Memorandum from the Campaign to Protect
Rural England (CPRE)
INTRODUCTION
1. The Campaign to Protect Rural England
(CPRE) welcomes the inquiry by the House of Commons Environmental
Audit Committee into the environmental implications of the Government-commissioned
review of housing supply by Kate Barker. A high standard and adequate
levels of affordable housing are important components of sustainable
development. The planning system has a key role to play in ensuring
that we meet the nation's housing needs while protecting and enhancing
the environment. However, we believe the threat to the environment
from the proposals in the Barker Review is both massive and multi-faceted.
2. Our initial reaction to the publication
of the Barker report was to describe it as threatening an "unnecessary
environmental disaster." This is in part because it is not
at all clear that the successful delivery of a housebuilding programme
on the scale envisaged by the Barker Review would bring the claimed,
albeit marginal benefit in terms of improvements in the affordability
of housing, given the acknowledged uncertainties surrounding the
housing market. And even if this benefit were forthcoming, we
believe its scale and significance would not justify the damage
to the environment that would result, as well as the wider and
longer term costs imposed on society and the economy.
3. The Committee's inquiry provides a valuable
opportunity to examine these issues. There are signs that the
Government too would welcome such scrutiny. The press release
issued by the ODPM (2004/0062) in response to Kate Barker's final
report stated that, while it accepted there was a need for increased
housebuilding: "The Government will need to consider the
scale of such development and how it can be delivered both nationally
and regionally taking into account the economic, social and environmental
implications and ensure that development is sustainable."
And in his Budget Speech the Chancellor said: "I hope that
over the next year all parties will study the Barker proposals
and it must be in the interests of the whole country to see whether
we can forge a shared approach that would safeguard our environment,
lead to more affordable housing, and at the same time keep interest
rates as low as possible and contribute to the greater economic
stability and prosperity of Britain."
4. The inquiry is also particularly timely.
With the delivery of aspects of the Government's Communities Plan
proceeding in the South East Growth Areas, however, we are seriously
concerned that decisions being taken now on the scale, location
and nature of new housebuilding we may later live to regret. Indeed,
the House of Commons ODPM Select Committee in its report Planning
for Sustainable Housing and Communities in April last year raised
doubts about the sustainability of the Communities Plan and stated:
"The Committee is not convinced that the enlarged house-building
programme can be accommodated in the South East without seriously
affecting the quality of the environment. Before new house-building
targets are approved, the likely impact on the environment must
be appraised within the Government's sustainability criteria"
(para 28, HC 77-1). The Committee also found that "The proposals
are unlikely to have nay impact on reducing house prices making
it all the more important for the Government to support a major
programme of affordable housing." (para 18)
5. We firmly believe that we can meet the
nation's housing needs while improving the urban environment and
protecting the countryside. But this requires an alternative approach
to that adopted by Kate Barker, based on the principles of sustainable
development and the effective use of the planning system. This
submission first outlines CPRE's broad position on housing and
the environment, considers aspects of the Barker Review, and then
addresses the specific issues raised by the Committee.
HOUSING AND
THE ENVIRONMENT
6. CPRE has been at the forefront of debates
over housing provision for many years. We have made many constructive
contributions to policy development over this period. We warmly
welcomed the 1998 Planning for the Communities of the Future White
Paper which announced an end to the discredited "predict
and provide" in housing provision and its replacement by
"plan, monitor and manage"; we played an active role
in the work of the Urban Task Force which led in 2000 to the Urban
White Paper, with its goal of securing an urban renaissance; and
we have strongly supported changes in planning policies designed
to underpin this goal, notably Planning Policy Guidance note (PPG)
3 Housing. Through our regional group and branch network which
covers the whole of England, CPRE's volunteers have played an
active role in helping to improve decisions on the scale, location
and design of new housing on the ground. We have also pressed
for effective action to tackle the lack of affordable housing
in town and country, suggesting ways in which the planning system
could be strengthened to address this issue and drawing attention
to the need for an increase in public funding for social housing
provision.
7. While housing provision is an important
component of sustainable development, housebuilding also has a
range of environmental impacts. It is the biggest single cause
of the loss of greenfield land. The construction and occupation
of new housing also makes demands and impacts on a range of natural
resources, particularly energy, construction materials and water.
Increased energy consumption and associated greenhouse gas emissions
from new housing are a significant factor in the rising overall
demand for energy and climate change. In addition, the location
and design of new housing has a significant impact on travel patterns,
particularly car use which is a major contributor to greenhouse
gas emissions. It has been estimated that 50-60 tonnes of aggregates
are required to build the average house, and new housing is one
of the main factors fuelling the increase in demand for water
resources. Increased waste generation, including construction
waste and domestic waste, as a result of new housing increases
pressure for new landfill sites. And the urbanising impact of
new housing development extends far beyond its immediate land
take. CPRE's ground-breaking Tranquil Area maps produced in the
mid-1990s revealed the extent of decline in areas of rural tranquillity
since the early-1960s, largely as a result of low density urban
sprawl.
8. We are aware that DEFRA has commissioned
consultants to examine the environmental impacts of increased
housing supply following the final report of the Barker Review.
CPRE was disturbed that the report of this largely desk-based
exercise did not receive much attention when it was placed on
the Department's website at the beginning of May. While it is
unclear precisely how the information in this report is to be
used by Government, we are encouraged that it has been commissioned.
We urge the Committee to give careful attention to the report's
findings and to how the Government will be addressing these. There
is also a need for further studies. As the report itself acknowledges,
it provides a relatively superficial examination of some of the
likely impacts of a major increase in housebuilding and omits
to address other important effects, such as the extra car journeys
arising from such an expansion.
9. CPRE is not in a position to comment
in detail on the scope or accuracy of the analysis carried out
for DEFRA. The data generated by this study, however, appears
to be broadly consistent with our own analysis. For example, we
have estimated that as a result of the Government's Communities
Plan over the next 30 years or so we could see over half a million
new homes built on greenfield sites in the four South East "growth
areas" alone. In terms of direct land take, with average
densities of 30 dwellings per hectare (the lower end of the target
range in PPG3) this equates to over 16,600 ha. On top of this,
if there was an increase in annual housing output of around 120,000
new houses, in line with one of the scenarios envisaged in the
Barker Review, we have estimated that this would require an additional
8,000 hectares of greenfield land over five years—equivalent
to building a city larger than Manchester.
10. While we have questioned the overall
level of requirements, CPRE recognises that there is a need for
new housing, particularly affordable housing which is within the
reach of those least able to access housing through the open market.
We are strong advocates of the role of the land use planning system
in determining the overall level of future housing requirements,
its broad location and matters of design and density. Planning
plays a vital role in reconciling the conflicts between meeting
housing needs and safeguarding the environment, helping to secure
public consent over the need for and provision of new housing,
as well as in setting standards in terms of the type and quality
of new housing. We accept there is a need for new housing to respond
to demographic changes, including population growth and changes
in the pattern of household formation. We do not believe there
is any clear evidence, however, to suggest that local planning
authorities are not making sufficient land available for new housing
through established planning processes. Indeed, recent evidence
from the South East Regional Assembly indicates that while sufficient
land has been allocated to maintain build rates in line with planned
requirements for seven years, housing completions are well below
the level required.
11. As stated above, we have strongly supported
the Government's urban renaissance agenda and we have helped to
promote the increased use of previously developed land and buildings
("brownfield" land), improvements in the design and
density of new housing, and an increase in the provision of affordable
housing. We have recently become seriously concerned, however,
that in practice the Government risks abandoning its commitment
to urban renewal and to the effective operation of the planning
system. The publication of the Communities Plan in February last
year was the first overt signal of an apparent change in approach.
CPRE responded by setting out five "tests" by which
we intended to judge whether the plan was delivering sustainable
development, where social and economic progress is made while
the environment is protected and enhanced. Our assessment of performance
against these tests a year after the publication of the Plan is
set out in an annex to this submission.
12. At the same time as highlighting some
of the weaknesses in the Government's approach to housing provision,
we have drawn attention to the considerable opportunities presented
by emerging plans for the Thames Gateway. Our recent report Thames
Gateway: Making Progress sets out CPRE's proposals for making
the most of an unprecedented regeneration opportunity which can
help protect the countryside across the wider south east England.
The Government is committed to securing the delivery of at least
120,000 new homes in the Thames Gateway by 2016. Many believe
this figure to be based on a serious underestimate of the available
capacity of previously developed land and buildings in the area
(which the Government estimates comprises over 17% of the available
supply of previously developed land in the South East). CPRE believes
that the target for new housing in the Thames Gateway should be
more than doubled and that this should be achieved without requiring
any encroachment onto greenfield land. In connection with programmes
to tackle areas of low demand for housing in some of the northern
regions, we have also drawn attention to the potential offered
by the re-use of existing housing stock in our report Useless
Old Houses?
13. CPRE's detailed analysis of and engagement
in the delivery of aspects of the Communities Plan gives rise
to serious concern that the Government is failing to pursue the
most environmentally sustainable approach to the provision of
necessary new housing. We fear this represents a significant shift
in focus and commitment away from an approach based on urban renewal
and countryside protection, and on meeting housing needs rather
responding to the short term, environmentally unsustainable demands
of the market. This fear has been exacerbated by the conclusions
of the Barker Review and the Government's immediate broad acceptance
of its main thrust.
THE BARKER
REVIEW
14. CPRE welcomed the review of housing
supply announced by the Chancellor and Deputy Prime Minister in
April 2003. We saw this as an opportunity to explore the positive
role of the planning system in meeting the nation's housing needs
and the relationship between housebuilding and wider social, economic
and environmental objectives. Indeed the formal terms of reference
of the review covered consideration of aspects of the housebuilding
industry and "the interaction of these factors with the planning
system and the Government's sustainable development objectives."
However, the outcome of the review was particularly disappointing
in this respect. Overall, we believe the review presented a one-sided
analysis of the role of the housing market and the planning system.
It failed adequately to recognise the wider role of planning in
protecting and enhancing the environment, the important policy
improvements secured in recent years designed to promote urban
renewal, and the implications of major new housebuilding for sustainable
development.
15. CPRE made several submissions during
the course of the review. We published research which revealed
that the area of land with outline planning permission held in
the top 15 housebuilders' landbanks increased by 17.6% between
1998 and 2002. We highlighted that the output of new houses for
sale in England had remained broadly static over the past 25 years
and had actually risen in recent years, from 117,000 in 2000-01
to 124,000 in 2002-03. And we pointed out the main reason why
the total output of new homes was at an historically low level
was the dramatic decline in the provision of new social housing
from over 100,000 each year in the 1970s to under 20,000 in recent
years.
16. Following the publication of Kate Barker's
Interim Report in December, we commissioned two research reports:
a critique of her economic analysis, A Basis on Which to Build?
and an exploration of the implications of this analysis for
the Government's wider environmental, social and economic objectives,
Missing Links.
17. A Basis on Which to Build? highlighted
that the Interim Report provided no solid evidence of an overall
undersupply of homes in the UK, and challenged the view that a
massive increase in housebuilding would solve the problem of the
lack of homes people on lower incomes can afford. Recent data
from the 2001 Census, referred to in the Interim Report, indicates
that there is a significant surplus of dwellings over households
in all regions in England and that this surplus has grown since
1991 (except in London where the balance is unchanged). Across
England, the excess of dwellings over households has grown from
2.4% to 3.7% from 1991 and 2001. The final report of the Barker
Review chose to overlook this data.
18. A further weakness of the Barker Review,
attributable in large part to its narrow remit to explore supply-side
issues, concerned its lack of attention to demand-side factors
in the housing market. These factors include an individual's willingness
to pay for new housing which is influenced, for example, by interest
rate levels, and the treatment of housing as an private investment
good. We believe such demand-side factors warrant careful consideration
in the development of policy measures to tackle house price increases.
We urge the committee to examine closely the gaps in the economic
analysis set out in the final report of the Barker Review.
19. For CPRE, the biggest flaw in the analysis
set out in the Barker Review concerns the environmental implications
of the very substantial increases in housebuilding levels it envisages.
Parts of the final report are fatalistic in suggesting damaging
environmental consequences are inevitable if we are to boost housebuilding
to the levels suggested. Paragraph 1.34 of the report, however,
acknowledges that: "There is no attempt to estimate the overall
cost for the environment or amenity." And Kate Barker herself
said, at the launch of the report, that she had not taken environmental
considerations fully into account and that this would be a matter
for ministers.
20. Despite this acknowledgement, it is
disappointing to note that the Barker Review sought to underplay
the impact of an increase in housebuilding in terms of land-take
and wider environmental consequences. Paragraph 1.46 of the final
report claims that an extra 120,000 homes each year in the South
East over and above existing plans would mean using an additional
0.75% of the total land area of the region (assuming an average
density of 30 dwellings per hectare and 60% of homes are on brownfield
land). This claim is preceded in paragraph 1.45 by references
to the land that is urbanised in England for which no source is
provided and which is much lower than previous official estimates.
Moreover, these figures relate only to direct landtake and do
not take account of the wider urbanising impact of development
referred to above. At the very least, we believe the figures for
urbanisation used in the report are problematic and we would urge
the Committee to treat them with caution. On top of this, and
in the light of its remit to consider the Government's sustainable
development objectives, in a throwaway line the report simply
states: "Extra housebuilding will have environmental consequences
and this cannot be ignored, however, the impact can be reduced
by ensuring that land which society values least is used and tackling
issues of water usage and waste management." (paragraph 1.46)
21. In CPRE's view, the absence of any serious
analysis of the implications for sustainable development means
that the Review largely overlooked the optimum solutions to the
problems of housing affordability. These solutions, we believe,
would involve further measures to target new housing on previously
developed (brownfield) land and buildings, securing an increase
in the average density of new housing in line with established
Government policy, and a stronger focus on meeting the needs of
those who find it hardest to afford a home to rent or buy at market
prices. These optimum solutions would allow overall environmental
and social gains to be achieved. There is a serious risk is that
the Government may choose to overlook or underplay the environmental
consequences in the light of an overwhelming desire to deliver
increased housebuilding levels in the short term.
22. The final report of the Barker Review
contains a number of important recommendations which are likely
significantly to influence the Government in its review of planning
and other policies. Some of these other proposals, CPRE believes,
are to be welcomed, such as the proposal to extend tax credits
and grants to long term derelict land (recommendation 25); the
importance of local authorities' imposing higher (up to 90%) council
tax charges on second homes in order to improve the efficiency
of the use of the existing housing stock; and measures to improve
the quality of new housing and construction methods (recommendations
32-35).
23. Other recommendations in the Barker
Review raise interesting questions concerning the use of tax measures
to extract some of the windfall gain arising from development
(a "Planning-gain Supplement" equivalent to a betterment
tax) (recommendation 26), the concomitant scaling back of Section
106 (planning gain) requirements (recommendation 24), and the
need for a Community Infrastructure Fund to bring forward otherwise
unviable development (recommendation 22).
24. A number of the Barker Review's recommendations
to alter the development control and local planning processes,
however, threaten to weaken environmental protection and undermine
the significant improvements recently secured in planning for
new housing through PPG3 with its focus on urban renewal and improvements
in design and density (recommendations 7, 9, 10, 11, 12, 14, 16,
and 23). Another, perhaps even more serious, concern is that the
Government decides to pursue the recommendation in the Barker
report that revised planning guidance should consider the "relative
value that society places on different types of land use"
(recommendation 10). Disturbingly, this is echoed in the Government's
draft Planning Policy Statement (PPS) 1 Creating Sustainable Communities.
Such an approach would fundamentally alter our historic approach
to greenfield and landscape protection to the detriment of the
environment, and is likely to be extremely difficult to implement.
25. We also have a particular concern that
proposals for local authorities to identify "buffer"
land in their plans which would be brought forward in response
to evidence of market "disequilibrium" combined with
a more cautious approach to the "viability" of brownfield
redevelopment will add to pressure to allow more greenfield development.
Moreover, we have serious concerns about measures proposed to
extend the role of regional planning bodies in managing regional
housing markets (recommendations 5, 6, 8, and 13) and to provide
incentives for local authorities to meet housing targets (recommendations
17 and 18).
ISSUES RAISED
BY THE
COMMITTEE
26. In summary, drawing on the principles
and positions set out above, this section provides brief responses
to some of the questions raised when the Committee announced its
inquiry. CPRE would be pleased to provide further detail on these
issues if necessary.
Are the conclusions of the Barker Review compatible
with the general principles of sustainable development?
27. For the reason set out above, we do
not believe that the conclusions of the Barker Review are compatible
with sustainable development principles. Sustainable development
requires the integration of environmental, social and economic
considerations and the final report clearly pays little or no
attention to environmental, or indeed social factors.
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?
28. CPRE believes that there is a need for
a more coherent national framework for the preparation of regional
spatial strategies which addresses the environmental and land
use dimensions of regional economic disparities, and promotes
measures to reduce development pressures in the wider south east
and secure urban renewal and reduced greenfield sprawl throughout
the country. The Communities Plan, and associated documents, is
seriously lacking in relation to environmental considerations
and needs radical overhaul
Is the current planning system robust enough to
ensure that the environmental implications of building projects
are fully taken into account? Would the proposed changes to the
planning system in the Barker Review have a positive or negative
effect on the environment?
29. CPRE does not believe the planning authorities
have the powers, tools or resources effectively to take account
of environmental implications of new development. Some recent
improvements have been made through the Planning Delivery Grant
and the reformed approach to planning for housing in PPG3 but
these risk being undermined by proposals in the Barker Review
which we believe would have a seriously damaging effect on the
environment in town and country. We also have some serious concerns
about the effectiveness of the reformed planning system following
the Planning and Compulsory Purchase Act 2004.
Where will the proposed new housing be built?
What are the implications for land use and flood-risk?
30. CPRE has particular concerns about proposed
increases in housing levels in the Milton Keynes/South Midlands
and M11 Corridor Growth Areas where the environmental damage and
loss of attractive, open countryside could be considerable. Flood-risk
is an important consideration in the redevelopment of the Thames
Gateway and flood-defence infrastructure will have environmental
implications, particular in terms of aggregates demand. Limiting
the amount of greenfield development in the Thames Gateway will
reduce the risk of fluvial flooding and the need for new flood
defences.
Is it possible to ensure materials and resources
used, and waste produced, during building do not have a harmful
impact on the environment?
31. The environmental impact of building
can be reduced by adopting key principles of sustainable construction
including: a sequential approach to development favouring previously
used land and buildings to minimise the direct environmental impact;
improved design to reduce the demand for resources in building
construction and operation; improved construction methods to improve
the efficiency of resource use; and use of resources from sustainable
sources through the re-use or recycling of previously uses materials
or use of new alternative technologies, such as for small scale,
"embedded" renewable energy generation.
Are the building regulations as they stand capable
of ensuring that new housing is truly sustainable in the long
term?
32. This is not an area where CPRE has particular
expertise but it seems clear that there is a need for major improvements
to building regulations to achieve more sustainable new housing.
We welcome the work of the Sustainable Buildings Task Group and
the new Code for Sustainable Building but believe much more urgent,
concerted and effective action is required in this area.
How will it be possible to ensure a sustainable
infrastructure to support any extensive housebuilding is put in
place?
33. CPRE believes that implementation of
the Barker Review would impose huge, unsustainable infrastructure
costs on the public purse. We believe this is a further reason
for favouring the redevelopment of previously used land and buildings
over greenfield development. While it is clear that much existing
infrastructure in urban areas will need renewing and extending,
the costs of achieving this are likely to be substantially less
that the often "hidden" infrastructure costs associated
with greenfield use. We draw the Committee's attention to the
valuable work of Professor Anne Power at the LSE in this area.
Do those involved in housing supply have the necessary
skills and training to ensure new housing meets environmental
objectives?
34. There are clear indications that a lack
of skills and training are vital factors in the underperformance
of the planning system and housing sector. We believe that too
many developers and local authorities lack capacity in terms of
design skills and unlocking brownfield capacity, for example through
the use of compulsory purchase powers. We broadly welcome the
outcome of the Egan Review of Skills for Sustainable Communities
which identified significant `generic skills and people shortages'
among built environment professionals, but believe there needs
to be a stronger emphasis in this sector on environmental knowledge
and best practice.
CONCLUSION—A
BETTER WAY
FORWARD
35. CPRE believes the Committee's inquiry
presents a significant opportunity to influence the Government's
response to the Barker Review. We hope the inquiry can help ensure
that any legislative, policy or institutional changes introduced
as a result of the Review:
— help to unlock the potential for
the redevelopment of previously used land and buildings in order
to make better use of existing housing stock, and to guide development
to where it can provide most environmental benefit in terms of
conserving valued, undeveloped landscapes, regenerating urban
areas and reducing the need to travel;
— significantly increase resources
going into the provision of social housing and enhance the capacity
of the planning system to deliver more affordable homes to meet
identified needs of those who suffer greatest housing disadvantage;
— secure improvements in the design
of new housing so that it meets high environmental standards,
and is built at higher densities than the bulk of existing new
developments;
— involve concerted action to reduce
regional disparities, including measures to reduce development
pressures in the wider south east, while promoting urban renewal
and resisting greenfield sprawl; and
— improve the capacity of the planning
system to control effectively the level of new housebuilding within
environmental capacity constraints.
36. We urge the Committee to recommend that
the Government carries out a thorough assessment of the environmental
effects of implementing the recommendations of the Barker Review,
and pursues alternative approaches to meeting the nation's housing
needs while protecting the countryside based on the objectives
set out above.
June 2004
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