Select Committee on Environmental Audit Minutes of Evidence


Examination of Witnesses (Question Numbers 81-99)

MR JOHN SLAUGHTER, MR DAVE MITCHELL, MR LEWIS SIDNICK AND MR NEIL JEFFERSON

20 MAY 2008

  Q81 Chairman: Good morning, I am sorry we are running slightly behind time. We have got about 40 minutes but a lot of ground to cover, so we will try and keep our questions concise and the more concise your answers are the more ground we will be able to cover. We are grateful to you for coming in. Because of the time constraints I will not ask, unless you very urgently want to make an opening statement, if that is agreeable to you.

  Mr Slaughter: Yes.

  Q82  Chairman: We know who you are and you know who we are. Could I start by asking the Government has set a target of two million new homes by 2016, to progressively higher standards, and another million zero carbon homes by 2020; are we on track to meet those targets?

  Mr Slaughter: It is very hard to say how far we are on track at the moment. We clearly face, currently, a difficult market situation on the one hand which the press is already indicating will probably lead to some reduction in housing completions over the coming year or two, but I do not think that should deflect us too far from looking at the feasibility of the targets. Beyond that we are in principle aiming to get there if we sort out a number of important issues which I am sure we will come on to today. Our premise is that we believe it is possible, if we get all the issues sorted out, to get to those targets, but whether we can say today that we are going to is impossible to say because we have not resolved a number of the key issues. On the numbers, from our point of view, that is still critically about the planning system and land supply on the one hand. We are going to need a better land supply than we have had over recent years if we are going to meet the targets, so we have been pressing government very hard for the need for that to work properly. Then on the environmental side there are a lot of issues that I am sure we will touch on about the definition of zero carbon, the nature of energy supply to zero carbon homes and many other related issues, and they are all quite substantive, practical issues that we need to sort out. We are aware of what they are, but we have to be clear that they do need to be resolved. Very briefly, the third issue is around regulatory cost where we have drawn attention to the fact that looking on a long term basis, not a short term basis, the industry is facing very substantial cumulative regulatory costs, not just zero carbon but affordable housing, infrastructure support and other objectives and we are also in discussion with government about how those objectives can be managed at the same time as providing a sufficient volume of affordable housing.

  Q83  Chairman: The NHBC has warned about what it refers to as "waves of error" setting in with more demanding standards throughout the housing market. Housing associations, however, are being required to meet a very steep trajectory towards zero carbon; if they can do so why is it so difficult for the private sector, do you think?

  Mr Sidnick: NHBC believes that the zero carbon principle should be based on sound science and currently in terms of renewable technology a lot of its development is at a very early stage. Our primary purpose is to protect the consumer and we do not want consumers to be used as guinea pigs to trial technology, so there are a number of risks around the technology point. On the consumer point the NHBC Foundation, our research organisation, has carried out a piece of research to get more information about what the consumer thinks of this agenda, whether people actually want these homes—it is an area that had not been investigated enough—and it found broadly that there was a lack of awareness and understanding of the zero carbon agenda. Our message is that we cannot go too fast too soon, that it needs to be based on sound science and avoid putting risk to the consumer.

  Q84  Chairman: Given the significant contribution towards greenhouse gas emissions that the housing sector constitutes, and given the availability now of technology which will certainly greatly reduce those emissions, surely it is not a matter of whether consumers are demanding this, the fact is that we have to accept tighter standards if we are going to get anywhere near the national targets for carbon emissions?

  Mr Jefferson: There is almost a consensus forming about the way forward in terms of a very ambitious target that has been set for zero-carbon by 2016. Along the way there have been a number of incremental stop-offs—level 3, level 4 and of course level 6. In terms of achieving those I think that the work that has been done over the past year or so would demonstrate that the way forward is perhaps to do the best we can in terms of fabric, insulation and airtightness which will take us to broadly around level 3 or level 4 and then beyond that we are into really providing renewables. Of course, the debate at the moment is regarding whether those renewables should be provided onsite, offsite or a mix of both, and whilst it is true to say that there are renewable technologies which are more mature and which are available on the market, a lot of these things, as my colleague says, are in their infancy. That is something that the NHBC Foundation is very interested in and produced a report earlier in the year which compared 11 types of micro-renewable technologies to see which ones were actually working, and it was the case that the more established technologies such as solar thermal collectors are working quite well whereas micro-wind, for example, is not quite as advanced at the moment. In terms of the next stages NHBC very much endorses the work that was launched last week by the UK Green Building Council at the request of CLG, which recognised that it is very difficult for some schemes—not all but the average size of development is around about 26 or 27 units per scheme—and that actually to achieve level 6, zero carbon, which is a very ambitious target, a large number of developments would not be viable at level 6 unless there was some provision for offsite generation. At NHBC we very much look forward to the consultation which will be held during the summer, and we will participate fully in responding to that to see the best way forward in order to ensure that we make the most of the challenges ahead. This is a huge investment for the UK and if you were to assume that there are 200,000 homes to be built each year going forward and if the incremental cost of reaching level 6 is £30,000 that is £6 billion a year. Beyond that, if there are 240,000 built it is a matter of £7 billion, a huge investment. There has been quite a lot of work done already and there is a lot more to do, but I think it is to do with the onsite/offsite generation issue which is the challenge for the next period.

  Q85  Dr Turner: Can I just follow up those answers from you, Lewis and Neil, because it rather sounds on the face of it as if you are making a rather feeble excuse for dragging your feet on getting renewables in zero carbon housing. After all, five years ago when I visited Japan I saw totally zero carbon housing being sold commercially, off plan, very popularly, with photovoltaic roofs, the works, no problem—it was routine, not just in its infancy. Equally in Germany developments with biomass district heating systems are routine, so why are you hiding behind the assertion that these technologies are in their infancy when they are not, they most certainly are not. There may be supply chain problems in the UK but that is just something you have to do something about.

  Mr Jefferson: I would very much like to say that we are not making excuses, we are not hiding behind anything. I would like to say that NHBC has very much embraced the agenda, we sit on the taskforce, we have signed up to memoranda, we have done a considerable amount of work through the NHBC Foundation, the research arm, and through the National Centre for Excellence in Housing which last week unveiled the first level 6 home built by a volume house builder, by Barratt, and we are delighted to showcase what can be done. In terms of rolling it out, we have also looked around the world, as you suggest, to see what other countries do and what we have learned from that is that other countries perhaps have different climates, also in terms of electricity they are decarbonised by different degrees depending on where we look. NHBC's experience, as the written evidence sets out, is that when there is a step change—and this is unprecedented in terms of a step change going forward—there are sometimes problems and over the years NHBC has dealt with those problems, perhaps most notably with precast reinforced concrete homes (PRC) around about 20 years ago where the NHBC for Government oversaw the repair of 17,000 homes which were not mortgageable under the right-to-buy scheme; we oversaw those repairs. Over the years we have been involved in those failures and our concern is to look after the interests of consumers and to make sure that we build on sound science so that home owners are not used as guinea pigs. I would like to say that there are very much some established technologies which can be used and there are other technologies which are emerging; what the NHBC Foundation research found was that it is very important that we use the right technologies in the right locations of those 11 types. Also, at the moment, there are additional costs involved as well; that is not NHBC's concern, that would be a concern for the house-building industry, but I would just like to say that we are not here to make excuses, we do not think we are making excuses, we are just concerned to make sure that homeowners of the future are brought into what they are going to receive, that there are not any maintenance issues regarding the renewable technologies which they receive in their new home, that they know how to use it properly to its optimum and to make sure we are not actually causing or storing up problems for the future.

  Q86  Dr Turner: This does not sound like a very adequate answer to the question that I asked; after all setting up a taskforce is the traditional British way of kicking something into the long grass and making sure that nothing happens for some time. I am not aware that the climate of Germany and Japan is very different from our own, so what will work there will work here. Can you substitute action for a taskforce, please?

  Mr Slaughter: Can I comment on this? Developers increasingly are but we have to be clear what level of the code we are talking about, going back to one of the earlier answers. To go to level 3 and 4 of the code we would agree with NHBC that what people will primarily look at will be improvements to fabric efficiency, so that that in itself does not necessarily require a large use of the renewable technologies onsite or otherwise, and it is when you go beyond that level that the technology issue arises. I would also agree from my own knowledge and discussions when we talk to an awful lot of people about this set of issues—and our members are engaging very widely with the renewables industry and the micro-generation industry too—there are some technologies that are more proven than others, but to look at code level 6 solutions, which is what we are really talking about here, the zero carbon solution, then even some of the proven technologies to install them onsite now are very expensive—the Government's own research has shown that—and so we have a combination of issues about what is technologically possible at the moment and what is financially viable in terms of affordable housing provision. That is why in my opening remarks I touched on the regulatory cost burden; we are looking at this as part of a wider picture where if, as we believe at the moment, it might cost something like £30,000 or possibly more per housing unit to provide a zero carbon standard as is currently set out, then that is an extremely expensive thing to do and does have implications for other housing policy objectives.

  Q87  Dr Turner: I cannot help thinking that if we had a line-up of your German equivalents we would get different answers and those different answers might be related to the difference in the legislative framework that underpins renewable energy in Germany compared with ourselves; would you agree with that? If we had a legislative framework which incentivised renewable energy more effectively, such as a feed-in tariff regime, would you be giving us different answers?

  Mr Slaughter: Quite possibly, yes. I do not know whether the Committee has registered this but we have actually publicly supported the case for a feed-in tariff; we have discussed that with the Renewable Energy Association. I know from my own knowledge of the energy industry that energy market reform—which is not just a feed-in tariff, I think we need to make a whole range of changes beyond that but the feed-in tariff is part of the picture—is probably going to be critical to achieving this objective successfully and affordably. We do need to stress the affordability issue, because the problem from the developer's point of view is that if the front-end capital cost falls entirely on the new housing development up front then that is a problem for all of us, not just for the developer, it is a problem for wider housing policy objectives. It is only if we get things like the feed-in tariff and wider changes to the energy market that will really incentivise and support investment distributed zero or low carbon generation and really promote that through the regulatory regime that we will actually achieve the twin objectives successfully because that will create a financial basis on which investment will come in to provide the infrastructure and networks to support local zero carbon supply, and that will make it more manageable for developers and for the energy industry. We need to have those energy market changes because especially in the electricity market investment essentially follows the regulatory rules.

  Mr Jefferson: Chairman, can I just express again that I very much agree with the point that has just been made and also just express again, perhaps, the comparison with elsewhere in the world because in the UK the level 6 target for zero carbon is the most ambitious that we have found because it includes the electricity that is required, as the Committee knows, to run all the household appliances. The next level down from level 6 is level 5, which is essentially a house whereby the legacy left by the house builder is a home which provides for itself in terms of space heating, water heating and lighting and in level 4 you take off the lighting, so in terms of the use of micro-renewables to achieve levels 4 and 5 we are beginning to see that happen and, as my colleague from the HBF has pointed out, you see it on rooftops around the UK now. The challenge going forward—just to be clear why perhaps it is different to elsewhere in the world—is about generating sufficient electricity onsite, or maybe offsite depending on the consultation in the summer, to run all those household appliances and, as we move forward, it is absolutely right to look at generation more broadly because we are into cost issues to do with how much we can charge for fuel in 2016, and the debate at the moment is that it is better done at community level rather than at the level of the home, or maybe even larger so that you are dealing as you perhaps are in Scandinavia where whole parts of cities have network systems. I would like to be clear, therefore, about the contribution that micro-renewables are making at the moment and where the next step is in terms of achieving the ultimate step of level 6 zero carbon by 2016.

  Q88  Mr Hurd: Can I bring you back to the issue of cost? There is clearly resistance on that attached to the zero carbon option. Zero carbon is very easy politically, we can talk about it, it is an easy language, but what I want to get a flavour of is the cost/carbon benefit analysis between 5 and 6 in terms of stretching for 6, which is easy for us to talk about. Are we in danger of losing sight of the cost/carbon benefit between 5 and 6, i.e. would we get greater co-operation and greater momentum and acceleration in the direction we want to travel if we were to be slightly more relaxed about the end game. Does that make sense in terms of the cost curve between of 5 and 6 where you have got, I am detecting, real concerns. Has anyone done a cost/carbon analysis to see if we were to go a bit further down that curve we would actually make much further progress because at the moment you are sticking in the mud?

  Mr Mitchell: If I can just bring you down to code level 4 at the moment, there was a Cyril Sweett report that was done and it had a graph in it of costs coming through the codes; there was a gradual increase in costs until you get between code levels 3 and 4 and then it goes sharply upwards. You mentioned code level 5, but if we bring it back to code level 4 that is when the sharp increase in cost occurs. If am brutally honest, what happens then is you will find the house has been developed thermally to such an extent that when you get to that position you are starting to rely on things like photovoltaics which are very expensive, and that is what is sending the costs straight up. What we are seriously looking at is how much can we do within the fabric of the house and then we can build on that with renewables, but it is between code levels 3 and 4 that there is a sharp increase in costs.

  Q89  Martin Horwood: Some of my points have already been made but I was really going to go back to Mr Sidnick and challenge the idea that the science is not well-established. I find that an extraordinary statement and it does sound like you are making excuses really because geothermal energy is well established and perfectly economic, this Committee visited the Centre for Alternative Technology in Machynlleth in Wales last week and saw a zero carbon house that was built 20 years ago. Photovoltaics are, as you rightly say, expensive, but surely if we were doing it on scale and the commercial entrepreneurial attention was paid to it that it needs to be then we might see that price fall quite sharply. Surely you can accept that other countries are a long way ahead of us, and that the reason you have to make such a step change is because Britain at a corporate level—I am not saying it is the commercial sector's fault entirely—collectively is starting from such a pathetically low base.

  Mr Sidnick: Firstly, in terms of making excuses, we support the objective of achieving zero carbon homes and we are investing significant funds to help support the industry to implement it, and we want to work with Government, industry and other stakeholders to successfully deliver it, so we are in favour of the objective, but there is a difference in terms of looking at what technology exists and how mature it is individually, looking at its application on the mass market and the cost implications of that. That is where I think there is a divide; yes, some of the technology exists effectively and we can demonstrate that but how effectively can that be implemented when you are building 200,000 homes a year, three million by 2020.

  Q90  Martin Horwood: But as Dr Turner said, that is already happening in other markets, is it not?

  Mr Sidnick: But not to achieve code level 6, to achieve a truly carbon zero home there are other implications in terms of delivering that to the mass market.

  Mr Slaughter: Just to add to that, there is a supply chain issue at this stage. The supply chain to deliver—going back to the earlier questions—levels 3 and 4 for everyone at the moment just is not there, so we do need a little bit of time for the supply chain to come into operation. There are some gaps that I think the serious economic and other studies that we have seen on this subject have identified, things that would be desirable but are not yet there like relatively small-scale biomass CHP for example. There are things that you would wish were there, therefore, that are not mature at the moment and then there are the cost issues connected with developing the supply chain and the installation and maintenance issues that go with it. From a customer point of view we also need to be confident that there is a service structure there for the future because the equipment that we are talking about is going to have servicing requirements, a lot of things that people are familiar with at the moment. In the work that we are doing we are having to look at all these issues and see how we can best promote that. The other point, coming back to your question, reinforces what I said to Dr Turner a moment or two ago about the energy market. What we precisely do not have in the same way as some other countries is a supporting set of measures that will help manage the investment cost and the investment risk in some of these new systems in the UK market context. It probably is not ultimately the most helpful way to do things to have too narrow or too compartmentalised a focus on what can be done just through new housing as opposed to a wider set of measures taking on board, for example, our European energy targets on renewables that are pretty stretching more generally.

  Q91  Martin Horwood: That argues surely for a tougher line on retro-fitting in existing housing stock and not for any dilution of the targets for new housing?

  Mr Slaughter: Absolutely, we are not arguing for a dilution of the targets. What I am arguing for—and we may come back to this in other questions—is what I call a more clever approach to how we achieve all of these objectives. If we look at this from the bigger picture perspective, we have what we expect to be a 50% renewables target for the UK by 2020. My understanding is that that should amount to something like 35% of our electricity coming from renewables by that time, it is absolutely massive, and what I think we need to do is look at how zero carbon homes can sensibly fit into that bigger picture and be a catalyst for helping to achieve the wider objectives. That is not a substitution for anything but simply as a country surely what we want to aim for is a picture where we achieve the best benefits for everybody on the most efficient basis possible.

  Q92  Mr Chaytor: Can I press you on this issue of the £30,000 additional cost. What is that made up of; what is the balance between internal adaptations to the building and offsite renewables?

  Mr Mitchell: If we are talking about the code, the £30,000 to get to level 6, of that £30,000 about £25,000 or £26,000 is on the CO2 element of the code, but we are talking about other elements as well. It is a substantial figure and that came out of the first Cyril Sweett report which was published a year or two ago. We are awaiting a second Cyril Sweett report, which should have been published towards the end of last year, and I do not know whether it will confirm those figures. Our own view is that it will probably be higher than that.

  Q93  Mr Chaytor: In terms of the home that has been unveiled at the BRE in the last few days by Barratt, does that match this estimate of £30,000 additional costs?

  Mr Mitchell: It is an awful lot higher because a lot of research has gone into that.

  Q94  Mr Chaytor: But that is a one-off, what is the extrapolation from that home in mass production, that is the issue?

  Mr Mitchell: They are working very hard on that to try and bring those costs down to make it a home that can be mass-produced.

  Mr Slaughter: I do not think we know the answer to your question, we honestly have not asked them.

  Mr Jefferson: As I mentioned before it was a joint venture between the NHBC and the BRE that led to that house being built. The house builder has not revealed the cost of building that home because it was a prototype. They are hoping to take the lessons learned from building that house into a range of house types that will be rolled out around the country and they will choose the technologies that have worked within the house. The one thing I will say about the home that was built at the BRE is that because it was built in isolation and therefore not connected to a centralised CHP system it relies on photovoltaics to get to level 6, the stamp duty exemption level that was being aimed for, so I would suggest that given the photovoltaics connected to that house it would probably be, given current market prices, in excess of £30,000. The house has been designed in order that it could be connected to a CHP system in the future.

  Q95  Mr Chaytor: You have commented on the associated problems of the energy market but is not one of the big issues also the way that we separate out the capital costs of building from the revenue costs of building, and have you done any investigation into the way in which the longer term reduction in revenue costs can be incorporated into the purchase costs via particular kinds of mortgages? Surely this is the issue and the marketing advantage that some of these homes would have with consumers. Is there discussion that some of these homes would have with consumers. Is there any discussion between the building industry and the mortgage industry as to how these lower revenue costs can be captured and incorporated to avoid expense?

  Mr Slaughter: We have had a few discussions with the Council of Mortgage Lenders on this subject and I think it is correct to say that ministers have also raised the issue of green mortgages with the CML. I have to say that the answer we have had to that question is that it does not appear to be in practice a very attractive option on the whole to lenders at this stage. Of course, the current financial market is particularly difficult and I am really referring back to discussions before the current financial situation got as stretched as it is, but at that stage I do not think there was a lot of interest in terms of the lenders and seeing how that would create an interest for them to provide an attractive mortgage product. That is probably connected to the fact that so far—we cannot pretend to predict how this will change in the future—as we stand it remains the case that customers probably would not give much weight to those revenue benefits in terms of their purchase decision and the price they were willing to pay for a home.

  Q96  Mr Chaytor: In respect of the current economic downturn and the credit crunch, what are the implications for the big expansion of house-building that everyone wishes to see. Do you think that the assumptions underlying the three million new homes are still there, is it still possible to deliver them given the current circumstances?

  Mr Slaughter: The assumptions are still there, the need for the homes is definitely there; the immediate problem with the downturn is we literally have our members talking to us about the fact that they have people who would like to buy their homes who at the moment are unable to get mortgages, so it is very much a finance-driven issue. We have raised this as a matter of urgency with the Government and with others for any assistance that can be provided, and the reason we are doing that is because from our point of view this is a serious issue for all of us because the consequence if the slowdown does continue for too long is a loss of capacity in the industry, because the industry cannot continue to produce at the level it has been producing if there are not purchasers out there. If we lose capacity then that will obviously have some impact in the immediate period on the level of output. That in no way changes the figure in terms of the supply situation: the household formation figures remain the same, the need in principle for the two million or three million homes is still there, but the problem we will have is a short-term one of adjustment following the price slowdown.

  Mr Sidnick: In terms of the need for homes it is still there but in terms of delivering the supply target NHBC's statistics on new starts have shown for quarter one in 2008, the number of new homes registered to be built has fallen 30% compared to quarter one in 2007, a significant fall, which is having implications on the number of units being built and will have implications for the final target, but the demand is still there.

  Q97  Mr Chaytor: Leaving aside the availability of credit, the other factor underlying the economic situation is the huge increase in the price of crude oil. The fact is that oil has gone up from $30 a barrel to $120 a barrel in two-and-a half years; are there longer term issues about assumptions over numbers of housing, the kind of housing, the location of housing, the nature of the infrastructure that we have not yet taken on board? Does the impact of the oil price affect the impact of property prices? We have got these eco towns springing up all over the country; is this still a viable model with oil at $124 a barrel and possibly rising further?

  Mr Jefferson: That is a very good question. The research that the NHBC Foundation carried out which we refer to in our submission was about consumer attitudes to zero carbon.[6] What the research found was that consumers were of course aware of climate change and the issues surrounding it and there was a desire to do things to improve the way people live their lives, to reduce waste, to reduce carbon emissions. However, what came out through that research, perhaps not surprisingly, was that people's decisions are often based on financial issues rather than anything else and in terms of asking a large number of home owners if they would pay more for a zero carbon home we found that roughly half the people interviewed would pay £6,000 to make a financial saving year in and year out, fewer as you went up the scale and very few would pay £30,000 at present day rates for level 6 but of course, as has already been mentioned by the Committee, it is expected that that £30,000 will drop in due course. As I mentioned earlier on, the price of fuel to run a home or the price of fuel to run a car will influence decisions on where people choose to live and the point you make about the additional cost of living in a zero carbon home and living in an eco town, these are all important factors because somewhere along the line some of the incremental cost of moving to these high levels will need to be absorbed. That is a big issue at the moment because the three things of supply, affordability and sustainability need to be quite carefully balanced over this period, although in the longer term as our colleague from HBF has pointed out the demand for homes will still be strong.

  Mr Slaughter: If I could follow up on that question, it is probably quite early in the process for there to be a very clear understanding of the issues you are raising, but they are certainly valid and I suppose, to be positive about this, one of the things that I would look for the PPS on climate change to do is to actually address these kinds of issues and assist the developers. In some of these areas, because they are actually extremely demanding and sophisticated issues that you are talking about, most individual developments are really very small and the large urban extension and so forth is the exception. For those kinds of development situations I think we are going to need a lot of help from enlightened dialogue with the planners and a real emphasis on forward-looking spatial planning which we would certainly support; that is what the planning system should first and foremost concentrate on in the challenging future we face.

  Q98  Colin Challen: On the back of a ten year house price boom most competent house builders have made record profits—I have looked at annual reports and I have seen the figures. On the back of that why should we not expect house builders to share some of the burden of paying for these extra things to make houses more zero carbon?

  Mr Slaughter: They already are. Before we get on to zero carbon, the industry in the last few years has been making a massive contribution in terms of affordable housing provision. Over half of the affordable housing that is provided comes from the private sector through section 106 and we would estimate that on current average provision levels that is a contribution of something like £30,000 per housing unit in itself. Then of course the industry is already contributing a lot in terms of infrastructure provision, so part of the concern I was raising in the introductory remarks about the future burden of regulation was that you are adding the cost of zero carbon on top of those other elements, and that becomes very difficult to support in terms of land values. The issue going forward is not about whatever profits have been made in the past, it is about whether there will be a viable land supply, whether when you look at all the value that is being contributed potentially from a development to public policy purposes—and we are not knocking the public policy purposes—what value is left in terms of the sale of the land by a landowner to a developer? Figures that we have looked at in broad terms suggest that that is a real challenge; the prospective regulatory cost going forward in a few years time could be in the region of £3 million per hectare, and the average price last year from the Valuation Office for land for residential development outside London was £2.9 million, so if you are in that kind of territory we are simply saying that there is an issue you need to look at. If the land is not viable or of interest for the landowner to sell then the land will not come forward and the housing output will be constrained because of insufficient land supply.

  Q99  Colin Challen: It seems that every which way we turn the industry is sort of pleading poverty really and I guess if we had asked similar questions five years ago we would have had the same kinds of responses. Surely the industry does have a greater responsibility and should not just look to others to find a solution; as Dr Turner suggested earlier what we are talking about should be seen as standard, so how will you actually approach that in terms of internalising this behaviour so that you can get the message across to your consumers that it is simply a good thing to do to buy these houses and how we should support them in making that choice rather than always relying on legislation to force the pace?

  Mr Slaughter: We do feel it is essential to have the right national legislation in this field because the reality of how the industry and the market works is that land supply is critical and the land market is very competitive. It is not possible for developers in general to be able to bid effectively for land in the land market.



6   See Ev 49. Back


 
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