Memorandum by Town and Country Planning
Assocation (TCPA) (AFH 49)
1. INTRODUCTION
1.1 In 2001 the Town & Country Planning
Association (TCPA) published Housing Demand and Need in England
1996 to 2016[34],
which updated the Government's latest projections (based on 1996
data) with projections based on 1998 population data—projections
which have not yet been updated by the DTLR. The TCPA was delighted
that the Joseph Rowntree Foundation subsequently took up many
of the elements of this work in their milestone report Land for
Housing[35]
and that the Urban Affairs Committee has seen fit to investigate
this issue. The TCPA welcomes the opportunity to contribute to
this investigation.
1.2 The TCPA campaigns inter alia
for the reform of the UK planning system to promote public participation
and sustainable development and for environment and development
policies which improve the living and working conditions of everyone.
Amongst the TCPA's objectives is "a decent home in a good
environment for everyone who needs it". The Association believes
the UK is a long way from achieving this aim.
1.3 In addition to the publication of the
Housing Demand and Need report, the TCPA also carried out the
recently published study for the then DETR, The Delivery of Affordable
Housing Through Planning Policy[36],
with Entec, Nottingham Trent University and Three Dragons Consultancy.
2. THE DEFINITION
OF AFFORDABLE
2.1 A series of focus groups for the Entec
study, defined affordable housing as social rented housing as
the first priority and forms of intermediate housing, ie shared
ownership and keyworker rented accommodation in addition to, but
not as a substitute for, social rented housing. Such subsidised
housing should take a whole variety of forms and tenures to widen
access to housing for those on lower or no incomes.
2.2 The study noted that there is a tendency
to equate affordable housing with social rented housing without
considering the full range of alternatives. A clear definition
is important in defining planning policy and developing mechanisms
for delivery.
3. THE SCALE
AND LOCATION
OF THE
DEMAND FOR
AFFORDABLE HOUSING
3.1 The need for affordable housing is not
a geographically specific phenomenon. People in all parts of the
country need to have access to housing, however, the scale and
type of need does vary between different regions. Evidence suggests
that around two-thirds of new households will be in the south
of the country, a part of the country that is already experiencing
rapid increases in house prices.
3.2 It is estimated that approximately 227,000
new homes per year will be needed over the next two decades. With
the current figures languishing at around 140,000 it is unsurprising
that house prices are rocketing along with the need for affordable
housing. The requirements for affordable housing, from the total
estimated housing need of 227,000, currently stand at around 85,000
new dwellings per year, to be met by new building, provision of
flats by conversion and possibly by acquiring vacant dwellings
and bringing them back into use. The spatial distribution of this
affordable housing varies considerably, with around 50,000 (58
per cent) likely to be needed in southern England.
3.3 The government needs to accept the scale
of the problem and the likely impacts such shortages will have
(see Section 12). It also needs to recognise that much of the
shortage comes, not from homeless or very low income groups, but
from those on low to medium incomes. The keyworker debate is an
important start, but there are huge numbers of people struggling
to afford decent housing who do not fall into this category, but
who would certainly be considered keyworkers by their employers.
4. THE QUALITY
OF AFFORDABLE
HOUSING
4.1 It has been suggested that, in order
to make some housing more affordable, it should be built to a
lower specification, for example, slightly smaller with fewer
frills. However, the internal space standards of new developments
in the UK have been declining in recent years and the TCPA strongly
advocates reversing this trend. If we are to create genuine mixed
communities, it is important that affordable housing is indistinguishable,
in appearance from market housing.
4.2 The most sustainable long term option
for any new housing stock is to ensure that it is capable of adaptation
over time to meet needs of varying household types. If today's
social housing is overly customised to today's small households,
it will be too inflexible to accommodate possible future increases
in household sizes.
5. THE ADEQUACY
OF THE
EXISTING SUPPLY
AND THE
AMOUNT OF
RESOURCES AVAILABLE
5.1 While the annual requirement for affordable
housing stands at approximately 85,000, this makes no consideration
of the backlog of unmet need. To make significant inroads into
this would require higher levels of new provision and this will
necessarily mean additional resources being made available.
5.2 It is an important factor that the cost
of land is rising rapidly, particularly in the south of the country,
and means that money made available for affordable housing is
effectively buying less and less. In addressing the affordable
housing issue therefore, there is also a need to address the wider
question of adequacy of supply—the current undersupply of
land for housing has been pushing up values (a relatively simple
market process).
5.3 The two factors, of general undersupply
of housing and insufficient resources are having a disastrous
impact on the number of affordable houses being built. The TCPA
believes that the ideal route to the provision of more affordable
housing in the UK is ultimately through a more transparent tax,
equal to a proportion of the added value accruing to a site through
its development. Such a tax would necessitate the abolition of
Circular 6/98 and apply to developments permitted whatever the
proposed use of the site (residential or commercial for example).
It is important to note however that the greater the amount required
for affordable housing from planning gain, the less will be available
for other important community facilities, transport improvements
and other measures which rely on planning gain funding.
5.4 In the absence of such a measure however
the TCPA supports steps to ensure that development for commercial
uses does not remain an option to serve the aim of avoiding fair
levels of contribution to public works such as affordable housing.
5.5 There is no evidence, of which the TCPA
is aware however, that planning systems can make good the shortfall
in the provision of housing needs. Planning gain and tax on land
value will only ever make a real contribution to affordable housing
provision if the tax is set at 100 per cent, which history has
proved impracticable. The major contribution must come from direct
provision of housing through central government funding. It is
disappointing in this regard to note that in 2001 less than one
fifth the number of affordable units was constructed than were
constructed in1980[37].
5.6 The TCPA would wish to see a restriction
placed upon the number of homes owned by local authorities that
are subject to right to buy. Tenants should retain a right to
apply to be housed in properties that can (after the satisfaction
of current conditions) be bought by their occupants through right
to buy legislation. A proportion of housing that must be protected
from market forces and remain in public or Registered Social Landlord
(RSL) ownership in perpetuity. The level at which this remains,
however, could be varied in line with the Government's stated
policy to plan, monitor and manage housing and other planning
provisions. Local authorities would therefore, be in a better
position to construct housing and to make a greater contribution
to meeting housing need than at present.
6. THE EXTENT
TO WHICH
PLANNING GAIN
CAN FUND
THE LEVEL
OF AFFORDABLE
HOUSING REQUIRED
6.1 There will always be other claims on
the planning gain pot, such as educations, health and open space.
As such, planning gain will only ever be able to deliver a small
proportion of the total number of affordable houses, JRF estimate
this to be around 15,000 per year, and much of this is likely
to be concentrated in areas with high land values. While affordable
housing is clearly necessary in such areas, it is by no means
confined to them.
6.2 House building is at its lowest level
for around 80 years, which has a knock-on impact for planning
gain, ie the fewer the number of houses built, the less money
there is for the planning gain "pot". If planning gain
is to be used to finance much of the affordable housing then it
is likely to fail to meet demand unless new house building generally
increases.
7. HOW RESOURCES
SHOULD BE
BALANCED BETWEEN
SOCIAL HOUSING
AND OPTIONS
FOR OWNER
OCCUPATION FOR
THOSE WHO
CANNOT AFFORD
TO BUY
(INCLUDING SHARED
OWNERSHIP) AND
WHETHER ADDITIONAL
MECHANISMS ARE
REQUIRED TO
BRING FORWARD
SHARED OWNERSHIP
TYPE SCHEMES
7.1 In some localities, low cost housing
for sale initiatives can contribute to affordable housing. The
DETR[38]
study showed that intermediate market housing could both find
a market as well as contribute to the need for affordable housing.
However, alternative forms of social housing are being squeezed
out, for example, co-ownership, self-build, co-operatives and
special needs housing.
7.2 Key to the success of social rented
provision is maintenance of a quota of stock in social ownership
(as discussed under right to buy, Para. 5.6). Key to the success
of the use of intermediate market housing, on the other hand,
is ensuring that rents remain at intermediate market levels and
are not driven up, for example by the maturing success of a particular
development. Legally binding conditions to ensure this, must form
part of any planning consent for intermediate market housing in
this context. The use of covenants on such properties should also
be considered.
8. WHETHER TARGETS
IN RPG ARE
APPROPRIATE
8.1 The TCPA does not believe that blanket
targets for the country as a whole are sufficient in their own
right, however it is vital that national housing projections continue
to be prepared with as much expertise as possible, however politically
unfashionable this activity may have become. Targets also need
to be agreed at the regional level by elected regional government,
without a more democratic mandate, housing targets are likely
to retain their "top down" image. Targets set at regional
level can better reflect the realities of the localities, than
national targets can. The TCPA believes that such targets would
carry more weight were they to be set by elected regional government.
9. WHETHER TARGETS
ON DECENT
AND AFFORDABLE
HOUSING WILL
BE MET
BY CENTRAL
AND LOCAL
GOVERNMENT
9.1 Recent experience suggests that such
targets, at least in the south east of England, are unlikely to
be met. The irony of extensive political negotiation by Government
in this region, which ended with the agreed target being set at
39,000 new homes per year (as against expert opinion, in the Secretary
of State's Inspector's report, that 55,000 homes per year were
needed), is that only 22,000 homes per year have actually been
built. The under supply of affordable housing is a proportion
of the overall under supply.
10. WHETHER CURRENT
POLICIES AND
PRACTICES ARE
LEADING TO
THE CREATION
OF MIXED
COMMUNITIES
10.1 The TCPA recognises and stresses the
importance of on-site affordable housing provision to ensure the
creation of mixed communities. The notion of mixed communities
is becoming more and more embedded in policy-making, however the
extent to which such communities are actually being created on
the ground is debateable. There continue to be large areas of
deprivation, with attempts to introduce mixtures of social groups
often failing. In addition, RSLs are still reluctant to pepper
pot their housing in mixed communities, preferring instead to
lump it together in "ghettos", on grounds that it is
easier to manage.
11. WHETHER MORE
GREENFIELD DEVELOPMENT
IS NEEDED
TO MEET
HOUSING NEED
11.1 The falsely polarised debate, that
says greenfield development is inherently bad, while brownfield
is good, is resulting in generally unsustainable development.
Blanket policies are rarely a sensible option when localities
vary so much and take no consideration of the merits or otherwise
of a particular site. Current debate frequently forgets that,
even if the greenfield/brownfield split is achieved, 40 per cent
of new development will continue to take place on greenfields,
we should therefore place a higher priority on ensuring that this
necessary Greenfield development takes place in a sustainable
way by planning positively for it. The likelihood is, that in
the southeast the greenfield proportion will need to be higher
than this if quality of life is not to suffer. There is therefore
an urgent need to devise and promote new and more sustainable
forms of development which are less damaging to the natural environment
to address the necessity for some greenfield development. Instead
of more greenfield development, it is necessary first to achieve
existing targets for greenfield and brownfield development.
11.2 While the TCPA believes that the role
of green belts is in need of review, it does not advocate their
rolling back in order to accommodate housing need. The TCPA was
involved in the establishment of green belts in the 1950s and
they are now perhaps the best-understood and most popular piece
of the current planning system. Green belts can and should ensure
that development is concentrated in well planned holistic new
communities and within existing towns rather than allowed to sprawl
unplanned across the countryside.
11.3 The government targets have a built
in recognition that some greenfield development will be necessary,
however, the TCPA argues that in some areas the proportion will
have to be higher than 40 per cent if we are to achieve sustainable
communities (sustainable communities must encompass social elements
in addition to environmental and economic, which implies accommodating
those on lower incomes). Therefore, a portfolio approach to planning
for housing provision needs to be adopted, whereby the decision
as to where new housing is located is based on a full range of
sustainability criteria.
11.4 The TCPA believes that while there
is likely to be a correlation between high density and high residual
value, it is concerned that the additional costs (ie social) of
high density may not have been factored into this assumption,
and will therefore need to be re-assessed.
12. THE COST
TO INDIVIDUALS,
BUSINESSES AND
THE ECONOMY
RESULTING FROM
THE SHORTFALL
IN THE
PROVISION OF
DECENT, AFFORDABLE
HOUSING
12.1 The TCPA is very concerned about the
social and economic costs of failing to provide for the nation's
housing needs. A lack of affordable housing in an area will mean
that those on lower incomes will not be able to afford to live
there. The impact of this on businesses will be evidenced by the
fact that they will have difficulties in finding employees. Similarly,
schools will have difficulties in employing and retaining teachers,
which will have knock-on effects for education standards in the
area. It is essential that localities maintain an approximate
balance in relation to income groups, if they are to be sustainable
and successful in the long term.
13. CONCLUSION
13.1 The provision of affordable housing
is not solely one of building more social houses; it is more complex
than that. However, the TCPA is adamant that sufficient homes
need to be built. Many of those experiencing problems in finding
suitable accommodation and an affordable price are not those on
the lowest incomes. Intermediate market housing could, therefore,
play a bigger part in overall affordable housing provision, provided
such stock is not lost to the private market.
13.2 To address this, issues such as high
land prices need to be tackled. The TCPA encourages the government
to consider, more widely, innovative solutions to the problems
of affordable housing and housing provision. Community land trusts,
which have been used in the US, could play a part in land assemble
for socially desirable purposes without need for changes in legislation.
34 Holmans A, (2001) Housing Demand and Need in England
1996-2001, TCPA & NHF. Back
35
Barlow J, et al (2002) Land for Housing: Current Practice
and Future Options: JRF. Back
36
DETR (2001) The Delivery of Affordable Housing Through Planning
Policy: Entec, Nottingham Trent University, TCPA, Three Dragons. Back
37
Barlow J, et al (2002) Land for Housing: Current Practice
and Future Options: JRF. Back
38
DETR (2001) The Delivery of Affordable Housing Through Planning
Policy: Entec, Nottingham Trent University, TCPA, Three Dragons. Back
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