APPENDIX 9
Memorandum from Legal & General Assurance
Society Limited
INTRODUCTION
1. DTZ Pieda Consulting submit on behalf
of Legal & General Assurance Society Limited (L&G), these
representations on the recent briefing paper prepared by the Environmental
Audit Committee, which aims to review the Barker Final report
entitled "Review of Housing Supply" and dated March
2004.
2. The Barker report recommends an additional
120,000 houses to be built on an annual basis throughout the UK
over and above commitments identified within the growth areas
of Thames Gateway, Milton Keynes and South Midlands, Ashford and
London/Stansted/Cambridge. These areas are the subject of local
studies, feeding into the review of regional planning guidance.
3. We understand the purpose of the Environmental
Audit Committee's review is to consider the environmental implications
of this anticipated level of housing growth, in order to ensure
that new strategic development is provided in a sustainable manner
and meets the Government's current sustainability agenda.
4. L&G own a mixed land portfolio comprising
strategic landholdings in the form of previously developed land
(PDL) and greenfield sites located at strategic locations on the
periphery or outside existing urban areas. Some of these landholdings
are located within the recognised growth areas identified within
ODPM's Sustainable Communities Plan. The corporate approach to
the future development of these strategic sites is through L&G's
commitment to a sustainable policy agenda, which promotes the
implementation of higher environmental and design standards, throughout
the planning and development processes. As strategic landowners
within the identified growth areas of the Government's current
housing plans, L&G take this opportunity to provide comment
on anticipated housing growth and suggested ways to mitigate potential
environmental impacts within these strategic locations.
SUSTAINABLE DEVELOPMENT
(CONSULTATION QUESTIONS
1, 2 AND 3)
5. We are of the view that the Barker report
reflects the general principles of sustainable development within
identified growth options of the south east and in accordance
with ODPM's Sustainable Communities Plan. Appropriate locations
within these identified growth options are currently being tested
through local studies in order to ensure that the anticipated
level of housing growth will be planned in a sustainable manner
and result in a minimal distributional impact, whilst achieving
sustainable development through the implementation of high environmental,
planning and design standards.
6. We are of the view that housing growth
by development of sustainable urban extensions to existing urban
areas together with the development of PDL, within or outside
urban areas (for example; major developed sites identified within
the Green Belt), offer a deliverable and sustainable development
pattern. Such development allows for proper integration between
new development of a critical mass and new and planned infrastructure.
Strategic developments at these locations provide the opportunity
for effective social and physical regeneration by virtue of their
critical mass potential and investment opportunity towards the
wider social, economic and environmental benefits, and new and
improved infrastructure to the local area.
7. We support the Barker report's recognition
(at paragraphs 3.16-3.20) that there exists clear development
constraints in bringing land forward for sustainable development
with a particular regard to abnormal costs for redevelopment,
landowners behavioural patterns and market variations together
with viability considerations and planning and environmental constraints.
We are of the view that the Government and Authorities should
be promoting some degree of flexibility to the application of
regulatory planning controls (ie release of less sensitive and
sustainable Green Belt locations for new development) where strategic
sites offer the development potential to bring forward sustainable,
mixed-use development, and in turn social and physical investment
opportunities, to the wider area.
8. Mixed-use sustainable development, which
is carefully phased over a period of time, can mitigate environmental
and social impacts through provision of community uses, infrastructure
provision and a range of remediation and mitigation measures.
These could include financial contributions through section 106
agreements, urban fringe land management plans, integrated public
transport systems and integration with existing urban areas. The
inclusion of affordable housing, social and community provision
and environmental improvements would also feature.
9. A sustainable economy is often critical
to meeting regeneration objectives and urban renaissance agendas.
A mix of greenfield strategic employment sites, integrated with
existing and proposed housing, can stimulate secondary employment
generation and reverse social deprivation. This approach provides
a range of jobs and housing options that help to foster socially
sustainable communities by creating a ladder of opportunity.
10. It is particularly important to recognise
the value of residential, mixed-use development within sustainable
locations, which can properly deliver the affordable housing provision
in order to meet a critical need in the southeast. As part of
this requirement, key worker accommodation and low cost housing
is an ever critical requirement to bridge the affordability gap
in the market sector, and within particular localities.
LOCATION OF
NEW SUSTAINABLE
DEVELOPMENT (CONSULTATION
QUESTION 4)
11. We generally support the Barker report
in its approach to the consideration of strategic sites, which
are appropriate for sustainable development through the application
of the sequential test, promoted within PPG3.
12. The report highlights the locational
criteria relating to the prioritisation of PDL and urban extension
areas for sustainable development, where there is a recognised
requirement to develop outside urban areas. The report importantly
also acknowledges market related criteria. These criteria relate
to site availability and the bringing forward of land for development
within a reasonable period of time (ie to take into account complexity
of land assembly and benefits of single ownership); suitability
of development proposed, and viability in reviewing market variations,
which in turn provides an indication as to whether public investment
intervention is required to bring forward development (ie public
and private partnerships, joint ventures or specific investment
vehicles to drive forward the first phases of development).
13. Such development should be provided
in accordance with delivering high standards of planning and urban
design coding, together with carefully managed new infrastructure
to serve new development.
14. We believe that carefully planned, sustainable
development can mitigate environmental impacts. With specific
regard to potential flood risk, appropriate mitigation measures
can often be identified within a wider flood alleviation scheme
to avoid damaging the water environment or property. Flooding
measures such as sustainable drainage systems can mitigate flood
risk and improve water quality by forming an integral part of
the design and overall masterplan.
ENVIRONMENTAL AND
DESIGN STANDARDS
(CONSULTATION QUESTIONS
5, 6 AND 7)
15. We consider the Government should properly
support, through the planning system, strategic landowners who
are committed to the implementation of higher design and environmental
standards to ensure proper, physical integration of land uses
together with new and improved public transport links, in order
to create vibrant thriving communities.
16. We are of the view that the overall
objectives of the physical masterplan should be developed within
the early stages of the planning process in accordance with the
principles of engagement (and in accordance with current enquiry
by design guidelines), in order to be considered of genuine value.
17. L&G promote this approach in accordance
with their current green policy agenda, which promotes high quality,
sustainable development through the masterplanning of a number
of their strategic landholdings in the region. Through the strategic
masterplanning processes, there is clear promotion of high quality,
mixed-use development through design coding and the implementation
of wider sustainability objectives: for example, the promotion
of Eco Homes "excellent" rating and the overall stewardship
to ensure implementation of the higher standards.
18. English Partnerships' review of their
identified millennium communities (which was undertaken by DTZ
Pieda Consulting) identified the need for local authorities to
relax the "usual Section 106 package", if the high environmental
and design standards were to be achieved and delivered through
the planning system.
19. L&G are generally in support of
the initial standards set out in the millennium communities programme,
which promotes the efficient and effective use of building materials
and resources, to include waste management during the construction
phases. Design innovations in relation to building technology,
energy efficiency and sustainability include reduced embodied
energy consumption and the promotion of recycling materials, grey
water recycling and reduction in on-site waste.Wider initiatives
include those relating to ecology, communications, stewardship,
financial management and partnership arrangements. All these promote
higher standards which we consider promotes sustainable development,
through the construction and development processes.
SUMMARY
20. We therefore support sustainable, mixed-use
development at strategic locations which assist in delivering
the anticipated housing growth critically needed within the South
East, whilst mitigating potential environmental impacts through
planned development and section 106 planning gain. Indeed, through
an inter-disciplinary approach to masterplanning, such strategic
locations can deliver significant gains to the economy, transport,
the environment and urban renaissance agendas.
21. It is also important to recognise that
strategic development of a critical mass can assist in delivering
the new and improved social and physical infrastructure to serve
new communities and the wider area, which if properly planned,
can mitigate any environmental impacts. Such strategic developments
and related investment opportunities also present a chance to
commit to higher standards of design and construction, which will
promote sustainable development, in line with the Government's
current sustainability agenda.
May 2004
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