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

Supplementary memorandum by Friends of the Earth (AH 84(a))



  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.


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. 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. Back

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