Memorandum submitted by Sustainable Development
Commission
SUMMARY
— For the Government to meet its ambitious
targets to reduce carbon emissions in the UK, the proportion of
policy effort devoted to the existing built stock needs to be
considerably greater than that addressing the wider environmental
impact of new build.
— The SDC is keen to ensure that that
the significant profile (in itself welcome) and political attention
given to Eco-towns does not divert effort from the critical importance
of regenerating existing cities, towns and villages. We believe
that making the UK's existing settlements denser and greener,
provides a much greater part of the solution to housing targets
and the need to reduce carbon emissions. The vast majority of
new homes will be delivered in existing settlements, and these
must also be delivered to the highest environmental standards.
— The design of communities is vital
in order to creating sustainable places. Rigorous adherence to
environmental and social standards during build, on-going maintenance
and resident engagement during use are necessary.
— The government has recently put in
place a package of ambitious policies to reduce carbon emissions
from new homes, and improve their sustainability performance.
We welcome these commitments.
— The definition of "zero carbon"
needs clarification as soon as possible, and should prioritise
on site and community scale renewable energy generation. It should
not include allowance for international emissions offsetting.
— Construction of new homes should
account for the full life-cycle environmental impacts of the build—from
the construction of the buildings themselves, and disposal of
any associated construction waste, to the operation of the buildings
and the reuse of resources at its end of life.
— Our research into recent new-build
and regeneration projects highlighted the need for government
to drive its policy ambitions proactively through the long and
complex housing delivery chain, and for more sophisticated monitoring
and evaluation of outcomes.
THE SUSTAINABLE
DEVELOPMENT COMMISSION
(SDC)
The SDC is the Government's advisor on sustainable
development, reporting to the Prime Minister, the First Ministers
of Scotland and Wales and the First Minister and Deputy First
Minister of Northern Ireland. Through advocacy, advice, capability
building and appraisal we help to put sustainable development
at the heart of Government policy. Further information about our
work can be found at: http://www.sd-commission.org.uk/
Our submission does not cover all of the questions
raised by the Committee's call for evidence. Instead, we make
some overall observations about the issues involved, and focus
on some of the questions posed by the Committee.
OVERALL OBSERVATIONS
1. The SDC is committed to helping government
develop policies for affordable homes (to buy or rent), and homes
that will enable sustainable lifestyles. We seek to encourage
developers to make better use of land, and create the new homes
as part of sustainable communities.
2. While this inquiry is focused mainly
on new housing, it is important to note that most of the housing
we will have in 2050 is already built. The construction of 10
Eco-towns will provide only around 3% of the Government's target
of three million new homes by 2020. Tackling the carbon emissions
from our existing built environment is a key priority if we are
to achieve our CO2 reduction target by 2050[45].
3. The delivery of new homes is relevant
to this agenda—our research shows that if new homes are
delivered within or as extensions of existing communities, they
will help to focus investment in these areas and encourage upgrading
of existing homes too. If new homes are delivered outside of existing
communities, they will carry a higher environmental impact and
may threaten the viability of existing communities. The SDC would
like to see Government support for the development of at least
one Eco-town within an existing settlement—as has been proposed
by a number of stakeholders, and by Government itself for the
Thames Gateway[46].
We encourage Government to progress this idea at the earliest
opportunity.
4. In terms of the direct environmental
impact of new build, the 2016 zero carbon homes commitment, the
Code for Sustainable Homes, and the Thames Gateway Low Carbon
and Water Neutrality studies and eco-region focus in the Delivery
Plan[47]
are welcome signs of government taking these issues seriously.
The environmental criteria for Eco-towns are another welcome step
to minimise adverse impacts of new housing and stimulate the market
for more sustainable products and services. Eco-towns can be seen
as large scale pilot developments of zero carbon housing.
5. Nonetheless, we are concerned that the
two million new homes that might be built between now and 2016
(when the zero carbon standard will be introduced) will make it
more difficult for the UK to meet its carbon emission reduction
targets. Much housing growth is also planned in seriously water-stressed
areas.
6. In 2007 the SDC reviewed progress in
delivering sustainable communities to examine the extent to which
government policy was helping to create sustainable homes and
communities on the ground[48].
Through an extensive programme of site visits, public opinion
research, stakeholder interviews, in-depth area studies and desk
research, we assessed delivery against the government's stated
sustainable development and sustainable communities principles.
Despite government's good intentions and pockets of good practice,
overall we found that few communities built so far are living
up to the promise of being environmentally sensitive, well-connected,
serviced and inclusive. Some of the key findings and evidence/examples
follow. The full report is available at: http://www.sd-commission.org.uk/pages/building_houses.html
7. In terms of the wider sustainability
of new housing developments, our research found that some residents
risk moving in to areas lacking good public transport and vital
services. In practice many developers are still funding road-only
mobility solutions and not paying enough attention to public transport.
This can lock people in to motorised and fossil fuel driven transport.
There seemed to be a combination of factors contributing to this
lack of local public services from mismatched and relatively short-term
government funding streams for infrastructure, to location, design
and density decisions. For example new housing on Ashford's outskirts
is disconnected from the town centre, and had been left without
local facilities, schools and bus routes by the time residents
moved in. And with Harlow North an almost entirely separate community
had been planned with little thought of the existing town.
8. It is possible to propose public transport
solutions when all partners work together, as demonstrated at
Eastern Quarry in the Kent Thameside. New build within existing
towns and cities can make use of and increase demand for existing
transport infrastructure and services. This is the focus of the
Growth Points, and we welcome that shift.
9. Effective governance and monitoring arrangements
are critical to ensure government and stakeholders understand
the full impacts of development, and progress being achieved.
While there is national and regional/sub-regional monitoring of
quantitative "output" measures, we recommend to government
that a fuller programme of monitoring sustainable communities
outcomes should be a priority. We believe that evaluation of sustainability
must aggregate impacts across communities as well as within them.
10. We also believe it important that in-depth
(qualitative and quantitative) evaluations are conducted on all
initiatives to build environmentally sustainable housing—eg
Millennium Communities, EP's Carbon Challenge and Eco-towns—
and any lessons learned input to the current programmes to deliver
new homes in existing settlements and new settlements.
11. The SDC hopes that this inquiry will
help inform the brief for the new Homes and Communities Agency.
RESPONSES TO
SPECIFIC QUESTIONS
How should "zero-carbon" be defined?
What role should carbon offsets play in meeting this target?
Zero carbon is currently defined by CLG to mean
that "over a year, the net carbon emissions from all energy
use in the home would be zero"[49].
As a design standard, this needs further definition and working
through to be robust and usable. The SDC considers that the key
questions are:
— what sources of zero carbon energy
are permissible (to ensure additionality in the context of UK
renewable energy policy)?
— how will "all energy use in
the home" be defined to ensure the homes are actually responsible
for zero carbon emissions in operation for their whole life?
CLG is working towards a consultation on the
full definition in summer 2008—the SDC welcomes this process.
This needs to provide certainty to developers to be able to deliver
zero carbon homes, and to deliver the best environmental performance
from homes.
The SDC does not believe that offsetting through
the international carbon offset market should be permissible within
the definition of "zero carbon" homes. Zero carbon policy
should promote energy efficient design and construction of buildings,
and the installation of onsite and community renewable energy
generation in the UK. The cost of installing renewable energy
generation at a "micro" scale on individual homes is
prohibitive in many situations, and there is a risk that individual
systems may not be properly maintained on individual homes. Greater
economies of scale and carbon efficiency can come from installing
zero carbon energy generation at a local "community"
scale, connected to multiple buildings, and this should be allowed
within the definition.
In order to enable all new homes to be built
to zero carbon standards, it may be necessary for house builders
to be able to contribute to the installation of "off site"
renewable generation. This must ensure that:
— this new capacity is additional to
that delivered through other UK renewable energy policies, and
— the supply of zero carbon energy
will be sufficient and guaranteed for the full life of the homes'
operation.
This should be the last resort, with the zero
carbon policy designed to encourage on site and local community
energy generation investment primarily.
Energy consumption in buildings is often found
to be significantly higher than predicted, and the government's
experience in reducing emissions from electricity use for appliances
in new homes is very limited. Electricity use for appliances is
understood to be rising fast[50],
and therefore there is a risk that the renewable energy generating
capacity installed for new homes will not be sufficient to meet
energy demand, leading these homes to draw extra energy from the
grid, which is not zero carbon.
Energy consumption in homes may also be increased
through installation of cooling systems as a response to rising
summer temperatures. Homes should be designed to cope with higher
summer temperatures using passive cooling methods such as shading
and thermal mass to deliver comfort for occupants without resorting
to energy intensive air conditioning.
The SDC recommends that Government should undertake
research on newly completed homes to inform the design standards
for zero carbon homes, ensuring that energy will be used efficiently
within homes throughout their lifetimes, and that renewable generation
will be sufficient to meet demand.
Note that although the SDC has previously recommended
that a mechanism could be developed whereby the emissions from
new homes could be "offset" with emissions reductions
in existing homes in the same region, to give net zero carbon
emissions growth, this is not intended as an alternative to achieving
the zero carbon standard in new homes.
What is the likely scale of environmental impacts
(especially carbon emissions) of the construction of three million
new homes (ie, irrespective of where they are sited)? How should
these impacts be reported? What should be the role of central
Government in minimising them?
In our research for the Foresight programme
on sustainable energy management and the built environment, the
SDC considered the social, economic and environmental impacts
of house building[51].
These include embodied carbon, land use, transport impacts, waste
generation and materials consumption, water consumption, flooding
impacts, air pollution, noise and disruption, and impact on existing
communities.
Existing data concerning the embodied carbon
emissions that result from the construction of new housing (the
carbon emissions that result from manufacture of materials, transport
of components and site activities) is sparse. Published estimates
range through 40[52],
50[53]
to 120[54]
tCO2 for each typical house. This variability of data means that
assessing the total construction impact for the three million
new homes planned by 2020 is difficult. However, it is currently
likely to make up somewhere between 10%-30% of lifecycle emissions
from homes, and this will increase towards 100% of lifecycle emissions
from "zero carbon" homes. Homes that are built to a
higher performance are likely to include more materials (more
insulation, additional ventilation and renewable energy systems)
and therefore to have a higher absolute embodied carbon content.
New homes use four to eight times more resources than an equivalent
refurbishment[55].
We recommend that the Government commissions more extensive research
into the embodied emissions of low and zero carbon housing, to
understand their importance and how they can be reduced.
The extent of land use for new homes depends
on the density of development. Land is needed for the homes themselves
but also infrastructure and amenities. A density of 50 homes per
hectare is a minimum sustainable density to support sustainable
infrastructure such as a regular bus service[56].
Where new homes are built on land of ecological value, this represents
a loss of habitat and biodiversity. Careful re-use of brownfield
land rather than undeveloped green field sites can reduce the
loss of biodiversity and habitat. Where new homes are built on
flood plains, this may increase the risk of flooding of homes
and communities on site, or shift the risk to other sites within
the river catchment.
Waste generated from construction, demolition
and excavation (CD&E) activities makes up 33% of UK waste.
The CD&E sector generates more waste in England than any other
sector, and it is also the largest generator of hazardous waste.
CD&E waste is also a major component of fly-tipped waste.
There are cost-neutral opportunities to use recycled materials
and reuse of CD&E waste on construction projects. But currently
only around 10% of construction materials in new homes come from
recycled sources[57].
New homes will increase demand for water and
wastewater management, with associated environmental impacts of
infrastructure development and water processing. Many sites where
new housing is proposed (particularly in the south east of England)
are water stressed, and have little scope for increasing capacity
of water infrastructure. New homes should be as water efficient
as possible, and the opportunity should be taken to retrofit existing
homes within the region with water efficiency measures to get
as near water neutrality as possible (see water neutrality study
for the Thames Gateway[58]).
New development typically increases the rate of surface water
run off, by reducing the permeability of surfaces to storm water.
This is likely to increase the risk of flooding locally and downstream
of new development sites. However, sustainable drainage systems
(SuDS)[59]
can be used to manage water run offs whilst bringing social and
environmental benefits in new developments.
Around 80% of the UK population live in urban
areas, and existing homes represent 99% of our total stock. Development
of new settlements outside existing declining communities can
create negative effects on the existing community, reducing investment
and even encouraging social polarisation. Lack of investment in
existing neighbourhoods increases the potential for decay and
eventual demolition of these homes, which has brings environmental
consequences including transport, land use, waste and materials
use.
Planning for housing simply on the basis of
demand, risks failing to build proper communities, and the essential
connections between housing, family, facilities, schools, transport
and jobs can be lost. We have already experienced this problem
with the earlier generation of new towns, which in only rare cases
have become sustainable communities. New homes built outside existing
communities are likely to generate major transport impacts due
to the need for residents to commute to different settlements
to see family, reach facilities, schools and jobs. Unless essential
public transport infrastructure is installed in new developments
from the start, residents will invest in a car and be "locked
in" to an unsustainable transport pattern, leading to carbon
emissions, air pollution, road safety impacts and congestion.
The Code for Sustainable Homes covers many of
these environmental impacts of new build housing, and the recent
requirement for mandatory rating of new homes against the Code
criteria is helpful in this regard. The rating achieved by homes
should be monitored by Government and published. If the uptake
of the higher standards of the Code is low, and therefore environmental
impacts are not being controlled, the Government should consider
ways to encourage uptake. The Government should consider including
wider environmental impacts of construction (including embodied
energy) in the Code for Sustainable Homes once sufficient evidence
is available.
Environmental criteria for eco towns are important
to ensure that these developments will lead the way with reducing
all the environmental impacts, and raise understanding in government
and industry of the techniques that can be used and standards
that can be achieved. The criteria therefore need to be ambitious,
and the learning for all future development (whether in new or
existing settlements) maximised.
As currently envisaged, how big a contribution
will [Eco-towns] make to reducing the environmental impacts of
housing in England-both in their own right, and in the development
of design and techniques that could be rolled out in other developments?
Ten Eco-towns will contribute at most 100,000
homes according to current proposals. This represents only 3%
towards the three million new homes target set by the Government
for 2020. Thus Eco-towns should be viewed as pilot programmes
to generate action research in how to build zero carbon housing
on a large scale, in readiness for the introduction of the zero
carbon housing standard for all homes from 2016.
It is important to remember that Eco-towns (and
in fact nearly all new housing) are additional to existing housing
stock. As such zero carbon eco-towns will reduce the projected
increase in emissions, not reduce overall emissions.
Learning from the Eco-towns as well as from
the Carbon Challenge developments and Millennium Communities needs
to be coordinated to ensure that lessons can be learnt and disseminated
widely.
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?
The SDC is pleased that the government's "brownfield"
target of 60% of new developments being built on previously developed
land is being exceeded. However, this still means plenty of "greenfield"
land is being used for housing. A critical issue here is that
there can be significant local variation—for example our
research in south Cambridgeshire indicated that only 37% of new
building in the area is expected to be on brownfield land. The
SDC's concerns here are not just about direct land use, they are
also about making the most of existing communities, helping to
ensure they remain vibrant and have good local services.
It is right that plans reflect local context—for
example that not all land within towns and cities is built over
because communities need good quality open spaces (gardens, parks,
informal shared spaces, allotments etc). However, because of the
sustainability benefits of development within existing communities,
we believe that government should extend/revise their brownfield
target further subject to robust and detailed evidence of availability
and use of brownfield sites. Stretching individual minimum targets
should be set for Growth Areas/points to help meet the national
figure. For example, the Government is aiming to achieve 80% of
development on brownfield land in the Thames Gateway[60].
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?
As outlined above, our evidence suggests that
the picture on infrastructure delivery is mixed. There are some
positive examples, like the bus service for the Eastern Quarry
development, and residents we interviewed in Barking and Dagenham
were satisfied with their local facilities. However, developments
in the outskirts of Ashford were lacking key services and were
largely satellite housing developments.
The government's new PSA framework should help
improve collaboration across government, by directing the right
infrastructure to new developments in a more timely and joined-up
way. Nonetheless, ensuring that the next phase of new housing
is delivered in ways that create genuinely sustainable communities—socially
just, thriving, and living within environmental limits—will
be a big challenge for the new Homes and Communities Agency.
1 May 2008
45 SDC (2006) Stock Take-delivering improvements
in existing housing Back
46
CLG (2007) Thames Gateway Delivery Plan Back
47
CLG (2007) Thames Gateway Delivery Plan Back
48
SDC (2007) Building Houses or Creating Communities? A review
of government progress on sustainable communities. Back
49
CLG (2007) Building a Greener Future: policy statement
http://www.communities.gov.uk/documents/planningandbuilding/doc/Buildingagreenerfuture Back
50
See for example ECI (2005) 40% House Back
51
Power (2007) Paper for the Foresight Programme on energy and
the built environment: does demolition or refurbishment of old
and inefficient homes help to increase our environmental, social
and economic viability? -unpublished paper for Foresight Sustainable
Energy Management in the Built Environment study. Back
52
J. Hacker et al (2007) Embodied and operational carbon dioxide
emissions from housing: a case study on the effects of thermal
mass and climate change http://www.concretecentre.com/PDF/RR_Embodied_Operational_CO2.pdf Back
53
Empty Homes Agency (2008) New tricks with old bricks Back
54
Regeneration & Renewal (2008) Uncertain calculations; renovation
versus rebuilding, 22 February 2008 Back
55
Empty Homes Agency (2008) New tricks with old bricks Back
56
Power et al (2004) A framework for housing in the London Thames
Gateway. LSE Housing and Enterprise LSE Cities. Back
57
See WRAP: http://www.wrap.org.uk/construction/construction_procurement/case_studies/housing.html Back
58
Environment Agency (2007) Towards water neutrality in the Thames
Gateway: Summary report Back
59
See CIRIA: http://www.ciria.org.uk/suds/background.htm Back
60
CLG (2007) The Thames Gateway Delivery Plan Back
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