Memorandum submitted by David Penney
RESPONSE TO THE INQUIRY ISSUES
A. THE CODE
FOR SUSTAINABLE
BUILDINGS
1. If current practice is taken as a guide,
then it is clear that the building industry has failed so far
to achieve well-designed, energy efficient sustainable buildings
which have minimal impact on the local environment. The industry
is slow to use new methods and materials with the result that
new housing is often sub-standard, of poor quality and fails to
incorporate energy efficient and saving measures in their construction.
So, I would definitely say that, on past record, a voluntary Code
for Sustainable Buildings would not work. A mandatory Code of
Good Practice needs to be imposed on the building industry and
enforced with penalties for non-compliance. For instance, the
Government could introduce a mandatory code with timeline targets
on energy efficiency measures, as has been imposed this year in
Germany, where all new houses have to include specific items and
all existing houses will have to be adapted to comply with the
code by 2025, at a rate of 5% per annum.
2. Most certainly not—there is little
or no incentive for the industry and the public to adjust to the
introduction of the code in 2006. I have not seen any evidence
of the promotion of the new code locally. The planning system
for new housing developments does not seem to be raising these
issues with the developers at the application stage. Planning
decisions taken in 2005 will be implemented in 2006 and need to
take into account the new code.
3. As already indicated in answer to issue
one, I believe the Government should introduce fiscal measures
to ensure that the Code is followed. There could be a range of
measures including reward for higher sustainable building quality
and greater environmental performance, such as VAT free on recycled
materials and energy efficient and saving measures. While use
of new materials and non-compliance with the Code could incur
penalties as well as VAT on new environmentally unfriendly materials.
B. SUSTAINABLE
COMMUNITIES: HOMES
FOR ALL
4. The ODPM Five Year Plan does not seem
to demonstrate a greater recognition of, and greater commitment
to tackling, the impact of increased building on the environment.
In fact, it seems to contradict the principles of building sustainable
communities, as set out in the ODPM Policy Document "Sustainable
Communities: Building for the Future" [March 2003], where
it outlines "What makes a Sustainable Community?" In
particular, the plan for four new growth areas in the south does
not take into account the severe strain on the existing surrounding
natural and built environment, as well as on the infrastructure
and services [see Section D below]. For instance, how would such
massive new developments foster a "sense of place",
"a diverse, vibrant and creative local culture, encouraging
pride in the community and cohesion within it" or "a
flourishing local economy to provide jobs and wealth"? In
other words, it is difficult to see how the principles of sustainability
could be applied environmentally, socially and economically to
a programme of increased house building on such a scale.
5. Personally, I can see little or no evidence
that the Five Year Plan seriously addresses the environmental
implications of the geographical distribution of demolition versus
new build. I have already commented on the disparity and imbalance
of housing policies, which increase the north-south divide, in
my response to the issues discussed at the ODPM inquiry: "Affordability
and the Supply of Housing" [dated 8 November 2005]. I can
summarise the points I made in that response in the following
way: the plan to build four new unsustainable growth areas in
the South and demolish sustainable housing in the Midlands and
the North in the nine Pathfinder areas is environmentally, socially
and economically irresponsible. It is wasteful in terms of resources
and public funds. It would be far more sustainable and save money
to redirect resources from the South to renovate existing properties
in the Midlands and the North and encourage relocation of people,
which would assist in the economic regeneration of deprived areas
in the Midlands and the North. It seems immoral to destroy sustainable
communities in the Midlands and the North and build new unsustainable
housing estates on greenfield areas in non-existent communities.
The Government should intervene in the housing market positively,
and not destructively, to reverse the drift from the North-South
by refusing to build four new growth areas in the South and redressing
the geographical distribution of housing and people so that the
Midlands and the North can be restored economically and socially
with environmental improvements.
C. LPS2020
6. I do not have any comments on LPS2020,
as I do not have access to the new construction standard for dwellings
nor am I aware of the results of the Consultation on it. If this
standard relates to the Code for Sustainable Buildings [Section
A], then they should be linked, complimentary and enforceable,
if standards are to be improved.
D. INFRASTRUCTURE
7. From what I have heard, it is highly
unlikely that the Government has "ring-fenced" sufficient
funds to provide the necessary infrastructure, such as transport
links, schools and hospital in the four growth areas. This is
evident by the fact that existing communities are struggling to
ensure they have adequate resources to fulfil their infrastructure
and service requirements. In particular, public transport provision
is in a state of disarray and over-stretched. For instance, Sustainable
Community Measures, such as "good public transport and other
transport infrastructure both within the community and linking
it to urban, rural and regional centres", "good quality
local public services, including education and training opportunities,
health care and community facilities, especially for leisure"
and "right links with the wider regional, national and international
community" are not being met in existing communities ["What
makes a Sustainable Community?", ODPM 2003]. So, how, with
the expected cut back in public funds by the Chancellor, can the
Government possibly guarantee extra new funding for the infrastructure
and services in the proposed four growth areas?
8. The supply of water resources is becoming
more critical in the South, particularly in the Greater London
region, the South East and East Anglia. If this is already the
case for existing households, then the development of four growth
areas in the same areas is bound to exacerbate the already difficult
situation with regard to the supply of water resources. The current
trend of hot dry summers, as well as drier winters, in the South
is due to continue and worsen as the impact of climate change
takes hold. Water companies do not have access to reserves to
tap into locally. Water supplies would have to be piped in from
other regions further north to meet the growing demand. The cost
of building the infrastructure with new reservoirs outside the
growth areas, filter stations and a network of pipes would be
astronomical. It would be far more economical to renovate homes
in areas with existing water supplies and access to local reserves—regenerate
the Midlands and the North and scrap plans to build four new growth
areas in the South.
9. Water is still wasted in some areas in
leaky supply pipes between reservoirs and homes. As the cost of
water utilities continue to rise, then people should realise the
value of water. However, there should be incentives to reduce
consumption and conserve water supplies with the mandatory imposition
of universal metering for all new and existing houses and premises.
There should be more education by the water companies and the
Environment Agency to make the public aware how essential, precious
and costly resource water is in society and not leave it until
there are periods of drought to raise the alarm bells. The importance
of water should be emphasised in the same way as the Government
should be doing in relation to energy efficiency and saving measures.
November 2005
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