Memorandum submitted by English Partnerships
1. How significant is the extra cost of building
low and zero carbon homes? What evidence is there that zero carbon
homes will be economically viable for private house-builders?
Consultants concluded the second of two studies
in November 2007 for CLG on the costs of achieving the Code for
Sustainable Homes (CSH). The report used the best available data
at the time and predicted roughly £5k increased build costs
for every step taken up by the Code.
However, this area is rapidly evolving, not
least with initiatives such as English Partnerships' Carbon Challengeplease
refer to earlier evidence. The costs of achieving CSH at scale
will come down significantly, assisted by the creation of supply
chains for the products and an increasing knowledge base.
English Partnerships is working with the NHBC
Foundation and BRE to research more comprehensively the real costs
of achieving the Code and we are exploring the practicalities
of issuing a decision support facility which will be a "live"
web-based tool which can be easily updated.
In terms of economic viability for private householders,
heat requirements will certainly be reduced, and power will be
needed for energy efficient appliances and probably even for cooling.
Overall, actual consumption will be considerably reduced. However,
residents will need to contribute to the costs of the new energy
infrastructure. In work that Arup are currently conducting, the
prediction is that energy bills for a Code Level 6 home could
be the same as for a standard home at current fuel costs. What
may cause standard homes to be more expensive to run, is if fuel
costs continue to rise.
2. Will the social and affordable housing
that is provided via private developers through section 106 payments
have to follow the same mandatory targets under the Code for Sustainable
Homes as private housing (ie Level 3 by 2010, Level 4 by 2013
and Level 6 by 2016)? Or will it have to follow the more stringent
targets for housing built by housing associations (ie Level 3
by April 2008, Level 4 by 2013 and Level 6 by 2016)? What do you
think about this?
Generally, homes provided by private developers
through Section106 payments will only need to meet the mandatory
targets of the Code for Sustainable homes as prescribed by Government
through the Building Regulations which are envisaged to be; Level
3 by 2010, Level 4 by 2013 and Level 6 by 2016.
In addition, all new homes requiring building
regulation detailed drawings approval from 1 May 2008, must get
a mandatory rating under the Code for Sustainable Homes. House
builders must get and declare a rating in the Housing Information
Pack and sales particulars, even if it is a zero Code rating.
It should be noted that it is expected that
implementation of the Code will happen through certain elements
of the Code being incorporated into Building Regulations and other
elements being incorporated into HIPs and the Code rating system.
Where development is taking place on land owned
by English Partnerships or in projects enabled or facilitated
by English Partnerships, all housing, including Section 106 housing,
must meet English Partnerships' standards which are 3 years in
advance of Government targets, namely Code Level 3, rising on
1 April 2010 and 2013 to Code levels 4 and 6 respectively.
All English Partnerships' projects which are
greater than 200 homes and which may be constructed over a considerable
timeframe (including Section 106 housing) shall be required to
achieve an appropriate level of the Code which reflect our aspirations
at the time that construction commences; therefore, homes where
construction is planned to commence after 1 April 2010 must achieve
Code Level 4 and where construction commences after 1 April 2013,
homes must achieve Code Level 6.
Where homes provided under Section 106 agreements
are being purchased or part funded by the Housing Corporation
through a Registered Social Landlord (RSL), they must achieve
the levels of the Code for Sustainable Homes as prescribed by
the Housing Corporation at commencement of the advertisement of
their current funding bid round; Level 3 from April 2007, Level
4 from April 2010 and Level 6 from April 2013.
Where an RSL takes ownership of Section 106
housing delivered by a private developer with Nil Grant from the
Housing Corporation, their requirement to meet the Housing Corporations
standards cannot be enforced. However the Housing Corporation
encourages RSLs only to take ownership of properties that meet
their minimum standards.
Where an RSL secures Section 106 housing using
capital recycled from previous projects which were enabled by
the Housing Corporation; "recycled capital grant", this
capital can only be reinvested in housing which achieves the level
of the Code currently adopted by the Housing Corporation.
Low Cost Home Ownership properties facilitated
by the Housing Corporation must meet the general levels of the
Code as prescribed by them.
The Housing Corporation has written to all Local
Authorities outlining their "Design and Quality Strategy"
(April 2007), which includes their commitment to the Code for
Sustainable Homes, encouraging them to require the same standard
of housing through Section 106 agreements; however local authorities
are not obliged to.
Many Local Authorities have adopted their own
environmental standards which they enforce through their planning
requirements. Local Authority standards may be equal to, less
than or greater than those required by either English Partnerships
or the Housing Corporation, and may or may not include the Code
for Sustainable Homes. If a Local Authority does have an adopted
environmental standard, all housing, including Section 106 housing
will need to meet this requirement for instance Manchester
City Council is requiring Code Level 3 now, 2 years in advance.
3. How well is the Government ensuring that
new developments are being designed and built with the necessary
public transport, social and energy infrastructures in place to
ensure they are sustainable communities?
At English Partnerships, our commitment is to
place making and we always attempt to integrate social, transport
and energy infrastructures. One of our quality standards is "Build
for Life" which draws on PPS3 and allows us to dictate and
measure the quality of neighbourhoods in English Partnerships'
facilitated developments.
A couple of our exemplar schemes are Greenwich
Millennium Village and Northstowe.
At Greenwich, English Partnerships has facilitated
an award winning neighbourhood from a former gas works. Creating
an inclusive sustainable community has been key to this development.
This has been promoted through the early provision of community
facilities, for instance, the bus services were running before
homes were built, the school and health centre were built first
and attracted pupils in from the existing neighbourhood. This
all helped to allow people to make positive choices such as not
buying a car because the new bus services and other facilities
were already there.
The sense of community is enhanced by designing
homes around garden squares and linking neighbourhoods with tree-lined
streets. A Village Trust was created which enables residents to
influence their surroundings and mix of housing types and tenures.
The Village is served by a CHP plant which reduces CO2 emissions.
Northstowe is a former air force base and is
being considered as a proto-eco town for 9,500 homes. Northstowe
will use the old disused line of the railway to introduce a guided
bus service and the form of the development is along this spine.
Sustainability is a fundamental feature of the
new town which will feature a town centre, employment areas and
schools for up to 24,000 people. Features exist to reduce energy,
water and waste. Adjoining communities have been involved in the
planning process and have input to the vision of sustainability
and high quality design.
4. To what extent are environmental controls
within the planning system effectively being used as a form of
nimbyism to block any proposals for new development, irrespective
of their individual environmental impacts? To what extent are
proposed reforms in the Planning Bill likely to affect this?
Within English Partnerships we do occasionally
encounter resistance to housing growth and the new features of
sustainable living such as wind turbines and Sustainable Drainage
Systemsthese topics are sometimes being used as spoiling
tactics in developments generally. With certain design elements
being new, such concerns can legitimately be expected, and can
often be explained and rationalised through a careful consultation
process. Usually, we design and promote schemes which include
these items as part of wider environmental measures. We consult
widely and use community engagement techniques to help gain buy
in at the start.
We understand that there are a number of proposed
changes to the Town and Country Planning regime with the objective
of speeding up the planning system. English Partnerships is supportive
of the proposals generally and of course any measures which will
speed up the planning process. We are still waiting to hear more
about changes to LDFs in the promised revision to PPS12, which
is now overdue. Within English Partnerships, we believe that one
of the proposals that Local Authorities should be able to review
more minor Planning Appeals would however be unlikely to work
as it removes the independent review offered by the Inspectorate.
The recently started Pretty review of the development
control regime is also aimed at speeding up the application process.
We welcome this review and again await the outcome.
There is of course a down side to continual
changes to the planning system, the system introduced in 2004
has hardly bedded in and it is changing again. Any change introduces
uncertainty and consequential delays and the uncertainty also
gives opportunities for legal challenges for those seeking to
resist housing growth.
June 2008
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