Select Committee on Office of the Deputy Prime Minister: Housing, Planning, Local Government and the Regions Written Evidence

Memorandum by the Environment Agency (AH 92)


    —  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 risk—including flood risk—of individual planning applications and contribute to the sustainability appraisal of planning policies, including their Strategic Environmental Assessment; and

    —  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 be addressed.

  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 flood risk.[198] 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 risk.

  3.3  Spatial planning should direct homes to places where the necessary environmental resources are already in place. It should flag up where new facilities—like 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 day—enough to supply water for 500,000 people.

  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.

Water resources

  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 develop—committing 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 and appliances.

Water quality

  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 water facilities.


  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[199] and 13.3[200] 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; and

    —  use of sustainable construction techniques.

  5.11  Investment in new infrastructure will be needed to deal with:

    —  the municipal waste new households generate;

    —  the move away from the use of landfill; and

    —  new recycling targets.

  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 it.

  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 run—a 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 small—we 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 East.

    —  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 Back

199   Based on housing growth in current and emerging Regional Plans. Back

200   Based on housing growth in high Barker affordability estimates. Back

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