Memorandum submitted by The Institution
of Civil Engineers (ICE)
The Institution of Civil Engineers (ICE) is
a UK-based international organisation with over 75,000 members
ranging from professional civil engineers to students. It is an
educational and qualifying body and has charitable status under
UK law. Founded in 1818, the ICE has become recognised worldwide
for its excellence as a centre of learning, as a qualifying body
and as a public voice for the profession.
Our evidence focuses on the need for sufficient
and sustainable infrastructure to support new housing developments
and the existing housing stock, and to a lesser extent on reducing
carbon emissions and eco-towns.
SUMMARY
— Increased energy efficiency in the
construction process and large reductions in the whole life energy
use and emissions from homes will be needed to enable the government
to meet its carbon targets.
— Government must also however drive
the creation and upgrade of sustainable and energy efficient infrastructure
to support "zero-carbon" housing developments.
— Plans for the delivery of "zero-carbon"
homes should encompass the retrofitting of existing dwellings.
— Government can do much to provide
the stable market conditions, within which will provide the confidence
industry needs to invest in developing the skilled individuals
and innovative practices required to deliver greener homes and
supporting infrastructure.
— To this end ICE calls for the establishment
of a Strategic Infrastructure Planning Body to help co-ordinate
infrastructure spending programmes across government, provide
improved information to the market and reduce unpredictable, stop-start
investment and procurement.
1. REDUCING CARBON
EMISSIONS FROM
NEW HOMES
Is the target for all new homes to be zero-carbon
by 2016 on track to be achieved? Does the Government need to do
more to deliver this target?
1.1 ICE believes that the Government is
unlikely to meet its "zero-carbon" target for all new
homes by 2016. The response to your other questions below will
provide reasons for our statement.
How should "zero-carbon" be defined?
1.2 ICE is concerned that the Government
did not satisfactorily define "zero-carbon" before its
"zero-carbon" targets were set. We believe that the
Government's existing loose interpretation for stamp duty relief
purposes, that homes should be heated and powered without the
use of fossil fuels is inadequate. This definition also differs
from those outlined in its Homes for the Future White Paperi issued
by the Department of Communities and Local Government.
1.3 Numerous elements must be included within
a definition of "zero-carbon", extending beyond the
structure itself.
— A "zero-carbon" home should
be defined as highly insulated and use onsite or community level
renewable energy for lighting, and heating or cooling.
— A home should only be labelled zero-carbon
if it is measured over the life cycle of the building. For instance,
a home cannot be "zero-carbon" if it is constructed
a large distance from services and centres of employment, access
to which would require a lengthy car journey.
— The carbon footprint of supporting
infrastructure should be included when measuring the environmental
impact from new housing. Homes with very low ongoing emissions
will not deliver a net saving if it is at the expense of extra
supporting infrastructure.
— "Zero-carbon" should also
include a measure of embedded carbon not simply emissions from
related to heating and power supply. Materials that have been
produced with low carbon emissions and its supporting infrastructure
should be used if carbon-neutral housing is to be delivered.
1.4 The construction industry needs a government
endorsed, and standardised means of calculating the carbon cost
of the initial construction, consequent maintenance and operational
energy costs of a home.
What role should carbon offsets play in meeting
this target?
1.5 ICE believes that at present any move
to have a large offsetting component within any definition of
zero carbon would be inadvisable.
1.6 Offsetting should not be used as a way
of circumventing carbon use. There is not enough woodland in the
UK to use to offset all the existing carbon emissions let alone
a small increase from new homes.
What impact will the progressive tightening of
energy efficiency building regulations have up to 2016?
1.7 Building regulations and the planning
system are both crucial elements in the move towards "zero-carbon"
buildings, and to encourage good practice. Progressive tightening
can help improve the introduction of new energy efficiency measures
and speed innovation.
1.8 However enforcement of the building
regulations remains a key issue. There is no value to making the
regulations more stringent if local government is not given the
resources to ensure completed buildings meet them.
2. ECO-TOWNS
As currently envisaged, how big a contribution
will they make to reducing the environmental impacts of housing
in England-both in their town right, and in the development of
design techniques that could be rolled into other developments?
2.1 ICE believes that new eco-towns will
contribute very little to reducing the environmental impact of
housing in the England, especially as they are being used to house
an ever increasing population.
2.2 There should be an increased focus on
allocating resources to increasing the energy efficiency of the
existing housing stock and developing the sustainability of existing
communities through improvements in local services and infrastructure.
2.3 The most pressing issue for energy efficiency
and housing is how to bring the existing housing stock up to an
acceptable standard. In this context the Government also needs
to understand the implications of rising population levels on
the use of the existing housing stock and the demands placed on
transport, waste, water and energy infrastructure.
2.4 The construction of towns does not equate
to the delivery of communities. In the past, the UK has not experienced
great success with "making" new towns as communities,
as the multi-faceted social aspects of communities are often ignored
because they are poorly understood.
CODE FOR
SUSTAINABLE HOMES
(i) What impact is the Code for Sustainable
Homes likely to have on the construction and purchase of new homes?
2.5 ICE welcomed the introduction of the
Code for Sustainable Homes, and in particular the promise that
it will flag upward movements in the Building Regulations, allowing
the main body of the industry valuable time to adapt.
2.6 Successive changes to the Building Regulations
since the early 1990s have led to significant improvements in
the energy/carbon performance of buildings, with energy efficiency
standards for new buildings now 40% higher than in 2002 and 70%
higher than 1990. However, the low replacement rate of the UK's
building stock has meant that reducing the UK energy requirements
needed for heating and cooling buildings has not moved on at great
pace.
How well is the mandatory rating likely to be
enforced?
2.7 We are not in a position to answer this
question.
Should the Code be changed in any way?
2.8 The Code for Sustainable Homes does
not contain any requirement for smart metering systems—these
have proven benefits in empowering building users to be more aware
of their energy and water consumption patterns and indentify low
cost actions to reduce demand.
2.9 There was initally some confusion as
to whether the code was seeking to set a new baseline standard
or a high peformance aspirational benchmark. We therefore welcome
the government's recent confirmation that all new homes will receive
a rating against the code from 1 May 2008. Such reporting may
in practice be more effective in driving change than a very high
aspirational, voluntary standard.
2.10 The code has narrow boundaries, covering
making housing units, fittings and appliances more sustainable.
To get a true picture of the sustainability performance of a house
would require a series of life cycle assessment of the structure
and fittings to be carried out in the context and location in
which they are being used. Users should be made aware of these
limitations.
(ii) Greenfield and green belt developments
2.11 No comment.
To what extent do, and should, planning controls
protect Greenfield and green belt land from development of new
housing? How adequately are environmental considerations (for
instance, biodiversity and rural landscapes) being taken into
account in deciding the location of new developments?
2.12 No comment.
3. INFRASTRUCTURE
What progress has the Government made, in the
two years since EAC's last report on this issue, in ensuring that
new developments are being built with adequate infrastructure
in order to make them successful and sustainable?
3.1 ICE is concerned that new home development
and so-called sustainable communities are not being afforded adequate
supporting infrastructure.
3.2 While ICE welcomes the £14 billion
Government spent on infrastructure in the three main regions of
growth (London, the South East and East) during 2006-07ii, we
believe that the UK still faces an infrastructure deficit that
requires significant investment across all sectors, including
transport, waste management, energy, flood defence, water and
waste water, and ports and harbours. This includes a renewal of
ageing infrastructure to meet new demands and regulatory changes.
3.3 As identified in the Eddington Reportiii
to government in 2006, this infrastructure is vital for enhancing
the UK's long-term economic competitiveness and for improving
the nation's quality of life, and needs not only immediate, short-term
solutions but also longer-term managed renewal.
3.4 Water resources need particular attention
especially in the context of climate change where the likely stress
on water resources in the South East of England has already been
highlighted. The demand for water in the region is growing because
of population growth and new housing development, among others.
3.5 We draw the Committee's attention to
two issues in particular:
— HM Treasury sponsored Barker Reviewiv
on housing supply identified significant additional needs in the
South and East of England. We are not aware of that there is a
current water supply solution to the high housing growth it suggests,
although demands could be met by new resource schemes currently
being considered in the South East, combined with more demand
management.
— In 2005, the forward plans of water
companies in the South East of England included projections for
new housing growth that were 20% lower (up to 2016) than the projections
contained in the government's Sustainable Communities Planv.
3.6 The Government must recognise that water
supply for new homes, particularly in the South East of England,
will be inadequate unless plans are made now to invest in new
water supply resources (potentially including new reservoirs)
and measures to implement demand management are introduced.
3.7 In addition, consideration should be
given to dual-use water supply, using a mix of fresh water for
potable uses and recycled water—grey water—from domestic
properties (eg baths, sinks, showers) for flushing toilet systems
and watering gardens.
3.8 The collection, treatment and disposal
of wastewater also needs to be dealt with more effectively. The
appropriate area scale for wastewater treatment needs careful
consideration to avoid wastewater being transported over large
distances for treatment, or to be treated at so local a scale
as to add unnecessary risk to public health and environmental
pollution.
3.11 Flood risk must be effectively managed
especially for extreme events which are set to become more frequent
with the impact of climate change. Increasing development on flood
plains increases the numbers of properties vulnerable to flooding
and can exacerbate existing flood risks by reducing drainage opportunities
for surface water and placing additional pressure on often ageing
drainage infrastructure.
3.12 In the longer term, and in the context
of climate change pressures, many areas of the UK will need to
make more widespread use of non-structural and sustainable flood
management measures, planning for which should begin now.
Skills and capacity to deliver supporting infrastructure
3.13 In reports published in 2005vi and
2006vii, ICE has called for greater investment in the infrastructure
that is critical to the delivery of sustainable communities. These
calls have been met with some success as demonstrated by commitments
in the recent Comprehensive Spending Review with major investments
in road, rail, energy, flood defence, waste management, water
supply and many other infrastructure schemes in the pipeline However,
to ensure these funds are spent effectively government and industry
must co-operate to make the most of the UK's existing capacity
to deliver major infrastructure and create the conditions to increase
that capacity.
3.14 However, the fundamental lack of clarity
of the future investment plans across infrastructure networks,
stop-start public spending, a lack of co-ordination of public
sector procurement, and lengthy delays in the planning process,
are having a profound effect on the engineering and construction
industry's ability to deliver this infrastructure at best value.
3.15 As a result we are concerned that the
UK civil engineering industry is facing a capacity and skills
shortage, a key factor affecting construction inflation which
is currently running at a rate well above the Consumer Price Index
(CPI). The current construction inflation rate is estimated to
be 6-6.5%. Continued inflation on this scale would put sever pressure
on the viability of public and private sector infrastructure investments.
3.12 In our January 2008 report State
of the Nation—Capacity and Skillsviii we have set out
the case for a Strategic Infrastructure Planning Body to help
co-ordinate infrastructure spending programmes across government,
improve the volume and reliability of the information available
to the market on future demand and reduce stop-start investment
and procurement.
REFERENCES
i Communities and Local Government, 2007, Homes
for the future: more affordable, more sustainable—http://www.communities.gov.uk/publications/housing/homesforfuture
ii Ibid.
iii HM Treasury, 2006, The Eddington Transport
Study, Her Majesty's Stationery Office, Norwich—http://www.dft.gov.uk/about/strategy/eddingtonstudy/
iv HM Treasury, 2006, Barker Review of Land
Use Planning—Final Report-Recommendations, Her Majesty's
Stationery Office, Norwich—http://www.hm-treasury.gov.uk/media/3/A/barker_finalreport051206.pdf
v Office of the Deputy Prime Minister, 2003,
Sustainable Communities: Building for the Future, Crown
Copyright—http://www.communities.gov.uk/communities/sustainablecommunities/sustainablecommunities/
vi Institution of Civil Engineers, 2005, State
of the Nation, Institution of Civil Engineers, London—http://www.ice.org.uk/downloads//state_of_the_nation_2005.pdf
vii Institution of Civil Engineers, 2006, State
of the Nation, Institution of Civil Engineers, London—http://www.ice.org.uk/downloads//State%20of%20the%20Nation%20report%202006.pdf
viii Institution of Civil Engineers, 2008, State
of the Nation; Capacity and Skills, London—http://www.ice.org.uk/downloads//sotn2008.pdf
25 April 2008
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