APPENDIX 12
Memorandum from the National Housing Federation
1. INTRODUCTION
The National Housing Federation represents 1,400
not for profit independent social housing providers in England.
The Federation's members include housing associations, co-operatives,
trusts and stock transfer organisations who manage more than 1.8
million homes provided for rent, supported housing and low cost
home ownership, and an increasingly diverse range of community
and regeneration services.
The Federation has led the housing association
sector to a new vision in Business for neighbourhoods,
predicated on commitments to neighbourhoods, customers and excellence.
We see this as a progressive change programme to deliver more
effective services and support for sustainable communities. It
is grounded in a vision of mixed neighbourhoods in terms of housing
type and tenure where associations contribute to meeting a range
of needs across age, ethnicity, economic status, household size,
faith, special needs etc.
2. BALANCED HOUSING
MARKETS: CONTRIBUTION
TO SUSTAINABILITY
The case for balanced housing markets
It is widely accepted that balanced housing
markets are essential for the economic and social success of communities,
regions and the UK as a whole. Achieving this balance requires
the government to respond to the problems both of housing shortage
and of over-supply. We would like to see the ODPM establish a
national delivery unit to respond to the "balanced housing
markets" PSA target.
Case for more affordable housing
We welcomed the spotlight that the Barker report
placed on the need to boost housing supply and in particular affordable
housing. Affordable housing has always had a key role to play
in sustainable development. Good quality, affordable housing is
central to any society's aim of improving quality of life; having
a direct impact on employment, social exclusion, education, health,
family life and social relations. Decent homes at a price people
can afford are central to the achievement of social progress and
the maintenance of high and stable levels of economic growth and
employment. The Sustainable Communities Plan also recognised the
wider importance of the quality of the built environment and the
liveability agenda.
The Barker report looks at housing supply from
a macro economic perspective of stabilising house price inflation.
As a result it recommends an increase of 17,000-23,000 affordable
homes each year above current provision, and a doubling of provision
from the private sector to 125,000 to 140,000 homes per year.
We look at supply side issues from the perspective of what is
needed to deliver the long-term objective of sustainable communities
and balanced housing markets in different localities. In our joint
Spending Review 2004 submission with the Local Government Association
and Chartered Institute of Housing we argued for a mixed housing
association programme, towards meeting future housing needs and
the backlog of unmet need, to deliver 60,000 affordable rented,
low cost home ownership and intermediate rented homes a year by
2007-08 building up from a programme of 35,000 homes in 2005-06.
Our analysis is grounded in a belief that a
failure to meet the needs of medium and low income households,
who are priced out of private sector options, will threaten the
achievement of sustainability objectives. More than 10,000 households
are currently living in bed and breakfast accommodation, a further
83,630 are in forms of temporary accommodation, and 1,260,000
are on housing waiting lists. Behind these figures are the immense
costs to individuals and society of people inadequately housed,
or placed in temporary accommodation, in some cases far from friends
and family unable to put down roots.
Rural housing issues
Whilst the shortage of affordable homes in urban
areas is well documented the needs of rural communities also require
supply side solutions. The Countryside Agency estimates that an
additional 10,000 affordable rural homes per year are required
to meet existing rural community needs, while the Rural Housing
Trust estimate there is a need for six to eight subsidised houses
in each of the 8,000 small villages in England—a total of
50,000 homes. Once local people are priced out of the market it
becomes harder to revitalise market towns, villages and the rural
economy. House prices are often driven upwards not by local incomes
but by pensions, savings and the sale of houses in other areas.
It can be impossible for low to moderate-income households to
compete in this environment.
Housing market renewal
It is important to note that the other side
of balancing housing markets is the need to invest in failing
and weak markets. In such areas, housing market dysfunction threatens
sustainability objectives. The blight of empty homes and degraded
environments are significant features in some areas of the north
and midlands. In our Spending Review submission we recommend that
the total level of expenditure for the existing Housing Market
Renewal Pathfinders should be £290 million per annum for
the Spending Review 04 period to enable these issues to be adequately
addressed.
Building on the Pathfinders we need a comprehensive
strategy for tackling low demand problems across the country.
This recognises that the Pathfinders cover only half the areas
experiencing abandonment and dereliction. We recommend that the
government should address low demand problems and dysfunctional
housing markets in all parts of the country by adopting a new
National Strategy for Housing Market Restructuring. To fund the
strategy we argue in our joint Spending Review 2004 submission
for an allocation of additional £350 million over the spending
review 04 period.
Conclusions on housing markets
The provision of housing in different localities
needs to be based on whole market assessments so that in different
localities an appropriate mix of housing between affordable rented,
low cost home ownership and intermediate rented housing is provided.
3. MIXED COMMUNITIES:
CONTRIBUTION TO
SUSTAINABILITY
Sustainability will be best met by delivering
inclusive and mixed neighbourhoods (in terms of housing type and
tenure to meet a range of needs across age, ethnicity, economic
status, household size, faith, special needs etc) where people
want to live. Research published by the Federation in September
2003 Regional Futures: Neighbourhood Realities indicates that
there is a general consensus that mixed neighbourhoods are the
places where people have the best chance of thriving.
Promoting mixed communities means action to
increase the mix on existing mono-tenure areas, such as peripheral
council estates, as well as action to ensure that new developments
cater for a mix from the outset. It is also about ensuring that
in areas, such as rural communities, that the needs of people
on low to moderate incomes are not squeezed out by rising land
and property values.
In the growth areas, political concern is tending
to focus on the large-scale physical infrastructure and flood
protection needed to make the developments sustainable. Whilst
these issues are important, we will not build sustainable communities
if we forget about social infrastructure and social mix. Also
of importance is attracting employment to these areas. The housing
market renewal programme also offers the opportunity to not only
restructure the built environment but also to let for mixed and
sustainable communities.
4. INVESTMENT
AND LAND
USE POLICY:
CONTRIBUTION TO
SUSTAINABILITY
Investment needs
A significant increase in the supply of affordable
housing can be achieved through the expansion of the housing association
development programme and through initiatives to bring empty homes
back in use. In our joint Spending Review 2004 submission we propose
a mixed housing association development programme costing £8.4
billion to deliver 60,000 affordable rented, low cost ownership
and intermediate rented homes a year by 2007-08. This is based
on the planning system complimenting public expenditure to secure
the supply of affordable housing set out.
Reform of planning policy
Indeed planning policy should be seen alongside
housing investment as central to ensuring that the nation's housing
needs are met and that individuals and communities enjoy quality
housing and neighbourhood environments. In areas of high land
values and limited supply the provision of new affordable homes
is heavily dependent upon land use and planning policies.
Prior to Barker, the planning system was already
undergoing major change. We welcomed the encouragement given to
mixed tenure in new developments in the recent consultation on
PPG3 and PPS1. However, we believe the statement in the draft
PPS1 that a "suitable mix of housing including adequate levels
of affordable housing" will be difficult to achieve unless
firmer commitments are made in PPG3. Therefore we have suggested
that "planning policy should include a presumption that all
housing developments should respond adequately to the full range
of needs—including the provision of a genuine mix of market
and affordable homes".
In our recent response to PPS1 we also endorsed
the statement that "sustainable development is the core principle
underpinning planning". But we stressed the need for a framework
to enable planners to achieve this. We suggested the model developed
within the Egan Review on "Skills for Sustainable Communities"
could provide a tool for planners to test the components of sustainability.
We would urge the government, in responding
to the Barker report's call to re-visit PPG3 and liberalise planning,
not to lose sight of the importance of affordable housing within
mixed developments and the achievement of wider sustainability
objectives.
With the passing of the Planning and Compulsory
Purchase Act, we are keen to keen to explore ways in which "on
site" in kind affordable housing through s106 schemes could
be maintained and promoted by planners to encourage mixed and
sustainable communities. We are concerned that the alternative
optional planning charge will, particularly in areas of high land
values, force local planning authorities to allow affordable housing
in areas of cheaper land where social housing is already predominant.
If the planning gain supplement, proposed by Barker, is to be
introduced, the details of how it operates would also needed to
be tested against mixed community and wider sustainability outcomes.
We are concerned that the Barker report's presumption
that land should be used for the most commercially viable purpose
could squeeze sustainability considerations. Also, "best
consideration" should only be one of a number of criteria
that public bodies have to consider in relation to land disposal.
The policy framework should be changed to also require them to
ask "how can this site be optimised for public benefit".
In this way sustainability objectives could be placed at the heart
of public land disposals.
Barker was right to draw attention to some of
the problems with the current planning processes. However, any
proposal to liberalise land-use planning and fast track approval
should ensure that quality and sustainability are not sacrificed
to speed. We welcomed the recently announced piloting of design
codes by English Partnerships in conjunction with CABE. Design
codes do have the potential to improve both the speed and quality
of development delivery. However there is a risk that by focusing
primarily, if not solely, on aesthetic considerations, design
codes will fail to secure wider sustainable outcomes.
On the specific point of unmet rural housing
needs, the rural exceptions policy (Planning Policy Statement
7) should be maintained alongside the new rural allocation policy
to enable sites solely for affordable housing to come forward.
Brownfield and high density development
The current emphasis of recycling urban land
before greenfield sites needs to be retained. In the light of
Barker's recommendations the government should look at what more
can be done to bring forward brownfield developments. There is
a need for effective land assembly and a further examination of
the role that English Partnerships could play in recycling unused
public sector brownfield sites in a way that optimises the benefit
to the public, including reflecting sustainability considerations.
Taking many large cities as examples, most available
sites for development now and in the future can be considered
brownfield sites. An accurate understanding of their additional
site development costs is needed to enable planners to safeguard
affordable housing provision on brownfield land.
High quality high density housing also has a
role to play in ensuring effective land-use. The contribution
that such developments can also make to sustaining social and
economic infrastructure, such as local shops and transport links
should also be acknowledged from a sustainability perspective.
A recent London Housing Federation report Capital
Gains: making high density housing work found a number of factors
in the success of higher density developments, these included:
accessible locations with good transport links, access to employment,
proximity to shops and other amenities; low occupancy levels and
child density. The research also recognised the contribution of
high quality designs and housing management to the success of
high density housing. With this, there needs to be a recognition
of the costs of such developments.
5. STANDARDS
OF HOUSING
DEVELOPMENT
The housing association sector
There are lessons for private sector developers
in the sustainable development approach that housing associations
are expected to take to new developments and the rehabilitation
of their existing stock. The Housing Corporation's 2003 Sustainable
Development Strategy has the objective of ensuring that all associations
with more than 250 homes address sustainable development issues
in their policies, strategies and action. The outcomes it wishes
to see include higher environmental performance standards and
lower energy and water bills for residents. These objectives are
central not only to environmental considerations but also to alleviating
poverty and wider social and economic objectives.
Housing associations build homes that are of
high quality that are intended to last for decades. Their investment
in homes and neighbourhoods is for the long-term. They have an
ongoing housing and neighbourhood management role, such that it
is in their interests to build homes and external environments
to high standards from the outset.
Housing associations develop new homes to the
Housing Corporation's Scheme Development Standards. These place
an emphasis on design and the quality of the whole living environment.
Locational considerations include convenience of local services,
such as parks, public transport, schools and post offices. Aesthetically,
buildings are required to be compatible with or enhance the local
environment. Schemes are also required to incorporate cost effective
energy efficiency measures and for new build homes this means
an EcoHomes rating level of "pass" is required—"good"
is recommended. Indeed the Housing Corporation's Sustainable Development
Strategy sets out an aspiration that all new affordable homes
programme schemes should meet the "very good standard"
by 2006.
Social Housing Grant to private sector developers
Consideration needs to be given to the potential
threat to sustainability objectives of the proposal to pay social
housing grant to private sector developers contained within the
Housing Bill going through parliament. How will government ensure
that quality is not compromised in an un-regulated private sector?
Will scheme development compliance audits be equally vigorously
applied? Will quality considerations take into account environmental
standards both within and beyond the home? How will private sector
developers be encouraged to build for mixed communities rather
than segregate tenures in pursuit of maximum land values? Will
the private sector be required to recycle surpluses into social
purposes in support of long-term sustainability?
If the government persists in going down this
route, the private sector recipients of grant should be required
to meet the same high scheme development standards (see above)
if the government is serious about its own sustainability objectives.
Also for the same reasons, if the private sector is to have an
ongoing management role, it should be required to meet the same
high standards as associations must under the Housing Corporation's
Regulatory Code. Long-term value-for-money considerations need
to take into account qualitative standards, including environmental
considerations, as well as the initial price per unit.
It is not clear at this stage how the Housing
Corporation sees its Sustainable Development Strategy as fitting
with the administration of grants to private sector developers.
To what extent will sustainable development principles be an explicit
grant allocation criteria? Also, as the Housing Corporation adopts
new policies over time, as illustrated by recent initiatives,
such as its Sustainable Development Strategy and the Decent Homes
Standard, how would these be applied to an unregulated private
sector if they were not a condition of the original grant condition?
6. GOOD PRACTICE
The Federation has promoted good quality designs,
through for example good practice publications such as Standards
and quality in development. Details of good practice in the sector
are available from us or from Sustainable Homes (www.sustainablehomes.org.uk)
they include:
— local sourcing of building materials;
— local labour schemes and a wide range
of construction training placements on new build and refurbishment
sites;
— waste reduction/recycling including
water recycling;
— high density high quality housing;
— energy efficiency homes.
We would be happy to provide further information
on the issues raised or good practice examples.
May 2004
| 
