Dr Michal Drewniok (University of Leeds; Dr Philip Graham (University of Cambridge);

Dr Anna Pagani (Kings College, London)                            ESH0083

Written evidence submitted by Drs A. Pagani, P. Graham, M.P. Drewniok, working as a HOUSING SUFFICIENCY WORKING GROUP

Select Committee Submission

On the compatibility of sustainable housing development
with environmental objectives

Submitted: 14th January 2025 (updated version).

Committee: Environmental Sustainability and Housing Growth

Inquiry: Call for evidence

A.              Introduction

A1.                The following submission represents the collated views of three built environment experts, specialising in the interfaces between housing design, housing policy, housing markets, energy use and environmental goals. Our work concerns definitions and justifications for housing sufficiency as an alternative basis for housing policy in the UK and internationally. Our expertise crosses the fields of systems thinking (AP & PG), housing studies (AP & PG), architectural design (PG) and civil / structural engineering and materials science (MPD), and has extra relevance due to our experience in participatory approaches (AP) and parallel work in industry and practice (MPD & PG).

A2.                As a multi-faculty, multi-institution, multi-disciplinary group, we feel uniquely well placed to comment on a call for evidence that cannot be answered from the point of view of any single subject area or specialism.

A3.                Our response is to Question 3 of the terms of reference. Here, the Committee has asked about the extent to which the current planning presumption in favour of sustainable housing development is compatible with the environmental objectives of the planning system.

B.              Executive summary

B1.                Numerous scientific studies show the current planning presumption in favour of sustainable housing development to be incompatible with the environmental objectives of the planning system. Indeed, the embodied carbon emissions from building 1.5 million new homes in England would be comparable to flying the entire UK population to New York, with added environmental damage on top, due to a combination of the habitat loss, material extraction and waste disposal associated with new build construction.

B2.                Taking a whole-system approach in pursuit of holistic solutions, we find little justification for the proposed house building programme, even beyond its environmental consequences. Considering that there are already 1.5 million empty or underused homes, continuous house building will not lower prices or expand homeownership, but rather perpetuate underlying distributional issues, including car lock-in and the continuing loss of affordable and social homes.

B3.                Instead, we offer alternative pathways to delivering housing that is research-backed and compatible with the environmental objectives of the planning system. This is premised on establishing a sufficient level of housing space per person and applying this to: (a) the available floor area capacity in any given area; (b) the potential for expanding this capacity through a combination of retrofit, subdivision, extensions and limited new build; and, (c) the headroom relative to climate commitments.

B4.                We recommend modernising planning rules, decarbonising the tax system, and supporting innovative finance measures to prioritise the reuse and retrofit of existing homes, encourage better matching of living space to changing and changeable housing needs, and ensure the long-term sustainability of the UK’s housing stock for households, communities and climate.

B5.                In summary, our evidence supports the view that ‘sustainable development’ as currently defined, may have political value and stimulate economic activity over the short term, but cannot be justified from an environmental, affordability or systems thinking perspective. Alternatives exist that could allow the government to deliver on the number of homes aligned with actual and changing needs, but within planetary boundaries and therefore by means other than new-build construction alone. Our response follows the above themes.
 

C.              Incompatibility with environmental objectives

C1.                The current planning presumption in favour of sustainable housing development is not compatible with the environmental objectives of the planning system.

C1.1.         The housing question is critical for climate goals because the construction and operation of new-build housing makes up 12% of the UK’s total consumption-based GHG emissions (zu Ermgassen et al., 2022).

C1.2.         Based on the modelling work of Drewniok, Dunant, et al. (2023), we calculated that the greenhouse gas emissions (GHG) from building 1.5 million homes in England would be around 60MtCO2e (estimate[1]). This is comparable to flying the entire population of the UK to New York[2] but with added environmental damage associated with all new-build construction. These externalities include long lasting habitat loss, material extraction, pollution, erosion, disruption to biosystems and waste disposal (Everingham, 2024).

C1.3.         The Government strategy is to add 1.5 million homes in England in the next five years, therefore 300,000 a year. The study of Drewniok, Dunant, et al. (2023) showed that adding 300,000 homes annually to England building stock by 2050 would double the cumulative emissions budget apportioned to house building until 2050 (Drewniok, Dunant, et al., 2023). Keeping today's level (234,000 a year), the cumulative emissions budget apportioned to house building until 2050 will be spent by 2040.

C2.                There is no way to decarbonise housing, except by reducing demand.

C2.1.         The built environment already accounts for 25% - 30% of the UK’s total territorial GHG emissions (UK Green Building Council, 2021), whilst the foundation industries in the UK (cement, metals, glass, chemicals, paper, and ceramics) that supply some of the heavy materials to the construction industry account for 10% (Hafez et al., 2024).

C2.2.         Opportunities to reduce emissions through high-tech decarbonisation strategies will not be sufficient to reach zero carbon by 2050 because they are limited by low carbon fuel availability, capital investment, and technology readiness. According to Hafez (2024), the UK’s 2050 net-zero carbon goal can be achieved only with 20-40% demand reduction. This can be done through (a) circular economy strategies, (b) material efficiency, and (c) changes in product specifications (Hafez et al., 2024).

C2.3.         As for point a, retrofitting the existing housing stock for energy efficiency improvements is an essential part of any circular economy strategy. With 29 million homes to be retrofitted – almost all of today’s existing stock – the task will need to be completed over 30 years, at a pace of over one million homes every year (LETI, 2020). Such a programme of retrofit can consume up to 10% of the UK’s carbon budget,[3] further reducing the available headroom for emissions from new-build housing.

C2.4.         As for point b, the decarbonisation of building products (cement, steel, blocks, glass, etc.) is essential to material efficiency. However, emissions reduction techniques during manufacture (e.g. using alternative fuels, improving resource efficiency in production and changing production routes) can only slightly reduce rather than entirely eliminate the emissions related to construction. It is therefore crucial to minimise the overall flow of materials - not just their embodied carbon - by directing resources towards only necessary needs (dematerialisation) (Drewniok, Azevedo, et al., 2023).

C2.5.         As for point c, material and therefore carbon savings can be made by switching to the most material and carbon efficient technology options for building components. Even wholesale respecification of main building elements, however - for example choosing a timber frame or single-leaf clay blocks, in place of cavity walls made out of brick and concrete blocks - would save only 4.5 MtCO2e each year, or 20% of the construction total (Drewniok, Azevedo, et al., 2023). Likewise, a switch away from concrete slabs to steel composite decking can save only 20% of the upfront embodied carbon on an average office building (Dunant et al., 2021; Hawkins et al., 2022) or in an equivalent residential building of six storeys or more.

C2.6.         In summary, even a combined acceleration of current endeavours towards retrofit, product decarbonisation and more responsible product specification, will not create enough headroom in the UK’s cumulative emissions budget to deliver the desired scale of new housing production. The only option is to reduce demand through dematerialisation (Drewniok, Azevedo, et al., 2023).
 

D.              Little justification

The evidence makes it difficult or impossible to justify breaking the UK’s carbon and biodiversity commitments on the grounds of housing need, for the following reasons.

D1.                Widespread under-occupancy in the UK’s existing housing stock could absorb the stated housing targets with minimal new construction and therefore minimal environmental damage.

D1.1.         The 2021 Census confirmed there are around 29.9 million dwellings in the UK[4] of which 1.6 million (>5%) are unoccupied[5] (ONS, 2024). This is supported by Mulheirn (2019) who found there were 1.2 million more homes than households in England in 2019.

D1.2.         Whilst many unoccupied dwellings can be found in coastal areas, 8% are in London, followed by other high employment areas such as Manchester, Bournemouth, Birmingham, Bradford and Leeds (Atkinson et al., 2024; ONS, 2024). ‘Ghost enclaves’ (areas with >20% of low-use homes) have also been identified in Cambridge and the City of London (Atkinson et al., 2024).

D1.3.         A recent study has shown that, considering that 17% of bedrooms in England are second and further spare bedrooms, and 2% are in second and empty homes,  there is capacity in England alone to meet the UK’s housing needs (Gough et al., 2024).

D1.4.         In summary, the increasing misallocation of housing space - a long term trend (Tunstall, 2015) - means there is already capacity to absorb the UK’s housing need (Gough et al., 2024). Whilst these numbers do not in themselves indicate the adequacy of the underused and under-occupied stock, they do reveal imbalances in the system which contributes directly and indirectly to higher emissions (Pagani, Macmillan, et al., 2024). These emissions come from residential energy consumption and the embodied carbon from unnecessary housebuilding.

D2.                Economic activity from construction does not have to rely on new house building

D2.1.         In the original NPPF consultation on planning changes, the stated policy objectives for building new homes included to “create jobs and investment in construction” (MHCLG, 2024b, Chapter 2).

D2.2.         However, whilst construction contributes to nearly 6.5% GDP (Hutton & Zaidi, 2024), the quarter share of output attributable to new build housing is similar to that for repair and retrofit (one fifth)[6] (Office for National Statistics, 2024).

D2.3.         This suggests that the growth-based case for new-build housing has been overstated, relative to the economic value of repair and maintenance. This is especially so given the greater potential for expansion in this sector (see C2.3, above).

D3.                Building homes will not meaningfully lower house prices, and therefore will not improve access to homeownership.

D3.1.         In the original NPPF consultation on planning changes, the stated policy objectives for building new homes included to “ensure people can afford to live where they wish” (MHCLG, 2024b, Chapter 2). This is consistent with a perception that supply shortage is the main driver to - and even synonymous with - the housing crisis, leading to the prevailing but contentious solution of pushing for a rapid increase in the number of homes to reduce prices (Barker, 2019; Dianati, 2022; Gallent et al., 2018).

D3.2.         Evidence shows, however, that not only has supply outpaced demand across England (and London) since 1996, but also that additional housing stock supply has a marginal effect on house prices (Mulheirn, 2019; zu Ermgassen et al., 2022). Those criticisms converge on the acknowledgment that ‘if we want to increase the affordability of housing, more effective solutions lie elsewhere’ (Mulheirn, 2019, p. 26; Ryan-Collins, 2024).

D3.3.         The marginal aggregate effect of the proposed house building target can be illustrated by the fact that building 300,000 more homes in England over 5 years will result in an increase in the floor area per capita by only 1m2 (Drewniok, Dunant, et al., 2023).

D4.                Attempts to fund new construction with market sale homes will continue to reduce the overall provision of good-quality affordable and social homes.

D4.1.         Data have shown that the decline in housebuilding since the 1970s is the result of an ‘almost complete cessation’ of construction by local authorities of council or social housing (Harris, 2003, p. 29).

D4.2.         Decades of austerity measures have pushed social housing providers to cross-subsidise the construction and maintenance of social homes through the construction, sale, or rent of market homes. Compounded by a decreasing quality of the housing stock, the need to meet ambitious government house building targets, and changing regulatory requirements, the cross-subsidy model continues to favour the demolition of social housing estates and their densification with market homes, resulting in a decrease in the number and share of social homes.

D4.3.         According to a study of Pagani, Macmillan, et al (2024), the focus on new construction to fund immediate and ongoing maintenance and repair of the social housing stock can put strain on housing providers’ resources, eventually hindering their ability to perform proactive maintenance. The resulting disrepair can lead to an increase in tenants’ complaints, more pressure on frontline staff, and a loss of evidence-based decision making, further compromising the quality of the housing stock. These cause-and-effect chains exacerbate the shortage of social housing and overcrowding, with negative effects on tenants’ health and well-being.

D5.                A focus on ‘units’ rather than living space and typology risks multiple environmental and social problems

D5.1.         Housing sprawl - especially when typologies are hard to adjust or homogeneous in size - will tend to lock in vehicle dependency and longer commutes (Cheshire et al., 2018; Mattioli et al., 2020).

D5.2.         Denser developments - especially where apartments cannot be joined, divided or elsehow expanded to accommodate changing needs - invite higher levels of transience or else wellbeing problems. Graham (2023) finds the resulting churn as expanding households move away, can lead to a weakened sense of community and arises when dwellings are so small that they preclude the addition of a long-term partner, carer, young family or adjustments for home working.

D5.3.         Low-rise properties - especially bungalows and detached housing - consume up to 15% more material and embodied carbon, relative to 6-10 storey residential buildings (Drewniok, Dunant, et al., 2023)

D5.4.         In summary, when the policy goal is to maximise additional ‘unit’ numbers, the supply-side response will tend to be small, inflexible apartments on higher value land, or else homogeneous, low-rise housing on cheaper land, resulting in some combination of longer commutes, higher energy use, a loss of social cohesion and difficulties absorbing changes in housing needs at the household level.

D6.                House prices and dwelling numbers – the units used in the proposed ‘standard method’ – are largely irrelevant to housing needs calculations

D6.1.         As for housing prices, the proposal to estimate housing needs using the ratio of house-price-to-earnings is unreliable, because house prices tend to follow interest rates - all other things being equal. For example, when interest rates are low, house prices will normally rise, giving the false impression of worsening affordability and therefore of increasing housing need (Meen & Whitehead, 2020).

D6.2.         This can be demonstrated by the fact that despite soaring house prices and broadly static incomes, mortgage payments have remained eminently affordable, albeit over longer repayment periods (Meen & Whitehead, 2020). In other words, monthly housing costs rather than overall house prices are the more reliable indicator of housing need (Mulheirn, 2019)

D6.3.         The same point can also be made by looking at the cost of deposit payments which - being a function of borrowing rules rather than overall house price or even monthly mortgage costs - mean certain specific and sometimes relatively well-earning groups with fewer savings would continue to experience affordability problems, even if more homes were to be built (Meen & Whitehead, 2020)

D6.4.         As for dwelling numbers, so long as the standard method estimates housing need in terms of dwelling numbers rather than living space (or bed spaces), it will overstate the case for building more homes whilst concealing the central problem that housing space is unequally distributed (Gough et al., 2024; Graham et al., 2024).

D6.5.         Based on the UK space standards minimums (Department for Levelling Up, Housing and Communities, 2015), building two 1-bed, 1-person apartments at 37m2 each (74m2 in total) will have double the policy impact of building just one 3-bed, 4-person apartment at 74m2, yet accommodate only half the number of people. Furthermore, such small apartments are inevitably inflexible and therefore more likely to limit their occupiers’ resilience against changing needs (Graham, 2023). Likewise, building a 4-bed, 2-storey home at 124m2 minimums - with no way to subdivide it into two separate 2-bed, 3-person apartments of 61m2 - will deny a community up to 5 bed spaces per dwelling, once the original occupants no longer need the entirety of their family home.
 

E.              An alternative pathway

Instead of destructive new-build, we offer an evidence-backed pathway to delivering sustainable development that is compatible with the environmental objectives of the planning system.

E1.                Take a systems thinking approach

E1.1.          The public sector, industry, and academia are jointly moving towards systems thinking approaches to engage with ‘the complexity and uncertainty inherent in the problems [they] tackle’ (CBE, 2023; Foreman et al., 2022).

E1.2.          The recent research project of Pagani (2022-2024) on systems thinking for a just transition towards housing sustainability has shown the potential for such an approach in helping stakeholders navigate the interdependence between policies and their outcomes in the social housing sector, which have too often been addressed in isolation (Pagani, 2024).

E1.3.          The project introduces a set of qualitative system maps (causal loop diagrams) developed through participatory activities, which support the identification and questioning of assumptions on causes and consequences of housing construction, and thus on what is feasible and socially desirable (Pagani, Macmillan, et al., 2024; Pagani, Zimmermann, et al., 2024).

E1.4.          The causal loop diagrams show how redirecting fundings towards the maintenance and repair of the existing social housing stock instead of construction (of market and social homes) could improve housing quality, reduce housing shortage (including its negative impact on social housing tenants and staff, and the associated costs), and eventually increase the means and willingness to maintain the existing stock over demolition (Pagani, Macmillan, et al., 2024; Pagani, Zimmermann, et al., 2024). In parallel, such an approach could prevent the redevelopment-driven displacement of established resident communities and instead, bring security and stability to the social housing stock, allowing housing providers to engage in longer-term decision-making.

E1.5.          In addition, the same causal loop diagrams show that VAT charged on maintenance, repair, and retrofit projects but not on new build can discourage building reuse, and instead incentivise new construction as well as any associated demolition (Pagani, Zimmermann, et al., 2024). Although a recent call for evidence was formulated on VAT relief on low energy technologies and materials to reduce energy consumption in buildings, the effect of differential tax treatment on decision making in the industry more broadly was overlooked (Call for Evidence: VAT Energy Saving Materials Relief – Improving Energy Efficiency and Reducing Carbon Emissions, 2023).

E2.                Take a space-first approach

E2.1.          Calculate local housing needs based not on house price, but on the total floor area per person needed for present and future populations to live comfortably, relative to the available housing space in that area. Gough et al. (2024) propose a rule of thumb derived from UK space standards that supports 40m2 for the first inhabitant and 10m2 for each subsequent household member, plus another 10m2 for guests. This guide can be further developed by means of a systems thinking approach and stakeholder engagement (see, for instance, Pagani et al., 2022).

E2.2.          Support schemes where dwellings can be joined and divided to rightsize their spaces, or else may spillover into certain shared spaces or amenities - a concept for which there are precedents as well as methods for evaluating outcomes (Graham et al., 2024).

E3.                Start with what’s already there

E3.1.          Promote the adaptation of non-domestic buildings for housing, which can help deliver over 50% upfront carbon savings compared to purpose-built single or two-family houses, and 30–40% savings compared to multi-family residential buildings (Drewniok, Dunant, et al., 2023). Adaptation should only be approved subject to extreme care for wellbeing consequences - an oversight that has beset the recent permitted development of non-residential buildings (Pineo et al., 2024).

E3.2.          Avoid the demolition of buildings to reduce annual emissions by up to 30% (Drewniok, Dunant, et al., 2023). This can be achieved by prioritising extensions, subdivisions, and retrofit - alongside any unavoidable new build housing.
 

F.               Recommendations for policy

By way of recommendation, we highlight certain ways of updating the UK’s housing institutions to improve outcomes from an environmental perspective.

F1.                MODERNISE THE PLANNING RULES to encourage spatial flexibility and adequate density

F1.1.          Permit only those developments or home alterations that can demonstrably minimise embodied carbon through retrofit, reuse or by accommodating multiple household scenarios and changes in housing needs over the longer term, without requiring people to move house or hold more space than they need (Graham et al., 2024).

F1.2.          Encourage a better matching between living space and needs, e.g. through alternative housing designs, occupancy rules, tenure models or degrees of sharing; (Graham, 2023; Karlen et al., 2022; Pagani et al., 2022).
 

F2.                DECARBONISE THE TAX SYSTEM to encourage sufficiency and circularity amongst households and builders

F2.1.          Incentivise builders and building owners to reuse and refurbish as a first priority, by at least equalising VAT charged on retrofit with that on new-build projects, if not exempting retrofit entirely.

F2.2.          Unlock tax barriers and disincentives to downsizing (Burgess & Quinio, 2021; Hilber & Lyytikäinen, 2017), such as Stamp Duty Land Tax (SDLT) which currently functions as a fine for moving house (Burgess & Quinio, 2021; Hilber & Lyytikäinen, 2017), and Inheritance Tax (IHT) which can reward people for holding space they no longer need (Corlett & Leslie, 2021).

F2.3.          Strengthen the acquisition of land and housing by the public sector and communities; for instance, through stronger compulsory purchase powers, the abolition of the Right to Buy, and a Community Right to Buy (Atkinson et al., 2024).
 

F3.                SUPPORT INNOVATIONS IN FINANCE to stimulate new types of housing supply that use buildings, space and materials that are already in circulation.

F3.1.          Support the nascent green mortgage industry in creating new incentives for climate positive housing choices and improvements (Sullivan et al., 2023). These should go beyond simply technical solutions (currently based on energy performance for heating and cooling) to include ways of making more effective use of available living space, construction materials, and existing buildings.

F3.2.          Develop alternative measures of value creation to include the long-term cross-sectoral benefits of housing (across health, employment, education (Pagani, Macmillan, et al., 2024; Pagani, Walker, et al., 2024).

F3.3.          In summary, some consumers and innovative lenders are already evaluating housing outcomes according to the expected impacts on climate, energy bills, household wellbeing and resilience over the longer term. Their power to choose or influence housing designs that prioritise dematerialisation and spatial sufficiency now needs policy support that goes beyond the current ‘numbers game’.
 

Acknowledgements

This response has been prepared by an academic group working on housing sufficiency, with contributions from:

Dr Philip Graham, Postdoctoral Research at University of Cambridge (Department of Architecture). Director of Studies for Architecture and Design at Homerton College (Cambridge). Architect at Cullinan Studio (London). Funded by the AHRC, part of UKRI.

Dr Anna Pagani, Senior Lecturer in Engineering at King’s College London (Department of Engineering; Faculty of Natural, Mathematical and Engineering Sciences); Honorary Research Fellow at UCL (Institute for Environmental Design and Engineering, Bartlett School of Environment, Energy and Resources).

Dr Michal Drewniok, Lecturer in Civil Engineering, University of Leeds (School of Civil Engineering).

We would be pleased to speak further about our response.
 

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January 2025