biodiversity. Indeed the TCPA guide Biodiversity
by Design points to how this could be done to the benefit of all.
However there is no leadership on this and it is unlikely that
any planning authorities will put this at the heart of there plans.
Green infrastructure is very nice for people and indeed it is
one of the pleasanter aspects of the plan. However green infrastructure
is not the same as adequate protection of the environment as regards
biodiversity.
1. To what extent does the Five Year Plan
address the environmental implications of the geographical distribution
of demolition versus new build?
It does nothing to address these issues. We
have seen only recently the ODPM's thrust to demolish perfectly
adequate dwellings in the Midlands and North of the Country (that
is following some refurbishment) and yet target even more growth
in the south of the Country. How is this sustainable? It encourages
migration to the South at the expense of future growth in the
Midlands and North and further exacerbates land shortages and
development pressures in the south. It must make sustainable sense
to spend approximately £25,000 renovating existing dwellings
for use rather than to spend £2,000 demolishing them and
then spending £130,000 building new ones. Total cost for
a single dwelling provision of £132,000.
It is indeed interesting at the same time as
the government supporting the importance of the growth areas,
"Our cities are back." Report for ODPM 2004 has been
produced of which the sub title is "Competitive Cities make
Prosperous Regions and Sustainable Communities." It explains
as the economic background that "Over the past decade competitiveness
in the world economy has undergone massive changes. Advanced economies
like Britain have focused increasingly on high value knowledge
based services and products." It goes on to say that cities
are key to supporting the knowledge based economies that are so
vital for the overall future of the economy of the UK.
It heralds Manchester as a huge success story
as it had an inner city population of 1,000 in 1991 and now has
a population of 15,000. If the government is so keen to support
the regeneration of cities across the UK, is it not questioning
the economic importance of the development in the growth areas.
D. INFRASTRUCTURE
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?
D7.1 transport investment priorities
It is recognised that the serious current shortfall
in infrastructure provision needs to be addressed, but there are
no statements or proposals on how this is to be achieved or where
the funding is coming from and in what quantity. Only vague references
have been made to a required increase in funding provision that
is necessary to meet both the current deficit and future needs
generated by the development targets. There do not appear to be
any policies relating to transport and is seriously lacking in
substance.
D7.2 It is recognised that if the scale
of developments envisaged are allowed to proceed then significant
and extensive infrastructure of all types is required to be provided,
but so far there has been no attempt to calculate or define where
the funding and infrastructure provision is coming from. This
is a major flaw in the various documents, reports and proposal
and needs rectification.
Note: quote from the House of Commons
Environmental Audit Committee report into the Sustainable Communities
Plan—"Lord Rooker's statement that there would be no
growth without infrastructure was welcome. However, if this is
so then the Government needs to make it clear how it intends to
ensure timely development of infrastructure to keep pace with
housing construction. This does not yet appear to be happening"
D7.3 There have been ODPMs suggests that
infrastructure costs can be "clawed back" through Section
106 and other Planning agreements. Infrastructure costs of this
magnitude could never be "clawed back" in sufficient
quantity by Section 106 agreements or Planning gains and our history
of ensuring that Section 106 agreements are signed up an implemented
is woeful.
Also suggested that existing local residents
will fund infrastructure through bonds and then local taxes -
why should they- why should existing residents fund the infrastructure
provision being installed for the benefit of new residents and
businesses moving into the area?
D7.4 It appears that sums of money indicated
as available for infrastructure funding will not be anything like
sufficient to meet the requirement generated by growth in the
various regions. The Government must address this issue as a matter
of urgency and make clear exactly what level of public funding
for infrastructure it intends to make available in the region
between 2001 and 2021. It needs to demonstrate to the residents
of the regions that this level of funding is adequate and will
be forthcoming in advance of any development. In this regard we
believe that Lord Rooker's statement that there would be no growth
without infrastructure is a positive step forward, however, if
this is to be so then the plan needs to make it clear how it intends
to ensure timely development of infrastructure to keep pace with
housing construction. The RTS plans for roadbuilding in the East
of England are costed at over £3 billion over the next ten
years, however there is only £1 billion allocated.
SUSTAINABLE BUILDINGS
AND TRANSPORT
IN THE
WIDER CONTEXT
The Eco Homes standards have a wide remit. They
are not solely about energy efficiency. They are about access
to public transport and other issues. We believe that this wider
context should be supported and enhanced. There are signs the
wider implications of transport and land use on sustainability
are being realised but are not being fully understood. The government
is bringing in Accessibility planning which begins to look at
the problems. However the basic problem is much wider. First people
commute further to work than they used to. The MKSM strategy only
allows for 12,000 new jobs in South Bedfordshire against 26,000
new homes by 2021. This is not following the principle of reducing
the need to travel. This disparity does continue around Bedfordshire.
In the SE 41% of all trips by car are leisure
trips or shopping trips according to the Sustainable development
commission's report for the IPPR on "Keeping the SE moving".
These trips have a considerable effect upon the sustainability
of the new build. Although the rise of out of town supermarkets
has not been supported by direct government policies, indirect
policies and unchecked trends have supported the demise of town
centres. The problem with sustainable urban extensions is that
they are often planned beside a new bypass. This is the case with
the following proposed roads Luton Northern Bypass, the Dunstable
northern bypass, the Harlow northern bypass, the Norwich Northern
Distributor road, etc. It can be much easier for the resident
of the "sustainable urban extension" to drive along
a new bypass than to deal with the congestion of the town centre.
Parking in out of town retail parks is free, compared with the
high prices of town centre car parks. There is often considerable
congestion surrounding the town centre. The sustainable urban
extension will add to the congestion but can easily make it worse
without adding trade to the town centre and so can help to destroy
the town centre. Like biodiversity town centres are in decline
and the decline needs to be reversed and acknowledged and planned
for in the Sustainable Communities Plan. According to the New
Economics Foundation between 1997 and 2002, specialised stores
closed down at the rate of 50 per week in the UK. In 1995 there
were 230,000 banks, post offices, pubs, grocers and corner shops
in Britain, by 2002 there were only 185,000. Over 40% of independent
food, drink and tobacco retailers have been lost in the past decade.
The loss of shops can create a considerable loss to the local
economy. Every £5 spent in the local economy creates £25
within the local economy.
It also has a dramatic social effect. Small
shops and markets play a huge social role. For many people it
can be the only social contact of the day Small shops will put
people in touch with others and form a network of help and care.
The cost of social services could be immense if this safety net
totally goes. Also if the whole culture is car based then the
social exclusion for the fifth of the population who do not have
access to the car will be considerable and will lead to more problems.
An active town centre is a meeting place for people and therefore
activities and culture tend to spring up and be supported. If
it is difficult to reach the town centre in the evenings but easier
to go by car to an out of town cinema complex then people will
do it. In Leighton Buzzard and Aylesbury there are very few buses
in the evenings so most people are cut off or drive to Milton
Keynes. Most people do not recognise the impact of their daily
actions, but when there is no town centre or community if they
have the means to, they will often consider moving to an area
where there are local shops and a more traditional way of life.
There needs to be a lead from government on these issues.
There are larger ramifications to the local
economy issue. Local food from local farmers can save on considerable
costs to the rest of the economy and environment. The amount of
km that our food travels has a considerable environmental cost.
According to a recent DEFRA report called "Food Miles".
"Social costs of congestion, accidents, infrastructure, CO2,
noise and air pollution, related to food miles are estimated as
over £9 billion per year." This report also says on
page 2 "Since 1978, the annual amount of food moved in the
UK by HGVs has increased by 23%, and the average distance for
each trip has increased by over 50%. Food transport accounts for
30% of all road freight transport tonne kilometres within the
UK". "Supermarkets tend to centralize all their distribution.
This can result in hundreds of extra miles. A sandwich company
in Derbyshire, for example, supplies its products to a major supermarket
chain and has a plant within a few hundred metres of one of its
shops. The sandwiches arriving on this shop's shelves, however,
have to be routed through one of the retailer's RDCs on a round-trip
of approximately 160 kms." The local food economy which is
being supported by the rise in farmers markets and the enormous
growth in demand for organic vegetables which is not being met
by the UK could be proactively supported by the government and
put at the heart of planning. The implications on transport, health,
biodiversity, reducing waste, supporting the farming industry
could be considerable. This is a matter for DEFRA and for the
DFT.
The lack of support for this aspect of sustainability
and indeed the tacit support for the opposite was clearly revealed
at a a conference on Funding and Delivery of Essential Transport
Infrastructure in the Greater SE" on 23 of November 2005,
Both Henry Cleary head of the New Growth Areas and Ian Jordan
stated that they supported town centres and that we cannot build
our way out of congestion. They also state that local congestion
is a problem. However, they also make reference to a large number
of dual carriageways which are described as unlocking development
sites. One of the key parts of the MKSM growth area is the widening
of the M1 and the Dunstable Northern bypass. (The new Community
Infrastructure Fund is supporting Junction improvements to the
junction 14 on the M1). All of these projects have links to new
lorry parks. A large growth industry in Bedfordshire is the distribution
industry. Money is therefore going from the government in to new
roads which will support those industries which use freight lorries.
A particular example of this is supermarkets.
The government is concentrating on the Strategic
Highway Network. This will facilitate movement and increase the
capacity for road freight. This can have serious negative consequences.
Bedford is suffering as so many people will drive to Milton Keynes
in order to do their shopping. The National Trust has issued a
report highlighting the problems with the amount of cars travelling
on rural roads for "days out".
The main problems with congestion are local.
43% of all trips are under 2 miles according to the national travel
survey 2002 and 60% are under 5 miles. Surely the aim should be
to concentrate on local trips. The DFT ad the Highways agency
talked of "locking in the benefits" of building roads
alongside schemes to manage demand. However in the existing consultation
on the Dunstable Northern bypass there is no mention of local
transport needs. In the case of the Linslade Western Bypass people
had to get arrested in order to achieve a strategy from the local
councils to lock in the benefits, such as traffic calming and
better buses.
We are also concerned that there is a long list
of roads schemes in the draft Regional Transport Strategy that
have not been through the appraisal process. According to the
new guidance from the DfT the "no road" option should
be seriously considered. Road building should only be considered
after a full range of options and solutions have been examined.
It is therefore worrying that so may road schemes without appraisal
are being put into the East of England RTS.
However to deal with local transport issues
there is a superb report published on the Department for transport
website called "Smarter Choices". This talks of the
effect of policies such as school travel plans, walking and cycling
and better buses on congestion. Congestion can be reduced by 21%
if these measures were implemented according to this report. However
there is no more money in the Local transport plan bidding process
to support revenue funding for buses and for soft schemes. The
money for developers as I have already stated is much in demand.
When I asked Henry Cleary from ODPM at this conference what should
happen in South Bedfordshire where there is a serious lack of
accessibility to key services due to the poor quality of the bus
services and the local congestion is so bad in Leighton Buzzard
that 75% of the population shop outside the town. His reply was
that there should be an application to the transport Innovation
fund for road pricing linked with better buses. This would be
very difficult politically in South Bedfordshire and it is odd
to expect local councils to take the lead when national government
is not prepared to take the lead. If Road Pricing comes in in
the next few years as the government is saying that it will, then
there will be a huge change in the assessment and appraisal of
the need to build new road schemes and there will be the funding
to go into public transport. The government should be leading
on this and on the drive for modal shift not leaving it to local
delivery vehicles.
The example of East West Rail is an example
of the contradiction in transport policy. The supposed justification
for the high level of growth in the MKSM, according to the Roger
Tym report "the background study to the Milton Keynes South
Midlands growth Area" of 2003, is the growth in knowledge-based
jobs as a result of the spin-offs from industries in Oxford and
Cambridge. It would seem to follow this that the railway between
Oxford Milton Keynes and Bedford with a link to Aylesbury should
be reinstated. The cost was estimated at £65 million in 2004
by the East West Rail Consortium. The government is funding the
first of a series of dual carriageways to link Milton Keynes and
Aylesbury. The cost of the present one, the Stoke Hammond and
Linslade Western bypass is £43 million, the next bypass is
the Wing bypass which is estimated at £80 million. There
is still then one more to link the route to Aylesbury. Yes this
route will be excellent for freight that wants to move from the
M1 corridor to the A41, but it will not promote the spin off industries
from Oxford in the area. According to Ian Jordan, head of South
East and East division in the DfT at the same conference as above
the main aim with rail is to keep the costs down. We believe that
this is unfair. Work that CPRE have done, has showen that the
normal escalation of costs in road building is around 40%. Against
this the cost escalation of railways is not so bad.
There are serious long term problems with congestion
in the SE and this could seriously impact upon the economy and
quality of life. RPG9 for the South East states: "Another
threat to the region's long term prosperity is the widespread
congestion." (para 2.19). The Highways agency stated at a
seminar for the EIP on the East of England Plan in September this
year that by 2021 even if all the road schemes listed in the RTS
were built there would be an increase of 44% in traffic queues
on the main networks in the East of England.
The Chairman of the Examination in Public for
the Milton Keynes and South Midlands Sub-Regional Strategy said
in his report to the Secretary of State "It became evident
to us that, despite laudable efforts being made in some place,
there is still along way to go before the MKSM towns will have
comprehensive town wide public transport systems that are sufficiently
attractive and frequent to enough to encourage a significant modal
shift……….There needs to be significant progress
towards this aim at an early stage in the strategy. It is not
a matter that can be left to catch up later. His most important
comment was that "of the various step changes sought in the
SRS this will be one of the biggest and most necessary if truly
sustainable communities are to be achieved." At the conference
on transport in the growth areas on Nov 23rd there was a total
acceptance that we cannot build our way out of congestion. Therefore
there is a desperate need for some leadership to deal with this
and help with a significant modal shift otherwise the SE will
be chocked by traffic and the environmental consequences will
be considerable.
Transport is responsible for nearly a quarter
of the UK emissions and is set to rise. If the proposed RTS for
the East of England goes ahead, there will be a rise of 30% in
carbon dioxide emissions due to surface transport in the period
2001-21 in the East of England according to a report done by Keith
Buchan for Sustainable Transport for the East of England and present
to the Panel of the EIP.
8. 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?
Concerns over water supply are a major concern.
The government is targeting massive development into the southeast
and East Anglia areas. These areas established as the driest rainfall
areas in the country. The region is the driest region in England
and yet the development proposals are the greatest magnitude in
England. There are various maps, identifying that in the majority
of the region water supplies are already fully committed and in
some areas abstraction is already unsustainable. So how can the
pressures of this huge development proposal be met without the
increased water provision by water transfer and/or increased collection
and storage measures? The provision of this increased water infrastructure
is already too late to keep pace with the proposed development
rates. Creation of new collection and storage facilities may take
at least 10 years to procure and become operational and therefore
should have been addressed long before these development proposals.
To further emphasise the above points, representatives
attended a meeting of the Chilterns Conservation Board where presentations
were given. Two were by the local water companies, Thames and
3 Valleys (Veolia). The former was very complacent about the increased
demand for water (but we know that they budgeted 100 million for
a de-salination plant to cope with the Thames Gateway proposal—and
were turned down by Ofwat). However, 3 Valleys lose at least one
water source a year with little opportunity for replacement. They
rely on having access to Grafham Water via Anglia Water (Anglia
have opposed this but the High Court recently gave 3 Valleys access
to 40% of their demand from Grafham).
Grafham cannot supply everybody's water needs
in the area especially with the existing rising demand.
More interestingly, 3 Valleys see sewage disposal
as more of a concern because you simply can't increase the size
of sewage plants or build more without dumping an increased chemical
burden into the rivers. Mostly, this is ammonia from the treatment.
The ammonia permissions have strict limits and they cannot be
exceeded without penalties. These limits may be EU limits in which
case even the ODPM office cannot bulldoze through them!
Water use may be reduced by metering but that
won't affect sewage quantities, in fact it makes the problem worse
because lower water flows pass through the treatment plants leading
to higher ammonia concentrations in the output. Also, reducing
the water flow reduces the volume of water into the river and
this has effects further down where other plants may discharge.
Thames Water have been ordered to reduce the
leakage especially in London to increase their available resources
but they suffer from the constant movement of the London Clay,
which constantly fractures the pipes. Anglia Water have the same
problem in the clay where the older pipes are asbestos cement.
So, although Thames theoretically have access to 25% more water
if they stop all their leaks, in practice it isn't easy to do
without spending vast sums (whose?) and huge disruption in Greater
London.
There are serious concerns that SCP could contradict
both the Habitats Directive and the EU water framework directive.
The latest ruling on the EU habitats directive
from the European Court states in paragraph 50 of the ruling that
the UK "has not transposed Article 6(3) and (4) of the Habitats
Directive correctly as regards water abstraction plans and projects".
This means that when water licences are given there is no requirement
in UK law to look at the effect that water abstraction could have
on protected sites. Development that has indirect impacts upon
SAC sites according to the habitats directive should be seriously
considered only if there is an over riding public interest. In
the Strategic Environmental Assessment for the East of England
Plan (RSS14) there are concerns in nearly all of the regions concerning
over over-abstraction and the effects that this could have on
biodiversity.
The Environment Agency stated in a seminar for
the EIP for the East of England Plan that they would be considering
getting water from the Trent. The river Trent flows into the Humber
Estuary which has internationally protected sites. If the flow
of the Trent is lessened due to supplying water for the East of
England then there could be detrimental effects upon the internationally
protected sites, which would make the development unlawful.
The EU Water Framework is in its early days.
It was signed up to in 2000 and is due to be implemented fully
by 2015. The aim is to improve the water quality in all water
bodies, streams, rivers etc by 2015. The aim is to achieve good
status. There are derogations in the case of "Sustainable
human development and overiding public Interest". River Basin
Management Plans are being set up in order to monitor and improve
the water quality in each area. Obviously the run off from farmland
can have a considerable effect on the ecological status of water
bodies. However treated sewage will have considerable effects
upon the quality of the water, as is shown above. The East of
England is set to have drier summers so the amount of surface
water will lessen in proportion to the amount of treated effluent.
If there is large scale development then the amount of treated
sewage flowing into the water courses will considerably increase
and could cause a serious deterioration of the water quality and
thereby might be contravening the EU Water Framework Directive.
South Bedfordshire Friends of the Earth are presently seeking
legal advice upon this issue.
9. Is there sufficient effort being made
by the Government, the Environment Agency and the water companies
to educate people about water efficiency?
No—see 8 above.
10. Consultation with Local Communities,
in the Implementation and Delivery of SCP.
We are concerned that Local communities are
being excluded from the process. Tony Blair said that "Local
communities should be at the heart of Sustainable Communities"
at the Sustainable Communities Summit in January 2005. However
the new planning system is extremely hard to understand. Terms
such as Local Delivery Vehicles and Local Development Frameworks
and Statements of Community Involvement are very difficult for
the public to understand. Local Delivery Vehicles to most people
mean a lorry or van delivering goods.
Most serious decision making is taking place
at the Regional Spatial Strategies. These draft strategies are
put together by unelected bodies. They are remote and intimidating
to local people and they cannot be voted out. The new Planning
Authorities LDV's are undemocratic.
There is little money being given by central
government to explain the system and to advertise it and to educate
people. Involving the community is an expensive and time consuming
activity. Unless people are aware of how they can be involved
then they will not consult.
Also most people resent being consulted and
then ignored. Involving local communities in the decision making
process can be the most powerful tool in truly creating places
where people want to live. However that power has to be given
to the community and the facilitation of the process has to be
financed otherwise it is meaningless. The Neighbourhood Initiative
with Planning For Real and "Free Form Arts" work in
Dunstable are exciting visions for the future of how local people
and agencies and government can work together in a way which will
often save money but needs to funded up front.
SUMMARY
The scale of development in the South east is
well beyond the Environmental Limits of the region and therefore
is contrary to the new UK Sustainability Strategy and the New
PPS1. However if in any of the new building in the SE there is
to be any hope of Sustainability, the government has to take a
proactive and in many case mandatory lead in supporting public
transport and road user charging, insisting upon carbon neutral
buildings, seriously reversing the decline in biodiversity, and
truly supporting local economies, local communities and local
food and the new green industries. It could be so easily done.
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