Select Committee on Environmental Audit Written Evidence


Memorandum from Legal & General Assurance Society Limited


  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.


  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.


  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.


  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.


  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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