Memorandum submitted by East of England
Regional Assembly (EERA)
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?
2. Should the Government
be introducing fiscal measures to reward higher building quality
and greater environmental performance?
East of England regional policy aims to minimise
any negative environmental impacts of new development, with an
emphasis in the Regional Housing Strategy and Regional Spatial
Strategy on density, design and quality of schemes. The Region's
Environment Strategy points out that there are two main types
of environmental impact: from the use of resources in construction
and by occupiers, and the impact on environmental character through
quality of design.
Use of the Code as a single national standard
would help to ensure that more detailed aspects of design relating
to energy and water use, waste disposal and flood resilience,
are given appropriate emphasis, and dealt with consistently across
the country. By itself however, the Code for sustainable buildings
can only have a limited impact. Mandatory use of the Code in public
sector building developments will set an excellent example and
ensure high standards for those buildings. However, this will
not be enough to secure sustainability improvements in the private
sector to any significant degree. Financial incentives and/or
further strengthening of the building regulations will be needed
for the private sector is to adopt similar standards to the Code,
across the board.
The need for improved design standards in new
buildings is paramount. Environmental improvements in building
design need to be part of a package of measures to ensure economic,
social and environmental sustainability of buildings in urban
and rural areas. This includes issues of site design and road
layout which are particularly important in relation to community
safety and ease of access. The draft East of England Plan (RSS)
policy SS16 on the built environment has a range of criteria that
must be incorporated into delivery of new buildings, through local
development documents. This includes measures to maximise contributions
to local character, density, mix of use and types as well as having
regard to community safety, access and resource efficiency. Environmental
enhancements through improved building design will also help to
meet regeneration objectives in areas of disadvantage.
During the public consultation into the draft
East of England Plan some respondents have suggested that the
policy on sustainable buildings could be stronger to help secure
better resource efficiency in new building. However, EERA feels
that there is only little that can be done to strengthen the policy
in the RSS, though of course we await the outcome of the ongoing
Examination in Public. Rather, to help delivery of improvements
to building design and sustainability, planning policy will need
to be supported by changes to the building regulations. Working
together they will have a much greater impact.
3. Is the government doing enough to promote
the Code, with the industry and the general public, ahead of its
imminent introduction early in 2006?
EERA has not been involved in the Code's development,
though would welcome the opportunity. We have seen little evidence
of promotion of the Code and its content, in the East of England.
It is recommended that the Government uses the Regional Centre's
of Excellence for Sustainable Communities, to do this on a regional
scale. Indeed, the Regional Housing Strategy for the East of England,
has already proposed that a regional perspective on the Code for
sustainable buildings is prepared, working closely with Inspire
East, the Regional Centre for Excellence in the East of England.
This will help to ensure that issues that are particularly prevalent
in the East of England are given priority, that the Code is promoted
widely in the Region and that support and training in using the
Code can be provided.
B—SUSTAINABLE
COMMUNITIES HOMES
FOR ALL
4. Does the ODPM five Year Plan 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?
5. To what extent does the 5 Year Plan address
the environmental implications of the geographical distribution
of demolition versus new build?
No comment.
C—LPS 2020
6. Construction standard for dwellings—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?
No comment.
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?
The Assembly's view is simply that the Government
is not doing enough to provide infrastructure to support the growth
plans they have for the East of England.
EERA issued the following statement on 10 December
2004:
"The East of England Regional Assembly
deplores the Government's grossly inadequate funding of the transport
infrastructure costs associated with the additional 478,000 houses
planned for this region between 2001-21.
Bearing in mind that the Assembly's acceptance
of this massive growth was conditional upon adequate government
provision of the necessary infrastructure; and mindful of Lord
Rooker's repeated written assurances that growth will not be imposed
without the associated infrastructure, this Assembly wishes to
make clear that it now regards its endorsement of the draft East
of England Plan as suspended pending a re-examination of the Government's
willingness to support its own aspirations adequately in financial
terms."
EERA's endorsement of the Plan remains suspended
pending continued examination of the Government's willingness
to fund infrastructure and support development, and to ensure
the Plan's proposals are conditional upon, and phased in coordination
with, infrastructure investment.
The Government's recent decision to postpone
improvements to the M11, the key transport corridor in the London-Stansted-Cambridge-Peterborough
growth area is likely to further undermine the Assembly's confidence
in the Government's assurances regarding the provision of necessary
infrastructure.
EERA has submitted evidence to the Examination
in Public in support of this position stressing that conditionality
and phasing are critical to delivery, and to some extent, public
acceptance of the East of England Plan. EERA is arguing that a
new policy should be introduced into the Plan to explicitly link
new development to infrastructure needed.
8. Are the water companies doing enough to
secure the supply of water resources to the four Growth areas?
Is concern about security of water supply in the South East a
valid one or simply a knee jerk reaction to a few hot, dry summers?
The East of England is the driest of all the
English Regions and EERA would dispute the assertion that any
concern about water supply is simple a knee-jerk reaction.
The Sustainability Appraisal of the East of
England Plan remarks that the growth policies therein are likely
to have significant negative effects on the water resources of
the region, particularly in southern parts where water availability
is lowest and the housing allocation highest. Work done by the
Environment Agency shows that there are already water supply and
demand issues in parts of the Region, with surface water through
the majority of the Region already fully committed to existing
abstractions in the summer and that no significant resource is
reliably available. There are a number of catchments where winter
abstraction is no longer reliable during very dry winters.
The East of England Plan policy on water supply,
management and drainage, Policy ENV 9, sets out a series of measures
to maximise the sustainable provision of water supply, and to
ensure that new development is appropriately located. For example
the policy requires that local development documents take account
of the Environment Agency's Regional Water Resources Strategy
to protect water resources and ensure provision for water abstraction.
The problems of infrastructure mentioned in
our response to question 7 above, include necessary water infrastructure.
The draft East of England Plan states that development should
not exceed the capacity of existing water supply systems or proceed
ahead of planned improvements to increase supply.
9. Is there sufficient effort being made
by the Government, the Environment Agency and the water companies
to educate people about water efficiency?
No comment
November 2005
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