Select Committee on Environmental Audit Minutes of Evidence

Annex A



The Government's Housing Policy

  Friends of the Earth has four fundamental concerns about the government's existing housing policy as specified in the Communities Plan (ODPM, 2002):

  Existing policy has led to the development of large scale greenfield sites with an undoubted impact on the environment. The development of these sites has often been unimaginative, low-density and largely dependent on the car. The provision of new housing in suburban locations has contributed to the decline of the inner areas of our towns and cities.

  I.  Existing housing policy has dramatically failed to deliver equity in the provision of housing. Many of the most vulnerable groups in society particularly the young and the elderly live in unacceptably poor housing conditions. The provision of large-scale new housing development would do nothing to meet these needs nor would it address the critical issue of affordability.

  II.  Current housing policy tends to reinforce the tension between the national need to provide new homes and the rights of individuals and communities to have a say over the way that their areas develop. New policy must make clear where the boundaries between these sometimes contradictory policy objectives lie in order to avoid divisive political polarisation.

  III.  Traditional forecasting techniques based on crude trend projection have proven inaccurate and insensitive to local needs. Forecasting for housing must be sensitive to local housing needs surveys and to the environmental and social capacity of a locality to take increased housing numbers.

Making good policy

  The consideration of housing policy should be conducted holistically, considering the full range of factors which define quality, quantity and accessibility. These factors include:

    —  Population and household formation rates.

    —  Housing conditions.

    —  Empty and second homes.

    —  Affordability.

    —  Tenure choice.

  The current debate over housing is dominated by housing land supply and underplays the need to address affordability and housing quality.

  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.

Friends of the Earth's Principles for housing provision

  New housing policy should be based on the principles of:

    —  Social Equity. Access to good housing is a basic human right (By delivering social housing needs through greater public sector investment).

    —  Sustainable Development. Communities which maximise quality of life and minimise resource use by operating within the environmental limits of the locality.

    —  Demand Management. The redistribution of housing demand from areas of high to low demand.

    —  Urban Capacity. By a greater sensitivity of social and environmental capacity of existing communities to accommodate new housing and of the housing needs of those communities.

    —  Design Innovation. By the promotion of innovation in housing design, construction and layout.

    —  Participative Processes. A planning system which places the views of local people at the heart of the planning system.

Regional redistribution

  Friends of the Earth supports the need for a National Spatial Framework for the UK which can provide the strategic context for sustainable housing provision. 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 a fairer more balanced distribution of population and industry to achieve:

    —  The social, economic and environmental regeneration of areas of low demand to ensure increased life chances and social well being.

    —  To prevent the continued breach of core environmental limits (such as biodiversity and water resources) in areas of high demand and continued decline 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. The practical result of this approach to housing is that 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.

Housing Land Provision

  Friends of the Earth strongly supports the use of a sequential approach to the provision of housing land, which is encouraged through PPG 3 and 13 and defined in paragraph 2.2 of this document. Friends of the Earth emphasises the need for this RSS to reflect a "plan, monitor and manage" approach to housing provision. This suggests that a flexible and iterative approach is required, with an emphasis on meeting local needs and formulating creative solutions to protracted problems through continual monitoring and adjustment. The housing aims of this RSS should reflect such an approach from the outset.

Setting targets for the recycling of land and buildings

  Friends of the Earth strongly supports the aim of increasing the percentage of housing development which takes place on previously developed land and the conversion of redundant buildings. This helps development to occur within the environmental limits of a region and can play a positive role in urban regeneration. Friends of the Earth believes that a greater level of "recycling" of land and buildings could occur if policies and programmes were in place to support it. Thus, it is essential that policies to guide such an increase are clearly set out in RSS and that funding regimes are put in place to support these policies. These should aim for at least 75% of all housing provision to be made on previously used land. Friends of the Earth recommends the following housing policy:

    Local authorities should include policies in their Development Plans which will lead to an increase in the level of housing development on previously developed land so that the target of 75% can be reached over the plan period. These policies should include:

    —  the use of phasing mechanisms;

    —  the reallocation of sites for housing which are currently specified for other uses; and

    —  requirements for higher densities of urban housing developments.

A phasing mechanism

  Friends of the Earth strongly supports the use of phasing mechanisms to ensure that housing developments take place on previously developed land before the use of greenfield sites. Phasing mechanisms should have three components:

    —  Policies need to ensure that land allocated in Development Plans is brought forward at a rate which encourages the reuse of urban land.

    —  Local authorities must be proactive to bring forward previously developed land.

    —  Policies should reflect paragraph 30 and 31 of PPG 3 which places an emphasis on: using previously developed sites within urban areas; converting existing dwellings and non-residential premises; raising densities; releasing land held for alternative uses; and facilitating area wide redevelopment through land assembly measures. RSS should emphasise the priority to achieve the most efficient use of land by adopting this sequential approach to ensure maximum use of previously developed land.

Design and density

  Fundamental to the attainment of achieving urban and rural renaissance is improving the attractiveness and safety of cities, towns and villages and, where new development takes place, the creation of high quality, sustainable places where people chose to live, work and take their leisure. Friends of the Earth is particularly concerned to emphasise the need for increased densities to be encouraged and for more resource efficient homes to be built in the region. To this end, Friends of the Earth recommends that minimum acceptable density levels are included as a guide in the RSS. PPG 3 states that low density of development should be avoided and emphasises that densities of up to 50 dwellings per hectare may be appropriate if close to existing centres. Circular 02/02 TCP (residential density) Direction 2002 reinforces the government's view that development of less than 30 dwellings per hectare should be avoided and creates specific power in the South East to review such applications. Friends of the Earth would also recommend a more proactive policy stance in regard to the reuse of vacant properties and the promotion of `homes above shops' as part of a comprehensive package to revitalise urban areas. Friends of the Earth supports measures which can help to make more effective use of existing urban areas but would wish to emphasise that infill development should not take place at the expense of the quality of the urban spaces.

  In addition, Friends of the Earth believes that Development Plans should be required to promote the development of resource efficient homes through the inclusion of policies which   specify acceptable levels of resource efficiency for all new developments. The recent ODPM Select Committee Report (Planning for Sustainable Housing and Communities: Sustainable Communities in the South East Eighth Report, ODPM, 2003) endorsed the Building Research Establishment measure of resource efficiency known as the "Eco Home" standard. Friends of the Earth strongly recommends that RSS should support the achievement of Eco Homes "excellent" standard for all new homes built over the plan period. ("One million sustainable homes: Moving best practice from the fringes to the mainstream of UK housing", WWF, January 2004)

  (Relevant advice is contained in "By Design—Urban Design in the Planning System:

Towards Better Practice" (DETR 2000)).

Low Impact Housing

  RSS policy should encourage new developments in housing design which combine elements of traditional building techniques with innovation in sustainable building materials, energy conservation and water and refuse recycling. Such development has a minimal or benign affect on the local and global environment and provides a visionary model for how sustainable communities might develop in the future. RSS should provide strong leadership in encouraging such housing design. Local authorities should consider the benefits of such development to sustaining the rural environment so long as they do not harm environmental and landscape designations of acknowledged importance.

Affordable housing

Housing equity is a vital part of the sustainable development of the region. There is need not just to increase the supply of affordable housing but to ensure a range of size, types and tenures of housing to be provided so as to ensure a greater level of equity in housing provision than that which currently exists.

  The RSS should make a clear commitment to ensure that approximately 30% of all new homes are affordable. Such targets may need to be exceeded in some areas depending on local circumstances.

Monitoring housing supply objectives

  Core indicators for monitoring housing supply are a vital part of effective implementation of housing policy. Friends of the Earth would recommend that the core indicators to be used are:

    —  affordable housing provision as a proportion of all housing completions (as stated);

    —  the number and proportion of new dwellings including conversions built on previously developed land, which should be above the aspirational targets set out in the RSS;

    —  the average density of new development, which should always be above 25 dwellings per hectare; and

    —  the number of households in substandard or overcrowded accommodation.

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