Memorandum by the Environment Agency (AH
The environmental impacts of Government's
plans for affordability and the supply of housing will depend
on the location of the homes, the adequacy of environmental infrastructure
and the standards to which new homes are built.
A well-planned approach to building
new homes and other development creates opportunities to improve
and protect the environment. Many environmental concerns can be
overcome if new communities and homes are planned and built to
the highest environmental standards. These standards can also
help improve the overall quality of the environment and create
better places for people to live.
The Government has committed to plan
and deliver environmentally sensitive, well-designed and built
sustainable communities. It would be helpful for Government to
explain what extra measures it is putting in place to do this.
This would help address concerns that housing expansion may result
in a decline in the quality of life for existing residents.
Some of the environmental impacts
of new housing can be reduced if, in parallel, the environmental
performance of existing housing stock is improved. This approach
could also reduce the need for costly infrastructure.
The concept of affordability should
apply not just to the cost of a home but to running costs. Higher
environmental standards in new homes will make houses more affordable
to live in, particularly for those on lower incomes.
1.1 The Environment Agency has an interest
in the environmental impacts of the Government's emerging plans
for improving housing affordability. We are the Government's leading
advisor on the environment. We are already working with national,
regional and local government to ensure that current levels of
planned housing growth are sustainable and that the environmental
risks of development are clearly understood and addressed.
1.2 Through the planning process we:
contribute to national, regional
and local planning frameworks to ensure planning policies are
in place to protect the environment, mitigate impacts and increase
the potential for environmental improvement;
highlight to local authorities the
environmental riskincluding flood riskof individual
planning applications and contribute to the sustainability appraisal
of planning policies, including their Strategic Environmental
provide guidance to developers on
avoiding and reducing the environmental impact of their proposals
and on maximising environmental benefits.
1.3 We also:
advise the Government on the adequacy
of water company Water Resources Plans;
regulate the treatment of contaminated
land and the treatment and disposal of waste; and
are responsible for the strategic
planning, management and delivery of flood risk infrastructure
and flood resilience measures.
2.1 The Barker Review of Housing Supply
proposed that affordability should be part of Government housing
policy and that between 70,000-120,000 new homes may need to be
built each year above current Regional Planning Guidance and Sustainable
Communities Plan levels to make homes more affordable. We understand
Government will, later this year, indicate how it will take forward
its housing affordability agenda.
2.2 If housing growth is to be sustainable,
the impacts on critical environmental factors such as water supply,
sewerage systems, waste disposal facilities, greenhouse gas emissions,
biodiversity and flood risk must be identified and addressed as
an integral part of delivery plans. The Government has acknowledged
this. Its manifesto stated "All newly developed communities
. . . will be built to high environmental standards on issues
such as energy efficiency and water use, and we will develop a
clear plan to minimise the impact of new communities on the environment".
2.3 Current levels of housing growth in
the South and East of the country are already putting pressure
on some resources. It is important that the cumulative impacts
of existing and new levels of house building and occupation are
fully understood. We are not aware that this assessment has yet
been undertaken by Government.
3.1 The location of new communities and
homes determine many of their environmental impacts. Homes and
new neighbourhoods must not be located in areas we will later
regret. Flood risk is a critical locational issue that needs to
3.2 Recent floods, storms and drought have
shown how vulnerable we are to the weather. The floods this summer
in Europe and the events in New Orleans illustrate this very well.
The Government's Foresight Future Flooding report highlighted
that, in the face of climate change, the risk of flooding over
the next 30-100 years increases significantly, and the damage
could be very costly if flood management policies remain unchanged.
Under the most extreme scenario, the annual cost of damage could
increase 20-fold from the current level of about £1 billion.
Research by the Association of British Insurers has shown that
one-third of designated development sites (up to 108,000 homes)
in the Government's South East growth areas are located in the
floodplain, and 10,000 properties may be built in areas with significant
However, these additional risks and costs could be reduced if
new building in high flood risk areas is carefully managed. We
welcome the review of Planning Policy Guidance 25 on development
and flood risk which is intended to give clear advice to local
authorities on the need to avoid development in areas of flood
3.3 Spatial planning should direct homes
to places where the necessary environmental resources are already
in place. It should flag up where new facilitieslike waste
handling facilities and sewage treatment works are needed and
signal where these types of infrastructure are a precondition
of housing growth.
4.1 The residential sector consumes significant
levels of resources. Homes use two-thirds of water put into the
supply network. They use 30% of energy and are responsible for
24% of greenhouse gases. An expansion of housing to meet affordability
objectives could increase the domestic sector's consumption of
resources. However, these impacts can be reduced if higher standards
of environmental efficiency are introduced in new homes. We support
the Government's commitment to introduce mandatory standards for
water efficiency in all new homes. We also support development
of the Code for Sustainable Buildings, due to be introduced in
April 2006, which will specify higher standards (than Building
Regulations) for all new homes built through public private partnerships.
4.2 Together these should improve the water
efficiency of new housing stock. Although England and Wales are
commonly perceived as wet, the high population density means that
for each person there is relatively little water (1,334 cubic
metres per year (m3) on average). Less, in fact, than in most
Mediterranean countries (Spain 2,775 m3/a; Portugal 3,878 m3/a).
In the Thames basin there is only 266 m3/a for each person.
4.3 Across much of the country current abstraction
to support our water use accounts for all the water resources
available in summer months. Climate change is expected to reduce
the availability of water resources.
4.4 The demand for water created by new
and existing homes could partly be met through improved standards
of water efficiency. Our work shows that water efficiencies of
up to 25% per household can be gained by ensuring pipework, fittings
and appliances maintain standards of performance while using less
water. The cost of these efficiencies is modest. In some cases
the cost of efficient units is less than conventional or standard
items. High water efficiency standards applied to all the one
million new homes currently planned for South East England could
save 60 million litres a dayenough to supply water for
4.5 A reduction in the environmental impact
of existing homes could release some "environmental headroom"
for new houses. The majority of households could save up to one
quarter of their current water use. Houses constructed more than
five years ago are likely to present water efficiency opportunities.
For example toilets are the single biggest water use in most homes
and offices. Retrofit or replacement of toilets can save between
8% and 16% of household consumption.
5.1 Our experience of delivery of the Sustainable
Communities Plan shows that accelerated housing growth to meet
affordability targets will, in some places, stretch the capacity
of existing environmental infrastructure. More investment will
be needed in water treatment, waste water drainage, flood risk
and waste management. New investment will be required to service
extra homes and people, particularly where new communities are
being created. These basic services must be properly integrated
into any plans for new housing, so investments are anticipated,
co-ordinated and made in advance.
5.2 For water resources, traditional resource
side options, such as reservoirs, are generally expensive, inflexible
and have high social, economical and environmental costs. In addition,
"large infrastructure projects" may take up to 20 years
to developcommitting customers and society in general to
an ongoing high energy/cost solution. Some new reservoirs may
prove to be necessary, but must be balanced by lower cost, flexible
opportunities to secure more efficient use of existing water resources.
5.3 Demand management options (ie measures
that reduce the use of water by consumers) will mitigate or at
least defer the need to develop some resources. Demand management
is key to establishing an appropriate mix of schemes which are
essential for us to meet the very substantial challenges we are
facing in maintaining secure, sustainable water supplies into
the future. This twin track approach is essential to balance the
social, environmental and economic needs of housing growth.
5.4 The delivery of a longer-term twin track
strategy depends on:
more rapid household metering penetration;
higher water efficiency standards
in new housing stock;
the development of incentives to
encourage retrofit of existing stock;
more public awareness; and
water labelling of fixtures, fittings
5.5 For water quality, a programme of investment
in sewage treatment works will be needed to protect the quality
of our surface waters. The Environment Agency has estimated that
up to 80 sewage treatment works will need to be upgraded in the
South East to service the demand from existing and new housing
being discussed in the draft South East Plan. This figure could
be much higher if there is a step change in housing growth to
meet affordability goals. We are now looking at the level of investment
needed in sewage treatment works across the South and East of
England if Barker type figures are adopted by Government.
5.6 In some locations we doubt whether the
technology exists to meet high levels of water treatment needed
to deal with housing and population growth.
Sewage and waste water
5.7 Concentrated housing growth in some
places will mean that the capacity of sewers will have to be extended
if residents are to benefit from acceptable levels of waste and
foul water drainage.
If, to meet housing affordability targets there
are to be large extensions to existing settlements, our experience
shows that existing waste water and sewage facilities may be inadequate.
A strategic and well planned approach to new facilities will be
required which flags the contributions needed by individual developers.
5.8 The use of Sustainable Drainage Systems
(SUDs) can reduce the need for more traditional forms of waste
5.9 Building new homes creates waste. We
estimate that plans for new homes in the South and East of England
could result in 10.1
million tonnes a year of Construction Demolition and Excavation
Waste (CD & E). Up to 20% of this could be hazardous waste.
5.10 These figures demonstrate the need
to drive down waste arising from construction through:
better on-site sorting;
re-use of excavated inert waste;
use of sustainable construction techniques.
5.11 Investment in new infrastructure will
be needed to deal with:
the municipal waste new households
the move away from the use of landfill;
We estimate that waste management facilities
to deal with up to seven incinerators or 50 waste treatment facilities
will be required to deal with waste from new homes in the South
and East of the country.
6.1 The principle of affordability should
apply not just to the cost of a home but also to the cost of running
6.2 Research by the Environment Agency has
demonstrated that there are financial benefits to householders
of building more environmentally efficient homes. Homes built
to deliver a 25% improvement in resource efficiency, (water, energy
and waste) will deliver reduced utility bills of around £138
a year, a six-year payback on the additional building costs. This
would make the house more efficient to runa critical factor
for lower income householders who pay a higher percentage of their
income in utility bills compared to the more well off. The total
benefits of building to these standards are likely to be much
greater if wider effects on the environment were costed.
6.3 The extra capital cost of delivering
more resource efficient homes is relatively smallwe estimate
just £800 extra capital cost per home. Even if these costs
were passed completely onto the home buyer, only £4 per month
would be added onto a typical £100,000 mortgage compared
to the annual savings of £138 per year.
Over the next two decades demographic
and economic pressures will drive increased demand for housing
in the South and East of England.
Housing growth will result in environmental
pressures. But it also offers opportunities to deliver sustainable
communities. Accelerated house building to meet affordability
targets will add to the environmental impacts being experienced
already in some parts of the country, particularly the South and
The location of homes is the biggest
determinant of environmental impacts. New homes must be located
away from areas of environmental risk.
Investment in environmental infrastructure
and some basic services like sewage and drainage must be a precondition
of growth if the quality of life of residents is to be secured.
Environmental infrastructure must be planned and delivered in
parallel with housing growth.
Resource efficient homes can reduce
environmental impacts, reduce the need for costly infrastructure
and make homes more affordable to run.
198 ABI (2007), Making Communities Sustainable p
7 http://www.abi.org.uk/display/File/Child/554/Making_Communities_Sustainable-housingsummary.pdf Back
Based on housing growth in current and emerging Regional Plans. Back
Based on housing growth in high Barker affordability estimates. Back