Memorandum submitted by the Royal Society
for the Protection of Birds (RSPB)
INTRODUCTION
1. Since the RSPB last submitted evidence
to the Committee in 2004, our thinking on and engagement with
the Government's Sustainable Communities Plan has developed further.
We are particularly concerned about the potential environmental
impact of a significant increase in the supply of housing, and
of the mechanisms proposed to achieve this through the planning
system. We have also recently submitted evidence to the inquiry
by the Select Committee on the Office of the Deputy Prime Minister,
on affordability and the supply of housing.
SUMMARY
2. The RSPB is concerned about recent Government
proposals for planning the provision of housing, which appear
to threaten the plan-led system. A significant increase in the
supply of housing may be seriously damaging to the environment
unless adequate measures are taken to mitigate the impacts, through
giving careful attention to the location and quality of house
building. In particular, plans need to deliver green infrastructure,
respect environmental capacity, conserve natural resources and
protect and enhance wildlife.
3. While the proposed Code for Sustainable
Buildings is a step in the right direction, we believe there is
a compelling case to make high environmental standards mandatory.
Although the ODPM Five Year Plan gives greater recognition to
the environment, the Government's commitment to tackling the environmental
impact of increased housebuilding can only be tested through its
detailed proposals for the Code and through decisions made on
emerging regional spatial strategies. We are particularly concerned
that plans to secure water supply in the growth areas may not
themselves be environmentally sustainable.
THE PLANNING
SYSTEM'S
RESPONSE TO
THE DEMAND
FOR HOUSING
FOR SALE
4. The RSPB is a strong supporter of the
plan-led planning system, as is now enshrined in the Planning
and Compulsory Purchase Act 2004. We welcome in particular the
new duty on plan-making bodies to contribute to the achievement
of sustainable development, and the guidance on how this is to
be achieved in Planning Policy Statement 1 Delivering Sustainable
Development (February 2005).
5. We believe that the planning system must
provide for legitimate development needs whilst ensuring that
the environment is properly protected and enhanced. To do this
requires a strong plan-led system in which development plans are
subject to robust strategic environmental assessment and in which
decision-makers treat social, economic and environmental objectives
in an integrated way without resorting to trade-offs.
6. We have also supported existing planning
policy on housing in Planning Policy Guidance Note 3 Housing
since its publication in 2000. It has been an important tool
in encouraging urban renaissance, protecting the countryside from
unnecessary development and generally promoting more sustainable
patterns of development.
7. In particular, we support the use of
"Plan Monitor Manage" rather than "Predict and
Provide"; making good use of land through higher densities;
the sequential test, favouring previously-developed land over
greenfield sites (with the caveat of protecting significant biodiversity
resources as expressed in PPS9), and the emphasis on creating
sustainable residential environments.
8. We have therefore been concerned by recent
Government proposals which appear to weaken elements of existing
policy in PPG3. In particular, we are concerned about the degree
to which the allocation of housing land will be market-driven,
rather than driven by the interests of good planning and sustainable
development.
9. Our detailed concerns about Planning
for Housing Provision may be summarised as:
— There is little opportunity to challenge
housing market areas defined by regional planning bodies.
— There appears to be an open-ended
commitment to housing growth in high demand areas.
— The sequential test is weakened by
focusing on sites which are developable in the short term.
— Proposals to roll forward housing
land in supplementary planning documents will not be subject to
full and proper public scrutiny.
THE SCALE
AND IMPACT
OF HOUSEBUILDING
ON THE
NATURAL ENVIRONMENT
10. In our previous submission to the Committee,
we raised concerns about the environmental implications of the
Barker Review. Since then, joint ODPM/Defra research has been
commissioned on the sustainability implications of a proposed
market housing affordability target and a large increase in house
building, but this has still not yet been published. There has,
therefore, been no opportunity for this research to influence
public debate on this issue, and the proposals contained in Planning
for Housing Provision appear to be premature.
11. Whatever the scale of the increase in
the supply of housing, we are concerned that there is likely to
be serious damage to the environment unless adequate measures
are taken to mitigate the impacts, through giving careful attention
to the location and quality of house building. In particular,
plans need to:
— deliver green infrastructure;
— respect environmental capacity;
— conserve natural resources; and
— protect and enhance wildlife.
12. Thus our concerns are not about growth
per se, but about the relationship between the scale of development,
its location and the quality of its design (particularly in terms
of its environmental performance).
SPECIFIC INQUIRY
QUESTIONS
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?
(i) The RSPB is not convinced that the building
industry will respond positively to a voluntary system. The obvious
lack of progress in making energy and water efficiency measures
mainstream, despite their minimal extra building cost and considerable
benefits in terms of reduced costs of living, does not inspire
us with any confidence.
(ii) RSPB research shows that building to
the EcoHomes "excellent" standard could save 10,000
megalitres of water per year, implying savings of £1.6 billion
on new water resources infrastructure, and 10 million tonnes of
carbon emissions per year, potentially worth £2.9 billion
over the next 30 years. The research suggests that the extra cost
of building houses to these standards is far outweighed (the cost:benefit
ratio is 1:8) by the benefits to society in terms of carbon saved
and the deferred costs of investing in new sources of water supply.
The costs of building to the EcoHomes `excellent' standard, in
terms of water and energy saving actions, are clearly worthwhile
for society and would help keep new development within environmental
limits. We believe there is therefore a compelling case to make
high environmental standards mandatory.
(iii) As far as it goes, however, we think
the Code is an essential step to making some progress in reversing
the rising trend in per capita consumption of water. The basic
level of water efficiency demanded (at we understand 25% less
potable demand per house) will help to ensure that all publicly-funded
housing will achieve significant gains in water efficiency. Building
300,000 planned homes to water efficiency levels of 25% would
save some 419 million litres of water per day. In areas of greatest
environmental sensitivity and water supply-demand balance problems,
the higher standards within the code (for 40% and 60% levels of
water efficiency) should be adopted.
(iv) If the Code is to be only voluntary,
we hope that local planning authorities will be made aware of
its benefits, and that they will insist on its use in local planning
decisions.
(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?
The impending ODPM consultation on the code
should be used as the key opportunity to promote its benefits
and uptake. We do not believe that current awareness is strong
among house builders or local authorities.
(3) Should the Government be introducing
fiscal measures to reward higher building quality and greater
environmental performance?
(i) Yes, the Government should introduce
fiscal incentives for greater environmental performance in buildings.
The measures needed to ensure higher environmental performance
are well understood. Their one-off costs have been assessed by
both the Housing Corporation and the Environment Agency as being
in the order of hundreds of pounds. They are worthwhile for householders
in terms of lower utility bills. They would benefit society through
savings of natural resources, which as we outlined above, would
be worth billions of pounds and be significantly greater than
the costs.
(ii) The only barrier to higher environmental
performance appears to be reluctance amongst developers to bear
slightly higher short term costs, which is a product of their
competitive situation. Therefore, a clear market failure is occurring,
with the market failing to deliver housing to an environmental
standard that is optimal both for householders and society. Fiscal
incentives should be introduced as soon as possible to correct
this failure.
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?
(i) Sustainable Communities: Homes for
All represents a welcome step forward in the recognition of
the importance of the environment in creating sustainable communities.
The RSPB welcomes in particular the references to sustainable
construction (including the need to conserve and enhance biodiversity),
better environmental performance and the proposed Code for Sustainable
Buildings. We also welcome reference to the issues under the "environmentally
sensitive" components of a sustainable community in Appendix
1, including energy efficiency, sustainable consumption and production
and biodiversity.
(ii) These issues were completely absent
from Sustainable communities: building for the future.
The environmental focus of this document, as far as it went, was
limited to the efficient use of land, the avoidance of a limited
range of national designations (Green Belt, national parks and
Areas of Outstanding Natural Beauty) and local "liveability"
issues.
(iii) This greater recognition is very welcome,
but the Government's commitment to tackling the environmental
impact of increased housebuilding can only be tested through its
detailed proposals such as the proposed Code, and through decisions
made on emerging regional spatial strategies.
(5) To what extent does the Five Year Plan
address the environmental implications of the geographical distribution
of demolition versus new build?
(i) It does not appear to address this issue
at all, either at the national scale or at any sub-national scale.
(ii) The issue of demolition and new build
presents several environmental questions which need to be addressed.
Firstly, what are the relative environmental merits of demolition
followed by new build, versus refurbishment? This question does
not necessarily have a geographical dimension, but even at the
national scale does not appear to have been addressed by the Five
Year Plan.
(iii) Secondly, if—to put it crudely—the
bulk of demolitions are concentrated in the north of England and
the bulk of new build in the south, that implies a relative shift
in the distribution of the housing stock towards the south of
England. Although there are significant amounts of brownfield
land available for housing in the south-east and east of England,
this regional shift has implications for water and other environmental
resources which have not been fully considered by the Five Year
Plan.
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?
A number of studies have recently been carried
out on infrastructure needs in the South East of England, which
highlight the significant costs involved. A study by Essex County
Council, for example, estimated the capital cost of infrastructure
to support new development in Essex during the period of the draft
regional spatial strategy at between £11.2 and £13.5
billion. While these studies included the provision of country
parks and local green space, we have two main concerns. Firstly,
that the studies are likely to have under-estimated the need for
large-scale habitat creation, a vital part of the `green infrastructure'
necessary for new and existing communities. Secondly, although
some funding is being made available by the ODPM and other bodies
for green infrastructure, in the competition for scarce resources
(whether from public or private sectors), this type of infrastructure
will inevitably receive a lower priority than transport, affordable
housing and other urgent needs.
(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?
(i) The responsibility for establishing
a sustainable water management regime that protects the environmental
requirement for water, safeguards public water supply and provides
for household growth lies not only with water companies, but with
Government departments, agencies, authorities and regulators.
(ii) Water company water resource plans
finalised in 2004 proposed a number of water resource developments
to help secure supply in the face of rising trends in demand,
not least from a predicted extra demand of up to 1,200 million
litres per day from the growth areas alone. Perhaps unsurprisingly,
water companies had little faith that the "sustainable communities"
would be resource efficient, modelling that they would use between
5 and 8% less water than current building regulation standard
dwellings.
(iii) The RSPB is concerned that these plans
to secure supply to the four Growth Areas involve an excessive
reliance on capital projects (new and bigger reservoirs, desalination,
river abstractions and inter-basin transfers), at the expense
of efforts to restrain the growth in demand. This is unfortunate
as many of the proposed schemes are unlikely to be environmentally
benign. Greater efforts are needed by ODPM and Defra to create
a regulatory and policy structure that promotes, enforces and
rewards efforts to make society resource efficient.
(iv) Pressures are mounting on available
water supplies, and not only from rising household demand and
the growth in number of households. Recent UK water industry research
suggest that up to 1,800 million litres per day of supply may
be lost or restricted in availability due to the impacts of agriculture
(chiefly rising nitrate levels in groundwater). Climate change
predictions have barely begun to be modelled thus far, with the
Environment Agency claiming little impact on resource availability
up until 2020 at least, but after that peak summer demand is expected
to rise further, with corresponding impacts on groundwater yield
and surface water availability.
(v) In southern England, the Environment
Agency have modelled and estimated the effects of levels of housing
growth on public water supplies. The results of the modelling
are stark. Even with construction of the water resource developments
in company plans, more than three quarters of the southeast's
water resource zones will be in summer deficit (many by several
millions of litres per day) by 2025.
(vi) The imperative for the "Growth
Areas" to accept environmental limits and maximise resource
efficiency in their design, should be clear.
(9) Is there sufficient effort being made
by the Government, the Environment Agency and the water companies
to educate people about water efficiency?
(i) While industrial and commercial demand
for water has declined in the last few decades, average domestic
household consumption has risen. While the average rise across
the water companies was just over 3% between 2000 and 2005, consumption
in some parts of southern and eastern England has risen by 5%
(Folkestone and Dover), 11% (South East Water), 10% (Three Valleys
Water), and 13% (Cambridge Water). Rising affluence appears to
lead to rising demand for high water consumptive "luxury"
products like power showers, spa baths and swimming pools. Unless
there is some regulatory or economic intervention, this trend
is likely to continue, as the water industry has recognised in
their modelling of future demand in water resource plans finalised
in 2004.
(ii) We believe that the potential for demand
to be managed and reduced has not even begun to be exploited in
England and Wales. The predicted increases in demand could be
prevented and even reversed if greater action were taken to raise
societal awareness of the issue, and if action were taken to raise
the water efficiency of the existing housing stock.
(iii) Charging by volume used (through metering)
must become the accepted norm as soon as practicable, and the
Government must be more pro-active in promoting metering, which
it has stated it supports, but is currently doing relatively little
to advance. We recommend that water meter installation should
be targeted initially at water resource zones that are predicted
to be in summer deficit by 2025 and/or to zones already showing
environmental stress. RSPB research has shown that vulnerable
groups can be protected from excessively high water bills in a
situation where metering is the norm through the use of tariffs
that provide a low-cost "essential use" block of water
with progressively higher blocks for further non-essential use.
Such a system would have the merit of providing a substantial
disincentive for "luxury" use by ensuring that tariffs
rose steeply on use over and above basic domestic needs.
(iv) We understand that research is being
undertaken into a possible water efficiency labelling scheme for
"white goods". This is a valuable means of educating
consumers and suppliers (which operates successfully in Australia),
and should be adopted without delay.
(v) To avoid a future of drought and water
shortages, the RSPB thinks that it is time that water efficiency
and conservation is taken more seriously across all sectors of
society. Unfortunately, evidence from surveys and water company
research suggests that water customers are increasingly less likely
to follow water company requests to curtail usage during drought
periods. A recent technical report produced by the Environment
Agency and Thames Water, The Effectiveness of Marketing Campaigns
in Achieving Water Efficiency Savings, highlighted the difficulty
of changing customer behaviour when water resources are not considered
an environmental priority and have little public recognition.
The establishment of a body to champion water efficiency, to replace
the current fractured and ineffectual approach, must be an imperative.
November 2005
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