Memorandum submitted by WWF-UK
1. EXECUTIVE
SUMMARY
1.1 WWF welcomes the opportunity to provide
evidence to the Environmental Audit Committee for its inquiry
on Greener homes for the future? WWF has extensive experience
and knowledge of the housing sector, formerly through the work
of our One Million Sustainable Homes initiative and more recently
through our One Planet Homes campaign, and our work to deliver
exemplary One Planet Living1 communities across the globe with
our partners BioRegional.
1.2 The target for all new homes to be zero
carbon by 2016 is challenging and it is too early to say whether
it is achievable. WWF supports the phased approach to reaching
the target. The target presents the building industry with opportunities
as well as challenges.
1.3 The UK-Green Building Council's zero
carbon definition report will be published in May 2008. This report
should be considered by the Environmental Audit Committee as part
of its inquiry.
1.4 The impact of progressively tighter
energy efficiency regulations and greater innovations in energy
saving measures will help to stimulate the market for retrofitting
these technologies to the existing housing stock.
1.5 The Code for Sustainable Homes will
lead to innovation and improved best practice in house building
and will help to raise awareness among home buyers. We believe
that transport should feature more strongly in the Code.
1.6 Newly built homes form only a very small
proportion of the overall housing stock. If the targets for reducing
CO2 emissions are to be met the government needs to put much greater
effort into improving the sustainability of existing homes.
1.7 Green belt development should have due
regard to environmental capacity and should seek to reduce the
impact of development in areas where this capacity is already
diminished.
1.8 In the last two years little development
has been made in Infrastructure and what little there has been
is limited to the growth areas.
2. INTRODUCTION
2.1 WWF asserts that it is absolutely essential
that all new housing in the UK reaches the highest sustainability
standards, not only in terms of environmental efficiencies but
also in terms of excellent design and planning. These things should
go hand in hand. Sustainable design is simply good design; that
which will be lasting, sensitive to its surroundings and the wider
environment and from which people derive pleasure. An essential
element of this is siting new developments in the appropriate
location. We must ensure that this programme—acknowledged
as the biggest home building programme for a generation—is
not simply about building homes, it must create vibrant new communities
(as well as regenerating, enlivening and improving existing ones),
offering safe, healthy and attractive places where people want
to move to, and stay.
3. REDUCING CARBON
FROM NEW
HOMES
3.1 It is currently too early to say if
the target for all new homes to be zero carbon by 2016 will be
achieved. WWF has always accepted that industry needs time to
adapt to the stretching new standards set for incremental carbon
emission improvements by 2010 and 2013, and for all new build
housing to be zero carbon by 2016. WWF has consistently supported
this timetable of revision of the building regulations to 2016
to enable industry to respond to this new challenge in a structured
way.
3.2 However, in order for the government
to meet its targets and for industry to be able to respond to
these targets we believe that measures must be implemented to
drive innovation ahead of regulation. As such, WWF has asserted
that the following are required:
— A mandatory rating against the Code
for all new homes in 2008.
— A strong Policy Planning Statement
on Climate Change (supplement to PPS1) which mandates that Local
Planning Authorities should require a minimum of 10% renewable
energy on sites, unless there are very strong reasons why this
cannot be achieved.
— Strategic and Local Planning Authorities
must also be strongly encouraged to set higher standards through
the Code at the regional and local level through planning documents,
particularly in growth areas and where significant development
is taking place.
— Guidance and tools for planners and
developers on taking a holistic approach to community infrastructure
delivery—such as the CLG/WWF/BRE Regional Sustainability
Checklists for Developments2. This tool is specifically designed
(in consultation with planners and developers) to facilitate better
planning decisions for sustainable communities.
3.3 The ambitious housing targets do bring
greater opportunities for economies of scale, for sharing innovations
and best practice, and for delivery of the best quality housing
and communities. We are aware through our conversations with the
industry as part of our benchmarking initiative—NextGeneration—that
many developers are already rising to the challenge of delivering
higher standards more quickly. There are currently many exemplar
schemes taking place across the country to demonstrate that zero
carbon housing can be delivered, such as Barratt's Hanham Hall
scheme.
3.4 WWF is an active member of the UK-Green
Building Council's Zero Carbon Task Group which is working on
recommendations for a final definition of zero carbon. The group
has been considering how to deliver zero carbon "on the ground"
to ensure all housing can meet zero carbon standards regardless
of where it is located. We would like to submit this paper to
the Committee when it has been finalised.
3.5 The progressive tightening of the building
regulations through to 2016 will enable a step change to take
place and for industry to "gear-up" to designing and
delivering more environmentally friendly homes that will meet
the higher levels of the Code for Sustainable Homes. The targets
for 2010, a 25% improvement over 2006 Building Regulations (code
level 3), and for 2013, a 40% improvement (Code level 5), are
achievable with developers already building homes to both of these
improved energy efficiency standards respectively and many are
striving to achieve Code level five and above. It is likely that
the challenge of meeting more energy efficient building regulations
will lead to greater innovation in energy saving measures and
help to stimulate the market for retrofitting energy saving technologies
to existing housing.
4. CODE FOR
SUSTAINABLE HOMES
4.1 WWF welcomes the introduction of the
Code for Sustainable Homes and the government's commitment to
zero carbon homes by 2016 and the proposed interim revisions to
Part L of the Building Regulations in 2010 and 2013. WWF believes
that the Code offers an opportunity for developers to build quality
new homes that, if designed right, can improve the environment
and reduce our carbon and ecological footprints. It also offers
house builders the opportunity to demonstrate innovation in house
building and how well their homes can perform with regards to
the environment.
4.2 The Code also offers an opportunity
to raise awareness amongst home buyers as regards the environmental
performance of their potential new home and also regarding their
personal impact on the environment.
4.3 The mandatory rating is likely to be
enforced through the planning process and the developer/house
builder providing an interim certificate to demonstrate the compliance
of the house(s) prior to completion and then a final completion
certificate being provided to the planning authority upon completion.
The successful enforcement of the mandatory rating is dependent
on the competency of the Code assessors who produce the interim
and final certificates and upon the understanding of the Code
of the local planning authorities.
4.4 While it is difficult to assess the
likely competence of Code assessors it is important to note that
local planning authorities are already under a great deal of pressure
with many having difficulty recruiting and retaining planning
officers. The increased numbers of housing required to 2020 will
put further strain on local planning authorities and without additional
resources it is unlikely they will be able to cope with the additional
number of planning applications alongside the additional requirements
under the code. There will be added pressure for those planning
authorities located in growth areas.
4.5 While WWF strongly supports the Code
for Sustainable Homes there is a distinct lack of detail on links
to transportation and we would like to see this strengthened through
the planning process for new developments.
5. ECO-TOWNS
5.1 Eco-towns are an exciting proposal and
are supported in principle by WWF. However there are concerns
around the wider context that should not be ignored. WWF has three
key points regarding the development and implementation of eco-towns.
— Eco-towns as a proportion of new
build. The Housing Green Paper estimates that two million new
homes will be needed by 2016, and a further million by 2020. The
present 15 Eco-town proposals would deliver around 100,000 dwellings.
Assuming all of these go ahead this would still only deliver just
over 3% of new housing need by 2020. This is a conservative presumption
in this instance as they are likely to be weeded down to at best
ten sites. With this in mind it is imperative that the other 97%
of new builds are also sustainable. WWF feels that the current
trajectory for new build, in carbon terms, is challenging and
ambitious and that if implementation (via 2010, 2013 and 2016
Building Regulation updates) follows regulatory intent the UK's
new build housing sector will be a global leader.
— New build as a proportion of existing
stock. In any one year, new housing completions will be around
1% of total housing stock. Therefore, we need to put much greater
effort into improving the sustainability of existing homes, especially
into their energy and water efficiency, and the sustainability
of their component parts. This area has been less well supported
by successive Governments, partly because retrofitting is expensive,
and partly because improving present stock is inherently less
appealing to politicians (and certainly to developers) than going
for new build. If the Government is to achieve the necessary 80%
reduction in carbon emissions, with 27% of the UK's carbon emissions
coming from housing, it is vital that existing homes are part
of the solution. WWF's How Low? Report3 launched in April
2008, demonstrated that through the implementation of low and
zero carbon technologies an 80% reduction of carbon emissions
from the UK's existing housing stock by 2050 was not only possible
but also cost effective. We would like to submit this report in
evidence to Committee at this stage.
— Eco-towns as stand-alone settlements.
The Eco-towns prospectus stated that Eco-towns should be stand-alone
communities. WWF firmly believes that it is vital for any new
development to be fully integrated with existing communities—thereby
strengthening those communities and improving their environmental
performance and access to local amenities. The previous track
record of the community coherence of new communities has been,
at best, patchy. While some communities, such as Bournville and
Letchworth have eventually matured, it has taken over a century
to do so and other initiatives of the 1950's and 1960's, eg Telford,
Harlow or Livingston, have still not fully achieved the "vibrant"
status that the Government aspires to. It is imperative that although
the Eco-towns are to be new towns, they complement, build upon
and support existing communities and infrastructure. They must
not become "eco-ghettoes" where the benefits are only
felt by those living in the eco-town and no-one else.
5.2 WWF supports the concept that eco-towns
should be exemplar communities that push the boundaries of sustainable
design ensuring maximum reductions of carbon emissions from all
aspects of the town's development. Eco-towns have an opportunity
to demonstrate that sustainable design can work and also operate
as pilots for designs and technologies to be rolled out in both
new build developments and also retrofitted onto existing housing.
5.3 WWF also believes that the final locations
of the eco-towns should be subject to a full ecological site assessment
and that they should be considered carefully so as to limit any
damage to the biodiversity of the area.
6. GREENFIELD
AND GREEN
BELT DEVELOPMENTS
6.1 Greenbelts were implemented to protect
the countryside from urban sprawl, and over the last 60 years
they have served a very useful purpose. Thanks to the greenbelt
policy we are not faced with vast sprawling cities as witnessed
in many parts of the world, particularly in the developing world.
Our cities are contained, with relatively easy access to the countryside
around them.
6.2 The principle of the greenbelt is a
good one; however, many argue that the time has come for a rethink
about its purpose and use. The reality is that to build the almost
one quarter of a million new homes each year (from 2016 onwards)
that the Government proposes, local authorities will need to reconsider
their approach to green belt land.
6.3 Green spaces in cities help to reduce
excess heat in summer (heat island effect) and can alleviate flooding
through natural drainage. Previous thinking has been that greenfield
development is bad and brownfield site development is good, however,
this is a very simplistic view as brownfield land can often be
rich in biodiversity. For example, the black redstart, one of
Britain's rarest birds, favours industrial and urban sites.
6.4 In contrast, land which has been used
for agricultural purposes for generations will be classed as greenfield,
despite the fact that it may have been doused with artificial
pesticides, fertilisers and other chemicals which have effectively
rendered it an ecological desert.
6.5 WWF believes that any developments on
greenfield and green belt land should have due regard to environmental
capacity and seek ways in which to reduce their impact in those
areas where environmental capacity is already diminished. As an
absolute minimum new housing must protect existing wildlife and
make every effort to enhance it for the future.
6.6 If new housing developments are to be
built on greenfield sites then they must have a well designed
and well managed green infrastructure that provides ecological
connectivity through the creation of a network of interconnected
green spaces. This will enable wildlife to traverse urban areas,
and will help meet the need for mobility and resilience for wildlife
habitats in the face of climate change. Currently, this is not
taken into account in any systematic way and should be designed
into any developments and be of a high quality rather than simply
amenity grassland dotted amongst houses.
6.7 All housing schemes should be tested
through Regional Spatial Strategies and Local Development Frameworks
reviews, including adequate Strategic Environmental Assessment
and Appropriate Assessment where necessary. These will ensure
that decisions take full account of evidence on environmental
effects and housing need, plus alternatives for meeting these.
6.8 There is a raft of policies that relate
to housing to ensure that new developments protect and enhance
our biodiversity and therefore any new developments should be
consistent with those policies. For examples, Planning Policy
Statement 9—Biodiversity and Geological Conservation and
its accompanying Good Practice Guide, and the Planning and Climate
Change Supplement to PPS1. Any housing should also be consistent
with the National Brownfield Strategy and where possible contribute
to the targets contained in the national Biodiversity Action Plan.
6.9 In the hierarchy of planning designations
European Special Areas of Conservation and Species Protection
Areas sites are probably best protected, followed by Areas of
Outstanding Natural Beauty and Sites of Special Scientific Interest.
Although this is an appropriate hierarchy it leaves local wildlife
and landscape designations to take their chances against green
belt and green field policies. With this in mind, planning policies
should take into account local biodiversity issues when considering
new developments.
7. INFRASTRUCTURE
7.1 In the two years since the last EAC
report covering this issue progress by the Government in this
area has been slow, and although there has been some movement
in the right direction this has been mainly limited to the growth
areas. Funding that has been made available to the growth areas
has enabled decent master-planning to take place, delivery vehicles
to be set up, and a better dialogue between planning authorities,
developers and the community.4
7.2 WWF believes that the development of
a tariff on new housing has promise. Unfortunately to date this
has only been implemented in Milton Keynes, and is only embryonic
in other growth areas such as Ashford.
7.3 S106 agreements remain the key way that
developments are made to bear the cost of essential infrastructure.
Traditionally, affordable housing, education and transport infrastructure
have been top of the list, with community and the environment
coming lower down. Green infrastructure is not just about wildlife;
it can contribute to flood protection, air quality and public
health. Where tariff or S106 funding is inadequate to provide
green infrastructure the Government needs to ensure that gap funding
is available.
REFERENCES
1. One Planet Living is a joint initiative of
WWF and BioRegional based on 10 guiding principles of sustainability.
The vision of One Planet Living is a world in which people everywhere
can lead happy, healthy lives within their fair share of the Earth's
resources.
2. For more information please visit—www.sustainability-checklist.co.uk
3. To view a copy of the report please visit—http://www.wwf.org.uk/filelibrary/pdf/how_low_report.pdf
4. For more information please visit—http://www.dft.gov.uk/pgr/regional/policy/cif/
12 May 2008
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