Select Committee on Environmental Audit First Report



38. Sustainable Communities: building for the future, which sets out the Government's Sustainable Communities Plan, was launched by ODPM as a £22 billion plan to drive forward thriving and sustainable communities for this and future generations. On launching the Plan, the Deputy Prime Minster, The Right Hon John Prescott MP, stated that it marked a real step-change in the Government's approach to urban and rural communities all over the country, which would create and maintain places in which people want to live, to which they would be proud to belong and which would stand the test of time.[33] In the process of our inquiry into the Barker Review and the impacts of increasing housing supply it became increasingly clear that the proposals for development and housing construction already underway within the Sustainable Communities Plan (SCP) have significant implications for the environment.

39. Sustainable Communities: building for the future did not give a definition of what a sustainable community should be. However it did list what ODPM saw as some of the key requirements for such a community:

  • A flourishing local economy to provide jobs and wealth;
  • Strong leadership to respond positively to change;
  • Effective engagement and participation by local people, groups and businesses, especially in the planning, design and long-term stewardship of their community, and an active voluntary and community sector;
  • A safe and healthy local environment with well-designed public and green space;
  • Sufficient size, scale and density, and the right layout to support basic amenities in the neighbourhood and minimise use of resources (including land);
  • Good public transport and other transport infrastructure both within the community and linking it to urban, rural and regional centres;
  • Buildings - both individually and collectively - that can meet different needs over time, and that minimise the use of resources;
  • A well-integrated mix of decent homes of different types and tenures to support a range of household sizes, ages and incomes;
  • Good quality local public services, including education and training opportunities, health care and community facilities, especially for leisure;
  • A diverse, vibrant and creative local culture, encouraging pride in the community and cohesion within it;
  • A "sense of place"; and
  • The right links with the wider regional, national and international community.[34]

40. Whilst it is undoubtedly the case that the language of the SCP goes a long way to acknowledging the need for growth which encompasses social and economic priorities, the same cannot be said with regard to the environmental impacts of growth. It is clear that the Sustainable Communities Plan does represent a positive change in how the Government approaches growth and regeneration. However, we are disappointed not to see set out explicitly in the key requirements for a sustainable community the need to comply with the principles of sustainable development; and we deplore the absence of any reference to environmental protection, or the need to respect environmental limits.

41. The document also set out how the Government intends to tackle the problem of unaffordable homes in some areas of the country and abandonment in others. The aim would be to create decent homes and a good quality environment in all regions through a step change in housing supply which would increase the availability of affordable housing, ensuring private builders build the right types of houses in the right places, while protecting the countryside and rural communities from urban sprawl.[35] Under the heading of "sustainable growth", the plan also sets out the rationale behind the four Growth Areas. The aim of these areas is to accommodate the economic success of London and the wider South East, thus ensuring that the international competitiveness of the region is sustained. It is planned to deliver sustainable growth through the provision of an additional 200,000 homes by 2016 in the Growth Areas, over and above the numbers already set out in Regional Planning Guidance. The SCP also sets out how these Growth Areas could potentially accommodate over 900,000 new homes by 2031. Nine Pathfinder areas were identified, outside the South East, where strategic action plans will be put in place for large scale clearance of old housing, refurbishments, new build and improvement in local services.

Is it Sustainable?

42. ODPM set out in its memorandum to us the five strategic priorities which it has adopted with the aim of creating sustainable communities:

It then went on to state that: "as is clear from the strategic priorities [set out above] the Office's aim and objectives clearly encompass the goal of sustainable development, integrating economic, social and environmental factors".[36] This is not the case. The above strategic aims do not, as they are set out, give any weight at all to the environment. In fact the environment is mentioned only once, under the second heading: "ensuring people have decent places to live by improving the quality and sustainability of local environments".[37]

43. Bearing this in mind we were particularly concerned to see the ODPM's response to the first recommendation of the Egan Review of Skills for Sustainable Communities (which is discussed in some detail later in this Report). Egan's Review recommended that all stakeholders involved in delivering sustainable communities should adopt a common understanding of what "sustainable communities" means. In its response the ODPM committed itself to having a broadly agreed definition that could be used by everyone engaged in the delivery of sustainable communities. This has not yet been published. ODPM also announced that it was "considering the links between sustainable communities and sustainable development via a Ministerial sub-group of the Central Local Partnership".[38] This may be welcome, though if, as ODPM told us, the SCP already encompasses the aims of sustainable development, it raises two question: firstly, why this is necessary at all; and secondly, how it can be possible to publish a definition of what a sustainable community is before its links to sustainable development have been established.

44. We would like to know if or when ODPM intends to publish its definition of sustainable communities. This definition must give a clear indication of exactly how sustainable development underpins sustainable communities; and should explicitly give the environment equal footing with social and economic goals.

45. The belated effort by ODPM to explore how sustainable development is linked to the Sustainable Communities Plan is a stark example of the failure of Government to place sustainable development at the heart of policy making and of how environmental considerations remain a bolt-on rather than a primary concern.

46. This general failure has been set out in greater detail in our recent report on the Sustainable Development Strategy. We highlight in that Report how Government still places insufficient weight on the environmental dimension of sustainable development, inclining more towards an economic interpretation of the term, and that insufficient emphasis is placed on the concept of environmental limits.[39] This is exemplified by the statement in ODPM's memorandum to us that "the economic and social effects of the current shortage of housing supply are not sustainable in their impacts either on communities or on individuasl. There are important environmental dimensions, but they are not to be regarded as placing an effective veto on addressing the problems of supply".[40] It is also vital that issues of increasing housing supply, important though they are, should not place an effective veto on addressing the environmental problems potentially associated with a major increase in house building.

47. ODPM seems to have taken the approach to sustainability and the SCP that by simply calling it "sustainable" and mentioning the environment occasionally, usually within the context of local environment or the need to minimise the use of resources, the Plan is inherently and obviously fully compatible with the principles of sustainable development. This is clearly not the case. As Jonathan Porritt told us during our recent inquiry into the Sustainable Development Strategy, "the aspiration to be less unsustainable is not the same thing as being sustainable". This is not something ODPM appears to have grasped. This is reflected in Ministers' comments to us during evidence sessions. We were told that it was not possible to pin down sustainable development in the Plan because it was "too high level";[41] we were given no explanation of what the ODPM sees as the differences between sustainable growth, an economic concept, and sustainable development, an environmental concept;[42] it was also implied that to ensure sustainable development the most important issue is not to have growth without infrastructure whilst at the same time we were told that sustainable development and growth are not compatible.[43]

48. For the Sustainable Communities Plan to be worthy of its name it would have to have as its central aim the creation of communities that are fully compatible with all the principles of sustainable development. Under the Government's definition of the term this would mean that effective protection of the environment and prudent use of natural resources would be as important as social progress and the maintenance of economic growth and employment. Indeed we would argue that without the first two aims being met it would be impossible to sustain either economic growth or social progress. The Government needs to recognise that a good environment is as vital to national prosperity as a sound economy or a cohesive society.

49. The feeling running through our evidence sessions was that whilst some of the language in the SCP could be interpreted as giving some weight to environmental concerns, this was not something that was necessarily translating itself into practice. For example, the World Wide Fund for Nature (WWF) told us that there is a top line of rhetoric that runs through the SCP with which it would be hard to disagree, but there has been very little action to deliver anything to meet that rhetoric.[44] Friends of the Earth told us "it [SCP] is a piecemeal approach to a housing crisis and […] it makes political judgments about growth and where it will take place before any effective assessment of environmental limits has been made"[45] and this has led to people taking "'sustainable communities' to mean a very pro-development agenda, particularly in the South East, and that as a result sustainable development has been put on the back foot."[46]The Local Government Association made a distinction between the housing agenda, where they had concerns about the poor quality of new housing and the proposed accelerated build rate, and the new approach to proposed settlements. It is this second part, which is meant to make the SCP more than a basic housing programme, that troubles the LGA most, insofar as other Government departments, the Department for Transport in particular, do not appear as yet to have taken it on board.[47]

50. Whilst there has been some attempt to address environmental issues within the SCP, which represents—even if only at the level of its rhetoric—improvement on how development has been approached in the past, the thinking behind it appears to be only to take the environment into account in ways that do not constrain plans for growth. This is of particular concern because it contradicts the central tenet of sustainable development: that growth should only occur within environmental limits and anything beyond that is unsustainable. We are concerned that the driving force behind the Sustainable Communities Plan is to meet economic and social demands and there is little understanding within ODPM of how the environment interacts with these.

51. The need for all Government departments properly to incorporate sustainability into policy implementation is becoming pressing. The Government Chief Scientist, Sir David King, is warning with increasing urgency about the need to address issues related to climate change. This can only be done if there is an understanding amongst all those in Government departments of the global environmental impacts of decisions made nationally and locally. Policies within the Sustainable Communities Plan aimed at ensuring the quality and sustainability of local environments are a wasted exercise if they are not also explicitly aimed at addressing the wider environmental impacts and consequences of growth.

52. The way the Government has taken forward the recommendations of both the Sustainable Buildings Task Force and the Egan Review of Skills contrasts starkly with how it has dealt with the Barker Review. Responses to the former were published within months, whereas ODPM and other departments intend to spend a year and a half at least deliberating and consulting before responding to Kate Barker's recommendations. It would appear to us that many of the efforts directed towards achieving sustainability within the SCP are little more than a window-dressing exercise. This is unsatisfactory and bound to have severely detrimental consequences in the long term.

Regional Implications

53. The conflict between growth and environmental limits within the SCP is most clearly seen in this focus on development in the South East and in particular within the four Growth Areas. Proposals include the building of 720,000 homes in the South East of England Regional Assembly (SEERA)[48] region by 2026 and 478,000 homes in the East of England Regional Assembly (EERA)[49] region by 2021. According to ODPM figures there were 5.7 million dwellings in the South East and Eastern regions in 2001. Building on the scale proposed would result in an increase of 21% in the number of dwellings in the most densely populated regions of the country.

54. The four Growth Areas were identified in Regional Planning Guidance 9 (RPG9) for the South East which was published in March 2001. Following on from this, various consultant studies were commissioned to identify the level of growth that these areas could accommodate. The findings of these studies concluded that overall an extra 252,000 dwellings, above those already being proposed, could be accommodated in the Growth Areas by 2031.[50] When the SCP was published in February 2003 it included a commitment to build 200,000 dwellings by 2016 in the Growth Areas identified in RPG9, over and above existing targets. It also included an estimate that the areas had potential to accommodate a total of 900,000 new dwellings by 2031.

55. The impacts of focusing the majority of growth in the South East were raised repeatedly in memoranda and in evidence sessions. Friends of the Earth were very critical of the chronology of development in the South East. Speaking for Friends of the Earth, Dr Hugh Ellis told us:

    "We approached the regional issue of over-development in the South East through the SCP before we had ever decided what the environmental limits of the South East were. The DEFRA [Entec] report only arrived two years after that point. So the process of strategic planning for England has been to accept large-scale growth in the South East as a political decision, then to begin to implement that in all sorts of ways, then to commission an economic study from HM Treasury on Barker, which in fact doubled that growth, and then DEFRA came along very belatedly and say that there might be a problem or two with that. Then at the very end we might actually begin to think about how transport infrastructure and various other things, which should have been central to the planning process, might only be delivered years after." [51]

56. The Royal Town Planning Institute told us that it was sure that, if a forum existed where there could be a debate over in which parts of the country growth would be best placed, the likely conclusion would be that some of the proposed housing growth would benefit other areas of the country far more than it would benefit the South East and East.[52] The LGA pointed out that the Government has been criticised for a policy deficit in failing to promote northern cities as competitive locations associated with urban renaissance.[53] Friends of the Earth called for strategic planning that ensured communities in the North have a future and that communities in the South have sustainable development in a way that upholds their quality of life. To achieve this they called for a national spatial framework that is in part redistributive.[54] The question of whether a model of unequal growth as seen in the Sustainable Communities Plan can ever be considered properly sustainable needs to be urgently addressed by the Government, as it is not clear to us that in its desire to encourage a national economy led by growth in the South East it has addressed this issue at all.

57. Sir John Egan, who was appointed as the Government's adviser on the Thames Gateway in November 2003, told us in evidence that "it is extremely important that communities are balanced and that everyone who needs to work in that community can get a house in that community and can afford to do so". However, he went on to tell us that the principal driver for housing in the South East was not the need for expansion or better housing for existing communities, but rather the desire to accommodate newcomers drawn to the area, for economic reasons, as a result of London's position as a world-class city. He told us that "these [newcomers] are people with world-class skills that are needed in things like the financial services industry. They are coming because they think they can earn far more money here than they can earn anywhere else in the world".[55] He went on to say that "we have an urgent need to find housing of high quality for some of the best people in the world who want to come here".[56] In response to the question of whether the emphasis on the Thames Gateway and the South East would exacerbate the general economic division between north and south he told us he did not believe this was the case and that people from the north of the country "will want to come because of the wealth and prosperity of the South East"[57] Sir John Egan was of the view that it will be very difficult, and probably detrimental to the economy, to focus too much effort on developing northern regions when there is such a draw to the South East from all over the country and from the rest of Europe. He implied that these other regions would develop of their own accord if they had the potential. Whilst this argument may make some sense from a purely economic perspective, it has few merits from a social or environmental one. It is alarming to us that a senior Government advisor should express such views: we believe them to be wrong and would like to hear from Government to what extent it supports them.

58. ODPM and HM Treasury must make clear at what stage they will judge the South East region to have reached its growth limits and what options they have considered to assist social and economic development within sensible environmental limits elsewhere in the country.


59. The housing targets for the whole of the South East region include 478,000 houses in the East of England Region. This was approved by EERA for their draft Regional Spatial Strategy in November 2004, though at the time EERA also rejected proposals by the ODPM for an extra 18,000 homes to be added to its targets within the Strategy. Since then, however, EERA has withdrawn its endorsement for the overall targets stating that it "deplores the Government's grossly inadequate funding of transport infrastructure costs associated with the additional 478,000 houses planned for this region". [58] There is also strong opposition within SEERA, which is in the process of consulting on future housing targets. The ODPM had suggested a figure of 720,000 homes to be built by 2026 in the region. SEERA's original intention was to consult on yearly targets of between 28,000 and 36,000 for the region, however following consideration by Assembly members this was reduced to between 25,500 and 32,000.

60. Lord Rooker presented the effect of the rejection of housing targets set by the Government as "miniscule" since the number of houses rejected by EERA is tiny in comparison to the numbers that it had, until recently, accepted within its Regional Spatial Strategy.[59] However should SEERA decide not to increase its annual target following consultation, the shortfall taken with that of the EERA region could over time be in excess of 70,000 homes. This is over a third of ODPM's target of an extra 200,000 homes being built in the Growth Areas by 2016. In our view this is by no means miniscule and raises the question as to whether ODPM would be willing to force through housing numbers on a significant scale should their targets be rejected. Furthermore, should the Government accept the Baker Review's suggestion that up to 120,000 extra homes a year should be built to improve housing supply, it is likely that these are exactly the regions, where there are currently the greatest problems with affordability, which the majority of this increase would be targeted at. Given the difficulties ODPM is having in convincing the regions in the South East to take on current housing targets, it is difficult to see how they would accept any further significant increases in the future unless forced to do so by the Government.

61. The approach to housing advocated by the Government at a local level in its planning guidance of "planning, monitoring and managing" supply does not seem to apply when it comes to housing provision at a regional and national level. The Government has taken the approach of predicting significant levels of demand for housing in the South East Region and planning to meet this demand without any attempt to manage growth or to shift it to other areas. The SCP simply predicts growth in the South East and sets out to provide for it. This predict and provide approach makes no attempt to rebalance housing demand and economic development in the country as a whole. Given the limited ability and willingness of the South East regions to absorb further growth, this reflects a short-term approach from the Government to what is a long-term problem. The undoubted result of the acceptance of such an unequal model of growth can only be to exacerbate regional differences in prosperity, to the detriment of the country as a whole.


62. The South East Region is already an area of the country under environmental stress. According to the Environment Agency, significant areas of the South East are already being supplied water by an unacceptable and unsustainable abstraction regime in both winter and summer months:

The Agency also told us that it estimates that, if the trend continues, quantities of municipal waste produced in the South East could grow by 67% to 2031 (from 4.1 million tonnes/yr to 7 million tonnes/yr). The anticipated new homes would generate an estimated further 1.7 million tonnes of municipal waste per year.[61]

63. The ODPM Select Committee inquiry into the SCP identified in April 2003 the problems of water availability and infrastructure provision for the South East, particularly in the Growth Areas, calling for impacts on water supply to be assessed, and expressing dismay that water companies were not involved in any discussion about proposed housing targets for the South East. The Select Committee's report also called for an independent comprehensive review of the environmental impacts of the proposed housing in the Growth Areas.[62] It is astounding that despite the clear need for an assessment of the environmental impacts of the proposals for the Growth Areas as a whole, nothing has been done to date by ODPM or DEFRA to address this issue.

64. The East of England Regional Assembly published the Strategic Environmental Assessment of its Regional Spatial Strategy in November 2004. This found that there were serious environmental impacts associated with the proposed growth plans in their region:

    "The rate and intensity of economic, housing and infrastructure growth envisaged for the region, especially its southern parts, is intrinsically damaging to many aspects of the environment and quality of life. Particularly serious problems include water resources, flood risks, quantity of movement to be accommodated, urbanisation and conflicts and competition for land (both inside and outside settlements) between development and public interests."[63]

65. In September 2004 the Southern Region Environment Agency office (which covers most of the South East of England Region) published a press release to accompany the publication of the State of the Environment 2004 report, with the heading "The development of 800,000 new homes in the South East could set off an environmental time-bomb".[64] The Regional Director for the Thames Region, was quoted as saying:

    "This State of the Environment report shows the fragility of our environment - in some parts of the region we are reaching our environmental limits. Unless the environment is built into plans for development now we will seriously threaten the quality of life in the South East."[65]

On being questioned about this Mr Morley told us "it was a regional office. It was not the Environmental Agency centrally that said that".[66] He went on to say that the Agency's views were based only upon what it perceived as a lack of forward planning. The Agency told us in its supplementary memorandum that development on the proposed scale would result in environmental pressures in the region if environmental issues are not considered as early as possible in the planning process. It stressed that it had not stated the view that environmental limits are close to being reached which appears flatly to contradict the opinion expressed in the press release. [67] It is not satisfactory that there seems to be a degree of confusion within the Environment Agency as to the environmental impacts of further large scale development in the South of England. Ministers should take steps to ensure that any remaining concerns within the Environment Agency are fully explored; and the Agency itself clearly has a responsibility to make sure that it is offering frank and consistent advice.


66. The Thames Gateway Growth Area runs along both sides of the Thames River from the London Docklands to Southend and Sheerness. It was identified as an area where there was potential for growth in both housing and jobs, and that was in need of regeneration, as far back as 1990. There is significant development already underway in many parts of the Gateway, including the construction of 11,000 homes at Barking Reach in Dagenham. The Gateway suffers from a high level of social exclusion and low level of employment, with only 500,000 local jobs and 1.5 million residents.[68] As a result of this the proposals for the Gateway differ from those for the rest of the Growth Areas, in as much as there is a need to create jobs as well as build new homes if the ODPM's aim of creating sustainable communities is to be met. The Sustainable Communities Plan envisages building 40,000 homes in addition to those already planned in RPG, bringing the total of new homes to 120,000 by 2016 and states that there is potential for creating at least 200,000 jobs in the area. The ODPM has so far committed £546 million funding for infrastructure projects in the area.

67. The Thames Gateway is the Growth Area where plans for development are at their most advanced. It is therefore of real concern to hear the LGA tell us in evidence that with regard to the SCP plans for the Thames Gateway "there is a very real danger that the current strategy in the Communities Plan, which started off with the Treasury model of envisaging about 50,000 or 60,000 new homes would produce exactly the kinds of problems […] talked about before: poor infrastructure, low community facilities, relatively low density, high environmental impact or low environmental sustainability" and went on to suggest a different approach "if we take a longer term strategy to developing the Thames Gatewayperhaps up to 2030at higher density with infrastructure development up front something like 120,000 to 150,000 new homes could be created with much higher environmental standardsaiming for standards like carbon neutral and so on, a much higher quality design and the way to do that is to build out now from town centres with the existing infrastructure [...] and to take a more measured view about what can be delivered over the next fifteen or twenty years."[69]

68. The SCP has been put forward by the Government as a way of meeting changing demographics largely due to the expected increase in single person households. It was with surprise therefore that we heard from Sir John Egan, the Prime Minister's adviser on the Thames Gateway, that this is not in reality the principal reason behind the plan. He referred, as previously mentioned, to an expected influx of 1 million people by 2010, from all over Europe, attracted by the prosperity in the South East. He also told us that the purpose of development in the Thames Gateway, in particular, is to provide high quality housing for the most highly skilled people, who are attracted to London as one of the most successful cities in the world. He was adamant that the purpose of development in the Gateway and the rest of the South East should be to allow anyone to live in any part of the region and commute into any part of London.[70] This approach to development in the Region is not only contrary to many of the key requirements for sustainable communities set out in the SCP, but would have significant environmental implications.

69. We also heard from Sir John that vital infrastructure projects in the Thames Gateway are already suffering from delays. He expressed concerns regarding delays in determining how rail infrastructure will be provided for the area, pointing out that it is important to get transport systems established in order to know which communities can be developed.[71] When questioned as to how the Government intends to deal with the problems of rail infrastructure which is antiquated, already running to capacity and with little physical space for expansion, in order to bring people to work into London from the Thames Gateway he was unable to answer, other than referring to the Crossrail proposal (which has yet to be properly approved and will not be in place for at least another eight years). Despite this thousands of homes are already being built in the Thames Gateway, with a total of 120,000 planned.

70. Development as proposed in the Thames Gateway will result in a long commuter corridor, where most residents will travel to London to work, unless every effort is made to create jobs in the area, provide local infrastructure and ensure a significant proportion of new housing is affordable. Lord Rooker in evidence to us acknowledged that this would be an undesirable outcome. And yet the reduction in commuting times to central London that are proposed are likely to result in increased house prices and will have little benefit for local communities, unless equal effort is made to develop infrastructure and jobs at a local level.

71. Also of concern to us is the scale of development that will take place in the Thames floodplain as a result of the growth in the Thames Gateway. The ODPM has recognised this and emphasised the need for developments to meet the requirements of existing planning guidance on flooding. Despite this commitment the Environment Agency has raised concerns with us about the level of development that will be at high risk of flooding in the South East as a result of the SCP. It told us that of the 2,811 planning applications to which it objected in 2003 and for which it knows the outcome, 323 were permitted by local planning authorities against the Agency's advice. Of these at least 21 were major developments.[72] The Association of British Insurers was also concerned about the impact of flooding on any future development in the South East. It drew attention to the Environment Agency's estimates that development in the Thames Gateway will cost at least an extra £4000-£7000 per property to pay for the additional flood defences required.[73]

72. Despite there being strong planning guidance against developments on land where there is a high risk of flooding, local authorities are still allowing significant numbers of such developments to go ahead. The proposals for growth, particularly in the Thames Gateway, are likely to result in a dramatic increase in the number of properties being flooded unless the Environment Agency's advice is heeded. We support ODPM's proposal that the Agency should become a statutory consultee for applications in areas notified as at risk of flooding or likely to add to flood risk. In the meantime, local authorities should be strongly encouraged to notify the Agency of the outcome of applications to which it had objected on the grounds of flood risk.

Infrastructure provision

73. Regardless of how and where new homes are built it will be impossible to consider any development sustainable unless the accompanying infrastructure is developed to ensure that existing communities grow, and new ones are created, in a way that minimises impacts on the environment. ODPM told us in its memorandum that it has committed £2.7 billion to transport schemes within the Growth Areas. It has also recently announced a further £100 million funding for infrastructure projects in the Thames Gateway, on top of the £446 million announced when the SCP was launched. Furthermore, the Department for Transport has recently set up a Community Infrastructure Fund (CIF), as recommended by the Barker Review, which will consist of a capital grant allocation of £200m to be made available as £50m in 2006/07 and £150m in 2007/08. Of this sum, £34m has already been earmarked for two schemes within the Thames Gateway growth area.[74] This funding will only be available in Growth Areas, something that was not specified by the Review

74. This is, of course, a step in the right direction. However it is not anywhere near enough to meet the infrastructure needs of all the housing that is envisaged in the SCP. A report published in November 2004 by consultants Roger Tym & Partners,[75] assessing the public costs of all the infrastructure and affordable housing required by the housing growth proposed in the South East Plan and the East of England Plan over the next 20 years, found there were significant costs associated with the proposed housing targets. The report found that there would be a need for between £2 to £2.5 billion public sector funding a year in the region, adding up to between £40 to £50 billion over the next twenty years, to meet the required infrastructure demands. The sheer scale of investment need is also illustrated by the East of England Regional Assembly's bid for £1.5 billion of investment needed to support the growth proposed in its region, and the subsequent withdrawal of its support for housing targets in its region as a result of what it sees as lack of adequate funding for transport infrastructure by the Government.[76] Kent County Council published a business plan for its area entitled What Price Growth? that set infrastructure costs for development envisaged by the SCP in its area alone at £1.65 billion..

75. CIF funding of £200m should be seen in the above context. In addition, the fact that the CIF funds are only available in the Growth Areas raises the question of whether other parts of the country may suffer as a result of lost funding. There is disturbing evidence that the sum so far allocated for infrastructure funding will not be anything like sufficient to meet the requirement generated by the Growth Areas. The Government should revisit this issue as a matter of urgency and make clear exactly what level of public funding for infrastructure it intends to make available in the Growth Areas over the next twenty years, and assure us and the public that this will not result in other parts of the country suffering a lack of resources as a result.

76. In building new homes there is a real need to ensure infrastructure provisions are provided in a timely way from the very beginning. Local infrastructure and sustainable transport provisions are vital from an early stage in order to ensure that car use is minimised. Badly planned, poorly funded infrastructure, particularly for transport and local amenities, would be completely contrary to the general principles contained in the SCP. Lord Rooker's statement that there would be no growth without infrastructure was welcome. However, if this is so then the Government needs to make clear how it intends to ensure timely development of infrastructure to keep pace with housing construction. This does not yet appear to be happening.

Environmental Appraisal of the Sustainable Communities Plan

77. When considering the environment within the context of sustainable development it is not enough to ensure that impacts are reduced and mitigated at a local level. The Countryside Agency, in evidence before us, was very supportive of ODPM's plans for including green areas and park within the development of the Growth Areas.[77] This, if done carefully, could have significant benefits for biodiversity and flood protection at a local level. However, whilst we welcome the efforts that are being made towards greening the Thames Gateway, for example, this is simply not enough. The focus in the Sustainable Communities Plan on improving and protecting the local environment is a positive step; however there is as yet no clear understanding of the impacts of development on the wider environment and this has to be urgently addressed. There is a pressing need for a thorough environmental appraisal of the Sustainable Communities Plan. In the meantime, hundreds of thousands of homes for which there appears to be no agreed associated infrastructure provision are going to be built to the minimal environmental standards contained in the Building Regulations with no assessment of the associated environmental impacts.

78. European Directive 2001/42/EC "on the assessment of the effects of certain plans and programmes on the environment", known as the Strategic Environmental Assessment or SEA Directive, came into force in July 2004. The Directive only applies to statutory documents of a national, regional or local nature, such as Regional Spatial Strategies, and therefore is not applicable to the SCP. However, the Directive does raise the question whether environmental appraisals should be carried out on all plans on a national scale, whether statutory or not, as a matter of best practice. The Scottish Executive, for example, has committed itself to carrying out SEAs on all its major national plans, regardless of legal status and including its National Spatial Planning Framework.

79. The SEA that was carried out for EERA on the East of England Plan concluded that it was possible that development as proposed in the plan would be less detrimental to the environment if situated in other parts of the country, though it was not formally within the remit of an SEA carried out on a regional basis to be able to determine this.[78] Lord Rooker argued when before us that the SCP was not sufficiently detailed to be analysed using the method outlined in the SEA Directive. Whilst the particular approach may not be appropriate for assessing the impacts of the SCP, it would still be possible to apply the general principles. That this is feasible is supported by the work carried out by Entec on the proposals of the Barker Review. Entec was able, from the level of detail available, to conduct a scoping study on the impacts of increasing housing numbers and densities, which is just one of the components of the SCP. Likewise, from the detail available it should be possible to carry out an assessment as to whether the selection of the Growth Areas is beneficial from an environmental perspective or whether other parts of the country would benefit more from investment and growth. It should furthermore be possible to assess whether the approach of large-scale demolitions taken in the nine Pathfinders, and indeed the selection of these areas, is the most beneficial for the country as a whole.

80. Of even greater benefit would be the production of a National Spatial Framework, as proposed by the Royal Institute of Town Planners and similar to those already in existence in Wales and Scotland, in which the principles and aims of the SCP would clearly be given a spatial dimension within the context of the whole of England. This would not only make it possible to address inter-regional issues but it would also allow a Strategic Environmental Assessment and Sustainability Appraisal to be carried out on the implications of the Plan for the country as a whole. It is imperative that something as significant as the Sustainable Communities Plan should be assessed for its environmental and other impacts on the country as a whole, not only for its impacts on the areas where growth and investment are planned. With this in mind, the Government should strongly consider a National Spatial Framework similar to those already in place in Scotland and Wales.

The Egan Review of Skills

81. The Egan Review: Skills for Sustainable Communities was published in April 2004. The remit given to Sir John Egan was a narrow one: what skills were required, and by whom, to achieve sustainable communities.[79] However, as he told us in evidence, Sir John's approach was much broader. The Review considered the attributes and qualities which make communities sustainable and how these elements can be measured in terms of success and failure; the processes necessary to deliver success; the professional skills needed for those processes and how they differ from those available now; and the necessary changes to processes and professional skills. The Egan Review made recommendations in each area. The main ones were summarised as follows in a press release:

  • "All key stakeholders should adopt a common goal of creating sustainable communities.
  • Local authorities should have the lead responsibility for working in partnership with others to deliver the common goal. They should encapsulate the vision for their area in a Sustainable Communities Strategy.
  • Further changes to planning processes are needed, especially the adoption of a pre-planning application process.
  • All occupations involved in delivering sustainable communities should possess generic skills, to different degrees and different levels depending on their roles.
  • A new National Centre for Sustainable Communities Skills should be established to work with others in developing world class generic skills, to contribute to research and national and international debate on sustainable communities, identify skills gaps, review formal education available for core occupations, and encourage more entrants into these professions"[80]

    82. The report included its own definition of what sustainable communities were, with the aim of creating a goal to work towards, and set out seven vital components all of which need to be addressed to ensure sustainable communities (social and cultural; governance; environmental; housing and the built environment; transport and connectivity; economy; and services). We welcome the Egan Review's work, which despite the fact that it was not part of the original brief, makes some progress towards a definition of what a sustainable community might be and which gives greater prominence to the environment than anything as yet put forward by the Government.

    83. The Egan Review found that there were in total over a hundred occupations relevant to sustainable communities. Some occupations, mainly those professionals working in the built environment (such as planners, architects and engineers), officials from all levels of Government and voluntary and community organisations, are at the heart of delivering sustainable communities, but there are also many more associated occupations, such as police officers and teachers, that are also involved in delivering sustainable communities.[81] The Evidence Based Review of Skills carried out by Ernst & Young to support the work of the Review found that there were particular shortages emerging in four areas: civil and structural engineers; town planners; transport planners and engineers, and conservation officers. The report also highlighted the fact that approximately half of Chartered Civil Engineers are expected to retire in the next 10 years and numbers applying to study civil engineering at university are falling, down 56% from 1994 to 2002.[82] According to the Construction Industry Training Board, the construction industry as a whole needs a "staggering" 76,000 new entrants a year to meet demand.[83] The Barker Review also found a shortage of skills, reporting that 90% of house building companies are already experiencing a shortage of skills, and concluded that even a modest growth in output would require 70,000 more workers in the house building industry. A more substantial expansion could increase this up to as much as 280,000 people.

    84. Egan's Review concluded that the lack of skills amongst built environment professionals and the people shortages in the four areas mentioned above have the potential to hamper severely the ability of government, local authorities and the housing industry to deliver the SCP. We would like to see the Government set out how it intends to improve the skills base of those professionals already practising and also improve the recruitment to relevant professions. It is imperative that the Government addresses the lack of skills and need for training, identified by both Egan and Barker, in all those professionals involved in delivering sustainable communities and regeneration, including outside agencies and consultancies.

    85. The main recommendation of Egan's Review was the creation of a National Centre for Sustainable Communities "which should be at the forefront of innovative thinking to develop the world class skills to create communities fit for the 21st century". The Government has taken up this recommendation and has set up a task group which is expected to make an announcement by early 2005 as to how the National Centre will be taken forward. Whilst we welcome the creation of the National Centre for Sustainable Communities this will not be enough to address the problems at hand. There is a need for a large-scale training programme for those professionals and officials at all levels already involved in delivering sustainable communities.

    86. If the shortages of skills are not properly addressed as a matter of urgency it is increasingly likely that we will end up with a large number of badly built houses in poorly designed communities with limited transport infrastructure that have severe environmental impacts, rather than the "sustainable communities" that are the Government's stated aim.


    87. In his report Sir John proposed a set of 50 indicators for Sustainable Communities. The Government response to the suggestion that these indicators should be incorporated into Community Strategies by the end of 2005 was anything but enthusiastic: "Indicators can be drawn from the Egan list but we would not want to preclude selection of others if these better reflect local circumstances".[84] In evidence Sir John told us that when using indicators local authorities should not be able to choose them arbitrarily. We agree with the proposition that there should be some core indicators used across the board to begin with, which should evolve to become a complete set of common indicators that local authorities would have to comply with.[85] The reluctance by the Government to establish a set of common indicators to measure sustainable communities is perhaps understandable since it has yet to set out what sustainable communities are. However this does beg the question of how the success of these communities and the SCP will be measured.

    88. As an audit committee we would be very interested to hear from the Government how it intends to measure its success at creating sustainable communities and how it intends to, if at all, compare communities' achievements without the use of a common set of indicators for sustainable communities.

    Planning and Sustainability

    89. The Government is currently in the process of revising general planning guidance as contained in Planning Policy Guidance Note 1: Policy and Principles (PPG1). This is within the context of a revision of all planning advice with the aim of separating guidance on practical implementation from policy statements. With this in mind it published a draft of the new Planning Policy Statement 1 (PPS1): Creating Sustainable Communities in February 2004. This makes clear that planning authorities will need to take an approach based on integrating the four sustainable development aims. It also sets out the three themes which should underpin the policies and principles of the planning system:

    90. The aim, stated within PPS1, is for a planning system that creates both sustainable communities and delivers sustainable development. However the Government has as yet failed to make clear the relationship between these two concepts. We are surprised to see the proposed PPS1 title "Creating Sustainable Communities", given that there is as yet no clear understanding of what sustainable communities are. The final version PPS1 should make very clear how sustainable communities and sustainable development relate to each other and not treat them as interchangeable concepts.

    91. From the contents of the consultation document on PPS1 it appears that, yet again, it is the Government's view that economic imperatives are the driving force within sustainable development. The draft PPS1, in its second paragraph, states that "planning has a critical role in delivering the Government's wider macroeconmic, social and environmental objectives" and then goes on to give two examples of these: the pressing need to achieve balanced housing markets and sustainable improvements in the economic performance of all English regions. Nowhere in the draft Planning Policy Statement 1 is recognised the need to ensure development occurs within environmental limits, or the need to adopt a precautionary principal with regard to what those environmental limits might be. This is a serious failing and should be rectified by ODPM.

    92. In view of the aims stated in the draft PPS1 and the inclusion in the Planning and Compulsory Purchase Act 2004 of a clause which states that those with planning responsibilities "must exercise their function with the objective of contributing to the achievement of sustainable development", and must do this whilst having regard for national policy and guidance, we would expect that planners will shortly be able to integrate all aspects of sustainable development into their work. This would mean having the powers to impose conditions on developers that would limit environmental impacts and to refuse planning permission on the grounds of proposals not being sustainable.

    93. However, it is unclear yet what weight will be given to the environment in practice within PPS1 as the Government has still to publish any guidance to accompany the proposed policy document. Mr Morley told us in evidence that "there will be stronger guidance issued to local authorities about the whole issue of sustainable development which has not featured in planning criteria very much so far".[86] Keith Hill MP, Minister for Housing and Planning, ODPM, told us that he would expect materials and quality of design with relation to sustainable development to be material considerations that should be taken into account.[87] The LGA told us that it was generally accepted that planning permission could be denied on physical grounds, such as the lack of appropriate infrastructure, but issues such as energy, waste or materials use are not material planning considerations, and it is not clear that PPS1 would change this.[88]

    94. It is imperative that the final version of PPS1 adopted by ODPM, together with the promised guidance on its implementation, makes clear that minimal environmental standards of new houses, and all other buildings, together with their wider environmental impacts, should become material considerations for planning decisions.


    95. Concerns have also been expressed to us that to meet the housing targets, as set out in both the SCP and the Barker Review, there will be a need dramatically to increase the development of both greenfield and Green Belt land. Organisations such as the Campaign to Protect Rural England (CPRE) and the LGA have made clear their anxieties about the implications for land use of building on such a scale. In response to claims that the South East is in danger of being concreted over, the Barker Review included an estimate that implementing the proposal to build 120,000 homes a year for the next 10 years would result in 0.75% of the undeveloped land in the South East of England being built on in the "highly unrealistic, and indeed undesirable, scenario that all additional development occurs in the South East.[89]" This was estimated to be equivalent to 10% of Buckinghamshire or 18,700 hectares.[90]

    96. Using the same assumptions as the Review, the need to provide the 180,000 homes a year already proposed under the SCP will result in a requirement for 28,050 hectares of undeveloped land. The total of 46,750 hectares is the equivalent of 25% of Buckinghamshire or 1.9% of the South East of England. These figures are broadly in line with those used by Entec in its report on the environmental impacts of increasing housing supply. Whilst we would accept that not all of this development would take place in the South East it is undoubtedly the case that the majority of house building in England over the next ten years is planned within the Growth Areas and therefore has significant implications for land use in these areas. Indeed, one of the conclusions of the Entec report was that the greatest burden of environmental impacts of increasing housing supply, with relation to land use, would fall on the Southern regions of the UK.[91]

    97. The Government has set a target that 60% of all development should take place on previously developed or brownfield land. Figures published for 2003 show that this has been met, with 66% of development nationally on brownfield land. This is very welcome news and we support this target being kept or even increased, although we acknowledge that there might be some difficulties with raising it. However, this level of development on brownfield land will still not be enough to meet the requirements of housing targets in the South East Region, and therefore there will still be a requirement for undeveloped land if they are to be met.

    98. The Government has encouraged higher density developments in planning guidance, stating that local planning authorities should encourage developments which make more efficient use of land (between 30 and 50 dwellings per hectare) and should also seek greater intensity of development at places with good public transport accessibility.[92] According to ODPM figures for years up to 2001, densities were generally much lower than this, particularly in the South East:

      "In 2001 the overall density of residential development in England was 25 dwellings per hectare. This has remained unchanged since 1996. Over the period 1997 to 2001, more than half of the land used for housing was built at densities of less than 20 dwellings per hectare and over three-quarters at less than 30 dwellings per hectare. In the South East, an area of high demand for housing where pressures for land are acute, the average for 1997 to 2001 was 23 dwellings per hectare."[93]

    Since then there has been a gradual increase in density with an average national housing density figure of 30 dwellings per hectare in 2003.[94] However, this is still the lower end of the Governments stated target and will need to increase further given the pressure to increase the numbers of dwellings being built. In order to limit the amount of undeveloped land being built on to meet housing targets, ODPM should use every effort to maximise both development on brownfield sites and housing densities.

    Green Belt Land

    99. The policy to date for designating land surrounding large urban areas as Green Belt, where there is a presumption against any kind of development, has been very successful in controlling the spread of development and preventing urban sprawl in the areas surrounding England's towns and cities. Although the overall amount of land designated as Green Belt has increased since the Government came to power, the situation is not the same across the whole of the country.[95]

    100. There have been growing calls for a change in approach as to how Green Belt land is used. The Countryside Agency told us that increased house building is likely to result in the need for development on greenfield sites in some areas and it accepts "that this might involve minor revisions to Green Belt land boundaries where this would result in the most sustainable option for the development in a particular location".[96] It also argued for an intermingling of urban and rural areas using more convoluted boundaries and the development of the urban-rural fringe in a way that strengthens the links between both.[97] Organisations such as the Countryside Landlords Association and the Town and Country Planning Association have called for a more imaginative use of Green Belt land that takes full advantage of its potential for rural communities, and improves sustainability.[98] Whilst there may be some advantages to exploring these options we would be strongly opposed to any changes that could affect the presumption against inappropriate development on Green Belt land. We are also concerned at any approach that would soften the boundaries between urban and rural land in a way that resulted in a slow encroachment of development into previously rural areas.

    101. It is vital that the increased pressure for development in the South East of the country does not lead to a gradual erosion of Green Belt land. Neither would it be acceptable for the Green Belt boundaries to be moved increasingly further out to compensate for urban encroachment.

    The Role of DEFRA

    102. The formal role of DEFRA in the provision of housing is limited. It is mainly involved with the supply of affordable housing in rural areas. Its memorandum to us sets out the areas in which it is contributing to the SCP: it is extensively involved in flood defence provision in areas such as the Thames Gateway through the Environment Agency, and also in work on green spaces and biodiversity through the Countryside Agency. It is also involved to some extent in work to determine how water and sewerage services will be provided in the Growth Areas. The memorandum also sets out DEFRA's aims when it comes to fulfilling the need for extra housing, namely:

    103. When challenged during evidence as to exactly how sustainable "sustainable as possible" was, Mr Morley acknowledged that "if we are building huge numbers of houses, we have a duty to ensure that they are sustainable. They cannot be only a bit sustainable". However, he also emphasised the fact that one of the key tensions in housing was in relation to costs, and that there was nervousness about the kind of standards that should apply to buildings because of the impacts they would have on the price of homes. He told us that he did not accept this as a major problem himself and agreed with us that it was possible to build a sustainable house at very little extra cost and recover this during the lifetime of the dwelling.[99] DEFRA's stated aim of ensuring that new communities are as sustainable as possible, given concerns about costs, highlights a certain lack of ambition within the Department. In our view, if the Government is serious about meeting its targets for reducing carbon emissions, the only feasible approach to housing in the long-term is the implementation of a zero carbon emissions policy for all new buildings.[100] DEFRA should see it as its role to take such a long term, but fundamental, aim forward and champion it within Government and the SCP. And yet when questioned about this Elliot Morley told us "It would be nice to build all zero carbon homes" but that this was not the intention.[101] We recognise that encouraging other departments to take on board the need for sustainable development to be incorporated into policies and practice is undoubtedly an uphill struggle, but this is very disappointing. The Secretary of State for DEFRA, The Rt Hon Mrs Margaret Beckett MP, has a duty to ensure that sustainable development, which is a vital component of the Department's responsibilities, is properly considered across Government. As a Committee we strongly support Mr Morley's efforts to champion sustainable development within Government and we regret that in the case of housing the Department seems to have been sidelined.

    104. It emerged during the course of our inquiry that ODPM and HM Treasury did not consult DEFRA on the terms of reference of the Barker Review. Despite this, the remit of the Review did include reference to sustainable development, asking Barker to consider the interactions between housing supply, and factors affecting this, and the Government's sustainable development objectives. This would be welcome were it not for the fact that, as already highlighted, there appears to be little understanding within ODPM of sustainable development. The fact that these issues were not properly taken into account is exemplified by the conclusions of Barker Review's interim report:

      "UK economic well-being could be improved by increasing the supply of housing. Set against this, consideration needs to be given to the associated environmental costs. This gives rise to difficult choices, and the Government needs to weigh carefully its different policy objectives to determine its overall approach to housing. Making a real difference to housing supply may require a robust set of policies".[102]

    The Review only briefly mentions environmental issues in either report, leaving them on one side as an area for Government policy. In our view this is a reflection of the fact that despite sustainability being included in Barker's remit little emphasis seems to have been placed on it by departments. Mr Morley acknowledged to us in evidence that the Review did not address environmental and sustainability challenges in detail and that this was disappointing.[103] We would hope that had DEFRA been given a role in commissioning and setting the terms of reference for this report the result would have been greater awareness by Kate Barker of the need to address these issues. We also found that DEFRA is not involved in the taskforce set up by ODPM and HM Treasury for taking Barker's proposals forward. We regard this as a serious omission.

    105. DEFRA is the department with responsibility for taking forward the Government's policies on sustainable development. We therefore find it highly unsatisfactory that when embarking on the Sustainable Communities Plan and the Barker Review - both of which clearly have major implications for the ability to meet sustainability targets - the Government did not feel it necessary to give DEFRA a more prominent role.

    106. The problems that have resulted from the separation of departmental responsibilities for land use and the environment, following the break up of DETR, are exemplified by the lack of any serious consideration that has been given to potential environmental impacts of development, as proposed in the SCP and the Barker Review. A further concern is the prominence given by the ODPM to sustainable communities—on a par with sustainable development—within PPS1, which further highlights the lack of weight currently being given to environmental considerations within planning and land use policy. Environmental considerations and sustainable development are central to land use and planning policy and it is inexplicable that responsibility for these areas was separated into different departments. It is a matter of urgency that they are once again integrated into a single Government department at the earliest opportunity.

    33   ODPM Press Release 03/15, 'Redressing the balance - Prescott sets out action plan for sustainable communities', 5 February 2003 Back

    34   ODPM, Sustainable Communities:: building for the future, February 2003 Back

    35   ibid Back

    36   Ev68 Back

    37   ibid Back

    38   ODPM, Government Response to the Egan Review - Skills for Sustainable Communities, 20 August 2004 Back

    39   EAC, Thirteenth Report of 2003-04, The Sustainable Development Strategy: Illusion or Reality? HC 624-1.Paragraph 34 Back

    40   Ev69 Back

    41   Q 748 Back

    42   Q770 Back

    43   Q 745 Back

    44   Q 31 Back

    45   Q 20 Back

    46   Q 21 Back

    47   Q 98 Back

    48   SEERA incorporates the following counties: Kent, East Sussex, West Sussex, Surrey, Hampshire, Berkshire, Oxfordshire, Buckinghamshire and Milton Keynes Back

    49   EERA incorporates the following counties: Bedfordshire, Cambridgeshire, Essex, Hertfordshire, Norfolk, and Suffolk Back

    50   ODPM: Housing, Planning, Local Government and Regions Committee; Eighth Report of Session 2002-03, Planning for Sustainable Housing and Communities: Sustainable Communities in the South East,HC77-I Back

    51   Q 14 Back

    52   Q 564 Back

    53   Ev43 Back

    54   Q 3 Back

    55   Q 603 Back

    56   ibid Back

    57   QQ 690-691 Back

    58   EERA Press Release, 'East of England Regional Assembly suspends its endorsement of the East of England Plan due to Lack of Central Government Funding', 10 December 2004 Back

    59   Q 846 Back

    60   Environment Agency, Water resources for the future: A strategy for England and Wales, March 2001 Back

    61   Ev281 Back

    62   ODPM: Housing, Planning, Local Government and Regions Committee; Eighth Report of Session 2002-03, Planning for Sustainable Housing and Communities: Sustainable Communities in the South East,HC77-I. Back

    63   EERA, East of England Plan: Sustainability Appraisal Report, October 2004 Back

    64   Environment Agency Press Release 142/2004, 'Environment At Stake Unless At Heart Of Development Says Environment Agency', 15 September 2004 Back

    65   ibid Back

    66   Q 756 Back

    67   Ev318 Back

    68   SEERA, Growth and regeneration in the Thames Gateway: Interregional Planning Statement by the Thames Gateway Regional Planning Bodies, October 2004 Back

    69   Q 95 Back

    70   Q 606 Back

    71   Q 602 Back

    72   Ev284 Back

    73   Ev256 Back

    74   DfT , Community Infrastructure Fund - Guidance Paper, 19 November 2004 Back

    75   Roger Tym & Partners were appointed by the South East Counties (the counties in the South East Region plus Bedfordshire, Essex and Hertfordshire) to carry out the work. Back

    76   EERA Press Release, ' Regional Assembly approves East of England Plan',5 November 2004 Back

    77   Q513-14 Back

    78   EERA, East of England Plan: Sustainability Appraisal Report, October 2004 Back

    79   Q 593 Back

    80   ODPM Press Release 04/96, 'Delivering skills for sustainable communities- Egan Skills Review', 19 April 2004 Back

    81   ODPM, The Egan Review of Skills for Sustainable Communities, April 2004 Back

    82   ODPM, Evidence Base Review of Skills for Sustainable Communities, Research Summary No 2, 2004 Back

    83   CITB Website,, 15 December 2004 Back

    84   ODPM, Government Response to the Egan Review - Skills for Sustainable Communities, 20 August 2004 Back

    85   Q 630 Back

    86   Q 415 Back

    87   Q 243 Back

    88   Q 116 Back

    89   Q 474 Back

    90   Kate Barker explained in her evidence to us how this figure had been arrived at.The figure assumed that 60% of development would be on brownfield land and building densities of 30 dwellings per hectare. It included an allowance for related infrastructure, and was estimated to be equivalent to 10% of Buckinghamshire or 18,700 hectares Back

    91   Entec, Study of the Environmental Impacts of Increasing the Housing Supply of the UK, April 2004, p48 Back

    92   ODPM, Planning Policy Guidance 3 (PPG3): Housing, 2000 Back

    93   ODPM Circular 01/02, The Town and Country Planning (Residential Density) (London and South East England) Direction, 2002 Back

    94   CPRE, PPG3-What progress 3 years on?, June 2004 Back

    95   According to Government figures in 2003, designated Green Belt land amounted to 1,671,600 hectares, about 13 per cent of the land area of England. Between 1997 and 2003, the area of English Green Belt has increased from 1,652,300 hectares to 1,671,600 hectares, a net increase of 19,300 hectares Back

    96   Ev139 Back

    97   Q 506 Back

    98   ibid Back

    99   QQ 363-4 Back

    100   Buildings that do not produce carbon emissions as a result of energy use during their occupation Back

    101   Q 395 Back

    102   Barker Review of Housing Supply: Delivering Stability: Securing our future housing needs, Final Report, March 2004, p130 Back

    103   QQ 373-4 Back

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