Memorandum submitted by Friends of the
Earth
Friends of the Earth England, Wales and Northern
Ireland welcomes the opportunity to provide evidence to the Committee
on the Government's delivery of sustainable housing. Friends of
the Earth is an NGO with 102,000 supporters and local campaigning
groups in 200 communities. We are also a member of Friends of
the Earth International, which has member groups in 70 different
countries. Friends of the Earth has worked on planning and housing
for over 25 years, and we are convinced that the land use planning
system is a key mechanism for delivering sustainable development.
SUMMARY
Friends of the Earth made clear in its submission
to the committee's previous inquiry "Housing; building a
sustainable future" (EAC 2004) that current Government policy
on regional development and housing provision is a major obstacle
in achieving sustainable development in the UK and conflicts with
the Government's own stated aims contained within the UK Sustainable
Development Strategy. [19]Overall
we see nothing in current or emerging Government policy to change
this view. We are particularly concerned about four areas of Government
policy:
I. The continued drive to implement the
damaging recommendations of the Barker Report (March 2004) exemplified
by ODPM's five-year action plan, "Sustainable Communities:
homes for all" (ODPM 2005) and the more detailed consultation
"Planning for housing provision" (ODPM 2005). The effect
of these proposals is to undermine the delivery of sustainable
development with wide-ranging implications for social housing
provision and environmental limits.
II. The overall failure to effect a step
change in building performance reflected in the disappointing
changes to the standards for building regulations.
III. The continued reliance of voluntary
agreements such as the proposed code for sustainable buildings
which will not deliver the necessary prescription or certainty
to effect lasting change in building standards.
IV. The profound failure of government to
grasp the opportunity that the spatial planning system offers
to tackle climate change particularly in relation to encouraging
carbon Zero development principles for housing and ensuring that
environmental limits and resource conservation are at the heart
of strategic planning.
1. THE IMPACT
OF "PRICE
DRIVEN" HOUSING
POLICY
1.1 The Government has laid out its general
policy position on housing provision in the ODPM five year action
plan "Sustainable Communities: Homes for all". This
document accepts uncritically the findings of the Barker report
and provides a general commitment to its implementation (Ref ODPM
2005). In addition ODPM has set out a more detailed policy approach
to the increased supply of housing in the consultation paper Planning
for Housing Provision. This paper makes clear that "plans
should use market information, in particular prices, in determining
the level and distribution of housing provision" (Box 2.2).
Friends of the Earth believe this a radical and regressive policy
development which places crude market indicators at the heart
of decision making. Annex 1 contains our response to the consultation
paper and provides further detail on why the specific proposals
at regional and local level would undermine the objectives of
sustainable development [not printed].
1.2 Sustainable Development, as PPS 1 makes
clear, is the fundamental objective of the planning system and
must underpin housing policy and be reflected fully in the forthcoming
draft PPS3. In line with the new Sustainable Development Strategy
(SDS DEFRA 2005), this means that economic, social and environmental
objectives should be integrated. SDS 2005 is very clear that "integration"
is essential, and that integration is different to "trading-off"
or "balancing" of the different objectives. This recognition
should be made more explicit in PPS3 by, at the least, replacing
"reconcile" with "integrate" whenever Sustainability
Appraisal is mentioned.
1.3 In contrast, existing policy, exemplified
by the Sustainable Communities Plani, the Barker Report and the
recent Consultation paper Planning for Housing Provision
is essentially a reflection of a market-driven conception of how
to meet housing needs in England. This model assumes that increasing
supply is the prime means for tackling affordability, and that
releasing more land in areas of high prices is the prime means
for increasing this supply, in effect making house prices the
key arbiter of the amount and location of new homes. While this
objective appears to offer a simple "fix" to the current
undoubted shortages in social housing provision, it ignores a
whole series of fundamental policy issues.
1.4 First, the social objective for sustainable
development is around securing housing need for everyone. House
prices are a very poor proxy indicator for this. Even slightly
more sophisticated price indicators—ratios of, for example,
lowest quartile income to lowest quartile house prices—are
poor indicators, because, for example:
— Affecting this ratio does not in
any way guarantee that people in housing need will be able to
buy these houses—low price houses are open to all to buy—speculators
as well as people in housing need.
— This ratio only deals with the owner-occupation
tenure.
1.5 Second, the means of tackling whatever
price indicator is chosen has already been deemed to be increasing
housing numbers. However if the policy objective is some target
around price, then the mechanism of increasing housing numbers
is almost certainly not the most efficient nor only means of meeting
it. First, the mechanism is not likely to be effective in its
own right:
— There is no guarantee that the houses
built will be affordable, or in the "lowest quartile".
— Supply-demand is not simple for housing—building
more houses in an area can make the overall house price go up.
1.6 Perhaps more importantly though,
there are many more policy mechanisms which could and should be
used to meet housing objectives, not just building more houses.
These include:
— Setting a higher percentage of affordable
homes in any development.
— Lowering the size-threshold below
which developers must build affordable homes.
— Tackling the incentives which are
fuelling the growth of second homes (eg council tax rebates and
the proposed SIPPS revisions).
— Relocating jobs from higher to lower
demand for housing areas.
1.7 Finally, in addition to not delivering
on the Government's housing objectives, these measures would also
lead to the focusing of growth in high demand areas in ways which
erode public participation in decision-making, and breach environmental
limits.
1.8 To deliver on all three elements of
sustainable development—economic, social and environmental—requires
that these aims are integrated at the beginning, rather than having
a policy focus on one element and treating the other two as "bolt-ons"
which are to a greater or lesser extent traded-off against the
supposed "main" objective. The primary focus here on
increasing supply neglects major side-effects on inequalities
(further growth in the strongest economic regions) and the environment
(more housing where there are greatest environmental pressures)
and is a prime example of failing to integrate at the start of
the policy making process.
IGNORING ENVIRONMENTAL
COSTS
1.9 We are aware that ODPM have commissioned
ENTEC to provide a view of the environmental impacts of implementing
the Barker Report and that this work is yet to be published. In
addition DEFRA published an analysis of the impacts of three expansion
scenarios including those recommended by Barker in April 2004
(Study into the environmental impacts of increasing the supply
of housing in the UK. DEFRA, April 2004). This report concluded
that there were a range of serious environmental implications
of such growth. These included:
— Increased climate change emissions.
— Potential water supply shortages.
— Impacts on Biodiversity.
The issues of flood risk are illustrative of
the wider failure of Government to consider environmental limits
before committing itself to particular growth areas. The ABI has
conducted research which illustrates that one third of all new
housing in the growth areas is to be built on flood plains and
that 10,000 houses will be in areas of significant flooding probability
(Making communities sustainable—managing flood risks in
the government's growth areas, Summary report, ABI, February 2005).
Government policy demonstrates an illogical and unreasonable approach
to a highest level of strategic planning and inevitably leads
to failures to directly consider infrastructure needs and environmental
limits of particular localities.
The launch of PPS 3 (housing) is likely to compound
all of these problems by adopting the Barker reports approach
to housing provision. This will lead to "point" development
outside the four growth zones where local authorities will attempt
to focus additional growth in high demand areas. This is a profound
mistake and undermines the government's own logic of trying to
focus growth where it might be best served by infrastructure.
Such additional growth beyond that envisaged in the Communities
plan is bound to compound the impacts on environmental limits.
Friends of the Earth and many other organisation have been calling
for a national spatial framework in which strategic choices can
made about growth based on the principles of sustainable development.
Such a framework would be able to address the need to redirect
growth to those areas in need of regeneration in order to achieve
a more efficient and sustainable pattern of growth across the
nation.
1.10 Given the range and breadth of concern
that has been raised about potential environmental impacts of
government housing policy it is surprising that both ODPM's five-year
plan and the consultation paper on housing provision failed to
adequately address these issues. "Planning for housing provision"
pays lip-service to the importance of the environment but provides
no indication whatsoever of how environmental limits can be respected
alongside the aggressive promotion of a market-led vision of housing
provision.
1.11 ODPM's five year plan does stress the
need to consider the environment (Chapter 8) but it is deficient
in two important ways:
— It offers a "voluntary"
and "best practice" vision of ensuring that environmental
standards, including design and layout, are incorporated into
new development. The profound weakness of this approach is dealt
with in more detail in section 3.
— The five-year plan has at its core
a dangerous policy gap between the objective for sustainable development
and the objectives of "sustainable communities". There
are significant differences in emphasis between the UK sustainable
development strategy and the list of objectives for Sustainable
Communities contained at Annex 1 of the ODPM five-year plan. For
example, there is no explicit reference in the principles of sustainable
communities to environmental limits or biodiversity. In addition
while the sustainable development strategy stresses the need to
integrate the principles of sustainable development rather than
"balance" or "trade them off"' the five-year
plan suggests that such principles should be "balanced and
integrated". This amalgamation of contradictory approaches
is more than just a semantic issue. Delivery of sustainable development
requires a common understanding of objectives, shared language
and a clear policy narrative and hierarchy. Government must make
a choice between a coherent vision based upon sustainable development
or an overall housing policy which continues to prejudice market
forces over all other considerations. In our view sustainable
communities must integrate the notion of sustainable development
set out in PPS 1 and the UK sustainable development strategy.
1.12 The failure to plan strategically based
on the principles of sustainable development has inevitably led
Government to adopt policies which will lead to serious breaches
of environmental limits. The most obvious example of this is the
fact that new buildings will go on contributing to additional
climate change emissions rather than playing a part in reducing
them. In the short term Government policy will also lead to significant
resource issues particularly over water supply.
2. THE FAILURE
OF BUILDING
REGULATIONS
2.1 The Government is committed to a 25%
increase in energy efficiency of housing to be delivered through
changes to Part L of the building regulations which come into
force in April 2006. While Friends of the Earth welcomes this
action it does not, in our view, take the full opportunity to
deliver the vital step change in building performance which is
required to see effective action on climate change. Because policy
action is more problematic in dealing with the retrofit of our
existing building stock it is vital that we secure effective action
on new-build. The objectives of policy must be ambitious and should
at least secure standards which will deliver carbon Zero development.
In the longer term the housing stock should be considered as a
net exporter of energy, maximising the possibilities of embedded
micro generation along with effective efficiency measures. Some
of the necessary policy actions must be dealt with by the wider
land-use planning system discussed in section 4. However, government
should go further to ensure that building regulations:
— Require the highest possible standards
of energy efficiency for new domestic and commercial buildings.
— Should apply such standards to new-build
and buildings undergoing significant renovation or extension.
3. THE FAILURE
OF VOLUNTARY
APPROACH TO
BUILDING STANDARDS
3.1 Friends of the Earth is extremely concerned
by the Government policy on housing design and layout. Current
policy fails to provide sufficient regulation and incentives to
affect the radical changes we need to make in housing design.
A clear illustration of how the Government regards the implementation
of sustainable housing standards can be gained from the Governments
Code for Sustainable Building (CSB). This contains a range of
proposals on energy efficiency, flood resilience and water conservation.
But the code will be voluntary—it will only have the status
of best practice. (See report of the Sustainable Building Task
Group, May 2004.) This exemplifies the clear gulf between the
available technology and design proposals (exemplified in the
detailed work of WWF "One million sustainable homes: Moving
best practice from the fringes to the mainstream of UK housing",
WWF, January 2004) and the government's unwillingness to identify
effective delivery mechanisms. A voluntary approach to policy
change is particularly flawed in relation to building standards
because:
— It fails to deliver certainty for
the house building industry. House builders are unlikely to meet
new standards if they believe their competitors are unwilling
to do so. The property development sector is not a homogenous
entity with single representative bodies and is therefore much
harder to influence through "best practice". Investor
confidence requires a level playing field best delivered by regulation.
— Voluntary measures may have value
in changing the attitudes of industry and consumers in the very
long term. However, the imperative to deal with issues such as
climate change and water conservation is now. This partly because
of the pressing nature of these problems and partly the opportunity
that planning reforms offers to make effective policy.
3.2 The solution to this problem is:
— Provide a greater degree of prescription
in building regulations to ensure that new build and conversions
enshrine proven resource conservation technology including small-scale
renewable technology and meet the Eco homes excellent standard.
— Provide much greater prescription
in a new PPS 3 on housing in relation to master planning and the
layout and service provision of new housing.
— Provide greater integration between
the Environment Agency and planning authorities in relation to
future flood risk and sea-level rise in order to provide strategic
guidance based on best available modelling from the Met office.
— Specify in PPS 11 a CO2 reduction
target for the delivery of new housing to be enshrined in Regional
Spatial Strategy.
— Increased investment for the retrofit
of existing houses with energy conservation technology.
— Underpin the new drive for sustainable
housing by enshrining the above objectives in a new Public Service
Agreement (PSA) target for ODPM.
3.3 There is no doubt that such development
will add cost to the delivery of new housing units. However, such
upfront capital cost will result in long-term savings particularly
in energy costs for users. Such savings will disproportionately
benefit those on low and fixed incomes who spend a higher proportion
of their income on energy. There will also be lower costs to the
economy as a whole, from reduced climate change impacts. In the
wider context, the contribution of sustainable housing to reducing
the negative impacts of climate change is likely to be significant
(these costs have been assessed in the recent Defra report: Study
into the environmental impacts of increasing the supply of housing
in the UK. DEFRA, April 2004).
4. THE FAILURE
OF SPATIAL
PLANNING TO
DEAL WITH
CLIMATE CHANGE
4.1 There is a growing view amongst a wide
range of organisations[20]
that the government has not grasped the potential of the use of
the land use planning system to make a significant contribution
to dealing with climate change. Planning has the potential to
draw together many of the issues discussed above in relation to
housing standards and integrate them with the wider issues of
transport, energy generation mixed-use developments to deliver
an overall vision of sustainable development.
4.2 Current government planning policy on climate
change is fragmented and fails to provide a clear linkage between
national rhetoric and local and regional policy action. The result
of this position is the patchy and largely ineffective delivery
of climate change reduction policy on the ground. A small number
of local authorities such as the London Borough of Merton have
introduced a successful policy to embed renewable micro generation
but research by Friends of Earth has demonstrated that such policies
remain the exception and are themselves very modestly drawn. Annex
2 contains a detailed briefing for regional decision makers and
sets out the barriers to implementation on climate change [not
printed]. In particular it addresses how target setting and carbon
Zero development principles could transform our response to climate
change by ensuring new housing development reduces rather than
exacerbates carbon emissions.
There is a clear and overwhelming case for ODPM
to publish a national statement on planning and climate change
which would provide an effective "route map" of policy
guidance and affect a "culture change" amongst decision-makers.
Such a document could draw together the provisions of building
regulations and the code for sustainable building and demonstrate
how these dovetail with the land-use planning system. In particular
it could make clear how aspects of the Code for Sustainable buildings
could be incorporated into development plan policy transforming
aspirational standards into statutory planning policy. It could
also provide reassurance that policy to require embedded micro
generation in new development was accepted and would end the ludicrous
situation where some government offices have objected to the inclusion
of such policies in the new local Development Framework. For example
as the recent Government Office of London objection to the London
Borough of Waltham Forest policy (WPM21) to require "10%
of total predicted energy consumption to be from renewable energy
sources, through on site generation for all commercial/industrial
developments over 1,000sq ms and housing developments of 10 or
more units."
4.3 The opportunity to deliver a step change
in housing standards by incorporating innovative policy into the
statutory planning framework has to be seized now. The Planning
and Compulsory Purchase Act 2004 requires the review of all local
Development Framework in England between now and the end of 2006.
There is also a parallel review of regional planning policy which
is already well underway. No government has ever attempted such
a complete review of the regional and local planning framework
in England in such a tight time frame. Effective action must be
delivered now if these new plans are to provide a proper policy
framework to deliver truly sustainable communities.
PPS 3 HOUSING AND
CLIMATE CHANGE
4.4 We are aware that government is about
to publish a draft PPS 3 on housing and this document provides
a very significant opportunity to shape the planning system response
to the environmental standards of the new housing. The current
PPG 3 fails to reflect the vital imperative for the planning system
to deal comprehensively with the causes of climate change. New
and existing residential development is a very significant contributor
to climate change emissions. Para 52 of the existing PPG 3 fails
to provide either the sense of imperative or detailed guidance
to deliver a step change in the energy and resource efficiency
of new housing.
4.5 PPS 1 Makes clear that "Regional
Planning bodies and local planning authorities should ensure that
development plans contribute to global sustainability by addressing
the causes and potential impacts of climate change." (Para
13 ii)
PROMOTING CARBON
ZERO DEVELOPMENT
PRINCIPLES
4.6 In order to assist in the achievement
of national and international carbon reduction targets, PPS 3
should promote a range of policy measures to ensure new development
is carbon neutral over the life-cycle of the development. Measures
should be considered to promote the retrofit of the existing building
stock whenever possible. Policy should focus on energy and resource
efficiency and on promoting renewable energy capacity.
ENERGY AND
RESOURCE EFFICIENCY
4.7 The PPS 3 should make clear that Development
Plans should be required to promote the development of resource
efficient homes through the inclusion of policies which specify
acceptable levels of resource efficiency for all new developments.
By 2006 the Energy Performance of Buildings Directive (EPDB) requires
the setting of minimum requirements of energy performance of new-build
and buildings undergoing major renovation (SD page 87). While
aspects of this agenda will be dealt with under Part L of the
New building regulations, PPS 3 has a major role in setting strategic
policy and driving up standards which can support the Government's
Code for Sustainable Buildings, by ensuring energy and resource
efficiency of vital considerations in deciding the principle of
new development and of the re-use of existing buildings.
4.8 The ODPM Select Committee Report (Planning
for Sustainable Housing and Communities: Sustainable Communities
in the South East Eighth Report, ODPM, 2003) endorsed the Building
Research Establishment measure of resource efficiency known as
the "Eco Home" standard. Friends of the Earth strongly
recommends that PPS 3 should support the achievement of Eco Homes
"excellent" standard for all new homes.
4.9 In order to deliver effective change
the new PPS 3 should endorse the BRE Eco-Homes excellent standard
as a minimum standard. However Eco Homes Excellent does not reflect
current best practice in sustainable construction. It does not
require the adoption of all aspects of environmentally sound construction
that would even further reduce the impact of new housing. PPS
3 should adopt the Z2 ("zero carbon, zero waste") approach
developed at Beddington Zero Energy Development and now being
planned in showcase developments in the Thames Gateway. The Environmental
Audit Committee's recent report recognised that:
"Simply taking the Building Research Establishment's
standard forward in the proposed Code (for Sustainable Buildings)
could result in a missed opportunity to achieve a step change
that is required in construction practices to reduce the environmental
impacts of all buildings, including houses."
4.10 As a result the new PPS 3 should include
the following objective:
"All new housing development must achieve
as a minimum the Eco Homes excellent standard for energy use and
resource efficiency and wherever possible the Z2 (`zero carbon,
zero waste') approach. RSS and Local Development Framework policy
should be required to drive up standards of energy and resource
use efficiency with the objective of carbon and waste neutrality
by the end of the plan period."
CONCLUSION
The Government's current proposals for implementation
of the Barker Report would result in deregulating control over
built development and so remove vital mechanisms through which
we might achieve a more balanced and sustainable development of
the nation. In addition, while the technology exists to radically
reduce the resource consumption of new homes, the government has
chosen to adopt a gradualist, voluntary approach to implementing
such standards. This is a profound policy failure and loses the
opportunity for a step change in the quality and long-term sustainability
of our communities.
To achieve sustainable development regional
and housing policy must seek to integrate the four pillars of
the UK Sustainable Development Strategy and not continually prejudice
economic growth as the prime objective. In addition we urgently
require a national framework for strategic planning which can
give spatial expression to the UK Sustainable Development Strategy.
PPS 1 has empowered the strategy as material to all planning decisions
but provides little or no indication of how this is meant to be
achieved. Such a project requires much greater inter-departmental
co-operation than has been evident in either the Communities Plan
or the Government's initial response to the Barker report.
REFERENCES
Review of Housing Supply "Delivering stability:
securing our future housing needs" Final Report, Kate Barker,
March 2004
A Better Quality of Life: A Strategy for Sustainable
Development for the United Kingdom, May 1999
Sustainable Communities Plan "Sustainable Communities:
Building for the future" February 2003
Friends of the Earth's submission to the Environmental
Audit Committee on the Budget, 24 March 2004
Driving Productivity and Growth in the UK Economy,
McKinsey, Global Institute, October 1998
Fourth Report of the ODPM: Housing, Planning, Local
government and Regions Committee, 2003
Study into the environmental impacts of increasing
the supply of housing in the UK. DEFRA, April 2004
PPS 1 "Creating Sustainable Communities",
May 2004
Sustainable Building Task Group Report, May 2004
One million sustainable homes: Moving best practice
from the fringes to the mainstream of UK housing, WWF, January
2004
"Making communities sustainable—Managing
flood risks in the Government's growth areas" summary report,
February 2005
November 2005
Association of British Insurers (ABI); Bill Dunster
Architects; British Wind Energy Association; CURE University of
Manchester; Friends of the Earth; Green Alliance; IT Power Ltd.;
Local Government Association; London Borough of Merton; London
Borough of Croydon; London borough of Woking; The British Photovoltaic
Association (PV-UK); Royal Town Planning Institute (RTPI); Planning
magazine; Royal Society for the Protection of Birds (RSPB); Renewable
Power Association; Royal Institute of Chartered Surveyors (RICS);
Solar Trade Association; Town and Country Planning Association;
Woodland Trust; WWF.
19 A Better Quality of Life: A Strategy for Sustainable
Development for the United Kingdom, May 1999. Back
20
Current supporters of the climate change campaign include: Back
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