Memorandum from Friends of the Earth
Friends of the Earth England, Wales and Northern
Ireland welcomes the opportunity to provide evidence to the Committee
on the implications of the Barker Report[1].
Friends of the Earth is an NGO with 200,000 supporters and local
campaigning groups in 240 communities. We are also a member of
Friends of the Earth International, which has member groups in
57 different countries. Friends of the Earth has worked on planning
and housing for over 25 years, and we are convinced that the land
use planning system is a key mechanism for delivering sustainable
development.
SUMMARY
Friends of the Earth believes that current Government
policy on regional development and housing provision is a major
obstacle in achieving sustainable development in the UK and conflicts
with the Government's own stated aims contained within the UK
Sustainable Development Strategy[2].
Existing policy, exemplified by the Sustainable Communities Plan[3],
is essentially a reflection of a market driven macro economic
model which assumes that the growth should be concentrated in
the broader South-East of England. Such a policy will reinforce
significant regional inequalities resulting in the continued decline
of some communities and the over-development of others.
The Communities Plan[4]
will also fail to deliver sustainable development because its
proposals were based on a scant understanding of the environmental
limits of those areas where the highest growth is to be delivered.
It also failed to identify how vital strategic infrastructure,
for example for public transport, would be funded so that in many
cases housing development will precede such vital investment.
In addition, while the technology exists to radically reduce the
resource consumption of new homes, the Government has chosen to
adopt a gradualist, voluntary approach to implementing such standards.
This is a profound policy failure and loses the opportunity for
a step change in the quality and long-term sustainability of our
communities.
The recommendations of the Barker Report would
exacerbate these trends by deregulating control over built development
and so remove vital mechanisms through which we might achieve
a more balanced and sustainable development of the nation. The
recommendations of the Barker Report would:
— exacerbate regional inequalities;
— result in widespread breaches of
environmental limits;
— result in the marketisation of planning
decisions; and
— remove vital democratic safeguards
from the planning process.
The Barker Report fails to recognise that it
is not possible to make recommendations on the future of housing
provision without understanding the environmental implications
of such development. As a result the Barker Report is a significant
barrier in achieving an integrated strategy for sustainable housing
development in England.
Overall the Barker Report is neither a helpful
nor authoritative analysis of the current housing crisis. The
report uses simplistic cost benefit economic analysis to approach
a complex social and environmental problem. As a result the report
is both divisive and distracts from the sensible debate we need
to have on the smart growth of our nation. To achieve sustainable
development regional and housing policy must seek to integrate
the four pillars of the UK Sustainable Development Strategy[5]
and not continually prejudice economic growth as the prime objective.
In addition we urgently require a national framework for strategic
planning which can give spatial expression to the UK Sustainable
Development Strategy and combat growing regional inequalities.
Such a project requires much greater inter departmental cooperation
than has been evident in either the Communities Plan or the Barker
Report.
INTRODUCTION
This memorandum focuses primarily on the implications
of the Barker Report and acknowledges the wide breadth of expertise
in organisations such as Shelter, TCPA, CPRE and WWF on other
vital issues such as housing need, sustainable housing layout
and design and housing forecasting. The memorandum is structured
in two parts. The first deals primarily with the policy implications
of the Barker Report the second deals briefly with a number of
specific concerns over existing housing delivery policy. The paper
does not deal with the Barker Report proposals for fiscal policy
which were addressed by an earlier submission[6]
by Friends of the Earth.
PART 1
THE BARKER
REPORT
Context
1.1 The Barker Report reflects a long standing
Treasury led policy agenda which seeks to question the core principles
of democratic planning on the basis that such regulation is anti-competitive
and a barrier to UK macro economic policy. (McKinsey[7]
was the first of these reports, produced for the Treasury in 1998).
It is significant that there is no empirical evidence to support
this view, a conclusion reached by an ODPM report[8]
in 2003.
1.2 The Barker Report accepts uncritically
the Treasury's macro economic idea of the "golden arc"
of growth (that is the wider South East defined by a line from
Bournemouth to Cambridge) which is essentially the economic driver
of the UK. This model of unequal growth lies at the heart of the
unsustainable nature of both Barker and the Communities Plan.
1.3 It is also important to stress that
the implications of the Barker Report go far beyond the provision
of housing, implying fundamental changes to the way planning decisions
are taken. The Barker Report's recommendations for deregulation
are at least as important in the debate on sustainable development
as the substantive recommendations for housing growth.
CORE MESSAGES
OF THE
BARKER REPORT
Market driven housing provision
1.4 The premise of the Barker Report is
to reduce high house price inflation by increasing supply. While
this can be achieved in a variety of ways the report focuses on
recommendations which would make the provision of housing through
the planning system price sensitive. This is a radical shift to
the planning system which is traditionally meant to integrate
or at least "balance" market pressures with other public
interest objectives such as sustainable development, and with
a process that is both participative and democratic. The planning
system has sought to provide for housing need based on demographic
change rather than housing land price which is a purely market
driven indicator.
1.5 The radical nature of the Barker Report
is illustrated by two specific recommendations:
1. LPA's should allocate up to 40% more
housing land than forecast need to be released in response to
local price volatility (Paragraph 2.36 and recommendation 9).
2. At box 2.1 the report recommends
introducing "price premia". If the price of land for
a particular use exceeds an established indicator, the price premia,
then there should be a presumption in favour of the development
of that type of land.
1.6 These two recommendations would make
land price the main material consideration in the planning process.
The direct implication is that a market mechanism should determine
the amount of land and its location. Paragraph 2.40 makes clear
that the private sectors' view of the viability of an individual
site should have a major influence on the location of development.
1.7 The report is particularly unhelpful
in analysing how these price mechanisms can be integrated with
environmental protection and the democratic nature of planning.
In fact the recommendations are not merely an adaptation of
the planning system, they overturn its very rationale and purpose.
1.8 Regulatory democratic land use planning
was a reaction to the failure of the private sector to provide
developments of sufficient quality in socially and economically
desirable locations. If the needs of the market, as defined by
land price, are to be taken as the prime indicator of what is
socially desirable then the there is no logical case for planning
regulation or its democratic basis. Economic considerations should
remain a central concern but should not themselves be allowed
to change the decision-making process.
1.9 The nature of planning decisions in
the UK is unique and based on the exercise of discretion by planning
professionals and local politicians to judge the outcome of individual
decisions using policy as key guidance. Any trigger mechanism
such as price premia will overturn that structure, changing the
nature and role of planning professionals and effectively removing
local democratic control from Development Control decisions.
1.10 The Barker model of decision-making
would result in the following decision-making model:
1. Local authorities are forced to allocate
a buffer of up to 40% more housing land than is needed in their
Local Development Frameworks.
2. Land price volatility breaches the
price premium for housing land in a particular area.
3. Local authorities must then release
land held as a buffer.
4. Planning applications for this land
would benefit from a presumption in favour of approval.
1.11 The use of a presumption in favour
would make it almost impossible for local authorities to reject
an application which, for other important material considerations,
might be unsuitable.
1.12 Barker has argued that since all housing
land is approved to the development plan process that these price
trigger mechanisms and the land allocated would be subject to
democratic scrutiny. This would only be true if local authorities
have the freedom not to adopt the price premia model in the first
place. Once having imposed a mechanism on local authorities they
are forced to allocate more land than is needed and left with
no real discretion to reject individual applications on that land.
1.13 This model assumes that:
— It is possible to establish a sensible
price premia.
— That local authorities can identify
the over-provision of housing land in areas with significant environmental
and social constraints.
— That the local population will accept
large-scale development which goes beyond social need.
1.14 A price sensitive planning system does
not just change the nature of decision-making it seeks to replace
the role of local politicians in safeguarding the public interest
with a crude measure of economic welfare. This point is reinforced
in the report by a number of references to removing democratic
scrutiny of individual decisions by the use of greater delegation
to officers (Paragraph 2.50). Indeed the report sates clearly
that "Using price signals in this way would help distance
land availability decisions from the political process" (Box
2.1). This statement, and by the recommendation for greater use
of delivery vehicles such as UDCs (recommendation 23) which remove
all democratic scrutiny from decisions, illustrates Barker's complete
failure to understand the importance of public involvement in
planning decisions. Throughout the report, Barker assumes, wrongly,
that the planning system takes place in a simplistic economic
vacuum, ignoring evidence as to the complex process and objectives
of the planning system.
1.15 Friends of the Earth is also extremely
concerned that the notion of price sensitive land use regulation
is an expression of a much wider Treasury view on how environmental
decision-making should be reformed and would have a very negative
impact on the Government's stated goal of achieving sustainable
development. The existing planning system may be less than perfect
but it embodies vital methodologies such as Environmental Impact
Assessment, with public participation and representative democratic
control.
Exacerbating regional Inequalities
1.16 The Barker Report makes clear that
to stabilise housing markets, increased housing provision should
be made in areas of high demand. This would have huge and obvious
implications for regional inequalities by concentrating unlimited
growth in a limited geographic area to the detriment of all other
regions and nations of the UK. Paragraph 1.54 explicitly acknowledges
that some areas will decline and that "this might mean taking
a much more active approach to demolitions and clearing stock
that is no longer required." The social cost of such extreme
free market urban policy would, particularly in areas already
defined by poverty and racial tension, be incalculable.
1.17 The report's implicit endorsement of
the "golden arc" treasury model ignores the fact this
model is now the most profound barrier to the sustainable development
of the United Kingdom by enshrining a market-led growth model
which shows inadequate regard for environmental limits and social
justice.
Ignoring environmental costs
1.18 While the report makes wide ranging
recommendations on the planning system, it gives no consideration
to the environmental costs of its key recommendations for a price
sensitive system. It does not make clear that the environmental
capacity of areas such as the South East is limited and that large-scale
development would inevitably compromise these limits.
1.19 DEFRA recently published an analysis[9]
of the impact of three expansion scenarios including those recommended
by Barker. The report concludes that this option, which amounts
to 300,000 new dwellings per year being built in southern and
central England between 2001 and 2016, would have very significant
environmental consequences.
1.20 In the year 2015-16 carbon dioxide
(CO2) associated with construction could represent 5% of all current
industry emissions. In the same year, CO2 associated with use
of the new dwellings could equal 12% of the current domestic CO2
total. These extra CO2 emissions are identified as the biggest
external cost of the plans.
1.21 The amount of additional aggregates
required in the year 2015-16 would equate to 10% of the construction
industry's entire consumption in 1998. (It is important to note
that there are already major environmental concerns over the impact
of aggregate production in general and in particular marine dredged
aggregates supply to the South-East, which currently accounts
for 35% of consumption) Additional household waste would be equivalent
to 25% of the current total. Water demand would be nearly 73 million
litres higher (We note that Thames water has announced a plan
to build the first desalination plant on the Thames which will
be energy and land intensive). And up to 77,500 hectares of greenfield
land would be built on between 2001 and 2016.
1.22 The Barker Report does have the briefest
acknowledgement that there might be environmental costs but there
is no detailed analysis, no indication of the level of these costs
or their severity. It is not sufficient for the authors of
the report to claim that these issues were not in their terms
of reference since they are factors which are profoundly important
in making sensible recommendations on housing provision. It
is also worth noting that the report exceed its remit in other
respects such as making recommendations which question the democratic
nature of planning.
Putting a price on the environment
1.23 The Barker Report assumes (recommendation
10) that the environment is valued only in relation to its opportunity
cost. This form of crude quantitative cost-benefit analysis, which
permeates the whole report, was largely discredited in the 1960's
in relation to strategic planning because costing long term environmental
impacts were too uncertain and the process ignored the complex
pattern of competing individual and community interest that surround
planning decision-making.
Housing provision and the private sector
1.24 The report lets the building industry
"off the hook". There is a very substantial difference
between the interim[10]
and final Barker Reports. The interim report nailed the industry
as one of the prime problems in housing supply. The final report
largely focuses on the planning system and proposes a voluntary
approach to encouraging the private sector to build more houses
(recommendations 32 to 36).
Social Housing
1.25 The Barker Report restates the longstanding
analysis of the shortage of social housing (Paragraph 5.2). However,
the report does not offer any detailed analysis or new solutions.
Simply increasing the total supply of housing will not substantially
impact on affordability. At best the report acknowledges it will
stabilise house price inflation.
1.26 Friends of the Earth's view is that
there is an overwhelming social justice case for meeting the demand
for social housing in every region in the most efficient manner
possible. In practice this means moving away from a model based
on the private sector provision of affordable homes through mechanisms
such as planning obligations (essentially a form of cross-subsidy,
so that higher value housing can subsidise low cost units). This
is inefficient in terms of land use and has not always ensured
the right tenure choice. Instead radical reform of the funding
and delivery of social housing is necessary which recognises that
it is a lack of public investment not the planning system which
is the prime cause of the social housing crisis. This reform should
be based on three principles:
— Significant increases in central
government funding on social housing.
— A return to the direct delivery of
housing by local authorities.
— Decentralised participative governance
of housing management.
1.27 Direct public sector provision allows
for the efficient use of land and the greatest integration of
housing provision with the planning process. Public sector control
allows the rate of housing unit production and the quality of
design to be effectively delivered.
Implementing Barker
1.28 ODPM is in the process of considering
how best to implement the Barker Report despite its obvious and
profound flaws. While we understand there will be a period of
consultation we also understand the Treasury is determined to
uphold the recommendations for a price sensitive planning system.
It is Friends of the Earth's view that, other than some recommendations
on fiscal measures, none of the key recommendations of Barker
should be implemented. Instead, if government is serious about
sustainable development it should begin again to assess housing
need on a national basis and along side indices of social deprivation,
housing need and environmental limits to produce a comprehensive
national spatial framework for sustainable development. Such a
framework should be subject to rigorous strategic environmental
appraisal and be the product of genuine cross departmental corporation
to avoid the fragmented approach which has characterised the Communities
Plan and the Barker Report.
PART 2
HOUSING PROVISION
IN THE
UK
The Communities Plan
2.1 The Communities Plan is a fragmented
and partial spatial response to housing shortages in the South-East.
The plan itself has an uncertain status since this output will
only have a real practical impact when incorporated into Regional
Spatial Strategies (RSS) which themselves have their own adoption
process. In addition the ideas of the Communities Plan have emerged
over a period of 18 months so that there is now more focus on
issues affecting northern cities. What is clear is that this ad
hoc approach was not based at any time on an overview of how to
deliver sustainable development in the UK as a whole. Unlike all
other planning processes the Communities Plan proposes significant
growth before it had any systematic measure of the suitability
of those areas to accommodate such development.
2.2 This illogical and unreasonable approach
to a highest level of strategic planning inevitably leads to failures
to directly consider infrastructure needs and environmental limits
of particular localities. In addition to the environmental impacts
identified by the DEFRA study[11]
this can lead to the focusing of growth in areas such as the Thames
Gateway where there is significant flood risk from climate change.
2.3 There is an important policy conflict
between the objectives of the Sustainable Communities Plan and
the achievement of sustainable development. This tension is illustrated
in the Draft PPS 1[12]
where there is significant confusion as to which of these principles
is meant to be the core objective of the planning system. What
is clear is that the definition of sustainable communities as
illustrated in Annex A of PPS 1 "Creating Sustainable Communities"[13]
are significantly different from the accepted notions of sustainable
development contained within the UK Sustainable Development Strategy[14].
Annex A for example, contains no reference to the importance of
nature conservation.
Friends of the Earth's response on Housing
2.4 Friends of the Earth recognises that
the environment sector has not always fully and responsibly engaged
in the policy debate on housing needs. Friends of the Earth accepts
that housing poverty reflected through homelessness and poor conditions
is a major contributor to social exclusion. The level of poor
housing conditions for children and the elderly are of particular
concern. We also recognise that demographics and particularly
the growth in household formation has created a demand for new
homes and new kinds of homes. We do not accept, however, that
"predict and provide" in relation to new-build provides
an effective or sustainable solution to these problems. We also
strongly reject the assumption that increased housing provision
will tackle house-price inflation. In order to achieve a lowering
of house prices through market mechanisms it will be necessary
to generate an oversupply of housing, which would breach the principles
of sustainable development.
Design and Layout
2.5 Friends of the Earth is extremely concerned
by the Government policy on design and layout. Specifically we
believe the Communities Plan approach to the implementation of
sustainable housing is a major impediment to sustainable development
by failing to provide sufficient regulation and incentives to
affect the radical changes we need to make in housing design.
A clear illustration of how the Government regards the implementation
of sustainable housing standards can be gained from the recent
publication[15]
of proposals for a Code for Sustainable Building (CSB) which contains
a range of excellent proposals on energy efficiency, floods resilience
and water conservation. Unfortunately this code only has the status
of best practice. This exemplifies the clear gulf between the
available technology and design proposals (exemplified in the
detailed work of WWF "One million sustainable homes"[16])
and the Government's unwillingness to identify effective delivery
mechanisms.
2.6 The solution to this problem is:
— Provide a greater degree of prescription
in building regulations to ensure new build and conversions enshrine
proven resource conservation technology including small-scale
renewable technology and meet the Eco homes excellent standard.
— Provide much greater prescription
in a new PPS 3 on housing in relation to master planning and the
layout and service provision of new housing.
— Provide greater integration between
the Environment Agency and planning authorities in relation to
future flood risk and sea-level rise in order to provide strategic
guidance based on best available modelling from the Met office.
— Specify in PPS 11[17]
a CO2 reduction target for the delivery of new housing to be enshrined
in Regional Spatial Strategy.
— Increased investment for the retrofit
of existing houses with energy conservation technology.
— Underpin the new drive for sustainable
housing by enshrining the above objectives in a new Public Service
Agreement (PSA) target for ODPM.
2.7 There is no doubt that such development
will add cost to the delivery of new housing units. However, such
upfront capital cost will result in long-term savings particularly
in energy costs for users. Such savings will disproportionately
benefit those on low and fixed incomes who spend a higher proportion
of their income on energy. In the wider context, the contribution
of sustainable housing to reducing the negative impacts of climate
change is likely to be significant (These costs have been assessed
in the recent DEFRA report[18]).
A National Spatial Framework for Housing
2.8 A more detailed description of Friends
of the Earth's policy on housing location and design is appended
at Annex A. The most significant strategic element of this policy
is Friends of the Earth's commitment to a national spatial framework
which would address issues of the over-development of the South-East,
housing abandonment, quality-of-life and negative inter-regional
competition.
2.9 This framework should have the prime
objective of redistributing demand pressures from areas of growth
in the South-East to areas of low demand in the North and West.
Such a policy should also address the need to deal with the drivers
of housing demand by restricting and decentralising public and
private sector commercial growth from South to North. This policy
should achieve the systematic redistribution of population and
industry to areas of low demand. Failure to deal with this issue
strategically will lead to the continued decline of some communities
and to the overcrowding of others, with all the attendant political
controversy and reduction of quality-of-life. The recent publication
of census data reinforces the decline of regions such as the North
East and North West while areas such as Milton Keynes have seen
growth of around 60% in the last 20 years. Government must address
the need to deal with the vacuum in policy left after the abandonment
of comprehensive regional redistribution policies in the early
1980s. Friends of the Earth believes that housing policy should
no longer attempt to meet general demand in all regions. While
social housing needs must be delivered everywhere, the continued
expansion of housing in the South East is not sustainable in the
medium and longer term.
CONCLUSION
If the Barker Report is successfully implemented
in full then price sensitive decision-making will do irrevocable
damage to the ability of the land-use planning system to deliver
sustainable development. Friends of the Earth believes that the
Government should carefully reconsider its regional economic and
housing policy. This policy should have the prime objective of
giving spatial expression to the UK Sustainable Development Strategy.
It should be based on an integrated assessment of the social,
environmental and economic circumstances of the nation.
REFERENCES
Review of Housing Supply "Delivering stability:
securing our future housing needs" Final Report, Kate Barker,
March 2004.
A Better Quality of Life: A Strategy for Sustainable
Development for the United Kingdom, May 1999.
Sustainable Communities Plan "Sustainable
Communities: Building for the future" February 2003.
Friends of the Earth's submission to the Environmental
Audit Committee on the Budget, 24 March 2004.
Driving Productivity and Growth in the UK Economy,
McKinsey, Global Institute, October 1998.
Fourth Report of the ODPM: Housing, Planning,
Local government and Regions Committee, 2003.
Study into the environmental impacts of increasing
the supply of housing in the UK. DEFRA, April 2004.
PPS 1 "Creating Sustainable Communities",
May 2004.
Sustainable Building Task Group Report, May
2004.
One million sustainable homes: Moving best practice
from the fringes to the mainstream of UK housing, WWF, January
2004.
June 2004
1 Review of Housing Supply "Delivering stability:
securing our future housing needs" Final Report, Kate Barker,
March 2004. Back
2
A Better Quality of Life: A Strategy for Sustainable Development
for the United Kingdom, May 1999. Back
3
Sustainable Communities Plan "Sustainable Communities: Building
for the future" February 2003. Back
4
ibid. Back
5
ibid. Back
6
Friends of the Earth's submission to the Environmental Audit
Committee on the Budget, 24 March 2004. Back
7
Driving Productivity and Growth in the UK Economy, McKinsey,
Global Institute, October 1998. Back
8
Fourth Report of the ODPM: Housing, Planning, Local government
and Regions Committee, 2003. Back
9
Study into the environmental impacts of increasing the supply
of housing in the UK. DEFRA, April 2004. Back
10
Review of Housing Supply "Delivering stability: securing
our future housing needs" Interim Analysis, Kate Barker,
December 2003. Back
11
Study into the environmental impacts of increasing the supply
of housing in the UK. DEFRA, April 2004. Back
12
Draft Planning Policy Statement 1: Creating Sustainable Communities,
ODPM. Back
13
Planning Policy Statement 1: Creating Sustainable Communities,
ODPM, 2004. Back
14
ibid. Back
15
Report of the Sustainable Building Task Group, May 2004. Back
16
"One million sustainable homes": Moving best practice
from the fringes to the mainstream of UK housing, WWF, January
2004. Back
17
Draft Consultation Paper on New Planning Policy Statement 11
(PPS11)-Regional Planning, ODPM, 2003. Back
18
Study into the environmental impacts of increasing the supply
of housing in the UK. DEFRA, April 2004. Back
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