Memorandum by the National Housing Federation
(UWP 03)
THE URBAN WHITE PAPER
INTRODUCTION
The National Housing Federation is the representative
body for 1,400 registered social landlords (often known as housing
associations) who between them provide some 1.3 million homes
for rent and low cost home ownership. Our members work in all
urban areas in England, and their presence manifests itself in
many and diverse ways:
— public investment through registered
social landlords in new and refurbished homes, supplemented by
private borrowing, will exceed £2 billion in 1999/2000;
— day to day reinvestment in the existing
housing stock by registered social landlords—independent
of any further subsidy—will amount to a further £500
million in 1999/2000;
— registered social landlords are experienced
in tenant and resident consultation processes and are adopting
the Best Value regime within their management processes;
— significant numbers of registered
social landlords are involved in Single Regeneration Budget, New
Deal for Communities, joint work with English Partnerships, and
other physical and social regeneration activity;
— they are very often the single largest
landlord in any given neighbourhood. Their investment in urban
areas, including the most deprived neighbourhoods, is tangible
and it is directly in their own financial interests (as well as
core to their values as not for profit organisations) that these
urban areas should succeed.
The National Housing Federation and our members
therefore welcomes the Government's intention to issue an Urban
White Paper. A wide range of issues, and a complex pattern of
interconnections between them, will affect the success of our
towns and cities as places to live and as engines of economic
activity and growth. The White Paper promises a coherent policy
framework that will maximise the chance of success.
We are concerned that the White Paper has been
considerably delayed. The report of the Urban Task Force raised
expectations, not least in the housing and particularly the not-for-profit
housing sector. We recognise that related work on issues such
as land use planning frameworks, the regional investment and governance
framework, and the work of the Social Exclusion Unit is still
incomplete. However there will not be a time when all such issues
are settled, and the cost of delay is in continuing uncertainty
for major public and private investment decisions and therefore
on the quality of life of individuals and communities.
1. COMPETITIVE
TOWNS AND
CITIES
The majority of households have a choice about
where they live. There will always be preferred and less desirable
locations. However, a fundamental policy aim must be to make urban
areas more attractive to those with choice—in other words,
more competitive as locations. This benefits the areas and communities
concerned; it will also reduce pressure in areas that Government
wants to protect—such as greenfield sites.
1.1 Physical infrastructure
Creating a new and attractive living environment
on a greenfield site involves less risk and is almost invariably
cheaper than creating a renewed and attractive environment from
previously used or derelict sites.
One policy option is to restrain the release
of new greenfield sites, and in its draft PPG3 the Government
has signalled its intention to do so. Whilst this may encourage
private investment in the "next best" sites, the policy
is a very blunt instrument when it comes to regenerating urban
areas as opposed to protecting undeveloped areas. Constraint in
one place will not necessarily target investment towards another.
In particular, it will not achieve investment in the most deprived
areas or excluded communities.
We therefore believe that Government should
provide fiscal incentives and direct subsidy towards the renewal
of designated areas—and especially those where the market
alone is unlikely to produce renewal. The Urban Task Force's Urban
Regeneration Company and Housing Regeneration Company proposals
provide appropriate vehicles and funding frameworks: the forthcoming
Comprehensive Spending Review provides an opportunity significantly
to boost investment in urban areas.
1.2 Housing as a vehicle for renewal
There are examples in all urban areas of successful
inner-city housing developments on previously used land, or making
use of derelict buildings. By investing in housing, these developments
also bring about vibrancy in the social, cultural and economic
activity of inner urban areas.
The National Housing Federation believes that
registered social landlords can play an important role in this
respect. We advocate a role for them as lead agents in the delivery
of urban renewal—in partnership with the private sector
and in the context of a strategy set by local and regional government.
A coherent strategic framework is crucial if
all partners are to have confidence in investing their resources
in this way. In many areas the process of Joint Commissioning
already allows local authorities and registered social landlords,
in conjunction with the Housing Corporation, to undertake housing
investment within a coherent strategic framework that combines
different funding sources. Whilst this model needs to be further
developed, it provides a natural starting point for working with
a wider range of partners and in all sectors of the housing market.
1.3 Social infrastructure
Investment in the physical infrastructure alone
will not produce competitive urban areas. Households with choice
are turned away as much by poor schools, perceived or actual crime,
ineffective transport networks, and a lack of employment opportunities,
as they are by a dilapidated environment and poor housing.
We are aware of the Government's policies in
these other areas, and that improvement takes time to achieve.
However, co-ordination between different initiatives is of vital
importance if—for example—investment in housing improvements
is not to founder due to a lack of local employment. It follows
that local flexibility within different policy streams, and co-ordination
between them, is essential for successful outcomes. The Urban
White Paper must contribute to wider reform of policy mechanisms
that are looking for the appropriate balance between pursuing
national policy objectives, allowing local decision makers to
provide the most effective response to local problems, and ensuring
transparency and accountability in the use of public resources.
1.4 Urban and regional economies
At the heart of any regeneration policy lies
the question of jobs. Whilst attractive physical environments
are a necessary component of successful towns and cities, employment
opportunities are absolutely fundamental.
Within this, measures are needed to target the
benefits of inward investment and employment growth towards the
most deprived communities, and to overcome the problem of continuing
pockets of high unemployment and poverty even if the wider economy
is growing.
RECOMMENDATIONS
Investment in housing is central to urban renewal,
and the provision of sufficient affordable housing is crucial
to achieving social mix and sustainable communities. The success
of housing markets also depends on the performance of the wider
social and physical environment. We commend the Urban Task Force's
proposals for Urban Regeneration Companies and Housing regeneration
Companies as vehicles for targeting and delivering physical renewal.
The Joint Commissioning framework operated between registered
social landlords, local authorities and the Housing Corporation
also provides a model for strategic intervention in the housing
market.
The Urban White Paper must address the issue
of local co-ordination between different policies and programmes,
all of which are necessary in the creation of popular, competitive
urban areas. Specifically, urban policy must make sure that the
benefits of growth and job creation area felt in all areas and
sections of the community;
Government should introduce fiscal incentives
and make available considerable direct subsidy for the physical
renewal of urban areas within its next Comprehensive Spending
Review. We believe that this expenditure would prove to be politically
popular, and would support other measures to protect undeveloped
sites and areas;
VAT rates for new house building and for rehabilitation
should be equalised at five per cent.
2. LIVEABLE TOWNS
AND CITIES
The built environment is a crucial component
of liveable towns and cities, but of course not the only one.
We point out above the importance of issues such as education
and training, transport, pollution and crime in determining whether
or not people will choose to live in an area. We also acknowledge
that other people and bodies are more expert in these subjects
and we are therefore not putting forward more detailed recommendations
in this respect. However we do have two important recommendations
in this area:
2.1 Community mix and diversity
The social health of urban areas is adversely
affected by a dominance of large single tenure estates or low-income
communities. It is for this reason that efforts to attract higher
income households into inner cities are so important, and this
involves retaining those who would otherwise leave as well as
attracting others in.
Social landlords (both local authorities and
registered social landlords) are familiar with the phenomenon
whereby once someone can afford to give up their tenancy and move
away to buy: this contributes to the residualisation of the community
that remains.
The Federation therefore supports policies aimed
at diversifying tenure in urban areas, and giving households the
opportunity to invest (and feel confident that this investment
is secure). This needs to apply to large areas of private rented
property as well as to social housing estates. Low cost home ownership
programmes, and initiatives such as homesteading and self-build,
provide important mechanisms whereby this diversity can be achieved.
We would also support mechanisms designed to provide greater flexibility
of tenure so that a household does not have to physically move
home in order to change from renting to owner-occupation.
A complementary policy must be to ensure diversity
elsewhere and especially on new housing developments, in order
to provide adequate numbers of affordable and low cost homes.
Greater consistency in this respect within the planning framework
is important (we have reiterated this point in our responses to
the draft PPG3 [Housing]).
Consideration of community mix and diversity
must extend to questions of ethnic origin and equality of opportunity.
There is ample evidence that some sections of the population suffer
worse housing and environmental conditions because of processes
of direct and indirect discrimination. The Urban White Paper must
include an understanding of the particular position of these communities
and measures that will overcome the disadvantage they face.
RECOMMENDATIONS
Planning policies, especially in respect of
housing, should more explicitly support diversity of community
and tenure in new housing developments. Government should support
this policy emphasis by championing and disseminating good practice
guidance;
Low cost home ownership should routinely be
used to encourage greater diversity in single tenure and single
(low) income areas. Self build and homesteading provide other
models that encourage people to invest in a local area.;
There is scope to provide greater and more graded
flexibility of tenure. Government should encourage the development
of policy and practice in this respect;
Urban policy must recognise and address the
position of particular communities, and especially ethnic minorities,
who experience direct and indirect discrimination in the market
and in existing public programmes.
3. LAND, BUILDINGS
AND PLANNING
3.1 Positive planning
For a variety of reasons, the land use planning
system in England is perceived and experienced as a hurdle to
be overcome by any form of development. Clearly some developments
would be unacceptable and need controlling. However, the planning
system should be capable of playing a more positive role in encouraging
development—and providing a measure of reassurance that
the location around a new development will itself be managed and
protected or upgraded over time.
We believe that this is a fundamental obstacle
(and therefore an opportunity for improvement) in the delivery
of urban regeneration.
3.2 Local master planning.
We believe that a local master-plan, set within
a wider strategic (and up to date) local authority wide plan,
is an ideal vehicle for consulting about and then guiding the
development and redevelopment of neighbourhoods and small areas.
3.3 Avoiding prescription
Considerable amount of attention is played to
issues of design and density for housing, with arguments made
that (for example) higher density housing development, with or
without provision for cars, provides at least a partial solution
to the problem of urban expansion driven by housing demand.
Planning policy should be cautious in its response,
facilitating development that meets broad strategic objectives
rather than prescribing detailed characteristics to be met on
each individual site. An over-prescriptive approach risks blocking
otherwise beneficial development and adaptation, and can lead
to development for which there is weak longer-term demand.
3.4 Land assembly and compulsory purchase
The cumbersome nature of the compulsory purchase
framework act as deterrents to the physical regeneration of urban
areas. Traditionally CPOs have been seen as a way of dealing with
unfit dwellings and enabling land assembly: we believe that their
role should be extended to deal with straightforward clearance
of housing that is not occupied, under-occupied or sub-standard
without being unfit. Forthcoming changes to the assessment of
fitness will provide an invaluable tool in the assessment of grades
of dwelling standards rather than a simple pass-fail test for
fitness.
The system is also made more uncertain by the
way in which valuations are carried out: a local authority and
its partners cannot reliably estimate the costs of a CPO or clearance
programme and this of itself inhibits otherwise desirable regeneration.
Speculators often buy up property in areas where regeneration
or some other intervention is proposed, in anticipation that compensation
for compulsory purchase will be above the price they paid.
RECOMMENDATIONS
The White Paper should contain proposals for
transforming the planning system from a negative to a positive
one. Specifically, the planning system should:
— set clear limits on the range of
acceptable development and then seek to encourage rather than
control development that takes place within this range;
— encourage the preparation, use and
regular up-dating of local master plans, with the intention of
encouraging investment and development in an area and providing
a measure of certainty and encouragement to those prepared to
do so;
— recognise the operation of market
mechanisms and choice, and avoid over-prescription of the detail
of housing development—for example in relation to size,
density and provision for car use.
The current CPO system is cumbersome, and in
many cases encourages speculation at the expense of regeneration
initiatives. The White Paper should draw on the current review
of the CPO system to provide a more transparent basis on which
to assess property and land values prior to the regeneration (including
the simple clearance) of areas of poor-quality property. Good
practice in the positive use of the CPO system is also needed.
4. GOVERNANCE:
CITY, REGION
AND NEIGHBOURHOOD
4.1 Neighbourhood management
The Government is pursuing an important agenda
of reform of local and regional government, through management
initiatives such as Best Value and Beacon Councils, through cabinet-style
local government and the emergence of regional chambers, to the
establishment of regional development agencies.
It is not yet clear how very local issues and
governance fit into this framework. Yet the success of local areas
and neighbourhoods depends on their specific reputation rather
than that of the town or city as a whole. The Federation is convinced
that for this reason, effective neighbourhood management is crucial
to the success of whole urban areas.
What we mean by this is:
— adapting governance frameworks so
that local residents can influence policies for their area, for
example through "planning for real" exercises;
— much more effective co-ordination
between different policies and programmes. This is a widely acknowledged
problem, and although alternative models have been put forward
(such as the Local Government Association's Local Challenge proposals)
there is still some way to go in this respect;
— greater emphasis on managing and
tailoring local services (such as parks and leisure, cleansing,
etc) to the wishes of local residents.
4.2 Diversity, resident involvement and expert
support
Neighbourhood management needs to be based on
democratic accountability and control, with a strong element of
local participation. However beyond this principle it would be
wrong to impose a particular model of operation: instead what
matters is what works.
However, we envisage that there is significant
scope for registered social landlords—amongst others—to
have an executive role in the delivery of services, including
consultation with residents and other customers about the nature
of these services. The framework should be one of expert support
and facilitation of locally determined choices.
4.3 Paying for neighbourhood management
Whilst we envisage a role for registered social
landlords in delivering strengthening and servicing neighbourhoods,
we are concerned that the tenants of social landlords should not
bear an unfair burden in meeting the costs of these services.
The resources available to registered social landlords derive
from capital (and limited revenue) grants from Government—or
from rents. A funding system for neighbourhood management is needed
that does not simply place an additional burden on income from
rents.
RECOMMENDATIONS
Neighbourhood management, including changes
to governance and operational management, needs to be further
developed. We look forward to the report of the Social Exclusion
Unit's PAT 4 on neighbourhood management: the White Paper provides
an opportunity for Government to take forward the recommendations
made.
Neighbourhood management should provide both
a form of local and accountable governance and a management response
to problems (including decline) that an area faces. The emphasis
needs to be on diversity or models and activities, and on expert
support for local choices.
A neighbourhood management approach must avoid
placing financial burdens on tenants and residents.
| 
