Select Committee on Environmental Audit Minutes of Evidence



  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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