Memorandum by Country Land and Business
Association (AFH 35)
INTRODUCTION
1. The Country Land and Business Association
(CLA) welcomes the opportunity to respond to the Urban Affairs
Sub-Committee of the House of Commons Select Committee on Transport,
Local Government and the Regions inquiry into affordable housing.
2. The CLA represents the interests of 45,000
members in England and Wales, who between them own around 5 million
hectares of land. Many of our members manage and own a range of
rural businesses including agriculture, forestry, tourism and
many other forms of commercial activity. As people who live and
work in rural areas, CLA members have a keen and direct interest
in the continued prosperity of rural areas. The provision of affordable
housing has important implications for the rural economy and communities,
therefore, our interest in this draft needs little amplification.
3. The CLA considers that current housing
policy has not developed in a way that will solve rural housing
needs. Without affordable housing in the countryside, not only
are people excluded (many ending up, against their will, relocated
in urban areas) but also businesses and whole communities suffer.
PLANNING ISSUES
4. We are concerned that the current approach
in PPG 3, ie the sequential approach, while achieving its urban
concentration aim, will mean that little residential development
could occur in rural areas. This would ultimately be detrimental
to the economy of these areas and the Government's aim of achieving
sustainable rural communities. In addition, we have doubts whether
local authorities will have the resources to carry out the brownfield
assessment adequately. If these surveys are not carried out efficiently
the whole principle of the sequential test will be undermined.
5. The CLA acknowledges that PPG 3 represents
existing planning policy with regard to affordable housing and
makes it clear that affordable housing is an important material
planning consideration. It emphasises that the planning system
has a key role to play in assessing needs and ensuring that they
are met within new development. This guidance will strengthen
the capability of planners to control the type and affordability
of new housing, particularly in rural areas. However, the current
approach to providing rural affordable housing is failing to meet
rural needs; this seems to be confirmed by recent statements from
the Countryside Agency. "Exceptions sites", though successful
to a degree have only brought forward a small percentage of sites.
In addition, the provision of sites obtained by planning gain
is negligible, due to the size of housing schemes in rural areas.
There is a need for an adequate policy that will allow a satisfactory
level of affordable rural housing.
6. We were disappointed that the revision
of PPG3 in 2000 did not take the opportunity to address the above
problem and suggest other imaginative and innovative ways of achieving
affordable housing in rural areas. We would suggest the following
as a starting point:
— local planning authorities still
seem to place too greater weight on other factors, such as environmental
protection when considering exception sites. There is no priority
given to the housing need in such circumstances;
— there is a case for land to be allocated
for affordable housing. Such a policy will need to be carefully
worded to ensure that occupation remains as affordable housing.
It must also ensure that it does not restrict the provision of
land for affordable housing, due to increased hope value by allocating
the site. There may be merit in looking at the proposal put forward
by the Countryside Agency for "Sites of Social Diversity".
Though we would stress that this proposal should not be at the
expense of current exception sites policy, it should complement
this provision;
— an increase in the population of
villages where local authorities can set appropriate thresholds
for affordable housing may be appropriate, possibly doubling the
figure;
— there needs to be a clear definition
of affordable. This will vary from region to region. There may
be a need for a mix of affordable homes, to rent and low cost
to buy these issues need definition;
— affordable housing needs to be for
the right people in the right location. This means having up to
date local needs surveys to ensure that the housing meets a specific
rural need. These surveys need to be readily available to landowners
and providers of affordable accommodation. The policy will fail
if affordable housing is provided and occupied by people who are
relocated out or urban areas to meet its housing problem;
— affordable housing needs to meet
a range of house types. Such housing is not necessarily small
two bed terraces; family homes need to be provided. Again this
relates to an up to date local needs survey;
— affordable housing is part of a wider
debate in rural areas. There needs to be a close link to adequate
employment opportunities and services such as shops and schools.
7. Affordable housing policies must be monitored
by local authorities. This allows changes in need to be addressed,
meeting the Government's objective of the right housing in the
right place at the right time.
RIGHT TO
BUY
8. CLA members have made sites available
for low cost schemes. It should be stressed, however, that the
proposals of the previous Government to legislate for a right
to buy rural Housing Association stock affected the confidence
that such donated sites would remain perpetually available to
the social housing sector. If more sites are to come forward the
Government will need to convince owners that land given for social
housing will be protected for this purpose.
9. The CLA supports the current recognition
of the advice on resale restrictions and right to buy in rural
areas. However, we feel there may be merit in increasing the threshold
limit from 3,000 population, this would allow some larger settlements
to retain their affordable housing stock. Although we have not
researched a specific figure we would, for the purposes of debate,
suggest doubling this threshold.
HOUSING CORPORATION
APPROVED DEVELOPMENT
PROGRAMME
10. The CLA welcomes the improvements suggested
in the Rural White Paper (Our Countryside: the future. A fair
deal for rural England, 2000) to increase funding and provision
of affordable housing, however we question whether this will be
enough to meet the identified need. There is serious under-funding
in the provision of affordable housing in rural areas. The Housing
Corporations approved development programme has been increased
to around 6 per cent in rural areas but this only brings the figure
back to a level it was at a few years ago. There is a need to
continue to increase this resource.
11. We welcome the increase in homes to
1,600 by 2003-04, as identified in the Rural White Paper, and
we would encourage the Housing Association, as the Government's
Housing Agency, to ensure this figure is met.
12. When setting investment priorities,
we suggest care is taken when setting indicators. We continue
to argue that there must be a move away from incorrect indicators
of affluence such as car ownership. More detailed site-specific
indicators must be used.
RURAL STRATEGIES
13. The CLA supports the need for sustainable,
mixed and inclusive communities and agree that this can only be
achieved if strategies are based on all stakeholders.
14. Whilst we agree that strategies reflect
the Rural White Paper by considering flexible local transport
arrangements, this must include recognition that transport in
rural areas does not only involve a range of public transport
modes. The use of the car is a necessity not a luxury in many
cases, while there is also a significant proportion that has no
access to a car. Such cases add weight to the argument that the
housing strategy must be flexible to provide homes in more remote
settlements and not just large local service centres. Thereby
allowing people to remain in the communities they are familiar
with.
15. The CLA fully supports the needs for
housing strategies to be based upon up to date needs surveys.
We wonder whether there is a place for the Housing Association
to specifically encourage local authorities to carry out such
work.
16. We support the commitment to housing
enablers. In our experience we believe that such a role provides
a valuable means of overcoming obstacles in achieving affordable
housing. For example, liaison between such a person and our Three
Counties Region brought forward many possible sites from landowners.
Any development of this proactive approach is good.
FISCAL ISSUES
17. Our final point on social housing relates
to fiscal issues. New small business ventures are hampered often
by the lack of affordable dwellings for employees of rural businesses.
The Government should signal further encouragement to the construction
of low-cost social or community housing by providing a deferment
of any capital gains where, and to the extent that, those gains
are re-invested in the construction, re-construction, alternation
or improvement of assets that become social or community housing.
Perhaps defining the latter by reference to the occupation of
the dwelling and whether the housing is affordable.
CONCLUSION
18. Affordable housing is part of a wider
debate in rural areas. There needs to be a close link to adequate
employment opportunities and services such as shops and schools.
Furthermore, we would encourage the recognition of low cost ownership.
The CLA has long argued that in addition to low cost renting there
is a need for homes for local workforce who are in a position
to purchase at an affordable price. We are pleased this local
needs aspect is recognised in the strategy.
19. We welcome the recognition of the importance
of providing sufficient quality affordable housing in rural areas.
As policies for urban renaissance develop it is likely to make
new rural housing developments more difficult to achieve with
obvious implications for prices. It is vital that people working
in or wishing to remain near family in rural communities have
the opportunity to find suitable housing.
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