Supplementary memorandum by Friends of
the Earth (AH 84(a))
CODE FOR SUSTAINABLE HOUSING
SUMMARY
The Code has a potentially vital role in reducing
environmental impacts from housing, particularly carbon emissions.
This will be essential for economic as well as environmental reasons.
However the Code does not do this at present, and is currently
a major missed opportunity. We are extremely disappointed that:
— The scope of code has been reduced
from all buildings to only new domestic dwellings.
— The code remains voluntary for all
private sector housing.
— That PPS 3 (Housing) provides only
the weakest incentive to local authorities to "encourage"
the use of the code and then only on large strategic sites.
We also believe that the reason the code is
currently so weak is because of fears about economic costs of
further action. In this note we set out reasons why these fears
are misplaced, and why a stronger code is good for the economy.
CHANGES TO
THE CODE
1.1 Implementation of the code
Currently the Code is voluntary for private
sector development, and so no matter what the standards within
it, there is no guarantee that house-builders or anyone else will
pay adequate attention to it. The planning system is the one of
the most important mechanisms for securing low carbon development
by enshrining code standards into the development plan system—This
can be achieved simply, via amendments to Paragraph 39 of the
Consultation paper on PPS3:
— replace the word "encourage"
with "require" in both instances;
— insert text "to meet the Code
minimum standard"; and
— remove the text "for strategic
sites that deliver a large number of new homes" and replace
with "for all developments".
These amendments would have the additional benefits
of creating certainty for business and investors by making clear
the general regulatory framework for sustainable construction.
This would correct the current position where some local authorities
require measures such as micro generation on new development and
some do not.
1.2 Standards within the Code
The minimum standards within the code are entirely
inadequate, particularly regarding climate change. For energy
use, the code minimum standard does not even go beyond the new
building regulations despite the fact that far greater efficiency
is technically possible. According to the ENTEC sustainable impact
study[238]
published alongside PPS3, carbon emissions will rise even if new
houses are built to the new building regulation standards. This
is contrary to the Government's own targets for a pathway to 60%
reduction C02 by 2050 (Energy white Paper).
The current Code proposals will lock us into
carbon intensive lifestyles, when far higher standards are possible.
It is particularly important to achieve these standards now given
the opportunity of the planned large scale expansion of housing
development. Retrofitting these new homes would be significantly
more expensive than designing efficient homes from the start.
We advocate that the minimum standard for
energy use should be the BREAM EcoHomes excellent standard.
We welcome the Code's recognition that a 5 star rating should
be awarded to homes meeting Carbon-neutral standard— the
Code should be ratcheted up quickly in future years, so that by
2010, all new homes meet this standard.
1.3 Economic reasons for a stronger code
Economic effects go beyond housing sector
It is important to look at the costs and benefits
beyond the housing sector. Housing accounts for around a third
of the UK's carbon emissions. If we don't prevent dangerous levels
of climate change there will be massive economic costs. In recent
years we have seen hundreds of billions of pounds of damage from
Hurricane Katrina, tens of billions for drought and floods in
Europe, and we are also not immune in Britain—floods in
Carlisle, Boscastle, and York have had major social and economic
costs. Climate change will cause more severe climate disasters
and much greater damage to communities and economies. It will
also be the poorest who will be hit hardest—they are least
able to protect their property and are less likely to be insured.
Climate change will also, affect the economy in other ways—
for example increased spending needed to build flood defences
and protect coastlines: all diverting spending away from other
priorities. Action on housing is urgently needed to prevent economic
damage from climate change.
Economic benefits of building better designed housing
Better designed and more efficient homes have
greatly reduced running cost—a major benefit, particularly
for lower income households who spend a greater percentage of
their income on electricity, heating and water. In the first year
of the Bed Zed development in London, running costs were almost
£500 a year lower than the average UK home—savings
of £80 on electricity, £225 on heating and £170
on water[239].
Economic costs of building better designed housing
Although better designed housing can cost more,
this is a small percentage of total costs, and will also come
down as a greater percentage of greener homes are built. Merton
local authority puts green design at just 2.5% onto building costs241.
Also, as more green homes get built, the unit cost will fall.
The architects and builders at Bed Zed estimate that at just 3%
of new developments, the unit costs would fall to the same as
conventional development.
http://www.odpm.gov.Uk/embedded object.asp?id 1162087
241 Adrian Hewitt's presentation to the Welsh Assembly,
7 December 2005.
238 A sustainable impact study of additional housing
scenarios in England- Back
239
Achieving sustainable communities-the ZED challenge. http://www.zedstandards.com Back
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