Joint memorandum submitted by Three Valleys
Water, Tendring Hundred Water and Folkestone & Dover Water
This response to the Environmental Audit Committee's
call for evidence represents the view of Three Valleys Water,
Tendring Hundred Water and Folkestone & Dover Water.
A THE CODE
FOR SUSTAINABLE
BUILDINGS (CSB)
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?
It remains unclear just what the CSB will involve.
Some have suggested that it may represent a token gesture. Others
have already criticised the fact that the code ignores specific
procedures. It is probably still too early however to criticise
the detail of the code. However we are of the view that the code
would be a valuable step to accelerate the implementation of water
efficiency measures in buldings and as a group we have been supporting
the development of similar standards such as BREAM.
Developers are commercial businesses and have
hitherto delivered what the market wants. In a rising housing
market with insufficient house building this translates into as
many houses as possible as quickly as possible. In this case it
is most probable that developers will only work to minimal building
regulations. When the property market is stagnant that developers
are forced to differentiate their properties and will endeavour
to develop added value, which could come in the form of adherence
to the new code. The Barker Report indicates that demand will
continue to outstrip supply for some time as such it is unlikely
that the new code will be successful in the short term. However
land is scarce in the southeast and building in the green belt
is a major issue. Developers are working to influence this planning
process. The code could be a valuable benefit to demonstrate eco-credentials
in seeking planning approval.
Alternatively if there is a fundamental change
in personal attitudes such that the consumer begins to demand
housing that complies with the new code. Then developers may be
forced to react. The current position is that homebuyers are not
demanding sustainable buildings. Attitudinal change will not be
easy to achieve and will probably require a consistent message
to be delivered by all parties over a number of years.
Given the targets for affordable housing that
sit within the Sustainable Communities Plan, planners and housing
associations have a strong role to take a lead in ensuring that
the CSB is adhered to and we welcome the Government's lead here.
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?
Promotion has been muted to date. There appears
to be little more than a short press release from Defra, which
resulted in a number of short articles in the construction press.
There is probably an element of awareness therefore within the
construction industry. But it is not clear that a wider awareness
or desire has been generated in the house building and planning
community by the limited publicity to date. It may well be that
a much larger PR campaign will accompany the code on its official
launch.
3. Should the Government be introducing fiscal
measures to reward higher building quality and greater environmental
performance?
Fiscal measures would clearly act as an added
incentive to reward higher build quality and greater environmental
performance. This has been considered as a broader measure, which
should apply to all properties much along the lines of the energy
efficiency commitment. The idea has been promoted by the IPPR
in their publication "Managing Water Resources and Flood
Risk in the South East". We would support a range of fiscal
measures to encourage the take up of water efficient technology
and to assist in reinforcing the water efficiency message.
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?
There is a chapter (nine) in the Five-Year Plan,
which deals with the environment. From a water company perspective
there is however only one relevant line "conserve water resources"
which occurs under the heading "six principles of sustainable
construction" Nowhere else in the chapter is water resources
or water efficiency mentioned. As a result we are left with the
feeling that water efficiency messages were overlooked although
we recognise that there has been much recent debate which is more
encouraging, such as work to change the Building Regulations.
5. To what extent does the Five-Year Plan
address the environmental implications of the geographical distribution
of demolition versus new build?
It is not clear from the Five-Year Plan that
this has been addressed in a coherent way. There are certainly
no policy statements on the subject. For water resource planning
it is important to know not only where new homes are to be planned
but also where demolitions will occur and hence where demand will
be reduced. We would welcome more clarity on this important area.
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?
We are not able to comment as we were not invited
to participate in this consultation.
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?
We are actively following the Sustainable Communities
issues at various for a as our customer base and infrastructure
provision will be significantly affected, in particular by the
M11 developments. We have been disappointed in the level of involvement
in the discussions from Government but remain committed to work
with other parties to ensure the efficient provision of infrastructure.
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?
The three water companies in the Veolia Water
Group endeavoured as far as was possible at the time, to incorporate
announcements by the ODPM regarding sustainable communities in
their 2004 Water Resource Plans. Subsequent releases of the London
Plan, East of England Plan and SouthEast Plan have provided detail
on the likely numbers. The distribution of housing is slightly
different from that within the Water Resources Plan however the
future water resource situation is not sensitive to these distributional
changes. As such the Veolia group is confident that security of
supply within the group has been adequately planned.
It is important to note however that water companies
plan on the basis of a level of service that includes for demand
restriction at a given period. This is important to ensure that
the environment is protected in the most severe weather conditions.
Restrictions on water supply are therefore not a mismanagement
of the resource but rather a prudent approach to water resources
planning.
9. Is there sufficient effort being made
by the Government, the Environment Agency and the water companies
to educate people about water efficiency?
The Water Industry have joined together to implement
Waterwise. Waterwise is aimed at increasing the profile of water
efficiency in the UK and Europe. The lack of funding in the 2004
periodic review for water efficiency research and publicity severely
restricts the abilities of companies to further the water efficiency
message. The EA are also financially constrained when it comes
to publicising the water efficiency message.
In addition to water companies, central and
local Government, the water industry regulators (Ofwat, Drinking
Water Inspectorate and Environment Agency) and environmental bodies
(such as English Nature), all play a key role in determining policy
and influencing supply-demand investment. It is therefore important
that there is joined-up policy and regulation. Closer integration
between these public bodies is still required to achieve a sustainable
supply-demand position across the UK, in particular:
Further regulation on water-saving appliances
is required to ensure that all new appliances are very water efficient.
Water companies were disappointed that proposed water efficiency
measures submitted as part of the 2004 water price review were
(with a few exceptions) excluded from price limits by Ofwat. There
is a need for Ofwat, Environment Agency and water companies to
work closer together to agree the need and funding for water efficiency
measures.
There is a need for Government and regulators
to agree on the explicit inclusion of supply-demand investment
arising from climate change impacts in water pricing reviews.
The next review is in 2009. This is essential to ensure that water
companies can implement actions in time to avoid more severe water
shortages in the future. Whilst it will not be possible to determine
precise impacts, measures to increase the resilience of water
supply systems to climate change will be needed in the medium
term (next 10 years).
The ippr have suggested that a new water efficiency
commitment along the lines of the energy efficiency commitment
would be a step forward in promoting water efficiency. We would
welcome such a move.
November 2005
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