The Government's Sustainable Communities Plan, launched in February this year, is by any standards highly ambitious and wide-ranging. Costed at £22 billion, it includes proposals for all of the English regions. By far the most problematic and controversial is the South East document, which sets out a range of far-reaching objectives for housing within the Region –

Firstly, to provide for the region's growing population. The region is one of the fastest growing with population growth of nearly 5.7% between 1991 and 2000 compared with 3.7% nationally.

Second, to turn around the trend in house completions. Completions at present are too low; they dropped to less than 23,000 per annum dwellings by 2000, 18% below the figure indicated by Regional Planning Guidance.

Third, to improve the match between housing needs and provision. At present, there is a substantial mismatch between housing needs and type of housing being built. For example, while there is a substantial increase in the number of single person households, new developments are more often for houses with three-to-four bedrooms or more.

Fourth, to make better use of land. Despite being one of the most densely populated regions, land is used inefficiently; overall the region has among the lowest average density rates for new dwellings in the country.

The action plan to meet these challenges aims to accelerate development in Thames Gateway, Milton Keynes-South Midlands and Ashford growth areas and includes the aim of building 200,000 extra homes above levels currently planned in regional planning guidance.

The question is, whether that is fully practicable, and above all whether it can be carried through sustainably. Significantly, the Plan for the South East does not specifically mention any environmental issues, raising a real question of just how joined-up planning is between the Office of the Deputy Prime Minister (ODPM) and the Department for the Environment, Food and Rural Affairs (DEFRA).

The ODPM Select Committee reviewing this matter concluded that the impact on the natural environment had not been adequately considered, although the South East is already one of the most densely developed regions in Europe. They thought that:

"The predict and provide policy for housing was being adopted regardless of the ability of the region to successfully absorb the level of housing expected in a sustainable manner."

It is, they said, quite clearly an economy-led strategy, with the assumption that projected growth should be accommodated, and then the intention is to try to make that growth as sustainable as possible in the circumstances.

Professor John Whitelegg, one of the witnesses, from the University of York, went further –

"I think it is very simple: we are piling far too much activity and too many expectations into South East England, and in terms of environmental capacity it is like a vessel overflowing. We cannot take any more in South East England".

This does raise a fundamental question: can one resolve the intense population and resources pressure on the South East exclusively, or even mainly, via housing policy? Or can it really only be contained via a much wider array of instruments which seek to address the underlying causes of this mounting pressure rather than simply trying to deal with the symptoms? In particular, can the problem really be resolved long-term without re-creating effective elements of regional policy, i.e. shifting the balance of economic forces to reduce over-heating in the South which often coincides with shortage and deprivation in the North? My own view is that housing policy alone cannot per se deal with the acute imbalance in the distribution of the UK economy, and that wider cross-regional planning policies are necessary to restore a sustainable equilibrium in the UK economy. I also think that so far UK economic policy does not yet appear to acknowledge that. However, I don't believe it is one or the other – housing policy alone or a new wider network of regional powers to redistribute underlying economic forces and pressures more evenly. I think both are necessary, an increase in housing in the South East, at least in the short term, because the immediate pressures are otherwise insupportable. But that must be complemented by much stronger planning powers to alleviate the underlying imbalances within the medium term, or we shall simply be chasing our own tail and recreating the same problem again 10 years from now requiring another huge injection of housing in an already grossly over-stretched and over-pressured region.

Against that necessary background, how has protection of the natural environment been handled within the context of creating 'Sustainable Communities in the South East'?

English Nature recognised that:

"Critical restraints, such as traffic congestion, water resources, flooding, loss of irreplaceable natural habitat and the impact of climate change, will eventually place a limit to further growth, and demand that attention is switched to accommodating development elsewhere".

But this has not yet been woven into overall policy. The housing capability study in 1998 into the potential for a major house-building programme in the South East outside London showed that the proposed additional housing provision beyond 900,000 extra homes between 1991 and 2016 could not be achieved without accepting a number of adverse consequences or initiating a more fundamental change in the planning system. "A level of provision over and above 845,000 dwellings could only be achieved with further Greenfield development. There would be serious difficulties and severe local impacts in some areas. As provision approaches 900,000dwellings, these would become more acute and more widespread". A sustainability appraisal of the draft RPG9 in 2000 highlighted problems in "identifying the implications for the sustainability of the Region because the Core Strategy, which includes the Growth Areas, is not developed to be very specific".

So the conclusion must be that the likely impact on the environment must be appraised within the Government's sustainability criteria, and a further sustainability appraisal of RPG9 is necessary as new house-building targets are set for the Growth Areas.

In fact, the Government has gone some way to offering this. They say that further assessment of the sustainability of the Growth Areas, including house-building targets, will be carried out as a part of the review of the Regional Planning Guidance for each area or in the London Development Strategy. It is certainly needed.

The most critical element is probably water. The South East is the driest part of England yet, with London, is home to a quarter of the UK population and produces a quarter of the Gross National Product. The demands for water are correspondingly high. The supply/demand balances of the water companies are significantly more critical than in other parts of the country. The concern is that with housing figures as proposed, the reliability of water supplies could be at risk over substantial parts of the South East if development occurs on this scale.

There could also be serious problems for water quality because of the intensive use of water. Further increases in population and development could aggravate the situation because the rivers do not have the capacity to cope with the consequential effluent from sewage treatment works, urban run-off and other discharges. The situation is often aggravated by low flows which limit the scope for dilution of pollutants.

The implications of climate change are also of critical importance in the region, in that the supply of water and the incidence of flooding are likely to become more extreme and less predictable. In addition, there is concern about sea level changes leading to inundation of low-lying coastal areas.

The Select Committee examining the ODPM housing proposals was dismayed that the water companies were not involved in any of the discussions about the new housing targets for the South East. Clearly the programme should take account of the time required by the water companies to provide sustainable water supplies and, as they said, importing supplies from other parts of England is likely to be costly and inefficient.

Moreover, the Government's review of Building Regulations should ensure that the new homes are built to the highest water conservation standards. The initial installation costs will be offset by the long-term environmental benefits. Water UK, the trade association body, argued that the water industry should be a statutory consultee on strategic planning issues, and I would agree with this.

The issue of flooding presents an even bigger problem. Building in the flood plains can pose a major flood risk and some have argued that the Government must accept that this could limit the house-building targets. At the very least, sustainable urban drainage systems should become a requirement for all new house-building to avoid surface flooding, and be funded by the developer.

More generally, the ODPM and DEFRA need to develop a joint programme of flood protection which identifies areas where development can be allowed and where the habitat should be protected and improved. Now, it is true that the Environment Agency (EA) is currently preparing a long-term strategy for flood management in the Thames Estuary, and will be assessing each of the 13 development areas in relation to flood risk. Much of this area is already defended to a high standard. But again the impression is given that the EA were not fully involved in the preparation of these housing plans before they were finalised and made public.

I turn now to the all-important question of standards of housing development. As you know, the BRE EcoHomes standards compare the consumption of natural resources by homes built to current building standards and those that include such environmental features as energy efficient lighting, grey water recycling and solar panels for hot water.

On average a household in the South East uses about 383 litres of water per day and produces a similar amount of effluent. A house built to the EcoHomes 'excellent' standard would consume 40% less water per bed space than a house built to current standards. Built to current standards of energy efficiency, each three-bedroom semi-detached house will produce 3.5 tonnes of CO2 a year. With higher levels of insulation, the use of solar panels, and more efficient domestic appliances, the emissions could be reduced by a third to 2.6 tonnes of CO2 a year.

Now, implementation of the EcoHomes standards is of course voluntary, although some public bodies are enforcing them. The House Corporation requires all new schemes which it funds to comply with the 'good' standard, and all homes built on English Partnerships' sites have to comply with the 'very good' standard. I think there is potential for public agencies to raise their standards. I think we should urge the Housing Corporation to increase its standard to 'very good' by end 2003 and 'excellent' by 2005, and English Partnerships to increase its standard to 'excellent' immediately.

Clearly the developments in the Growth Areas offer an opportunity to develop a new model of environmentally efficient housing which has equipment to reduce water and energy consumption, and high levels of noise insulation. The initial installation costs will be offset by the long-term savings in running costs. Environmental features such as those required to achieve the higher EcoHomes standards should in my view be made a condition of planning approval and included in Building Regulations. The Building Regulations on noise insulation also need to be effectively enforced. In addition, local authorities should be required to include in their local plans policies to secure environmentally efficient housing and to give greater priority to achieving high environmental standards when deciding on planning applications. I think the Government's intention to re-introduce the Seller's Pack, including the SAP energy data, in the draft Housing Bill is particularly welcome here.

I have to say I think the Housing Corporation is being unduly modest here and rather unambitious. In 2003/4 the minimum requirement in Scheme Development Standards (SDS) is for an EcoHomes 'Pass' rating. They say their research has shown that, taking into account the new Building Regulations and the revised SDS requirements, the additional cost of achieving a 'Pass' rating will be minimal. Achieving a 'Good' rating will remain, but only as a recommended item in the SDS.

One might ask: what price the longer-term environmental benefits? In the Housing Corporations's view, the answer appears to be rather low. It is true the Housing Corporation then goes on to say that in 2005/6 they intend to make the achievement of a 'Good' rating a minimum requirement in the SDS, with 'Very Good' becoming a recommended item. They claim that, in most cases, if EcoHomes features are designed into the scheme as the feasibility and planning phases, costs will be covered. Of course, cost is always a very important consideration. But one has a distinct impression that this approach has reduced the environment to little more than a residual variable.

Of course, I know that the Housing Corporation has a sustainable development strategy including use of brownfield sites, the choice of building materials, residents' use of such resources as energy and water, and the availability of public transport and other forms of transport (walking/cycling), all of which have major environmental implications.

But I think that the measures it intends to take to improve sustainability lack bite. They include:

• Providing tools to housing associations to assess their environmental impacts and develop effective strategies to minimise them over the short, medium and long term.
• Encouraging the adoption of energy efficiency measures and the procurement of renewable energy.

All very worthy, but more deliberate impetus is needed if they are to be made to transform our housing standards in the country.

Maybe a small puff to the Peabody Trust as an RSL would not be out of place here. In its Sustainability Strategy published in June last year, it offers proposals to tackle fuel poverty. It is estimated that around 4 million households in the UK are fuel poor. In real terms the cost of fuel has not increased over the last 10 years. However, more recently gas and oil prices have been on the increase. They propose a two-fold strategy to address both the demand and supply side of energy. On the former they intend to reduce the level of fuel poverty amongst their tenants by improving the overall energy efficiency of their housing stock. On the latter, they say they will reduce their dependency on depleting and polluting fossil fuels and become a major supplier of renewable electricity. Assuming that is all done, there are some good lessons here.

As they say, incorporating energy efficiency into new-build schemes need not be problematic. However, it is much more challenging to achieve this step change with refurbishment programmes, for both existing estates and stock transfers. But increasing energy efficiency is possible by using new technology and by being more radical about the approach to refurbishment – perhaps considering demolition and rebuilding of some estates in order to achieve modern standards of performance and quality. However, regrettably, they do not specifically mention water efficiency in their sustainable strategies.

I conclude with the announcement only two weeks ago that the Government is setting up a new Sustainable Buildings Task Group. According to the press notice, the aim is to -

"Pinpoint ways in which industry and Government can work together to promote sustainable development through better environmental performance in new and existing buildings, and improve significantly performance on key issues including water, energy, waste and building materials such as timber."

Am I the only one in thinking there is a sense of deja-vu here? But as an optimist, I prefer to take things on the merits of the case as they are presented, and assume things are now about to get significantly better. However, I end by acknowledging that the definition of a pessimist is ... 'someone who has to live with an optimist'. I hope on this occasion my optimism may be justified.