Memorandum submitted by East Herts Council
1. INTRODUCTION
1.1 The population of the district of East
Hertfordshire is currently around 130,800, half of which live
in the five main towns of Bishop's Stortford, Buntingford, Hertford,
Sawbridgeworth and Ware. The remainder live in over 100 villages
and hamlets across the district, with much of the area Green Belt.
East Hertfordshire is the most rural district
in Hertfordshire but is under great pressure from development
due to its proximity to London and its position in the Eastern
Region adjacent to Stansted and the M11 growth corridor and Harlow
North proposed expansion.
The district's special character is largely
due to its surviving mixture of historic buildings in their picturesque
settings. Development and building has been carefully and sensitively
controlled by the Council in order to protect the local environment.
Although the district's rural character means
it has an important agricultural base, the local economy is in
fact dominated by the service sector. In the main it is a prosperous
district and enjoys higher than average earnings, with a high
proportion of workers commuting into the capital.
1.2 The District Council is currently heavily
involved in the East Hertfordshire Local Plan Public Inquiry and
as such available officer time to respond in depth to the Committee's
call for comments has been limited. Nonetheless the Council is
very keen to make representations and we therefore hope that the
following brief points will be of assistance to the Committee
in its deliberations.
1.3 The following comments are set out in
accordance with the list of inquiry issues published by the Committee
on its website.
2. EAST HERTFORDSHIRE
COUNCIL—COMMENTS
(A) THE
CODE FOR
SUSTAINABLE BUILDINGS
2.1 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?
We strongly welcome the introduction of the
Code for Sustainable Buildings and believe that it will assist
in the step change required in terms of energy efficient sustainable
design. However, we are of the view that unless the Code is made
compulsory many of its potential benefits will not be fully realised.
This is because private sector developers will be less inclined
to adopt the Code until they are required to do so. If the Code
were to be compulsory a level playing field would be created which
would not disadvantage any particular developer.
2.2 Is the Government doing enough to promote
the Code, with the industry and the general public, ahead of its
imminent introduction early in 2006?
We are not in a position to comment on promotion
of the Code to industry, except in terms of public sector awareness
where its imminent introduction is known. However, in terms of
the general public we feel it has been poorly promoted and can
only hope that this will dramatically change with the Code's national
roll-out in 2006.
2.3 Should the Government be introducing fiscal
measures to reward higher building quality and greater environmental
performance?
The Government should introduce suitable fiscal
measures to reward higher building quality standards. We believe
there are a wide range of measures that could be adopted, many
of which have been brought to the Government's attention by environmental
and industry bodies during past consultation on economic instruments.
The Government's existing lower rate of VAT on some energy efficiency
measures has been very welcome. However, we believe the Chancellor
should extend this to include a wider range of products whether
professionally installed or not. The District Council has for
some years operated a solar club which was initially set up to
encourage the DIY installation of solar thermal systems. However,
the disparity in VAT rates reduced the economic advantage for
householders installing their own system on a DIY basis, reducing
take up at the lower end of the market and requiring greater reliance
on the "clear skies" grants for systems to be cost effective.
In addition to further VAT reforms the key measure
that could be adopted is a reduction in stamp duty for energy
efficient homes, which would fit well with the forthcoming introduction
of the Home Information Pack.
(B) SUSTAINABLE
COMMUNITIES: HOMES
FOR ALL
2.4 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?
Sadly we are of the view that the ODPM Five
Year Plan, "Sustainable Communities: Homes for All"
whilst laudable in some respects does not properly take into account
environmental considerations. The Plan has very serious implications
for districts such as East Hertfordshire, promoting as it does
the huge step change in housing supply, leading to unsustainable
developments such as that proposed at Harlow North. It appears
to concentrate solely on economic drivers to the detriment of
environmental quality and does not appreciate that there must
be an upper limit to housing development in order to create a
"sustainable" community as a whole.
2.5 To what extent does the Five Year Plan
address the environmental implications of the geographical distribution
of demolition versus new build?
We do not consider that the Plan addresses the
environmental implications of the geographical distribution of
demolition versus new build. Again, we would emphasise that the
plan is economically driven, placing its emphasis on development
in the south eastern quarter of the UK and so in effect backing
Kate Barker's "Review of Housing Supply" (March 2004).
The Strategic Environmental Assessment undertaken
of the Eastern Region's Regional Spatial Strategy (RSS14) recognised
that there had been insufficient consideration by the Government
of the North-South Divide and the move to increasing new build
in the south-east.
(C) LPS2020
2.6 The Government
has consulted on the new construction standard for dwellings (LPS2020).
On the basis of that consultation is it possible to determine
whether the new standard will be a positive force for change and
add value to the construction process?
As a local authority we do not appear to have
been specifically consulted on LPS2020. However, we welcome the
general principles of LPS2020 in terms of setting higher performance
levels for dwellings. However, we would emphasise that new build
must be of high design quality both in terms of its construction
and its aesthetics.
(D) INFRASTRUCTURE
2.7 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?
It is our view that the Government is in no
way securing sufficient funds for the timely provision of infrastructure.
In Hertfordshire we desperately need to improve existing deficiencies
in terms of infrastructure before even contemplating massive new
levels of house building. Development, like that proposed at Harlow
North, will therefore put an intolerable strain on infrastructure
such as schools, medical services and transport links.
Traffic congestion is a major issue for Hertfordshire
as a whole, and it regularly features as a chief concern of residents
in Council MORI polls. The area has a very high level of car ownership
and poor public transport links east-west and those north-south
are very focussed on London. We believe that the current infrastructure
is barely capable of supporting existing demand and problems will
only be exacerbated as housing development proceeds. For example
we have seen cases of road improvement measures cancelled, but
have not seen the Government redirecting that funding into local
public transport.
The East of England Regional Assembly has suspended
its endorsement of the Regional Spatial Strategy because of the
Government's lack of clarity and commitment to the provision of
infrastructure.
Given the Government's approach we therefore
question how future development in our area, such as that at Harlow
North, can in any way be termed a sustainable community.
2.8 Are the water companies doing enough to
secure the supply of water resources to the four Growth Areas?
And is concerned 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?
We are of the view that security of water supply
is a key issue for the district. The Strategic Environment Assessment
of RSS14 voiced serious concerns over future water provision and
we believe that the Government has not provided an adequate answer.
The East of England already has less water per capita than some
parts of the Middle East, and water use in Hertfordshire is already
one of the highest in the UK. Climate change scenarios are also
predicting the situation to worsen.
If the water companies continue to abstract
locally to meet demand, we will see more rivers with low flows
leading to major problems for the biodiversity and general environment
of the District. We are not convinced that the aim to see a 25%
increase in the water efficiency of new build will be sufficient
to avert problems given the level of new construction proposed.
2.9 Is there sufficient effort being made
by the Government, the Environment Agency and the water companies
to educate people about water efficiency?
There appears to be very little effort by the
water companies or the Government to educate and inform people
of the need for water efficiency. Any promotion that does exist
seems to focus around hose-pipe bans. There is a real need to
step up the water saving message and perhaps consider water efficiency
schemes. The Environment Agency does now seem to be producing
some promotional material on water efficiency, but it is insignificant
compared to that on flooding. The time would appear to be right
for a balanced campaign on flooding, water efficiency and climate
change. Any such campaign would need to be properly resourced
and local authorities would be keen to be involved given the appropriate
funding.
November 2005
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