Annex A
EXTRACT FROM FRIENDS OF THE EARTH'S GUIDE
TO REGIONAL SPATIAL STRATEGIES
HOUSING
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.
— Empty and second homes.
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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