Select Committee on Environmental Audit Minutes of Evidence

Memorandum from the Campaign to Protect Rural England (CPRE)


  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.


  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.


  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).


  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.


  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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