APPENDIX 15
Memorandum from English Heritage
English Heritage welcomes the opportunity to
submit evidence to the Select Committee's Inquiry into sustainable
housing and the implications of the Barker Review of Housing Supply.
English Heritage is the Government's statutory
advisor on the historic environment in England.
1. How future housing building programmes
can be made truly sustainable and take full account of environmental
objectives
English Heritage is concerned to ensure that
all those making decisions in relation to strategic housing provision
are aware of the contribution historic buildings make to the total
stock. Every effort should therefore be made to make best use
of the existing stock to avoid unnecessary environmental and financial
costs of demolition and new build. It is also important to ensure
that the debate does not deal only with the supply of new housing
but also looks at making best use of existing buildings through
"Living over the Shop" initiatives, conversions to residential,
reducing vacancies in local authority and other public housing
etc.
Evidence submitted at the public inquiry into
the Nelson West housing development plans which proposed large-scale
replacement of Victorian terraced housing stock with new-built
homes demonstrated that in this case the typical cost of refurbishing
one of the existing houses and maintaining it for 30 years was
under £25,000 compared to a total cost of £64,000 for
replacing it with a new property and maintaining it for a similar
period. We recognise, however, that it is not realistic to retain
every building, nor should one focus entirely on increasing demand
in low-demand areas without paying attention to the high demand
in the SE.
Our work on historic landscape characterisation
in the Thames Gateway is helping to identify those areas best
able to cope with significant new house building while also presenting
elements of the historic environment that can form the centrepieces
or set the standards and character for new development. English
Heritage believes the historic environment is crucially important
to the regeneration of the Thames Gateway. Physical investment
in the built environment acts as a catalyst for regeneration,
encourages additional funding and private sector investment, supports
local businesses and enables economic growth. The impact of heritage
investment is also demonstrated in new economic confidence, changing
perceptions of places and a stronger sense of community identity
and distinctiveness.
2. Are the conclusions of the Barker Review
compatible with the general principles of sustainable development
and the Government's own sustainable development objectives?
The Barker Review has very little to say about
the environment in general and does not mention the historic environment.
English Heritage welcomes the production of the report and its
analysis which is of considerable assistance in understanding
housing issues. However, because of the focus on economic factors
there is a danger that some of the recommendations may have a
negative impact on our heritage as well the wider environment.
Of particular concern are the proposals for fast-track consent,
the possible requirement for local authorities to overallocate
housing land and the general lack of emphasis on the need to build
on brown field before greenfield land.
More work is needed to demonstrate how the recommendations
in the Barker Report can be achieved within the general principles
of sustainable development. English Heritage considers that it
will be a challenge to do so, but that it should be possible to
significantly increase housing supply in areas of highest demand
in a broadly sustainable manner, although this is likely to be
at the cost of some less important elements of the historic environment.
It is important that new housing, and its associated
infrastructure, does not exacerbate problems in existing urban
areas, for example by shifting a settlement's focus away from
the traditional historic core. New housing needs to be planned
in ways that increase rather than decrease the viability of historic
settlements by making best use of existing (often historic) infrastructure.
3. In view of the Barker Review is there a
need for an overarching national strategy to ensure that the environment
is at the heart of any building programme
The current review of A better quality of life
offers the opportunity to set out succinctly the Government's
commitment to a sustainable housing policy. English Heritage is
not convinced that an additional document is necessary.
4. Is the current planning system robust enough
to ensure that the environmental implications of building projects
are fully taken into account? How can the planning system be used
to increase the building of more sustainable housing? Would the
proposed changes to the planning system in the Barker Review have
a positive or negative effect on the environment?
The planning system is already in the process
of undergoing significant changes, and some of these (particularly
in relation to Regional Spatial Strategies and Local Development
Frameworks and their need for SEA-compatible sustainability appraisals)
and the review of PPS1 and other PPSs further emphasise the importance
of sustainable development. Given that the planning system is
in flux, it is difficult to be certain whether it is or is not
robust enough to deal properly with environmental implications.
The current initiatives to speed up the planning
process (which our "Transforming Casework" project contributes
towards) should help to increase the building of new houses but
we are concerned that some of the suggestions in the Barker Review
could have a negative effect on the environment, if it is not
fully integrated when the details are worked up. The areas of
particular concern are:
— The potential increased flexibility
for greenbelt allocation/deselection.
— The relaxation of permitted development
rights.
— "Outline Only" permissions.
— The stripping back of 106 agreements
to only deal with direct impacts.
— The freeing up of Planning-gain supplement
funds which might give a few cash-strapped authorities a financial
incentive to grant permission.
— A lack of recognition that quality
is a key to long term success in housing developments.
Until some of the details of the Barker recommendations
are worked out, it is not possible to give a definitive statement
on whether the impact on the environment will be positive or negative,
but there are elements which English Heritage believe will need
very careful handling to avoid significant negative impacts on
the historic environment.
5. Where will the proposed new housing be
built? What are the implications for land-use and flood risk of
the large-scale proposed building projects?
English Heritage is working with Government
to provide a better information base for making decisions in both
the high and low demand areas. This is principally through rapid
historic landscape characterisation which provides a simple but
robust character framework which will be of assistance to decision-makers
and which identifies areas of high and low sensitivity, We believe
our work in the Thames Gateway and in the Pathfinder areas will
provide timely contextual information that, along with other social,
economic and environmental information, will provide the basis
for more sustainable housing developments that remain valued by
residents in the long-term. The challenges of accommodating large
numbers of new housing units in the south east are extremely challenging
and English Heritage is keen to play its part in ensuring they
are accommodated without unacceptable damage to the historic environment.
6. Is is possible to ensure materials and
resources used, and waste produced, during building do not have
a harmful impact on the environment?
English Heritage is keen to encourage sustainable
construction techniques and is involved in research into traditional
building materials and techniques which may be of assistance in
contemporary construction. As a general rule it is more energy
efficient to adapt existing buildings than demolish them and build
afresh and many housing developers, such as Urban Splash, have
demonstrated that it makes for a successful business model.
7. Are the building regulations as they stand
capable of ensuring that new housing is truly sustainable in the
long term? How could they be improved? Could greater use be made
of existing environmental standards for housing?
English Heritage has no observations on this
issue.
8. How will it be possible to ensure a sustainable
infrastructure, including transport and water supply, which will
be necessary to support any extensive house building, is put in
place?
The implementation of sustainability appraisal
and strategic environmental assessment in significant new plans
and programmes, and through the regional and local development
plan system should ensure that the sustainability of major infrastructure
projects is tested at an early stage. The taxation of land value
increases and changes to the 106 agreements system suggested in
the Barker Review must ensure that high quality infrastructure
is provided, in advance of housing development, in a way that
does not cause significant damage to the historic environment.
9. Do those involved in housing supply, both
in the public and private sector, have the necessary skills and
training to ensure new housing meets environmental objectives?
If not, how can the knowledge base of those involved in the planning
and building process be improved?
Our involvement in casework relating to new
housing development in historic areas makes it clear that there
is still considerable work to be done to improve understanding
of how taking environmental considerations into account from the
earliest stages in a development brings social, environmental
and economic benefits. We are tackling the skills issue in the
public sector through HELM (Historic Environment Local Management).
This is a comprehensive training programme aiming to improve decisions
that impact on the historic environment by raising awareness of
its intrinsic value among non-heritage professionals and decision-makers.
Those involved in housing are one of the target groups. See www.helm.org.uk
for more detail. We are also involved in developing technical
building skills training to make these more sustainable and better
reflect our environmental concerns. We are aware that there is
a considerable amount of work to be done in the area of housing
supply, and further encouragement from government in this area
would be particularly welcome.
These initiatives fit well with the findings
of the recently published Egan Review and we are examining its
findings to help fine-tune our work.
May 2004
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