46.Heatwaves can cause acute increased demand for health and social care services. During the 2013 heatwave, approximately 1,166 GP consultations for heat illness took place, double the amount in a non-heatwave year. A study of the 2003 heatwave found that hospital admissions for the over 75s in London were 16% above average. A lack of preparedness for this risk could lead to inadequate or sub-standard care or, in extreme circumstances, service collapse or failure. The Adaptation Sub-Committee’s Climate Change Risk Assessment Evidence Report explains:
Heatwaves affect the functionality of hospitals and care homes. Health services will be vulnerable to an increase in the frequency and intensity of heatwaves. Care homes are at risk of overheating, and care management practices may not sufficiently address heat risks.
47.In June 2018, the Prime Minister announced a new five-year funding settlement for the NHS of £20.5 billion. The Government stated that the funding will support a new ten year long-term plan and enable the NHS to “regain core performance and lay the foundations for service improvements.” Given that the effects of climate change, including heatwaves, have a serious impact upon the future planning of the health service, we hope the Government has considered this in the funding and planning of the NHS.
48.The Adaptation Sub-Committee found that frontline staff felt unprepared for heatwaves. A study of hospital managers, nurses and healthcare assistants found that although hospital managers showed good awareness of the Heatwave Plan for England, this was lacking in frontline staff. A survey of GPs found that less than half were confident about their resilience to extreme events.
49.The number of heat-related deaths in the UK is expected to rise from 2,000 to approximately 7,000 each year by the 2050s. Milder winters will only reduce cold-related deaths by 1,000, as outlined in figure 2.
Fig. 2: Heat-related (A) and cold-related (B) deaths in the UK per year for all ages based on an ensemble of nine climate model realisations. Source: Hajat S, et al. J Epidemiol Community Health 2014; 0:1–8.
This results in a net increase of 4,000 weather-related deaths each year, which will place additional pressure on healthcare services if they are unprepared. During the 2003 heatwave, deaths in hospitals in southern England for the over 75s increased by 36.5%. Excess deaths occur during the first few days of a heatwave, so advance warning and preparedness are vital.
50.However, we found that preparation for heatwaves in the healthcare system is much weaker than winter preparation. During the roundtable with hospital and care home staff for this inquiry, an NHS Trust Site Operations Manager explained:
For cold weather, we know the warning’s coming and we’ve got five days to get our services in place to cope with extra numbers of respiratory, cardiac, stroke presentations, but for heatwaves that is a lot quicker, in terms of our ability to ramp that up and bring in extra staff, because we know we get increased A&E attendances with respiratory, cardiac and sickle cells and dialysis patients … We are much better at having a cohort co-ordinated plan for winter … but summer is a real challenge. We have seen some of our busiest times at A&E in July.
51.NHS England and NHS Improvement produce guidance on winter resilience, first issued by the National Urgent & Emergency Care Director in July 2017. The guidance notes that “pressures have been building on A&E departments for several years and can significantly increase over winter because of a rise in the number of people admitted to hospital.” Stephen Groves, Head of Emergency Preparedness, Resilience and Response suggested that winter plans could be used for heatwaves, but did not confirm that there were any plans to produce specific guidance on summer pressures. Although Public Health England includes guidance for healthcare professionals in its Heatwave Plan, the Medical Director outlined the barriers to ensuring it is implemented:
We will do—and we do do—all that we can within the powers that we are given to ensure that the evidence around how to reduce harm from heatwaves is applied, whether in the NHS, local government, local planning decisions or industry, wherever it is. But we do not have the specific management levers into NHS hospitals; that is an NHS responsibility.
52.Heatwaves place pressure on healthcare services. The majority of heat-related deaths occur in the first few days of a heatwave, so it is essential that frontline staff are prepared. However, many frontline staff are unaware of the Heatwave Plan and fewer than half of GPs feel prepared for extreme events. It is worrying that Public Health England makes recommendations it is unable to monitor and enforce. NHS England should issue guidance on planning for summer pressures, to ensure that adequate steps are taken to prepare the healthcare system for more frequent heatwaves. NHS organisations should submit annual heatwave plans to ensure they are prepared for the sudden onset of a heatwave. In their response to this report, the Government should set out how it has accounted for the risks from climate change in its recent NHS funding settlement and how this risk is being considered in the production of the new ten year NHS plan.
53.There is also concern that hospitals and care homes are at risk of overheating. Data from the NHS Estates Return Information Collective found that there were 2,980 instances of overheating above 26°C in healthcare trusts in 2016–17. Kathryn Brown, Head of Adaptation at the Committee on Climate Change told us that temperatures in hospitals “sometimes exceed 30 degrees when the outside temperature is about 22 degrees.” The Committee on Climate Change told us that there are “no requirements in place to ensure that hospitals and care homes do not overheat in high temperatures, and there are no building or other regulations to address heating risk.”
54.The risk of overheating in healthcare buildings is not being managed. Overheating does not form part of the Emergency Preparedness, Resilience and Response (EPRR) assurance sought by NHS England. Responsibility for design of estates and facilitates lies with NHS Improvement, whereas preparation for an extreme event lies with NHS England and the response to climate change lies with the NHS Sustainable Development Unit. The Adaptation Sub-Committee express concern about this fragmented approach:
Problems of organisational management and communication between different groups of health and social care personnel may make response to severe weather events less efficient. It is important to take a ‘whole system’ perspective when considering the impacts of climate risks on health and social care delivery.
55.There is a lack of robust evidence of overheating in care homes and nursing homes, however a study by Professor Rajat Gupta concluded that due to a perception that older people “feel the cold” there was a lack of recognition of the health risks of overheating in care homes. The study of four care homes found that the heating was left on 24 hours a day even during summer months. The study also found that while all care managers interviewed were aware of the Heatwave Plan for England, awareness among frontline staff was lower. When we asked about responsibility for improving staff awareness, the Minister for Primary Care and Public Health set out a fragmented system:
Steve Brine: It depends on who commissions the beds.
Chair: If the council commissions the beds it is PHE and if the NHS commissions the beds it is NHS England?
Steve Brine: Correct. You are probably thinking that seems a bit fragmented, Chair—
Chair: You seem to be thinking it as well, Minister.
Steve Brine: I put words in yours and my mouth at the same time, which is quite a new trick.
56.The Government’s written evidence confirms that “there is currently no central data set on care and nursing home preparedness against which to judge the risk of overheating during heatwaves and the impact of climate change on this risk.” This is concerning given that during the 2003 heatwave, deaths in nursing homes in southern England increased by 42%. Stephen Groves, Head of EPRR at NHS England told that, us due to “capacity issues”, NHS England has not yet been able to require nursing homes to demonstrate compliance with EPRR core standards.
57.The Care Quality Commission (CQC) regulates all providers of regulated health and adult social care activities in England. The CQC’s role is to provide assurance that the care given meets essential requirements of quality and safety, including ‘safety and suitability of premises’. However, the CQC do not currently inspect for risk of overheating. Kathryn Brown, Head of Adaptation at the Committee on Climate Change told us about the barriers to inspecting for overheating:
In our last report we had a recommendation on assessing and managing the risk [of overheating] in care homes. We did go to talk to the Care Quality Commission about what that might look like. Their feeling was at the moment they are not sure what they should be inspecting for.
58.Hospitals, care and nursing homes are vulnerable to overheating. In 2016/17 there were nearly 3,000 instances of overheating in healthcare trusts. However, overheating risk is not part of the NHS Emergency Preparedness, Resilience and Response (EPRR) approach and the Care Quality Commission do not inspect for it. Care and nursing homes are not required to demonstrate compliance with the core standards of EPRR. NHS England should include overheating as part of EPRR assurance, and ensure that all hospitals and NHS operated nursing homes are compliant with it. The Department of Health and Social Care should provide guidance to the Care Quality Commission on how to inspect for overheating risk, and ensure that overheating risk forms part of its inspection for safety and suitability of health and social care premises.
59.The 2017 Climate Change Risk Assessment Evidence Report found that warming UK temperatures may lead to an increased risk of overheating. Overheating in buildings causes risks to health and well-being and links have been established with lower workplace productivity and worsened indoor air quality. There is no clear definition of overheating in buildings but discomfort temperatures have been established as guidelines, for example 26–28°C for bedrooms and living space. There is no law for maximum working temperatures but employers must abide by health and safety law which includes keeping the temperature at a comfortable level.
60.Dr Anstasia Mylona, Research Manager at the Chartered Institution of Building Services Engineers (CIBSE) explained that some types of buildings are particularly vulnerable to overheating:
At greatest risk are single-aspect flats, flats with communal corridors with uninsulated hot water pipes going through them, and properties that rely on natural ventilation, so people need to open windows, but they are in very highly polluted, high-noise areas, so actually people cannot open the windows. They have no other means of cooling the space, which means that temperatures increase.
There are also buildings with very high internal gains, such as schools and hospitals. Those that are mechanically cooled can deal with that, but those that are not are at high risk. There is also top-floor flats, usually because of the heat traveling upward.
Professor Gupta from the Oxford Institute for Sustainable Development told us that a mid-terrace tends to overheat before an end-terrace and a single-story flat will overheat before a two story terrace. Kathryn Brown, Head of Adaptation at the Committee on Climate Change, suggested 1960s newer builds are more at risk than older Victorian buildings, which tend to be more resilient to heat.
61.At current temperatures, one in five of the UK’s homes overheats. Overheating can be defined as prolonged high temperatures that affect health and wellbeing. This presents a risk to occupants, particularly those who are vulnerable to high temperatures such as older people, those with underlying cardiovascular or respiratory conditions, those with disabilities and children. A survey of 135 school teachers conducted for this inquiry found that 90% of teachers had to take additional measures to make their classroom a ‘bearable’ temperature during periods of very hot weather. Many teachers responded that they had to personally purchase fans that they were not reimbursed for. Dr Mylona, CIBSE, told us that it should be the “responsibility of the building regulations or the regulatory framework to address health issues, including overheating.” Kathryn Brown, Head of Adaptation at the Committee on Climate Change expressed frustration at the Ministry of Housing, Communities and Local Government’s view of the purpose of building regulations:
[The Ministry] has been fairly emphatic with us that those regulations are not designed to protect health … They are not health regulations. We recommended that something was needed - we do not have a view whether that is in the building regulations or not - that looks at the health aspects of overheating.
62.However, when we asked the Minister for Housing, Dominic Raab MP why building regulations are not designed to protect health, he responded:
I don’t think that is quite right because the 1983 Act gives the power to make building regulations for any purposes, “Securing the health, safety, welfare and convenience of persons in or about buildings.” While the building regulations do not explicitly protect people’s health with regard to high temperatures, the overarching enabling power clearly envisages that.
63.Public Health England issues guidance on making buildings less vulnerable to overheating as part of its Heatwave Plan for England. However, their Medical Director and Director for Health Protection told us that it was not able to review uptake of its recommendations. CIBSE conclude:
We would stress the need for a regulatory response for new and existing buildings in order to… protect building owners and occupants from the growing health impacts of overheating buildings.
The Government needs to coordinate the regulatory response to overheating buildings and put the issue of public health front and centre. The Department of Health and Social Care should not overlook the health impacts of overheating simply because the solution may lie within another department’s policy.
64.The Adaptation Sub-Committee of the Committee on Climate Change note that a survey of building professionals found that 45% recognised overheating as an issue after the completion of the building work. According to CIBSE “the treatment of overheating at design stage is fundamental in increasing the resilience of buildings in hot events, now and in the future”. Zero Carbon Hub’s 2015 report on Overheating in Homes found that overheating affected housing providers’ reputations and led to costly remedial works. For instance, one housebuilder had to carry out £100,000 worth of retrofitting to bring a block of apartments within an acceptable temperature range.
65.New buildings must conform to standards set in the Building Regulations Act 2010 (as amended). Building regulations are a set of performance-based legal requirements for design, construction and alterations to buildings. Building Regulation Part L focuses on conservation of fuel and power and requires that “reasonable provision shall be made for the conservation of fuel and power in buildings by limiting heat gains and losses.” This is the only reference to overheating in the building regulations, even though Part F relates to ventilation. The Adaptation Sub-Committee of the Committee on Climate Change set out in detail in its 2014, 2015 and 2017 reports to Parliament that there is a need for a legal requirement to minimise the risk to occupants from rising temperatures, however there remains no standard or regulation to prevent overheating in new buildings, other than a requirement to make ‘reasonable provision’ to limit heat gains for the purposes of fuel conservation. Thermal comfort is not addressed anywhere in the building regulations.
66.Property developers can demonstrate compliance with the requirement to make reasonable provision to limit heat gains by following the guidance set out in the Government’s Approved Documents. However, there is industry concern that the guidance does not identify overheating buildings and that homes with poor thermal comfort continue to be built.
Box 3: Approved Document L1A and Standard Assessment Procedure Appendix P
Approved Document L1A sets out how new dwellings can be made compliant with regulatory requirement relating to fuel conservation for “reasonable provision” to be made to limit heat gains:
(i) appropriate window size and orientation;
(ii) solar protection through shading;
(iii) other solar control measures;
(iv) ventilation (day and night);
(v) high thermal capacity.
To measure whether solar gains are excessive the Approved Document recommends the use of the Standard Assessment Procedure (SAP) Appendix P. Appendix P consists of a calculation for each month of June, July and August using average weather data for the month in question and produces a single predicted average internal temperature for the property for each month. Buildings are given a score of high, medium, slight or low risk of overheating. Only a ‘high’ score amounts to failure of the test
67.Dr Anastasia Mylona told us that a dynamic thermo-modelling test to identify overheating buildings was removed from the Approved Document guidance in 2010. This test required the use of dynamic thermal modelling to assess overheating risk and introduce a more in-depth approach which considered solar gains, internal gains, fabric, occupancy profiles and hourly performance. CIBSE note that the removal of the test “was a downgrading of the treatment of overheating within the overall regulatory and guidance framework.”
68.When we asked the Minister for Housing, Dominic Raab MP, why the test was removed from the guidance he responded:
Compliance can be achieved through dynamic thermal modelling tests if preferred; we have an illustrative list but it is not exhaustive. No one is saying that dynamic thermal modelling is not a legitimate way of addressing the regulation requirements.
69.Zero Carbon Hub expressed concern that the current overheating assessment, Standard Assessment Procedure Appendix P, does not accurately identify overheating buildings. CIBSE has produced guidance on a more robust methodology for identifying overheating buildings, which sets a maximum percentage of hours that a building can exceed temperature thresholds. Approved Document L does not make reference to CIBSE’s overheating tests, despite the Minister for Housing’s praise of CIBSE’s work in this area. There is reference to CIBSE’s test for solar gains however this is recommended only for designers who “want to exceed the requirements in the current Building Regulations to consider the impact of future global warming on the risks of higher internal temperatures occurring more often.”
70.The risk of overheating is not adequately addressed in the building regulations and the wider regulatory framework. The health and future health of occupants should be a key priority of the building regulations, especially as severe heat events have become increasingly common since 1950 and are set to become more frequent. The Committee on Climate Change has repeatedly recommended a standard or building regulation to prevent overheating in new buildings, however thermal comfort is still not addressed in the building regulations. As the 1983 Building Regulations Act was written with the protection of people’s health in mind, the Government should use this enabling power to create a regulation to stop buildings being built which are prone to overheating. If the Government do not ensure that new buildings are designed to prevent overheating, housing providers or homeowners will have to pay for costly remedial works as heatwave risk intensifies.
71.The Government has weakened consideration of overheating risk by removing guidance on a dynamic thermo-modelling test from Approved Documents for Building Regulation Part L. This loss of clarity is regrettable. The recommended alternatives, such as Standard Assessment Procedure Appendix P, are inadequate. The Government should make the use of a dynamic thermo-modelling test, such as the Chartered Institution of Building Services Engineer’s TM59 and TM52 guidance, a regulatory requirement for new buildings. Requiring the test would enable property developers to demonstrate compliance with the new overheating regulation to protect health. The Government should explore extending the Green Deal to cover heat-resilient measures.
72.Dense urban areas are often significantly warmer than the surrounding countryside, especially at night. The air temperature in the centre of a large city can be 5 - 10°C warmer than rural areas. This is known as the urban heat island effect (UHI). London has the strongest urban heat island in the UK, with the city centre about 10 degrees warmer than outer parts of London.
73.Heat islands exist because the land surface in towns and cities, which is made of materials like tarmac and stone, absorbs and stores heat all day, and then emits heat at night. This causes night time temperatures to remain high. Paul Cosford, Medical Director and Director of Public Health at Public Health England, explained that temperatures remaining high at night affects physiological recovery from heat which is particularly important for health. The 2003 heatwave brought a large short-term increase in excess mortality in London. The Committee on Climate Change notes in its written evidence that the urban heat island effect is not included in current UK Climate Change Projections (UKCP09) due to difficulties in resolving city-scale detail in global models. There is concern that “assessments of heat-related health effects which use these projections may underestimate the actual magnitude of future health impacts in areas with urbanisation.”
74.The Met Office explain that there is a socio-economic element to vulnerability to the urban heat island:
… high UHI areas (linked to building density) coincide with poor housing quality (in terms of its potential to overheat), and poverty. Simple methods of cooling a building, such as opening windows at night, may not be options within high-crime areas that are also coincident with these areas. The poorer areas of the city are therefore most at risk from the effects of high-temperatures within a city.
75.The Town and Country Planning Association express concern that increasing development in urban areas, including the building of poor quality housing units, is resulting in adverse implications for people’s health and wellbeing. The Mineral Products Association criticises the Government’s funding of “modular” housing:
We note that the Government is now directly and indirectly supporting the use of factory produced housing, which is largely made from lightweight systems and materials of unproven durability. We would caution against this approach, not only on the grounds of robustness and longevity, but also because this type of housing is likely to offer poor resilience to the effects of future climate change, specifically overheating and flooding.
According to a study on Modular Construction in UK Housing by Pinsent Masons, there are currently around 15,000 modular homes built in the UK each year by China National Building Material Company.
76.Dr Mylona, from the Chartered Institution of Building Services Engineers outlined that homes are now also being built in areas of high noise and poor air quality, which makes it more difficult for occupants to open windows to ventilate their homes during a heatwave. Dr Mylona suggested that this was due to a lack of guidance.
77.The urban heat island effect is exacerbated by the use of air conditioning, which emits waste heat into the environment. The Government’s 2013 National Adaptation Programme noted that demand for domestic cooling could triple between 2010 and 2050. The Greater London Authority sets out a comprehensive approach to mitigating this demand:
The draft London Plan sets out policy to minimise the risk of new developments overheating and also to reduce their impact on the UHI through a cooling hierarchy that prioritises design, orientation, shading, and ventilation over mechanical cooling. It also requires planning assessments that consider overheating as well as energy efficiency.
78.There are several ways that rising urban temperatures and demand for air conditioning could be addressed through local and national planning. Dr Mylona from CIBSE recommended a holistic approach to planning, that takes account of air and noise pollution issues as well:
If we continue building the way we are at the moment, cooling will be inevitable, not just because of the techniques, the materials and the ways we are building and designing our buildings, but because there does not seem to be any mitigation of climate change and there is intense urbanisation.
79.Professor Cosford, Public Health England, explained the public health benefits of a well-designed urban environment:
For me, the most important issue is a real understanding of the importance of how we design the environment—the urban environment, hospital environment, and healthcare environment—for people’s health and wellbeing. It is hugely under-represented and misunderstood—or not understood sufficiently. If you want a view on where the greatest gains in the public’s health are to be found in the middle to long term, this area is among those at the top of that.
80.The design of urban and rural environments is structured by a local development plan, which must meet the standards in the Ministry of Housing Communities and Local Government’s (MHCLG) National Planning Policy Framework. Individual planning applications must be determined in accordance with the development plan, unless material considerations indicate otherwise. MHCLG states that local plans:
… set out a vision and a framework for the future development of the area, addressing needs and opportunities in relation to housing, the economy, community facilities and infrastructure–as well as a basis for safeguarding the environment, adapting to climate change and securing good design.
81.However, the Committee on Climate Change found that the majority of local plans do not address future overheating issues from climate change. The Town and Country Planning Association told us that “local plans in England have a very short time horizon of between 10 and 15 years”. A review by Land Use Consultants and JBA Consulting found that local plans focus on current, rather than future, climate risks. Kathryn Brown, Head of Adaptation at the Committee on Climate Change commented:
Flood risk tends to get talked about, but overheating, in almost all cases, does not have a lot of coverage … . A very firm message was coming back that they felt there was no scope to do much on adaptation.
82.The Town and Country Planning Association suggest that this is due to a reduction in local authorities’ budgets:
The planning service has had budget cuts of up to 48% and will be cut further because of reduced funding to local authorities. These cuts impact upon the skills and experience of staff, reducing their ability to find time to attend training and development opportunities, and to deal with a complex public policy issues.
83.The new revised National Planning Policy Framework (NPPF) outlines that local plans should take a proactive approach to mitigating and adapting to climate change, including the risk of overheating and rising temperatures. Kathryn Brown praised this change:
The NPPF—the National Planning Policy Framework—consultation that is out at the moment does include raising the profile of overheating. It has gone from an appendix, where there was guidance, into the main discussion about what should be in local plans on climate change adaptation. That is positive.
84.However, the Committee on Climate Change and other witnesses suggested that more guidance is still needed, particularly as there is no mention of the urban heat island effect in the NPPF. Cassie Sutherland, Policy and Programmes Manager for Climate Change Adaptation at the Greater London Authority (GLA) said:
From the GLA’s perspective, we would like to see stronger references to mitigating overheating in the NPPF, and taking the approach that we are actually taking in the London plan—the existing one and the draft new London plan—that looks at minimising internal heat gain and then looks at minimising the impact of new development on the urban heat island effect. We think the cooling hierarchy in the London plan at the moment is one option or framework that could be used as an example of including that kind of more targeted focus on overheating.
85.Rising temperatures in towns and cities increase vulnerability to heat-health problems, however the urban heat island effect is not currently included in future assessments of the health risks from heatwaves. Modular homes are not resilient to heatwaves, and should not receive support from the Government. The Government does not make reference to the urban heat island effect in the National Planning Policy Framework and heatwaves are not outlined as a specific climate change risk in the accompanying guidance. Local plans therefore tend not to include measures to mitigate urban heat islands. The Ministry of Housing, Communities and Local Government should make specific reference to the greater risk of overheating in urban areas and require local planning authorities with responsibility for dense urban areas to demonstrate how they have mitigated this in their local development plan, including the use of a well-enforced ‘cooling hierarchy’ to avoid the exacerbating impact of air conditioning. The Government should work with local authorities so that local plans take long term risks such as climate change into account. The Government should stop directing financial support to modular housing from its Home Building Fund.
86.Green spaces and infrastructure are known to reduce the urban heat island effect, however urban green space in England has declined to 56% in 2016 from 63% in 2001. The surface temperature in an urban green space may be 15–20°C lower than that of the surrounding streets, resulting in an air temperature 2–8°C cooler. Kathryn Brown pointed to some research that demonstrated the impact of green space at reducing the urban heat island effect:
There are a few studies we have included in the latest climate change risk assessment that looked at this. One of them, which was in Glasgow, looked at increasing green cover by 20%, which is obviously quite a big amount. The estimates for that suggested it could eliminate 30% to 50% of the expected extra urban heat island effect. It is not a temperature metric, but is the increase in the urban heat island by 2050. It was looking at reductions in surface temperature of around 2 degrees.
87.Professor Mike Davies, a member of the Adaptation Sub-Committee of the Committee on Climate Change and a Professor at the UCL Institute for Environmental Design and Engineering, told us that parks can reduce temperatures at a very local level:
There is some empirical evidence of parks locally reducing temperatures… there may be some value in having this [green space] distributed across a city such as London to prevent the full development of the potential maximum of the urban heat island.
88.The Town and Country Planning Association note that urban green spaces and trees have wider benefits of improving mental health, increasing biodiversity, protecting against UV radiation and providing space for shade and rest during heatwaves. Public Health England supports these findings in its document Spatial planning for health: an evidence resource for planning and designing healthier places, however this is only guidance for local action and there is no monitoring on the provision of urban green space in local plans. There is no explicit mention of the importance of shading streets and parks in the National Planning Policy Framework.
89.The new London Plan proposes a policy called the urban greening factor, which enables developers to quantify how much green space they should incorporate into their building plans, such as through green roofs and walls. Lord Gardiner provided some examples of other local councils improving their provision of green spaces:
Bristol City Council announced that they are looking to increase their tree canopy from 15% to 30% by 2050, precisely on the back of cooling shade. Greater Manchester is discussing being a city of trees—grassland trees, in fact, because that is a better way of cooling the city.
90.However, the majority of local plans to do not contain any strategies to reduce the urban heat island effect. The 25 Year Environment Plan outlines the Government’s ambition to improve health and happiness through greening the England’s towns and cities. Actions include planting one million trees in towns and cities by 2022, drawing up a national framework of green infrastructure standards, supporting local authorities to assess their provision of green space against these standards and exploring how green infrastructure commitments can be built into national planning guidance and policy. However, there is no mention of the benefits of green spaces for reducing the urban heat island effect, and protecting the population of towns and cities during heatwaves. There are no national targets to increase urban green space back up to 2001 levels.
91.Green spaces have been proven to reduce the urban heat island effect, however urban green space has declined in England. The Government’s commitments to green towns and cities are not measurable or target driven and do not link green spaces to urban heat island reduction. The Government should introduce an urban green infrastructure target as part of the metrics for the 25 Year Environment Plan and in the National Planning Policy Framework to ensure towns and cities are adapted to more frequent heatwaves in the future. The Government should aim to increase urban green space to 2001 levels, and higher if possible. The importance of shaded spaces in urban areas should be included in the Framework’s section on ‘promoting healthy and safe communities’, so that all local planning authorities have to demonstrate their provision of shaded spaces in the clearance process of their local plans.
92.Future projections of hotter, drier summers are likely to result in low water flows and reduced water levels. Heatwaves also put extra pressure on the water supply by increasing demand. During the period of very hot weather in late June 2018, homes in Shropshire, Staffordshire and Derbyshire were temporarily without water as demand outstripped supply across the network. In Northern Ireland, a hosepipe ban was introduced.
93.It is predicted that there will be less water available per person in the future. Paul Hickey, Head of Water Resources at the Environment Agency, told us that the reduction in public water supply due to climate change is between 4% and 7% across the UK. In its 2016 roadmap Creating a great place for living: Enabling resilience in the water sector the Government acknowledged:
By the 2050s, summer temperatures are likely to increase while summer rainfall decreases, leading to increased risks of short-duration droughts. The population in England is forecast to grow by over 10 million people over the same period, with a large part of this growth occurring in areas where water is already scarce.
94.Waterwise’s Water Efficiency Strategy for the UK outlines that a water-saving culture must be developed throughout the UK to manage demand:
We know that most people take some actions to save water, but we also know that there is a lot more to do. Water efficiency needs to become the norm across all activities throughout everybody’s lives–wasting water should be seen as going against the norm.
95.Anglian Water explained that the urban heat island effect increases demand even further:
For water companies, the most demonstrable effect of the urban heat island effect is the increased water consumption that comes with the prolonged higher temperatures. In some places, water consumption can increase significantly and this will only exacerbate the situation in water-stressed areas. This makes it all the more important to embed water efficiency at the heart of planning policy and to ensure a minimum standard of resilience for the public water supply.
96.Paul Hickey explained that households are more likely to undertake water efficiency measures if water companies are addressing their own leakage problems. The National Infrastructure Commission found that, at present, 20% of the mains water supply is lost to leakage every day and recommended that the Government set a target for water companies to halve their leakage by 2050. We support this recommendation, and urge the regulator, Ofwat, to use its powers to ensure this occurs and that the water network is more resilient.
97.Household behaviour can have a significant impact on the water supply. For example, showering for one minute less each day can save about 3,000 litres of water per year, saving £7 on energy and £12 on water bills. There is evidence that charging by volume leads to more efficient water use. Standard meters can reduce average consumption by 15% and smart meters by 17%. At present, water companies can only impose volume-based charges for new homes or occupiers where households use large quantities of water or in areas classified as seriously water stressed by the Environment Agency.
98.The Government has weakened its water efficiency ambitions. A leaked draft of the 25 Year Environment Plan indicates that the Government originally intended to introduce tighter water efficiency standards into the building regulations. Part G of the building regulations sets a water efficiency requirement for buildings of 125 litres per person per day. There is an optional tighter requirement of 110 litres per person per day. The optional requirement only applies where a condition has been imposed as part of the planning process. The original version of the 25 Year Environment Plan proposed making the lower option the default standard, but in the final Plan this ambition was revised to:
We will work with industry to determine appropriate targets for personal water consumption and the measures needed to achieve them.
Anglian Water told us they would support the application of more ambitious water efficiency targets, and they have made representations to the Government on this.
99.The urban heat island effect results in water stressed areas experiencing increased demand for water during heatwaves. It is expected that there will be less water available per person in the future. Regardless, the Government has weakened its water efficiency ambitions and has overlooked industry representations to make per capita consumption standards more efficient. A water-saving culture needs to be embedded to ensure that people understand the strain heatwaves place on the water supply and to make more water is available during a heatwave. The Government should adopt 110 litres per person per day as the mandatory standard in Part G of the building regulations for all new buildings.
100.Sustainable drainage systems (SuDS) can reduce the urban heat island effect, as well as providing a sustainable way to collect storm water to irrigate green infrastructure. Waterwise, a water efficiency charity, advocates for integrated water management systems that recognise the co benefits of water management solutions such as blue-green infrastructure and SuDS.
Box 4: Sustainable Drainage Systems
Sustainable drainage systems (SuDS) are environmentally sustainable ways to manage surface water and run off, by mimicking natural drainage as closely as possible. SuDS allow water to infiltrate into the ground, which helps to maintain soil moisture, and provide collection of water for reuse in irrigation of green roofs or walls. The evapotranspiration (water evaporation) from SuDS provides a cooling effect, which can be beneficial to reducing the urban heat island effect.
SuDS are a regulatory requirement in all new developments in Scotland, Wales and Northern Ireland. The draft revised National Planning Policy Framework (NPPF) for England outlines that “major developments should incorporate sustainable drainage systems unless there is clear evidence that this would be inappropriate.” The Chartered Institution of Water and Environmental Management’s report A Place for SuDS? criticised the NPPF’s weak wording as a barrier to widespread uptake of SuDS. The report is supported by over fifteen environmental organisations.
101.In the 2013 National Adaptation Programme, the government committed to implementing Schedule 3 of the Flood and Water Management Act 2010, which provides for increased uptake of SuDs in new developments, by April 2014. However Anglian Water told us that the government reversed this commitment.
102.Waterwise and the Environment Agency suggest that local authorities should have a greater role in ensuring water efficiency than currently outlined in the Government’s Climate Change Risk Assessment (CCRA). Anglian Water suggest that SuDS should be a requirement in the NPPF, as this would make them a statutory requirement in all local plans. This would provide multiple benefits of reducing the urban heat island effect, providing irrigation for green infrastructure and retaining soil moisture, which we heard is crucial for reducing temperatures during a heatwave. Paul Hickey emphasises the importance of building SuDs to a sufficient standard to ensure they are adopted and managed sustainably. The Secretary of State for Environment Food and Rural Affairs, Rt Hon Michael Gove MP told us that the Government intends to make proposals on sustainable urban drainage “a little later this year.”
103.Sustainable drainage systems (SuDS) provide multiple benefits of reducing the urban heat island effect through evapotranspiration, providing irrigation for green walls and roofs and retaining soil moisture. However, England is the only country in the UK that does not require SuDS for all new developments in its planning policy. In the 2013 National Adaptation Programme the Government promised to make SuDS a requirement by 2014, but this commitment was quietly dropped. This is disappointing especially as it is now over 10 years since the Pitt Review’s recommendation to make SuDS compulsory. As the population in dense urban areas grows, the Government should recognise the benefits of an integrated water management system for reducing the urban heat island effect. There is no need for further review of the benefits of SuDS. Before publication of the revised National Policy Planning Framework it should be updated to require SuDS in all new developments. Guidance on how to build SuDS to an adoptable standard should also be produced. This would ensure that all local authorities, particularly those with dense urban areas, manage water more responsibly as heatwaves become more frequent.
69 A Elliot et al, ‘Using real-time syndromic surveillance to assess the health impact of the 2013 heatwave in England’, Environmental research, 135, 31–36 (2014).
70 R S Kovats et all, ‘The impact of the 2003 heat wave on mortality and hospital admissions in England’, Health Statistics Quarterly 29, Spring 2006, 6–8
73 Environmental Audit Committee, Q67, oral evidence, Environmental Principles and Governance Consultation, 19th June 2018,
75 R S Kovats et al, ‘Mortality in southern England during the 2003 heatwave by place of death’, Health Statistics Quarterly 29, Spring 2006, 6–8
76 , Heatwave Plan for England
80 the costs of providing and maintaining the NHS Estate including buildings, maintaining and equipping hospitals, the provision of services e.g. laundry and food, and the costs and consumption of utilities.
82 Committee on Climate Change ()
85 R Gupta et al, Care provision fit for a future climate, Joseph Rowntree Foundation
91 Professor Rajat Gupta ()
97 Chartered Institution of Building Services Engineers (CIBSE) ()
98 Chartered Institution of Building Services Engineers (CIBSE) ()
100 Part L, Building Regulations 2010 (as amended)
101 Committee on Climate Change ()
102 The 2006 in Approved Document L2A test looked at hourly summertime performance and how many hours the indoor temperature went above 28°C. If it reached that temperature for more than 1% of occupied hours, the building was deemed overheated. and Chartered Institution of Building Services Engineers (CIBSE) ()
103 Chartered Institution of Building Services Engineers (CIBSE) ()
106 Chartered Institution of Building Services Engineers (CIBSE) (). CIBSE outlines a series of key simplifications and assumptions made by SAP Appendix P which reduces its ability to identify overheating buildings.
107 CIBSE’s guidance and , , ,
108 HM Government,
111 R S Kovats et all, ‘The impact of the 2003 heat wave on mortality and hospital admissions in England’, Health Statistics Quarterly 29, Spring 2006, 6–8
112 Met Office ()
113 Committee on Climate Change ()
114 Met Office ()
115 Town and Country Planning Association ()
116 Mineral Products Association ()
117 Pinsent Masons Research, Modular Construction in UK Housing: An Overview of the Market, the Players and the Issues, February 2017
120 Greater London Authority ()
124 Town and Country Planning Association ()
127 Town and Country Planning Association ()
129 Committee on Climate Change (),
131 Committee on Climate Change ()
132 Town and Country Planning Association ()
138 Committee on Climate Change ()
139 UK Government ()
141 (now withdrawn)
143 Anglian Water Services ()
149 A Place for SuDS? is supported by the Wildfowl and Wetlands Trust (WWT), Royal Town Planning Institute (RTPI), Royal Institute of British Architects (RIBA), Institution of Civil Engineers (ICE), Institution of Environmental Sciences (IES), Landscape Institute, University of Exeter Centre for Water Systems, Susdrain, Future Water Association, Association of Drainage Authorities (ADA), Cornwall Community Flood Forum, the Construction Industry Council Champion for Flood Mitigation and Resilience, Royal Society for the Protection of Birds (RSPB), WWF, the Angling Trust, Buglife and Salmon and Trout Conservation UK.
150 Anglian Water Services ()
151 The Government’s acknowledges “risks of shortages in the public water supply, and for agriculture energy generation and industry, with impacts on freshwater ecology” as an area where more action is needed. The actions to address the risk to the water supply focus on the role of water companies and there is no mention of the role of local authorities.
154 Environmental Audit Committee, Q67, oral evidence, Environmental Principles and Governance Consultation, 11th July 2018,
Published: 26 July 2018