Memorandum submitted by the Green Party
SUMMARY—THIS PAPER PRESENTS OVERALL
COMMENTS BEFORE ADDRESSING THE SPECIFIC QUESTIONS OF THE INQUIRY
IN SECTION 4 BELOW
1. PRIORITISE
IMPROVEMENT OF
EXISTING NOT
BUILDING ON
GREENFIELD AND
GREEN BELT
The government's current proposals for housing
focus on predict and provide, responding to economic analysis
completed before the house price crash.
Instead of this approach, which is leading to
a propensity to plan for too much unaffordable housing to be built
in the wrong places (and subsequent over-build), the government
should take a different approach. Housing supply should be within
environmental limits, and should target affordable housing, where
it is needed.
This will mean an overall change in housing
strategy, prioritising all of our towns and cities to become sustainable
communities, through a focus on retrofit (for example, looking
beyond the current grants in cavity wall insulation which by-passes
the one third of UK housing with solid walls).
So instead of eco-towns to make up a small percentage
of new housing, green and affordable homes, should be provided
for all.
2. AN ALTERNATIVE
PROPOSAL FOR
NEW HOMES_AFFORDABLE
HOMES IN
THE RIGHT
PLACES
Therefore, we propose that instead the government
should seek to:
— maximise the availability of truly
affordable housing within new developments;
— make funding for social housing a
priority;
— oppose privatisation of the ownership
or management of social housing; and
— oppose new building on Green Belt
land or on flood plains.
Therefore we would propose that:
— the Government ends its homes-follow-business
strategy, by spreading economic activity more evenly over the
country;
— the government replace its current
target for total number of houses (which the private sector may
or may not choose to deliver) with a target for affordable housing.
This should both include national funding for truly affordable,
good quality housing and money for buying, improving and converting
existing dwellings;
— the government force empty properties
into use through Empty Property Use orders;
— increase regulation of private sector
rents and lettings; and
— ensure all new houses are built to
much higher environmental standards in the right places, with
post construction monitoring and post occupancy evaluation to
ensure provide feedback to design and ensure it is not zero carbon
house design, but zero carbon home delivery.
3. ARGUMENTS
FOR THE
PROPOSAL
The Government argues that three million new
homes are needed based on economic projections of supply and demand
by 2020,[64]
most of them in the South, to accommodate rising population and
smaller household size and "solve" the affordability
issue. To do so they propose allowing the private sector to build
new homes and towns on both greenfield and brownfield sites, sometimes
on floodplains.
We argue that this is misconceived in two ways.
First, the real crisis is in affordable homes
for mainly young families, and that is where the effort should
be concentrated; in 2002 only 37% of new households could afford
to buy a property compared to 46% in the late 1980s.[65]
There is no evidence that the new building planned will have any
appreciable effect on house prices; doubling the supply of new
houses[66]
is still likely to lead to house prices increasing at a real rate
of over 1% pa.[67]
Affordability needs to be addressed directly; simply increasing
the supply just ruins the environment without helping young families.
The South, especially the South East is already
overcrowded. The economic over-development of the South East is
part of the problem. But we are not saying no new homes in the
South_affordable homes are very necessary there because prices
are so high. The main reasons for housebuilding is internal migration
in the UK and reducing household size and is already leading to
over-development in some places and for some housing types.
Second, we already have 700,000 empty homes,[68]
and many more homes that are either underused, in poor condition
or in places of lower economic activity. We should consider first
encouraging economic activity and re-building communities in these
areas, repairing houses, buying existing houses for social use
or ensuring empty houses are used before building new homes.
4. RESPONDING
TO SPECIFIC
QUESTIONS HIGHLIGHTED
IN THE
INQUIRY
4.1 Zero Carbon Home Delivery now—not
zero carbon house design in the future
Government Policy—All new homes are to
be zero-carbon by 2016, with a progressive tightening of mandatory
energy efficiency standards up to that date. The government projects
that meeting this target would save at least 15 million tonnes
of CO2 per year by 2050.
Government predictions of the amount of energy
they will save through Building Regulations in England, Wales
and Scotland is 9.9MtCO2 by the end of 2016.[69]
This makes a mockery of government plans to actually deliver savings
in home energy use in the UK. These figures have not only ignored
advice of the Environment Select Committee on housing[70]
but also conveniently ignore research they have commissioned that
shows that around 43% of new homes fail to meet building regulations
AND the actual energy savings achieved in practice are only 50%
of predicted savings. This means that we have a hole in the UK
carbon budget of at least five million tonnes CO2/year. It could
be much bigger except the government has never bothered to actually
find out the actual standards for what is being built today.
Firstly, buildings are not actually achieving
the energy efficiency requirements in the building regulations—as
these are not enforced. There has never been a prosecution. The
total amount of new buildings that fail building regulations is
43%.[71]
The amount of savings are not known as new homes are not to be
monitored to see if they meet the regulations. The only place
where this is happening is a voluntary initiative where a group
of house builders have agreed to monitor energy use for two years
once houses are constructed.[72]
This monitoring will highlight the second (main) problem as follows.
Secondly, the actual savings that are achieved
by building regulations improvements do not just depend on the
construction industry but on how we choose to live in houses.
Based on government's own statistics only half of the building
regulation carbon savings will be turned into actual savings.
Research for government by the Building Research Establishment
shows that the past 30 years of energy efficiency improvements
have only resulted in half the emissions savings that are predicted,
partly as we choose to heat our homes warmer—by around seven
degrees since 1970. For example, Chris Sanders and Mark Phillipson
of Glasgow Caledonian University[73]
note that, "it is possible to quantify either a reduction
factor or a comfort factor from five of the reports. These figures
suggest that the best estimates for the reduction factor and the
comfort factor expressed as a percentage of the theoretical expected
energy savings are: Reduction factor: 50% of which Comfort factor:
15%.
This means that the amount of carbon savings
from the introduction of Building Regulations could be an over-estimate
by at least a factor of two. The government is conning us that
is acting on climate change—while the reality is they are
not." This is not just about making false promises in how
the government plans to cut CO2 emissions here but also affects
the degree to which the UK fails or succeeds in complying with
the European Union's Energy End-Use Efficiency and Energy Services
Directive, which requires a 9% energy saving target by 2016.
Therefore, the specific carbon reductions claimed,
due to higher building regulations are probably over stated by
around a factor of two—7.5 million tonnes of CO2.
Also, a number of wider factors mean that the
overall impact is likely to increase, as opposed to reduce, total
carbon emissions:
(i) energy consumption has consistently been
proportional to energy use per home, so increasing the number
of homes will tend to push up overall energy use. A reduction
of overall energy use from the domestic sector requires improvement
(retrofit) of existing homes;
(ii) only around 50% of the energy savings due
to improvements in building regulations are likely to be realised
(research by Caledonian University shows this is due to a combination
of quality of construction and occupancy, including choosing increase
in comfort accounting for around 15% of the difference); and
(iii) need to account for the energy involved
in the construction of new homes—which is significant compared
to 50% of the predicted savings from building to new building
regulations.
Is the target for all new homes to be zero-carbon
by 2016 on track to be achieved?
Many housebuilders and local authorities are
already exceeding the government's targets for zero-carbon new
houses. For example, one developer has an internal target to deliver
50% to code level 4 and the London Borough of Sutton now requires
all houses to be delivered to Code Level 3. This is three years
ahead of the government's schedule.
Does the Government need to do any more to deliver
this target?
Based on the above, the government should provide
more leadership to accelerate the process to ensure that all local
authorities and housebuilders keep track with best-practice.
How should zero-carbon be defined? What role should
carbon offsets play in meeting this target?
Current zero-carbon is net-zero carbon in-use,
in theory, at the design stage. Carbon reductions should be reduced
to zero-carbon for all existing and new homes including construction,
occupation, maintenance, renovation and deconstruction. Zero-carbon
should apply to both existing homes (reducing net environmental
impact) and new homes (not increasing environmental impact). Both
of these must be achieved—not offset between them.
How should compliance with the targets be measured
and enforced?
There is interesting work to draw on in terms
of requirements and measurement (post construction monitoring
and post occupancy evaluation—see Good Homes Alliance
for examples, as noted above)—that should be, and enforced.
There is currently insufficiently effective monitoring of actual
construction delivery.
4.2 Ecotowns[74]
and Code for Sustainable Homes
Q—As currently envisaged, how big a contribution
will they 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?
Government Policy—10 new eco-towns of
between 5,000 and 20,000 homes are to be built as "exemplar
green developments."
We think it is the wrong approach to give some
new developments special status. All new major developments should
be built to excellent ecological standards.
Food is getting scarcer and food prices rising—we
need our farmland for security of food supply and for recreation.
Q—What impact is the Code for Sustainable
Homes likely to have on the construction and purchase of new homes?
How well is the mandatory rating likely to be enforced? Should
the Code be changed in any way?
Government—From 1 May 2008 it will be
mandatory for all new homes to measured against nine categories
of sustainable design, including energy, water, and waste; and
given a rating of one to six stars as a result.
We note that the shift from Ecohomes to the
Code for Sustainable Homes removed criteria that would prioritise
the location of new homes within or adjacent to existing communities.
4.3 Greenfield and green belt developments
and Infrastructure
Q—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.
Q—What progress has the Government made,
in the two years since the 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?
A—(To first half of Q1 only—as the
latter half should be precluded by planning controls and Q2).
This reply draws on evidence from the new Regional
Spatial Strategy (RSS) for the East of England, which was published
on 12 May 2008. Question 1 is answered in relation to the proposed
development of Harlow North. Question 2 then considers this in
the context of the overall revised RSS for the East of England.
This is considered a useful focus as the East of England RSS is
the first to be revised since the initial series of RSS were produced
alongside the Sustainable Communities bill[75]
in 2003.
The government is going against its own findings
to propose a new town the size of St Albans on Greenbelt land,
being challenged by the campaign group "Stop Harlow North"
(http://www.stopharlownorth.com/what_is_being_proposed.htm).[76]
The site is north of Harlow proposed as a new town on the other
side of the river.[77]
The land is owned by BP pension fund and development proposal
led by a company called Ropemaker Properties ltd. The initial
sustainability study for the new town was done by a consulting
group called Beyond Green formed at the time. The Plan argues
for the need for Harlow North to "kick start the regeneration
of Harlow" (see plan—ref below). Harlow has empty homes
and also lots of wasted space as it is a new town. The RSS claims
the best way to regenerate Harlow is to build on the other side
of a wide river valley (that is a floodplain)—which is still
a significant journey from the existing town. But above all this
is Greenbelt. Its site includes a meadow due for protection by
the Hertfordshire Wildlife Trust.
This revised final plan (RSS for the East of
England) has even more development, more jobs and more housing
proposed than the original.[78]
It includes one site ruled out by the inspectors on the panel:
Harlow North (see panel report). This is unaffordable being built
in the wrong places. Instead of massive housing expansion across
our countryside we need affordable housing to make existing communities
more sustainable.
This is the first of revision to the region-wide
RSS. "As the Secretary of State's planning policy for the
East of England, it embeds within the statutory planning system
a sustainable long term vision for development in the region".[79]
This plan has an explicit focus on building
on the Green Belt (policy SS7, page 20), again implying that development
at locations such as Harlow North are the "most sustainable
locations" in spite of its greenbelt status, apparently trumped
by the need to "ensure that sufficient land is identified
to avoid the need for further review to meet development needs
before 2031". It proposes "compensating strategic extensions
to the green belt" instead.
The Harlow North development appears to be justified
as a potential sustainable community as one where it is (only)
required due to increases in jobs that would result from an expansion
of Stansted airport. This is therefore a massive housing project
that is only considered sustainable based on airport expansion,
yet this is sufficient justification to build over greenbelt.[80]
The house building targets have been raised
in the RSS, but environmental and infrastructure limits are not
considered as constraints here.
Also, the targets in the RSS are dependant on
a cut of water from existing dwellings as well as stringent targets
for water use per person for new dwellings. Demands for water,
energy and waste must be managed in parallel—so the carbon
and ecological footprints are reduced together.
June 2008
64 Gordon Brown on 12 July 2007, see http://www.independent.co.uk/news/uk/politics/brown-plans-three-million-new-homes-456904.html. Back
65
Barker review pg 3 at http://www.hm-treasury.gov.uk/media/E/4/barker_review_execsum_91.pdf. Back
66
Which is effectively what the 3 million figure requires. Back
67
Barker review pg 5. Back
68
Figure quoted by CPRE at http://e-activist.com/ea-campaign/clientcampaign.do?ea.client.id=21&ea.campaign.id=141. Back
69
Government's 2007 "Energy Efficiency Action Plan". See
http://ec.europa.eu/energy/demand/legislation/doc/neeap/uk_en.pdf. Back
70
Environmental Select Committee (2005) Housing Report. http://www.publications.parliament.uk/pa/cm200405/cmselect/cmenvaud/135/13507.htm£a23 Back
71
Energy Saving Trust and Building Research Establishment (2004)
P Grigg, 10 November 2004. Assessment of energy efficiency impact
of Building Regulations compliance. Building Research Establishment.
Report for the Energy Savings Trust and Energy Efficiency Partnership
for Homes. http://www.est.org.uk/uploads/documents/partnership/Houses_airtightness_report_Oct_04.pdf Back
72
Good Homes Alliance Code. See http://www.goodhomes.org.uk/code/ Back
73
Sanders, C and Phillipson M (2006) Review of Differences between
Measured and Theoretical Energy Savings for Insulation Measures.
Prepared by Glasgow Caledonian University for the Energy Saving
Trust. http://www.defra.gov.uk/environment/climatechange/uk/energy/research/pdf/insulationmeasures-review.pdf Back
74
You can see the list of 15 proposed towns at http://news.bbc.co.uk/1/hi/uk_politics/7327717.stm Back
75
The Sustainable Communities plan was published in Feb 2003 (see
http://www.communities.gov.uk/documents/communities/pdf/146289.pdf) Back
76
The land for this is currently owned by BP Pensions Fund (who
commissioned the sustainability study, via Ropemaker Properties
to Beyond Green-their first major project (see www.beyondgreen.co.uk/main.php) Back
77
The website for proposed new town: www.harlownorth.com/plan.php
and campaign against the development: www.stopharlownorth.com/what_is_being_proposed.htm) Back
78
The plan is not totally supported by EEDA, the Regional Assembly.
They are not happy as it "does not have enough money to give
them the roads that they want to make it sustainable". The
original sustainable communities plan in 2003 shows a massive
growth in the London to Peterborough corridor (in particular).
The plan was expected to respond to this and provide sufficient
investment in the supporting infrastructure to support new housing/development.
The criticism at RDA level as it fails to do this. There was also
a Strategic Environmental Appraisal (SEA) completed on the original
Sustainable Communities plan (for the East Region), which was
completed post-hoc as an appraisal of the draft plan and
concluded that the sheer weight of the development proposed would
cause irreversible environmental damage to the region. Back
79
Reference: http://www.goeast.gov.uk/ Back
80
From the RSS: "The roles of Stansted and Luton Airports are
outlined in the 2003 Air Transport White Paper... Airport growth
will provide a catalyst for the regeneration of nearby towns,
notably Harlow, Luton, Norwich and Southend... The housing allocations
for Harlow, East Hertfordshire and Uttlesford should be sufficient
for both airport-related and other housing needs, though this
will need to be kept under review as the airport develops. The
substantial growth in housing at Harlow should provide for a growing
number of Stansted employees to live there, from where they can
reach the Airport conveniently by public transport. Development
plan documents for Uttlesford and East Hertfordshire should reflect
the sustainability benefits of a growing number of airport employees
living at towns close to the Airport." Back
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