Memorandum submitted by the Royal Academy
of Engineering
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?
1.1 No, in most areas it must be enforceable.
Although voluntary codes can go some way to addressing the issues,
in the end statutory requirements are likely to be needed. The
voluntary code will no doubt be taken up by publicly funded organisations
for their schemes (which make up a large proportion of building
industry operations) and by a vanguard of private sector organisations;
however, a significant proportion of private sector organisations
will not take up the code unless compelled to do so. Private sector
developers already face a host of obligations including requirements
to contribute financially to affordable housing and infrastructure,
and are unlikely to add to costs without promise of return through
increased house prices. Hence, while there is little market demand
or fiscal incentive for well-designed, sustainable buildings,
it is unlikely that a voluntary code will have significant impact
on the manner in which housing and other buildings are delivered.
1.2 Comparisons can be made with BREEAM
(Building Research Establishment Environmental Assessment Method),
where take-up of the scheme has been greatest amongst public sector
organisations. Some private sector organisations have taken up
the scheme but it is the planning system that has been significant
in compelling the use of the scheme, by making planning consent
contingent upon certain environmental standards being met. However,
this is often difficult to enforce in private sector schemes,
since detailed design (which ultimately determines BREEAM ratings)
is usually only settled later on in the construction process,
after the granting of planning permission.
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?
2.1 No. The code has hardly any presence
in the public domain at all. Even amongst reasonably well informed
construction industry professionals, awareness of the code is
at far too low a level.
3. Should the Government be introducing fiscal
measures to reward higher building quality and greater environmental
performance?
3.1 There certainly need to be some measures
to secure higher building quality and higher environmental performance.
These could be financial incentives such as stamp duty relief
or reduced VAT on buildings meeting certain standards, which would
return handsomely to Government and participants alike; or the
measure of making the Code compulsory—for example, planning
authorities could make consent conditional upon schemes complying
with the code. It is noted that the proposed revisions to the
Building Regulations address some major environmental issues,
such as energy use and CO2 emissions.
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?
4.1 The ODPM's plan places environmental
sustainability firmly on the agenda, and together with changes
in the planning system, it is generating innovative approaches
and solutions in new development. Environmental sustainability
goes beyond the protection of habitats and a focus on brownfield
development, and must address the environmental performance of
new development (for example in respect of energy and water consumption,
use of natural resources, waste management).
4.2 While all of this is recognized in the
Sustainable Communities Plan, the realisation of environmental
sustainability will require sustained and aggressive challenging
of existing practice and regulations across Government. Competing
interests and demands on public and private investment mean that
environmental considerations are often subsumed by other considerations
(eg affordable housing and public facility provision). Consistent
and sustained public investment and overhaul of the existing regulatory
regime should be combined with the proposed revisions to the Building
Regulations to ensure sustainable outcomes. Hence, while the Sustainable
Communities plan does demonstrate a greater recognition of, and
greater commitment to tackling, the impact of increased house
building on the environment, there is need for long term commitment
to the issue in order that the present recognition does not become
mere lip service.
5. To what extent does the Five Year Plan
address the environmental implications of the geographical distribution
of demolition versus new build?
5.1 Section 6 of the plan addresses the
replacement of housing stock in the Midlands and the North for
the purpose of reviving the housing market in those areas, and
hence considers primarily the economic impact of demolition, rather
than the environmental (and social) impact that demolition will
have. Demolition, and the construction of replacement buildings,
will have significant impact on waste generation, energy usage,
emissions, demands on natural resources etc—yet the Five
Year Plan does not take into account the energy costs of demolition.
There will also be impacts during construction in relation to
traffic, air quality and noise. Hence the plan only partly addresses
the environmental implications of the distribution of demolition
over new-build. While there are obvious downstream environmental
benefits to be gained through the renewal of housing estates (for
example, the improved sustainability performance of buildings),
it is considered that the balance of impacts is not given adequate
consideration in the Plan.
5.2 By focusing the growth of new houses
on the South East, the plan does not appear to take into account
the demand on energy, water resources, need for waste management
facilities, and greenhouse gas emissions which will all place
increasing pressures on the environment in this region. Indeed,
it seems curious that, as the Plan has been introduced in parallel
with far-reaching changes to the planning system, including the
requirement for Strategic Environmental Assessment (SEA) of Plans,
Policies and Programmes to be carried out, the Sustainable Communities
Plan has not itself been subject to a SEA. Hence, while the Plan
advocates the protection and enhancement of the environment, it
gives limited consideration to the geographic spread of environmental
impacts of proposed development.
C: LPS2020
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?
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?
7.1 The timely provision of infrastructure
is a critical aspect of the sustainability of growth areas. Infrastructure
which lags behind development has serious implications for sustainability.
Very little effort has been put in by Government, and currently
there is insufficient recognition that many growth areas already
face a shortfall in provision. Existing shortfalls as well as
the needs generated by new development must be addressed as part
of the development of the four Growth Areas. Public investment
proposals, reform of the section 106 regime, and investigations
into the shortfall in infrastructure provision commissioned recently
in the South East are all positive steps aimed at addressing infrastructure
provision. However, indications are that more is required both
in terms of upfront public investment and realising private sector
contribution.
7.2 In addition to ensuring that the scale
of public investment matches the problem (particularly in relation
to public transport provision), the Government must take further
steps to ensure that the potential to capture development value
is realised, particularly in Growth Areas. Lack of certainty is
a key issue for local authorities and developers alike and has
the potential to undermine the realisation of growth proposals.
Support for initiatives such as the Milton Keynes Roof Tax[25]
will be critical to ensuring that the necessary investment in
infrastructure is secured.
7.3 To achieve greater sustainability in
the new communities, the Government could look to open up infrastructure
provision to new providers with new ideas. In the utility sector,
this would be relatively straightforward and with sound precedents
for gas and electricity networks, but is more problematic for
water given different competitive and regulatory arrangements.
Ofwat—which grants licences for water infrastructure provision
and operation—could follow the Ofgem approach and allow
incoming companies to develop and operate new networks serving
domestic customers. As a point of equity and to allow light-touch
regulation, water charges should be no higher than for existing
customers—that is to say that incoming companies should
be bound by the incumbent's price control. Without this arrangement,
it is likely that incumbent water companies will face limited
competitive pressure to develop better solutions, leaving only
weaker regulatory signals to deliver the wider sustainability
goals. Making developments of this size sustainable is a very
significant challenge. But the scale also presents a huge opportunity
to prove new approaches to utility provision, for example introducing
the use of state-of-the-art telemetry to monitor network performance.
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?
8.1 Water supply in the South East is a
real and valid concern, as well as a critical sustainability issue.
Proposed growth, combined with the impacts of climate change and
the Water Framework Directive will place enormous pressure on
existing resources. This is widely recognized by water companies,
the Environment Agency and environmental groups such as English
Nature and CPRE.
8.2 The problems in the South East are due
to more deep-seated climatic problems than localised periods of
dry weather. It is the area of England with the driest climate,
yet it is the area where housing growth has been focused. Problems
are exacerbated by the effects of climate change, since climate
change has led to wetter Winters and drier Summers (meaning that
there is greater discrepancy between the periods of highest rainfall,
and periods of highest demand), and to increasingly frequent occurrences
of extreme weather. These effects are likely to become more severe
in the future and will lead to problems of lack of raw water availability
in the Summer months, and to a strain on the treatment works and
distribution systems during periods of high demand.
8.3 Water companies recognize the tough
challenge involved in supplying new development. They are addressing
the problem by following the "twin-track" approach of
economic demand management measures (including Water UK's WaterWise
programme), together with prudent development of water sources
to achieve a balance which minimises cost and environmental impact.
In order to support water companies in the supply "track"
of this strategy, Defra, the Environment Agency and other regulators
should more strongly signal their acceptance that supply enhancement
schemes will be required, alongside efficient demand management
measures, to ensure adequate water availability in the future.
This includes new reservoirs or other water sources, where these
are demonstrated to be cost effective and with acceptable environmental
impact. Since the development of new resources has a long lead-in
time, and is only partly within the control of the water companies
themselves, the development of new resources will need to be supported
by Government Agencies and upheld through the planning process
if a secure supply is to be realised.
8.4 One option for securing supply of water
to the South East would be bulk transfers from areas in the North
and West with greater supplies. However, only transfers from nearby
regions would be feasible, and certainly water is too costly to
transport for any kind of national water grid to be acceptable.
Any system of water transfer should also be carefully researched
to ensure that it does no economic or environmental harm to the
companies and regions involved.
8.5 As a general point, water management
appears to figure very little in the development of Government
policy on housing, land use planning and industry. Water companies
are not, but should be, statutory consultees in the planning process.
The Sustainable Communities plan should have featured water more
highly than it appears to, having directed housing growth to the
area with the driest climate. It is imperative that the delivery
of housing in the South East is linked to the ability to ensure
a sustainable and secure water supply. As part of the plan, monitor
and manage programme, this may mean that if a sustainable solution
can not be found, that development in the South East should be
put on hold.
9. Is there sufficient effort being made
by the Government, the Environment Agency and the water companies
to educate people about water efficiency?
9.1 The twin track approach being pursued
by the water companies includes demand management initiatives
and efficiency measures. Water companies can help to reduce demand
from customers by giving more advice on saving water, including
information about the water consumption of household appliances.
For example, Water UK announced the launch of the "WaterWise"
initiative in 2005, building links between affordability and water
efficiency and promoting the benefits of water efficiency to customers.
Demand management is also promoted and supported by the Environment
Agency.
9.2 However, with the exception of leakage
control (which must be addressed head-on), demand management is
a political issue and is for a large part outside the control
of water companies. Action needs to be taken to raise awareness
amongst the public of the value of water and to encourage them
to be more responsible consumers. For example, it is important
to promote public acceptance of hosepipe bans—which should
be accepted as necessary during extended periods of dry weather.
Metering represents the greatest opportunity for managing demand
and so Government should do more to accelerate the introduction
of metering, to ensure that the public are prudent users of the
water supply. Demand management is dependent on the intervention
of a range of agencies and the introduction of changes in the
regulatory process (for example in relation to the metering of
existing properties, pricing and building regulations). Such initiatives
are essential and must be joined up with public awareness campaigns
to ensure that the per capita demand is managed, not just in new
development but also in existing areas.
9.3 Further regulation on water-saving appliances
is required to ensure that all new domestic appliances are very
water efficient. Demand can be effectively managed by introducing
water saving appliances such as low water-consuming washing machines,
dishwashers, low flush toilets, spray taps and push-taps which
automatically stop, low-volume showers, trigger-gun hosepipes
and so on. Therefore, all new private and public developments
should explicitly include water efficiency measures in their design.
These are very important measures to ensure that future water
use is minimised, and their cumulative impact over several years
would be substantial. There is a need therefore for Ofwat, the
Environment Agency and water companies to work closer together
to agree the need and funding for water efficiency measures. Water
companies were disappointed that proposed water efficiency measures
submitted as part of the 2004 water price review were (with a
few minor exceptions) excluded from price limits by Ofwat.
November 2005
25 The Milton Keynes Roof Tax, devised by the Milton
Keynes Partnership, is intended as an "infrastructure tax",
which would contribute towards the cost of supplying infrastructure
to the areas of housing growth around Milton Keynes. The Partnership
estimated that the costs of supplying infrastructure to the proposed
extensions of the town would be between £1.2 billion and
£1.5 billion by 2011. Landowners and builders would pay between
£18,000 and £20,000 for each new home built, potentially
raising over £270 million towards infrastructure costs. Back
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