Memorandum by the Chartered Institute
of Housing (UWP 30)
THE PROPOSED URBAN WHITE PAPER
The Chartered Institute of Housing is the professional
organisation representing all those working in housing. Our purpose
is to take a leading and strategic role in promoting the provision
and management of good quality, affordable housing for all. CIH
has over 15,500 individual members working for local authorities,
registered social landlords, academic institutions, the Rent Service
and within the private sector.
INTRODUCTION
The Chartered Institute of Housing (CIH) welcomes
the opportunity to submit written evidence to the Environment,
Transport and Regional Affairs Committee for their Inquiry into
the proposed Urban White Paper. The Report of the Urban Task Force,
led by Lord Rogers of Riverside, and the government's work on
social exclusion, are likely to be central to the Committee's
deliberations. CIH supports the government's aim of creating an
urban renaissance to regenerate our towns and cities and protect
our countryside from over-development. Other government aims,
such as promoting social inclusion and ensuring that everyone
has the opportunity of a decent home are equally important and
these are given due emphasis in our response.
Where appropriate, we highlight other documents
produced by CIH giving more detailed information on the points
made. We are happy to provide further material to clarify or expand
on any aspects of our response. Our comments are structured around
questions selected from those listed in Press Notice 02/1999-2000,
1 December 1999, which announced the Inquiry.
SUMMARY OF
OUR RESPONSE
An Urban White Paper is needed to respond fully
to the challenges of the Urban Task Force report, and send out
a clear message to all relevant stakeholders of the government's
determination to achieve an urban renaissance.
Local authorities have already a wide range
of relevant responsibilities and the democratic legitimacy to
be the strategic leaders and co-ordinators of change at local
level. The Urban White Paper should examine the need for additional
powers, for example, to enable greater flexibility over local
authority involvement in companies.
Models for delivering urban regeneration, such
as Urban Regeneration Companies and Housing Regeneration Companies,
should be encouraged. Such models would build on the important
existing contribution of Registered Social Landlords to housing-led
regeneration.
The planning system must be modernised to fulfil
a new, more proactive role of facilitating positive change, rather
than arbitrating over the use of land. Detailed changes to planning
policy guidance are needed.
Reforms to enable local and regional agencies
to impact on the urban environment are essential, but are not
sufficient to tackle the root causes of decline in some parts
of our Northern cities. A national response to address the impact
of long term structural decline in the employment base in parts
of the UK is required.
The possession of strategic vision is vital.
However, the detail of implementation must also be right if urban
renaissance is to be achieved. This means relevant agencies having
enough flexibility to deal with the local context, and achieving
the right balance between idealism and realism, for example, in
relation to development densities and restrictions on car parking
provision.
The problems of low demand neighbourhoods should
not obscure the need for new housing development elsewhere, particularly
affordable housing, including in rural locations, where this contributes
to the sustainability of rural communities.
Below we consider in more detail selected questions
from the Inquiry press notice.
Question: What added value a government White
Paper should provide in addition to other government announcements
on urban policy
An Urban White Paper would enable the government
to respond fully to the wide ranging challenges of the Urban Task
Force report. Such a White Paper would need to build on and integrate
with other existing and anticipated government statements, in
particular, the expected Housing Green Paper, Rural White Paper
and National Strategy for Neighbourhood Renewal. By responding
in a comprehensive, rather than piecemeal fashion, it would be
an opportunity to give a clear and unequivocal message to local
authorities, RSLs, private developers and other stakeholders of
the government's determination to create an urban renaissance
and tackle social exclusion. It would also assist in the process
of turning the vision of the Urban Task Force report into a set
of practical propositions. The White Paper would set the framework
for more detailed reform to government guidance and, where necessary,
legislation, to assist in bringing the urban renaissance into
being.
Question: Which of the recommendations of the
Report of the Urban Task Force should be a priority for implementation?
To a large extent, the Task Force's proposals
are inter-dependent and need to be seen as a package. Nevertheless,
we highlight below some of the areas that CIH believes must be
addressed with particular urgency. We also raise questions about
some aspects of the Task Force's proposals that we believe could
be counter-productive to the government's aims. Our comments are
listed under the headings used in the report's Executive Summary.
DESIGNING THE
URBAN ENVIRONMENT
CIH agree that high quality design work is vital
in ensuring sustainable development in our urban neighbourhoods.
In many areas, the density of new residential development will
need to increase to accommodate additional households on previously
used sites. The quality of design employed in such schemes will
be crucial to their success and many of the Task Force's proposals
to improve design standards are welcome. However, if these proposals
are to be successful in retaining and attracting people to urban
environments there needs to be a realistic approach to their needs
and preferences.
For example, social landlords often find single
bedroom and bed-sit accommodation difficult to let even to single
people, and research has shown that single people often aspire
to two or three bedroom houses (HRF/NHBC, 1998). Households containing
persons with a disability may need additional space and/or guaranteed
parking close at hand. The provision of one parking space per
household may be acceptable in many locations, but the proposal
for this as a maximum standard for all new urban residential development
seems inflexible and excessive.
If design standards are overly restrictive,
there is a danger that new developments, in any but the most attractive
locations, will not attract medium and high wage earners. This
would undermine the government's aims of urban regeneration and
mixed communities, and lead to continuing demands from the public
for development in urban-fringe or rural locations. As a starting
point, the development of maximum density standards which reflect
local circumstances, set alongside the minimum standards proposed
by the Task Force, is required.
MANAGING THE
URBAN ENVIRONMENT
The Task Force report calls upon local authorities
to provide strong, strategic leadership on behalf of their local
populations to lead the urban renaissance at local level. While
local authorities already have wide ranging powers and responsibilities,
the report calls for local authorities to be assigned a new strategic
role in ensuring management of the whole urban environment. This
proposal should be given serious consideration, but would need
to be matched by the availability of the resources needed to make
this role effective.
More specifically in relation to housing, CIH
believes that local authorities should be given a stronger strategic
role to enable them to properly influence the housing market in
their area, by working with agencies such as lenders and builders.
CIH is currently working with the Council of Mortgage Lenders
on research assessing the extent to which local housing authorities
currently reflect private sector housing issues in their local
housing assessments (Blackaby, 2000 forthcoming).
The Task Force report recognises that high quality
urban management is essential to build on and sustain capital
investment in the built environment. Their call for pilots to
evaluate models of neighbourhood management chime with those of
the Social Exclusion Unit's Policy Action Teams (PATs). CIH understands
the requirement for a holistic approach to the problems of deprived
neighbourhoods, and the need for ongoing intensive management
to consolidate investment. In many deprived neighbourhoods, housing
professionals already provide an on-the-spot link between town
hall managers and communities.
DELIVERING URBAN
REGENERATION
The Rogers report calls for the creation of
Urban Regeneration Companies (URCs) and Housing Regeneration Companies
(HRCs) as crucial delivery mechanisms for regeneration. URCs would
include directors from a range of stakeholders with an interest
and role to play in regeneration. These would normally include
the local authority, a Registered Social Landlord (RSL), community
representatives and the Regional Development Agency (RDA). To
be fully effective some of the restrictions placed on local authorities'
involvement in companies would need to be reviewed. HRCs could
be a free-standing RSL or a subsidiary of an existing one.
Given appropriate legal and regulatory flexibility,
both types of vehicle could play a key role in regeneration. HRCs
could be particularly important in regenerating mixed tenure and/or
low demand inner city areas. CIH is conducting research into options
for RSL structures given the variety of new activities in which
many are now engaged, including regeneration and "housing
plus" services (CIH, 2000).
INVESTING IN
SKILLS AND
INNOVATION
CIH agrees with the Task Force that professionals
will require new skills if the urban renaissance is to be achieved.
CIH is reviewing its own professional qualifications in the light
of this changing context. A crucial aspect of this is the need
to ensure that professionals from different disciplines work together
more effectively. CIH is talking to the other built environment
professions about how this can be achieved both for new entrants
and through programmes for continuing professional development.
MANAGING THE
LAND SUPPLY
Public concern has been raised about government
projections of household growth and how this feeds into requirements
for new housing. CIH accepts the concerns of the public and the
government about the need to avoid unnecessary development on
greenfield sites, especially where this undermines urban regeneration.
Nevertheless, the Government's own White Paper, Planning for the
Communities of the Future recognises the damaging effects of providing
insufficient land for housing, for example, higher land prices,
more enforced sharing, and, in extreme cases, homelessness.
Current government proposals call for a move
away from the "predict and provide" approach, to a more
devolved mechanism led by Regional Planning Bodies (RPBs). CIH
agrees with the Task Force's assertion that under these new proposals
for allocating land for housing, clear procedures are needed to
ensure the early correction of an emerging under-or over-supply.
In cases where RPBs propose a move away from an approach based
on central government derived projections, a sound, nationally
accepted methodology is required to enable the production of regional
housing assessments. The report of PAT 7 on Unpopular Housing
recommended that RPBs link with RDAs and sub-regional groupings
of local authorities to agree policies and levels of housing provision
that better match demand and supply and provide choice while avoiding
over-provision (DETR, 1999). Urban capacity studies have a role
in determining how far urban areas can meet housing need, but
they must not become the tool for estimating that need.
The need for clear regional targets which include
provision for affordable housing has been recognised by the Environment,
Transport and Regional Affairs Committee. CIH, together with the
National Housing Federation, Room and Shelter supported this point
in their National Blueprint for Delivering Affordable Housing
through the Planning System (CIH/NHF/Room/Shelter, 1998).
The government is also proposing a move to a
sequential approach of directing development to previously used
sites. CIH support this principle, but have highlighted potential
problems with such an approach if applied inflexibly. These include:
increases in property values for brownfield sites making the delivery
of affordable housing more problematic; difficulties in integrating
land release with regeneration funding programmes; sustainability
tests linked to this approach could deter the provision of affordable
housing in rural areas.
CIH are awaiting the release of finalised Planning
Policy Guidance Notes (PPGs) affecting many of these issues. If
the concerns raised by CIH and other agencies on the consultation
drafts of these PPGs are not fully addressed, these issues should
form part of the proposed Urban White Paper. (Further CIH comment
on draft PPG Note 3 and a joint response to the draft PPG 11 from
CIH, Shelter and the National Housing Federation are available.)
PLANNING FOR
CHANGE
CIH support the Task Force's view that the current
land use planning system is too concerned with controlling development
rather than playing an active role in securing positive change.
The planning system should be a tool to facilitate the delivery
of the government's wider economic and social objectives. This
will require significant changes to the planning system and the
way it operates.
MAKING THE
INVESTMENT
The Task Force report outlines a range of measures
for attracting the financial resources—public and private—that
will be needed to power the urban renaissance. Proposals include
tax measures, new financial instruments for attracting institutional
investment into the private rented sector, and national public-private
investment funds for area regeneration projects. CIH agrees with
the Urban Task Force that the objective of an urban renaissance
should be included in the terms of reference for the forthcoming
Comprehensive Spending Review and call for these and other measures
outlined in the report to be given serious consideration.
Our urban areas need holistic regeneration reflecting
the complex mix of economic, social and physical problems that
exist. Improving housing conditions is an essential element of
a holistic approach, but experience has shown that it is often
not enough to turn around declining neighbourhoods. The Task Force
report advocates debt cancellation to facilitate transfers of
council housing to dedicated management organisations able to
make use of private finance to improve conditions and raise standards
in public housing. Stock transfer will continue to have a role,
and CIH welcome the government's moves to consider large scale
transfers in cities such as Coventry and Birmingham. Public spending
constraints are, however, likely to restrain the extent of debt
write-offs and other options need to be considered, not least
in cases where tenants are resistant to transfer. Together with
the Local Government Association, CIH produced a report describing
a range of models for separating the strategic and management
functions of local authority housing departments, as advocated
by Rogers and by the government itself. Such models could prove
attractive where transfer is impractical, providing that these
efficiency improvements were accompanied by some linkage to investment
needs (HACAS and Trowers & Hamlins, 1999).
Poor conditions in some parts of the private
housing sector—both for owner-occupiers and private renters—also
require attention and investment. It is unclear at this stage
to what extent the problems of this sector will be addressed in
the forthcoming Housing Green Paper (CIH, 1999). The Task Force
report highlights the problems of areas with large numbers of
pre-1919 terraced housing, often with high levels of unfitness
and disrepair, particularly those in more socially and economically
marginal areas. CIH advocated a package of grants, loans, equity
stakes and tax relief in its report Sustainable Home Ownership
(CIH, 1997), and many of these kinds of ideas are also reflected
in the Task Force report.
Question: The future for urban areas suffering
from low demand for housing and social decline.
Housing providers are acutely aware of the problems
of changing patterns of demand for housing. CIH were pleased that
the PAT 7 report identified the complexity of this issue. For
example, it recognised that the phenomenon of unpopular housing
reflected the existence of both surplus housing in some areas,
but also accommodation that is unpopular even in locations where
acute pressure on housing ensures that vacancies can be filled.
This problem is not exclusive to social housing, and needs to
be tackled in all tenures. Our latest research into this issue
focuses on the impact of low demand on housing associations (CIH
2000, forthcoming).
As the PAT 7 report highlighted, a range of
responses to the problems of unpopular housing need to be addressed
at local, regional and national level. Action required includes:
improving links between regional planning bodies and RDAs to avoid
under- or over-provision, more intensive housing management, improving
the housing stock and surrounding environment, better marketing
of housing, and selective clearance. Where clearance is required,
full involvement of local communities is needed to ensure that
this is carried out in a sensitive way and avoid the mistakes
of the past. This is particularly important as many of those "left
behind" in unpopular neighbourhoods are vulnerable households,
including many older people and those from minority ethnic communities.
There are, however, limits to what can be achieved
by action at regional and local level. Our report Low Demand:
Separating Fact from Fiction (Holmans and Simpson, 1999) pulls
together a range of data illustrating the steady trend of movement
from cities in the North to the increasingly populous South. National
action is required to reduce the economic disparities within the
UK which are the key driving force of population movement. Financial
and other incentives should seek to push employment back into
the areas currently losing population. While even this action
may not be enough to reverse decline in those neighbourhoods with
the most entrenched problems, in other more marginal areas, economic
growth can play a vital part in stabilising the community.
Question: The consequences for the urban renaissance
of housing and business development on greenfield sites.
CIH agrees with the views of the Urban Task
Force and PAT 7 that inappropriate greenfield development can
undermine urban renaissance. Nevertheless, some greenfield development
will be necessary to meet housing and other needs. Our report
Low Demand: Separating Fact from Fiction confirmed that the phenomenon
of changing levels of demand had not significantly affected the
number of new affordable homes that are needed (CIH, 1999). Around
85,000 new affordable homes are still required each year which
is more than double the number currently being built. These new
homes must be provided as part of mixed, inclusive communities
where economic or demographic analysis shows they are needed,
including where this can help to sustain rural communities. CIH
believes that mixed tenure communities should become the norm.
As part of this process, Planning Circular 6/98 should be reviewed
to include the removal of the thresholds that make it harder for
local authorities to achieve mixed residential development on
small sites.
References
CIH (2000) Winning Structures—Registered
Social Landlords in a changing world, CIH: Coventry
CIH (2000 forthcoming) The economic consequences
of low demand for Registered Social Landlords, CIH: Coventry
CIH (1999) Putting the House in Order: Housing
professionals' agenda for legislation, CIH: Coventry
CIH (1997) Sustainable Home Ownership—New
policies for a new government, CIH: Coventry
Blackaby (2000 forthcoming), Local Housing Assessments:
A Review of their coverage of the private housing market,
CIH/CML
CIH/NHF/Room/Shelter (1999) National Blueprint
for Delivering Affordable Housing through the Planning System
DETR (1999) Unpopular Housing, DETR: London
HACAS and Trowers & Hamlins (1999) New Structures
for Council Housing, CIH/LGA
Holmans and Simpson (1999) Low Demand: Separating
Fact from Fiction, CIH: Coventry
Housing Research Foundation/National House Builders
Council (1998) Home Alone, NHBC: London
David Fotheringham
Policy Manager
January 2000
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