Select Committee on Office of the Deputy Prime Minister: Housing, Planning, Local Government and the Regions Memoranda

Memorandum by Council for the Protection of Rural England (CPRE) (HOU 36)


  1.  This paper sets out CPRE's views in response to the call for evidence from the Housing, Planning, Local Government and the Regions Select Committee for its current Inquiry on affordable housing. Please note that this paper follows generally the line of our submission to the previous Inquiry, with some changes to take account of recent developments.


  2.  A number of factors have contributed to the recent renewed interest in Government housing policy, and planning for housing in particular. Among other things, recent housing completions figures (which showed that housing output was at its lowest level since 1924) have been used by a number of interested bodies to predict a crisis in homelessness and—inaccurately, in our view—conflate a number of quite distinct issues. Among these issues are: the overall supply of sites for housing; affordability of market housing for key workers, in London and the South East especially; levels of affordable housing provision more generally; homelessness and use of temporary accommodation; the effects of revised PPG3 Housing (2000); Green Belt policy; and the debate over the appropriate balance between housing on greenfield and brownfield sites.


  3.  Policies for the provision of new housing are at the core of CPRE's concerns. We are interested in both the role of the planning system per se and the contribution of new housing to the environmental, social and economic well-being of the countryside. We have a record of close involvement in this issue over many years.

  4.  Our report Housing with Hindsight (1996) showed that, despite significantly more private market housing being built than had been projected, there was a dramatic shortfall between the identified need for affordable housing and the amount built. This means that large amounts of land identified in plans to meet social housing need were being used to provide market housing over and above identified need, fuelling further imbalances in local demography and workforce composition, with consequences for service provision. We have no reason to believe that this state of affairs has altered significantly since then.

  5.  The continuing reduction in housing completions appears to be very largely as a result of the slump in social housing provision rather than constraints on market housing. Of the 135,000 houses completed during 2000-01, according to the former DTLR's figures, 86 per cent were provided by "Private Enterprise" and around 12 per cent built by Registered Social Landlords, with just 0.5 per cent accounted for by Local Authority housing. The same figures show an increase in housing starts for the first two quarters of 2001-02 over the previous year. This compares with the situation from the mid-1950s until the mid-1970s, when the combined housing output of local authorities and Registered Social Landlords remained generally comparable with that of private housebuilding (Office of National Statistics).

  6.  CPRE joined forces with Shelter, the TCPA and the NHBC for a national inquiry into housing need in rural and urban areas in 1998. Progress with changes to national planning guidance, however, has been limited: the latest Circular 6/98 Planning for Affordable Housing and the Rural White Paper contributed only marginal improvements in the policy framework, some of which have not been taken up by local authorities; and PPG3 introduced the welcome requirement for local authorities to co-ordinate housing strategy with planning, but this has yet to produce significant results.

  7.  CPRE fully acknowledges the vital importance of adequate provision to meet identified social housing need. We have a number of suggestions as to ways in which this issue might be addressed without causing unnecessary harm to the countryside.


  8.  CPRE believes that there are dangers in the use of the term "affordable". There is an uncertain distinction between housing for social need and housing provided on the open market at prices which are simply relatively more affordable (or less out of reach) than the bulk of supply. We therefore favour the use of the term "social housing" rather than "affordable housing". We would strongly support the removal of subsidised market housing from the general definition of social/affordable housing and limiting the definition to property available in perpetuity for letting at sub-market rents to meet an identified need. This definition should also be adapted to include shared ownership/rented housing, where the tenant/part-owner may not take full possession and the property remains in the hands of a social housing provider.


  9.  There is clearly higher demand for housing at sub-market rents and prices in the South East, London and other highly prosperous parts of the country. We emphatically do not believe, however, that this need justifies or requires large releases of greenfield land for new housing. There remains considerable (underestimated) capacity for making better use of previously used land and buildings for new housing development across the country, including in the South East and surrounding regions (see paragraph 13 below for more detail on urban capacity studies). Of the approximately 750,000 empty homes in England reported by the Empty Homes Agency, at least 327,100 are in the southern regions of England (London, the South East, South West and East of England). 90,700 of these have been empty for more than 12 months. The recent report of the TLR Select Committee Inquiry into empty homes highlighted the estimated national need for 83,000 affordable dwellings per annum to 2016, of which approximately 50,000 per annum. are required in the southern regions of England. The Report goes on to say that:

    "In crude terms (leaving aside issues of price, location and quality) the long term empty homes thus represent almost two years' worth of the required supply of affordable housing in the four southern regions."


  10.  We believe that arguments that planning constraints on greenfield housing are a significant contributory cause of the shortage of affordable housing are deeply flawed. Available figures, notably those used by the Urban Task Force in its Report, indicate that: (a) land supply is ample, even in the South East; but (b) developers are not always willing or required to provide the sort of housing which is most needed and on sites which have been identified. This message is reinforced by the experience of CPRE volunteers closely involved with the planning system across the country. While there may now be a heightened need for social housing in some parts of the country, we see little clear evidence of any connection between this issue and land supply for housing.

  11.  The recently published National Land Use Database figures indicate, as Lord Rooker has himself acknowledged, that the supply of previously developed urban land and buildings is no obstacle to meeting the Government's brownfield housing target of 60 per cent. CPRE welcomes the early achievement of the 60 per cent target. We believe it vindicates our long-held view that there is great potential to increase the proportion of housing built on previously developed land. We strongly advocate an increase in the target to at least 75 per cent. This would not only bring benefits in terms of reducing the damage to the countryside from greenfield housing, but also help underpin the Government's objective of Urban Renaissance. Greater use of previously developed land and buildings should also bring public economic and social benefits by directing housing towards those areas where maximum use can be made of existing infrastructure and services, and where residents can enjoy maximum ease of access to their daily needs.

  12.  The argument that land supply is restricting housing supply bears little examination. The density of current housing development continues to waste land throughout the country: the figures for 2000-01 show an average density of housing of around 25 dwellings per hectare (dpha). This is for a number of reasons, but significant among them appear to be a combination of inertia and resistance to change among local authorities and developers, and a reluctance on the part of Government Regional Offices to intervene to enforce national planning policy guidance. If the sites developed for housing in 2000-01 had been developed at an average density of 40 dpha, mid-way within the (we believe unambitious) minimum range set out in PPG3 of 30-50 dpha, 60 per cent more housing would have been provided on exactly the same amount of land. This waste of land is an issue which affects the whole country, not just the pressured South East.


  13.  Recent criticism of revised PPG3 Housing (2000) that it has reduced supply of housing seems implausible, given that most permissions last for three to five years, and that PPG3 has been in force for barely two years and only patchily applied by local planning authorities to date. There could conceivably be medium-term implications for land supply where local authorities are finding it hard to adapt from a "greenfield first" approach to one focused on assessing, and making the most of, urban capacity, as PPG3 requires. We believe that PPG3's immediate effect has, however, been blunted by the reluctance of some local authorities and the Government Regional Offices to pursue and enforce the prescribed changes to policy and practice. We would draw the Sub-Committee's attention to the welcome emphasis in the Regional Governance White Paper Your Region, Your Choice on the need for, and desirability of, greater co-ordination between assessment of housing need, housing investment strategies and planning policy and practice at the regional level. We believe the new Public Service Agreement relating to protection of the countryside, announced in July, also has an important role to play in guiding co-ordinated activity.

  14.  Far from reducing the planning system's ability to provide for social housing need, PPG3 contains clear advice on co-ordinating local authority housing and planning strategies. This requirement has, however, so far had little discernible effect on local authority practice, and is one of a number of areas where much greater Government attention to delivery is required.

  15.  PPG3 also requires all local authorities to carry out a full urban capacity study before any land allocations are made for housing. This is necessary to ensure that maximum use of previously land and buildings before greenfield sites are released, following the sequential approach. Although some local authorities (eg Plymouth) have made great progress with such studies, others have been slow to comply. Even where Urban Capacity Studies have been carried out, in a number of cases these have been of doubtful quality, throwing into question the validity of their findings and giving rise to the suspicion that they have significantly underestimated the potential for supply.


  16.  We would also highlight the following issues in the context of the Sub-Committee's Inquiry.

    —  We believe there are grave dangers inherent in simplistic approaches to this problem, such as confusing simple market demand for housing with housing need.

    —  There has been a widespread failure by local authorities and providers to make full use of the tools already available to them, as indicated most recently by the former DTLR's own research Delivering Affordable Housing through Planning Policy (February 2002).

    —  We would like to see stronger promotion of the ways in which planning could help secure more affordable housing, eg though clear policies in development plans for the percentage of affordable housing to be required of developers, and full implementation of PPG3 Housing.

    —  We would encourage the Committee to explore examples of local authorities where good practice is being followed in PPG3—eg in reviewing plans, removing of unsuitable greenfield sites, applying the sequential test, actively promoting the re-use of previously used urban land and buildings, requiring higher density development and integrating housing strategies with planning policies—to show that progress is possible.

    —  The restatement in the Rural White Paper of support for a one-for-one (market/affordable) housing policy requirement appears to have had little noticeable effect, and needs to be made use of by all local planning authorities that have rural areas.

    —  We warmly welcome the increased funding recently announced by the Chancellor in the Comprehensive Spending Review. However, we believe that the importance of providing proper funding for social housing, including setting the spending limits for providers at realistic levels within which they can work, has been neither sufficiently acknowledged nor acted upon by successive Governments, and more needs to be done, including through reforms to the planning system (see below), to address the other factors (eg the hope value for market housing development) which determine the effectiveness of spending on social housing.

    —  We believe there is a pressing need for effective integration of housing investment and planning strategies at the regional and local levels, including the setting of regional targets for the provision of affordable housing. The Housing Corporation, particular, needs radically to improve its communication and collaboration with local planning authorities.

    —  We welcome the Government's decision, announced in July, not to proceed with proposals to fund social housing provision through development tariffs. There was an acute danger that the mooted higher tariffs for greenfield sites, while designed to encourage regeneration, would serve as a perverse incentive to local authorities to allow greenfield development in order to gain funds to spend on unrelated activities. We see a future role for improved planning gain arrangements, but the objectives to be secured by expected planning obligations should be clearly agreed and set out in development plans first, and draft section 106 agreements open to public scrutiny at an early stage of negotiation. We believe that the simplest and most effective option is much stronger use and application of planning conditions and a duty on local planning authorities to enforce them. This should be addressed in the Government's forthcoming proposals for reform of local planning and enforcement powers and procedures.

    —  Possible mechanisms to promote the allocation of sites in development plans specifically to meet social housing needs as part of mixed communities, eg along the lines recently proposed by the Countryside Agency (sites of social diversity), should be seriously considered.

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