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

Memorandum by Town and Country Planning Association (TCPA) (SHC 19)


  1.1  The Town and Country Planning Association welcomes the opportunity to comment on this inquiry. 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.

  1.2  The TCPA welcomed the acceptance by the Government, in the speech by the Deputy Prime-Minister in July, that the issues of housing and sustainable communities are of critical importance.


  2.1  The Deputy Prime-Minister is right in his conclusion that there are different problems in different parts of the country: generally, overcrowding in the south (particularly the south east) and market failure in parts of the north.

  2.2  There are two parts to the problems in the south: a shortage of housing generally and a shortage of affordable housing for those on lower incomes. A study carried out from the then DETR by Entec with the TCPA, Nottingham Trent University and Three Dragons into Affordable Housing[17] defined affordable housing using a series of focus groups:

    "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".

  2.3  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.

  2.4  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%) likely to be needed in southern England.

  2.5  The government needs to accept the scale of the problem and the likely impacts such shortages will have (see below). 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.

  2.6  The definition of key workers needs to be defined. At present key workers tend to be seen as nurses, teachers and other public service workers, but the problem is not confined to these groups. Employees in the private and voluntary sectors can also be defined as "key" to the functioning of these organisations and should be recognised as such in the provision of housing.

  2.7  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.

  2.8  Although the Deputy Prime-Minister clearly recognises the reality of the housing crisis, he clearly does not see the whole picture. He claims that the Government is meeting the 60% brownfield target, but ignore the fact that this represents 60% of a far lower level of house building than is required.


  3.1  The additional funding being made available and the commitment from Government is likely to ease pressure on the housing market in those areas experiencing high prices, however, it is unlikely to significantly reduce prices unless the money is targeted. It is also questionable whether the Government would see significantly lower prices as desirable, however beneficial this may be to those on lower incomes, since this would leave large numbers of home owners with negative equity.

  3.2  The additional funding could have significant impact on house prices if channelled into selected areas, for instance the four growth areas outlined by the Deputy Prime-Minister. However, a number of pre-conditions would have to be met: a dedicated agency would need to be set up (eg a Special Purpose Vehicle) to oversee implementation; such an agency should also be required to ensure that corresponding infrastructure was developed in parallel, for instance public transport, retail and other community facilities. It is likely that the funding earmarked for this will not be sufficient.


  4.1  Special Purpose Vehicles (SPV) will be critically important, particularly for the hard to develop area of the Thames Gateway. The recognition by the Deputy Prime-Minister of this is welcomed.

  4.2  In addition, the concentration of much of the new development into growth areas will help to achieve more effective results. As mentioned in paragraph 3.2, if development of new housing is built along side other facilities and takes the form of new communities (be these free standing on urban extensions) then real results are possible.


  5.1  While the TCPA agrees with the principles of the urban rennaisance and the re-use of brownfield land, we are concerned about the intention to intervene in applications for developments under 30 dwellings to the hectare. Such a policy will further erode the ability of local planning authorities to decide what is best for their particular circumstances.

  5.2  Similarly, the TCPA has been a long time supporter of the principles behind green belts, however we do believe that in some cases the broad swathes of land designated as green belt around cities can actually run counter to the needs of sustainable development. The TCPA believes that green belt designations should be reconsidered and, where necessary, boundaries redrawn. For instance, designations could be changed to allow for development of housing in areas where there is employment but a shortage of housing and vice-versa. For example, releasing land around some out of town shopping centres to allow housing and community infrastructure to develop, or to release employment land in towns and villages in the green belt that have become essentially dormitory towns.

  5.3  So long as the new housing is planned in an integrated way, together with jobs, transport and other community infrastructure, the proposals would not result in sprawl. In fact, they would be likely to result in far more sustainable land-use patterns and reduce the need to travel.


  6.1  The three proposed new Millennium Villages in East Ketley, Milton Keynes and Hastings . . . I don't feel able to comment here!


  7.1  Both housing associations and private sector house builders are interested in providing "intermediate market housing" particularly for key public sector workers. Public funding should be available for these types of initiatives as well as for low cost home ownership. There should however be proper safeguards to ensure that either properties remain "affordable" in perpetuity or that any funds generated from their resale are channelled back into additional affordable housing provision. Subsidising market housing is not advocated by the TCPA.

  7.2  Social housing providers, rather than the TCPA are better placed to advise on policy on funding distribution across different housing tenures.

  7.3  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.

  7.4  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).

  7.5  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.

  7.6  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.

  7.7  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%, 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 in 1980[18].

  7.8  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.



  8.1  The TCPA believes that decisions should be taken at the most local level possible to ensure effective planning. Over centralisation of decision making can, and does, result in generalisations, whereas in reality problems are often unique to a locality or differ between them.

  8.2  In relation to numbers the strategic element is of critical importance, therefore the most appropriate tier will be the regional. Other decisions on issues such as density would be better made at more local level, since these should be based on local circumstances. The TCPA does not agree that developments with densities lower than 30 dwellings per hectare should be automatically called in by the Secretary of State.

17   DETR (2001) The Delivery of Affordable Housing Through Planning Policy: Entec, Nottingham Trent University, TCPA, Three Dragons. Back

18   Barlow J, et al (2002) Land for Housing: Current Practice and Future Options: JRF. Back

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