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Chartered Institution of Water and
Environmental Management (CIWEM)

106-109 Saffron Hill, London, EC1N 8QS  
Tel: 020 7831 3110 Fax: 020 7405 4967
 

Sustainable Communities

Purpose

This Policy Position Statement provides an overview of CIWEM's position on the Government's "Sustainable Communities Plan" and sets out the areas which the Institution considers are in need of attention.

CIWEM's views:

  1. CIWEM recognises that a growing UK population needs to be housed, and that this should be achieved in communities which meet the components detailed in the Government's definition of a sustainable community(1)
  2. CIWEM broadly supports the components that have been set out in the definition of a sustainable community by the Office of the Deputy Prime Minister (ODPM).
  3. CIWEM questions whether these components are deliverable under the current plans and present Government policy on the environment. There is a need for greater Government commitment to comprehensive environmental husbandry interwoven at every level of planning and delivery of new developments. Otherwise, these communities will not be sustainable as we move into an era of increasing environmental pressure.
  4. CIWEM is concerned that the principal focus of the plans, a large-scale expansion of housing provision in the South-East of England, marks a repetition of unsustainable and outmoded "predict and provide" planning practice and more radical action is required to deliver a greater proportion of the capacity through centrally supported regeneration in other parts of the country.
  5. London and the South-East of England, in particular, face pressures on already stretched resources in future decades which will be exacerbated by expanded housing provision. This does not sit well with the commitment in the Government's strategy on sustainable development(2), to live within environmental limits.
  6. The Government has the regulatory tools and capacity to initiate considerably improved building standards, resource efficiency and environmental consideration, which it must employ to instigate significant attitude and behavioural change amongst planners, developers, industry and the wider population.
  7. CIWEM asserts that there is a range of fundamentals that must be considered and delivered upon if new development is to truly meet the needs of both present and future generations.

The Chartered Institution of Water and Environmental Management (CIWEM) is the leading professional body for the people who plan, protect and care for the environment and its resources, providing educational opportunities, independent information to the public and advice to government. Members in 97 countries include scientists, engineers, ecologists and students.

Context

The Sustainable Communities Plan was announced by the Deputy Prime Minister in February 2003. The plan proposes to deliver sustainable communities in both urban and rural areas, through tackling housing supply issues in the South East, lower demand in other parts of the country, and the quality of public open spaces. It claims to herald a "real step-change" in "how we build and what we build" (3) with new buildings meeting strict environmental standards.

The plan highlights four growth areas - Thames Gateway, London-Stanstead-Cambridge-Peterborough corridor, Ashford and Milton Keynes-South Midlands. Over 1 million homes are to be built in these areas by 2016 - approximately 200,000 over and above those proposed in existing regional planning guidance, in order to address an apparent discrepancy between supply and demand.

London and the South-East of England remain the focus for economic productivity and growth in the UK and together these regions have a population of over 15 million. Meanwhile, many previously prosperous parts of the country, which relied on traditional manufacturing and heavy industries (particularly cities and towns in the North and the Midlands) have seen economic decline and outward migration over recent decades. Whilst aiming to provide for predicted growth in the South-East, the plan also aims to tackle urban decline across the country.

London and the South-East of England face resource pressures (e.g. water resources and waste management capacity) in coming decades. If new housing development is to take place in this part of the country it is essential that this meets strict and ambitious environmental standards and is accompanied by the requisite investment in infrastructure.

Key Issues

What is a sustainable community?

ODPM criteria(1) state that sustainable communities should meet eight overarching criteria: active, inclusive and safe; well run; environmentally sensitive; well designed and built; well connected; thriving; well served, and fair for everyone. Further detail is provided for each criteria, with the following being set out regarding communities being environmentally sensitive:

  • actively seek to minimise climate change, including through energy efficiency and the use of renewables
  • protect the environment, by minimising pollution on land, in water and in the air
  • minimise waste and dispose of it in accordance with current good practice
  • make efficient use of natural resources, encouraging sustainable production and consumption
  • protect and improve bio-diversity (e.g. wildlife habitats)
  • enable a lifestyle that minimises negative environmental impact and enhances positive impacts (e.g. by creating opportunities for walking and cycling, and reducing noise pollution and dependence on cars)
  • create cleaner, safer and greener neighbourhoods (e.g. by reducing litter and graffiti, and maintaining pleasant public spaces).

CIWEM considers that for a community to be sustainable it should conform to the three 'pillars' of sustainable development, i.e. balance economic growth, protection of the environment, and social equity.

The South-East faces significant future resource / carrying capacity pressure
London and the South-East of England are the most populated areas of the country. 25% of all UK inhabitants live in this area and inward migration is predicted to grow. The area also faces pressure on its resources exacerbated by the demands placed upon them by the density of its population.

One of the main pressures on the area concerns the availability of water resources. Average rainfall is lowest in this part of the country, whilst per capita household consumption of water is highest, as is the requirement for agricultural irrigation. Some water resources have no additional water available or already suffer from unsustainable or unacceptable levels of water abstraction(5). Climate change scenarios show that this situation is only likely to worsen, with less summer rainfall and higher rates of evaporation affecting southern parts of the country in particular.  This will mean that river, groundwater and reservoir yields may fall significantly and new resources are likely to be required even to supply the current population.  Demand management will play an important role but will not in itself be sufficient to meet the need.

Many local authorities in the South and East are uncertain they will be able to meet EU and government targets to reduce the amount of waste sent to landfill, yet the predicted number of new homes over the next 20 years will increase the quantity of household waste produced by around a third(6) and the targets set will become increasingly stringent over this period.

The Government claims that it will ensure a minimum density of 30 dwellings per hectare to reduce urban sprawl, that at least 60% of new development will take place on previously developed (brownfield) land, and it will maintain or increase the greenbelt in each region(1). The Government's Green Belt Direction and Density Direction require inappropriate planning applications (either by location or density) to be referred to the First Secretary of State. Whilst the Thames Gateway represents the largest area of brownfield land adjacent to a European capital city, many of the developments on the other growth areas will take up significant tracts of previously undeveloped land(7).

Many locations allocated for development lie in flood plains. The Environment Agency has produced indicative flood plain maps which show clearly the geographical extent of potential flooding. CIWEM believes that due to future climate change scenarios and resultant increases in storm events and, in the longer term, rising sea levels, building on flood plains is not sustainable. The Institution has proposed the creation of a 'Blue Belt' land designation in the most flood prone areas, in which there should be a presumption against future development. Additional urbanisation within a catchment will result in more hard surfaces, increased runoff, 'flashier' responses to rainfall events and consequently increased flood risk in the flood plain. A further effect of this is that rainwater runs away before it gets the chance to infiltrate the soil and re-charge groundwater resources.

Continued net migration to the South-East is unsustainable in the long-term
The South-East of England has been described as the 'locomotive' of the UK economy(8). 2001 census data indicates that the so-called 'North-South Divide' continues to exist(9) and the ODPM states: "there is now a widening competitiveness divide between the south eastern regions around London and all the other regions"(10).

The Government has placed a high priority on improving the performance of all regions and reducing the disparities between them, and has highlighted the largest English regional cities - so-called "Core Cities" to drive competitiveness in the knowledge economy in the regions.

Despite this apparent commitment, the clear focus of the Sustainable Communities Plan remains the expansion of housing provision in the South-East. The Sustainable Communities Plan has simply set out to provide for the predicted levels of growth in the area. The Environmental Audit Committee(11) expressed concern that this constitutes a short-term approach to a long-term problem which will only exacerbate it "to the detriment of the country as a whole". However, the Government contends that redistribution of economic activity from the South to the North will simply not work, and that "Displaced economic activity will simply go overseas or will not happen at all"(12).

Future development must take greater account of environmental impact
The Environment Agency(6) expresses concern that if all new homes were built to current energy efficiency requirements, domestic CO2 emissions would increase by 24 percent, placing strain on long term targets for carbon emissions reduction. The Environmental Audit Committee(11) notes that unless significant action is taken, carbon emissions from the housing sector are likely to almost double from their present 30 percent contribution to the UK's target amount, to over 55 percent. It also highlights a widespread lack of compliance with Part L of the current Building Regulations (which govern energy efficiency) and states that enforcement should be tightened significantly. It is clear, therefore, that far greater emphasis should be placed on more local and diverse sources of energy supplies when planning new communities, including renewables such as solar power and wider use of combined heat and power.

The environmental performance of new buildings constructed under the Sustainable Communities Plan is emphasised in the criteria that have been set out, both in terms of impact during construction and in the longer term once occupied. Revised building regulations are due to be issued in late 2005 (and updated every 5 years hence), which the ODPM claims will increase energy and water efficiency of new dwellings by 25 percent, and the Government aims to raise average energy efficiency of the entire residential housing stock by 20 percent by 2010 by improving the efficiency of existing stock. A voluntary code of practice, the 'Code for Sustainable Buildings' will aim to promote best practice at an even higher level and is due in 2006.

The Government wishes to encourage greater recycling of materials in construction. There should be maximisation of the use of materials which are sustainable, recycled or recyclable and which are locally sourced. It is likely that the Code for Sustainable Buildings will propose a minimum of 10% recycled material in new build. Soils from brownfield sites may conceivably be cleaned for re-use, however the UK's waste legislation (derived from European Directives) places barriers (both administrative and sociological) on the efficient re-incorporation of such materials into construction; hence, recycling targets are currently unable to be met, and these soils even when cleaned are sent to landfill.

The impact of the proposals on biodiversity has not been considered in detail and it is likely that with up to 40 percent of new development taking place on previously undeveloped land the proposals will have a significant negative impact. The Government promises to protect and improve biodiversity via the plans therefore it is important that provision is made for wildlife in new developments, and appropriate mitigation and compensation techniques are employed. It is also important that management agreements are put in place to ensure ongoing management of open space and habitats. Their creation is inexpensive when put in the context of the overall costs of a development but often once created, wildlife areas go unmanaged and their biodiversity value suffers. It is also important to note that brownfield land may have become locally important wildlife habitat.

Discussion

CIWEM acknowledges that the UK has a growing population which needs to be housed. We welcome the fact that the Sustainable Communities Plan attempts to address issues that have previously received scant attention when planning for growth and regeneration. However, we are concerned that if the Plan is to deliver a real step change in building, as is claimed, it must go much further otherwise we do not believe the outcome will justify the use of the term 'sustainable'.

We suggest that a truly long-term perspective is required when considering the impact of the plan on the country as a whole. We consider that the present focus of the plan is weighted far too heavily towards housing expansion in the South-East, and that this constitutes a repetition of previous 'predict and provide' approaches to planning. Instead, we would urge the Government to facilitate development and growth in presently declining regions in the North and the Midlands, rather than placing yet more pressure on the already stretched infrastructure and environment of the South-East.

A key message from the Government's strategy for delivering sustainable development in the UK (2) was to work towards defining environmental limits and living within them. CIWEM considers that population is a defining factor of such limits and the impacts of population pressure on the environment and how this is managed in future is something that should be examined in the context of the Sustainable Communities Plan.

CIWEM is unconvinced by the Government's assertion that attempts to encourage business development away from the South-East will result in this either not happening at all or will result in relocation overseas. The Institution contends that in coming decades significant action will be needed to address the major wider environmental impacts of long-distance transportation of many goods and services which could be provided locally. In addition, modern communication technologies mean that there should be less need for businesses to be clustered in the same geographical areas and the Government should be examining how to optimise the flexibility that such technologies offer now and in the future, particularly in areas of the economy that deal primarily with intellectual property.

The Green Belt land designation is 50 years old and was a hard-won planning device which has successfully prevented towns and cities sprawling into the countryside. The planned rapid expansion of housing in the South-East represents a real threat to the landscapes and rural communities that Green Belt was meant to protect. Individually, such developments may not seem much, but pieced together they are significant. Whilst the Government claims that Green Belts are being expanded, it is crucial to expand them in the right places so that they continue to serve their intended purpose. A simple net increase nationally will not be enough.

Whilst the Plan states that many of the proposed growth areas will see large-scale employment creation, CIWEM is concerned that there is a real risk such areas will simply become dormitories for commuters working in and around London. We are not convinced that there is sufficient evidence of future Government investment in infrastructure and local jobs on a scale required to ensure that this does not happen.

CIWEM supports the criteria that the ODPM has set out to define a sustainable community. However, it is difficult to see how under the current plans and present Government policy on the environment, these criteria are deliverable, at least in relation to that development which is undertaken now. Whilst the forthcoming Code for Sustainable Buildings and update to Part L of the Building Regulations will be a welcome step, we believe that a voluntary code is insufficient to deliver the pressing improvements required to make development in the UK sustainable. Significantly tighter statutory standards are urgently required to head off scenarios such as those presented by the Environment Agency(6) and the Environmental Audit Committee(11) on future domestic CO2 emissions.

CIWEM considers that the Government has an opportunity in this plan to mark a defining point in the future development of the country. There are a great many issues that to address require brave and radical action, and the Government has the legislative and fiscal tools to instigate this should it so choose. The Institution recognises that Government cannot achieve the desired results on its own. A concerted programme of public awareness and education is therefore essential in order to foster improved levels of environmental consideration throughout the UK business community and the wider public. We believe these issues must be considered with the utmost seriousness and decisive action taken if future communities are to prosper through different environmental realities to those faced today.

References

  1. ODPM, Sustainable communities, www.odpm.gov.uk
  2. HM Government, Securing the Future - Delivering UK Sustainable Development Strategy, March 2005
  3. ODPM, Sustainable communities: building for the future, February 2003
  4. Office of National Statistics, Census 2001 statistics, www.statistics.gov.uk
  5. Environment Agency, Water Resources for the Future, March 2001
  6. Environment Agency, Position Statement: Sustainable Communities, October 2004
  7. Defra, Study into the Environmental Impacts of Increasing the Supply of Housing in the UK, April 2004
  8. SEEDA, An Economic Profile of the South East, 2002
  9. Daniel Dorling and Bethan Thomas, People and Places - A 2001 Census Atlas of the UK, June 2004
  10. ODPM, Our Cities are Back - Third report of the Core Cities Working Group, December 2004
  11. House of Commons Environmental Audit Committee, Housing: Building a Sustainable Future, January 2005
  12. HM Government, Government Response to the House of Commons Environmental Audit Committee Report - Housing: Building a Sustainable Future, May 2005

August 2005

Note: CIWEM Policy Position Statements (PPS) represents the Institution's views on issues at a particular point in time. It is accepted that situations change as research provides new evidence. It should be understood, therefore, that CIWEM PPS's are under constant review, that previously held views may alter and lead to revised PPS's.

 

Chartered Institution of Water and
Environmental Management (CIWEM)

106-109 Saffron Hill, London, EC1N 8QS  
Tel: 020 7831 3110 Fax: 020 7405 4967

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