Annex
FIVE FAILINGS: HOW PROGRESS WITH THE GOVERNMENT'S
COMMUNITIES PLAN MEASURES UP IN TERMS OF SUSTAINABILITY
When the ODPM launched the Communities Plan
in February 2003, CPRE responded by setting out five tests. We
believe these tests should be used to judge whether the plan is
delivering sustainable development—in which social and economic
progress is made while the environment is protected and enhanced.
Pre-emptive strike—this test concerned
the importance of allowing independent testing of proposed housebuilding
figures in line with the Government's own "plan, monitor
and manage" approach set out in PPG3, rather than imposing
top-down targets on local authorities without regard to their
environmental impact. We have been disturbed by a number of instances
where the Government has sought to pressurise local authorities,
and in the former case the independent panel appointed to oversee
the Public Examination, not to question the need for higher housing
provision in connection with the Milton Keynes and South Midlands
and M11 Corridor Growth Areas;
Wasted space—this test concerned
the need for radical improvements in the efficient use of land
and other natural resources, including higher housing densities.
While the Government states it is committed to reducing the wasteful
use of land, the average density of new housing remain unacceptably
low. ODPM figures published in May show that although there have
been improvements in housing densities over recent years, in 2003
the average density of new housing stood at only 30 dwellings
per hectare (dpha)—the bottom of the target range in PPG
and well below the 40 dpha required to support a viable bus service
for example. In addition, the Communities Plan was unambitious
in its aspirations for higher standards in sustainable construction.
While the Sustainable Buildings Task Group has made some progress
in setting best practice environmental standards in housebuilding
in its Code for Sustainable Buildings produced in May, the Government
appears reluctant to make these standards mandatory.
Missing a trick—the test concerned
the need for Government to adopt a higher target for the reuse
of brownfield land for new housing. Despite meeting its 60% brownfield
target seven years early, and despite last year achieving 66%
of new dwellings from previously developed land and conversions
(for the second year running), the Government refuses to raise
the brownfield target in order to make effective use of the continuing
high levels of derelict urban land. The National Land Use Database
shows that of 65,500 ha of previously developed land across England,
at least 29,000 ha is suitable for housing—enough for nearly
1.5 million homes at medium densities of 50 dwellings per ha.
And nearly one third of previously developed land is in the South
East, London and East of England regions. There are also more
than 700,000 empty homes across the country. CPRE has consistently
called for an increase in the brownfield target to 75% in order
to promote the more effective use of this wasted resource. We
believe the evidence increasingly shows this is realistic.
Tackling regional disparities—CPRE
wants to see the Government adopt a coherent strategy to share
economic opportunities across all the English regions and to reduce
regional disparities while protecting the environment and the
countryside from urban sprawl. To some extent this test is reflected
in the joint PSA between the ODPM, Treasury and Department of
Trade and Industry. But we fear that the Communities Plan with
its focus on promoting growth in the already overheated and overcrowded
South East will only exacerbate regional imbalances. Moreover,
proposals in the Northern Way produced by the ODPM earlier this
year concerning a northern economic growth corridor centred on
the M62 risk frustrating efforts in the northern regions to promote
urban renewal and more sustainable patterns of development. CPRE's
report Even Regions, Greener Growth (2002) sets out the need for
a coherent national approach to sustainable development in the
English regions in order to encourage more investment in urban
areas outside the wider south east which are most in need of regeneration
in order to relieve pressures elsewhere.
Planning for people—the test here
is to ensure genuine opportunities for participation by local
communities in decisions on plans for new development in their
areas. While the Minister for Planning and Housing has frequently
referred to the need for local communities to be involved in local
planning processes, the reality is that the creation of so-called
"special delivery vehicles" such as Urban Development
Corporations to secure development in the growth areas tends to
make it harder for local communities to influence decisions. CPRE
believes that this, coupled with provisions in the Planning and
Compulsory Purchase Act 2004 which abolish County Structure Plans
and Unitary Development Plans as the main vehicle for strategic
planning, replacing them with new Regional Spatial Strategies
administered by remote, unelected regional bodies, is likely to
seriously reduce the effective involvement of local communities
in planning processes.
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