Royal Commission on Environmental Pollution

The Federation is the trade body representing approximately 1,400 not-for-profit registered social landlords (often referred to as housing associations) in England. We are a growing housing provider and currently our members provide some 1,200,000 homes for social housing including rented and shared ownership homes for those on or at near benefit levels, housing for elderly persons, and housing projects for people with special needs. In the financial year 2000/2001 our members will provide circa 19,000 new and refurbished homes through a combination of social housing grant (awarded through the Housing Corporation, the sector regulator) and private finance.

The Federation is increasingly aware of the importance of sustainability in both construction and maintenance. We are active participants of the Sustainable Homes group, and promote energy efficiency measures to members. The Federation would like to respond to the following points.

1.      ENVIRONMENTAL SUSTAINABILITY
b)       Whilst the Federation welcomes environmental objectives, they should be feasible and linked to wider considerations. The housing sector can be highly land intensive and susceptible to planning actions which make development sites difficult to obtain adversely affecting rent. New measures should address the potential impact of tenants. Housing is therefore a particularly sensitive sector. Environmental objectives should be framed with a recognition of the constraints actors face when responding to new initiatives. Social landlords provide housing at affordable levels to vulnerable members in society. Environmental objectives may introduce new demands upon social landlords and thereby increase building and maintenance costs.

d)       The Planning Policy Guidance No 12 (1999) requires local authorities to 'test' their policies and proposals against the four sustainable development objectives outlined in the UK Sustainable Development Strategy (1999) and secure greater involvement from the public and key stakeholders in shaping the development plans. This plan led approach, which gives consistent and quicker planning decisions, is dependant on local planning authorities having secured adopted Local Plans with development policies and proposals. The reality is that in over 25% of local authority areas in the country the new Local Plans have not yet been adopted. This effectively means that they are still operating on Local Plans that may have been prepared without undertaking full environmental capacity studies to effectively protect the environment and adequate assessments on the impact on natural resources. The proposed Community Plans will be a positive step forward as they will promote greater openness in the planning process and enable local residents to take greater ownership and responsibility for the economic, social and environmental activities in their local community.

e)       The effectiveness of plan, monitor and change is dependant on the robustness of the regional planning guidance and development plans policies, the adequacy of the indicative monitors and targets, and the regularity of the review process. At this stage none of the Regional Planning Guidance documents have been finally adopted so it is too early to assess whether the new process will be successful in avoiding environmentally unsustainable outcomes. However the Proposed Modifications to RPG9 would suggest that the effective protection of the environment and prudent use of natural resources are seen as fundamental to the core strategy and vision for RPG 9. It is highly probable that the RPG 9s approach on environmental matters will be followed by all other RPGs and subsequent development plans.

h)       The planning system can play a significant but not singular role in limiting environmental damage. The construction industry is a significant environmental polluter and planning can play one particular role in promoting environmentally sound building work. The host of recent construction policy strategies such as the Rethinking Construction agenda, the Building a Better Quality of Life strategy, and the intended revision of the building regulations provide the opportunity to approach environmental construction on two fronts: the building itself, i.e. its energy performance and efficiency; and, through planning, the particular location of the building within a wider environmental context. The Rethinking Construction agenda emphasises innovative construction techniques and the application of new source materials. These could prove controversial in some planning process contexts. Therefore, although the two policy areas are complementary, the Commission should cater for linking the two programmes to reduce the significance of construction upon climate change.

2.      BOUNDARIES
c)       The land use planning system already has responsibility for transport and planning through PPG13 and there may indeed be scope for the planning system to help contribute to other areas. The government has placed the environment as a policy priority demonstrated by a number of schemes and initiatives to tackle pollution and unsustainable development. Regulatory instruments or more aspirational performance indicators are the current means to achieve these. Within the emerging framework, the introduction of a new role for planning guidance may help promote the delivery of environmental policy targets.

3.      INTERGRATION AND CO-ORDINATION?
d)       The land use planning system is a necessary part of building and development. Time efficiency is the chief concern. The increased scope of measures to test, should greater environmental objectives be embraced by the planning system, will undoubtedly lead to a more lengthy planning process. The introduction of new environmental planning assessment criteria may extend the time taken to reach a planning decision.

f)       The Federation argues that the scheme is not fully integrated and that there are differences between rural and urban development projects. There are different requirements for each area type and the linkages between rural sector development and transport and social infrastructure provisions are significant.

5.      ASSESSMENT APPROACHES
b)      Effective dissemination of the environmental implications for development projects is key to understanding trends and the relevance, feasibility and performance of environmental planning systems. The potential scope of environmental variables for assessment are significant. A government agency would appear to be the most suitable location. Close liaison with those involved in site development is also desirable. Criteria of what is meant by 'quality' should be more carefully specified.

e)       There are broadly three categories of interest surrounding environmental sustainability. Some notable contributors are highly keen to develop environmental plans, some are interested yet not active, and some are not interested. Environmental considerations therefore need greater publication. There are means for dispersing knowledge to practitioners, for instance through telephone hot-lines such as constructionline. Training and conferences can also increase the awareness of actors. Further initiatives are required to extend knowledge about the importance of the environment. The growing number of regulations and the heightened policy profile of environmental considerations will see environmental knowledge become a significant part of future development, and as yet requires greater dispersal.

The Federation would welcome any further opportunities to discuss the points raised in this response.

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