Select Committee on Environmental Audit Minutes of Evidence


Memorandum from the Countryside Agency

1.  The Countryside Agency welcomes the opportunity to submit evidence to the Select Committee's Enquiry into the environmental implications of the Barker Review of Housing Supply and Government policy for sustainable housing.

2.  The Countryside Agency is the statutory body working to make:

    —  the quality of life better for people in the countryside;

    —  the quality of the countryside better for everyone.

  The Countryside Agency helps to achieve the following outcomes:

    —  empowered, active and inclusive communities;

    —  high standards of rural services;

    —  vibrant local economies;

    —  all countryside managed sustainably;

    —  recreation opportunities for all;

    —  realising the potential of the urban fringe.

  We summarise our role as:

    —  statutory champion and watchdog;

    —  influencing and inspiring solutions through our know how and show how;

    —  delivering where we are best placed to add value.

  3.  The Countryside Agency has a statutory duty to advise Ministers and assess the impact of Government policies on the countryside and rural communities. We have a particular duty to advise government on designation of and policies relating to nationally designated landscapes (National Parks and Areas of Outstanding Natural Beauty). We have a great deal of experience in our community forests work and in other ways of working on development and environment issues in the areas around our great cities.

SUMMARY OF EVIDENCE

4.  The Countryside Agency believes that we should be creating sustainable communities in which people want to live, work and play and which enhance the environment. The need to meet housing requirements and increase housing affordability must be pursued in a way that also improves the environment and enhances local communities. We must grasp the opportunity to meet housing needs in ways that enhance the environment and improve quality of life. We must create locally distinctive and high quality environments that future generations will be proud of. The planning system has an important role to play in delivering high quality sustainable communities and should be given the tools and resources to do the job effectively.

5.  The Countryside Agency believes that if additional housing development is to take place, far greater emphasis should be placed on the quality of new development and the needs of rural areas. The following measures would greatly assist:

    —  More vision-led planning policies and supporting guidance on sustainable development that inspires a new approach to development; (see paragraphs 16-19).

    —  Additional resources and support for local authorities and local communities to fully implement the planning reforms; with a clearer obligation on local authorities to lead developers in coming up with practical ways of delivering the development society needs (see paragraph 17).

    —  A requirement that the planning system should be used to deliver quality sustainable development that enhances local character with local development documents setting out clear quality criteria (see paragraphs 20-21).

    —  The Building Regulations revised to incorporate sustainability considerations including energy and water efficiency and the re-use and recycling of materials (see paragraph 35).

    —  Local communities actively involved in planning for the future of their areas and directly shaping development proposals (see paragraph 22).

    —  Local communities receiving direct and substantial benefits from development in their areas (e.g. through offsetting environmental and social gains) (see paragraphs 32, 36 and 38).

    —  A significant proportion of the value of the planning-gain tax passed directly to local councils to spend on local community benefits (see paragraph 37).

    —  A significant new funding programme to deliver community forestry within the countryside close to towns and enhance land in the Green Belt.

    —  A significant new funding programme to deliver community renewable energy schemes in development areas.

    —  Additional compulsory purchase powers to enable regional and local authorities to acquire derelict land left vacant and unmanaged.

INTRODUCTION

  6.  Housing is a basic human right. We support Government policy that everyone should have the opportunity of a decent home and a reasonable choice of location. As a nation, we should plan to meet the housing requirements of the whole community, including those in need of affordable and special needs housing in both urban and rural areas. It should be recognized that simply increasing the level of housebuilding may not improve affordability locally in rural areas and a range of measures will be required. Securing a mix of housing types and tenures is a key part of achieving sustainable balanced communities; so all new housing development should include an appropriate balance of owner occupied and rented housing. Our evidence focuses on the environmental aspects of a sustainable housing policy but it is vital that issues of social cohesion and economic prosperity are also addressed.

7.  We welcome the main conclusion of the Barker report that there is a significant shortage of affordable housing. Indeed, the shortage of affordable housing is one of the most critical issues affecting the future of the countryside and rural communities. The Agency has estimated that there is a need for at least 10,000 new affordable homes per annum in rural districts, just to meet the needs of households who already live in those areas. Without any further increase in the supply of affordable rural housing, many of those in rural communities (especially, but not only, young adults) will find it difficult to remain there. The Countryside Agency therefore welcomes the commitment to create sustainable communities in rural as well as urban areas set out in the Sustainable Communities Plan.

8.  The Agency supports the development that is necessary to meet housing needs and contribute to economic prosperity. We are keen to help find solutions to the lack of affordable housing and to meet housing needs in ways that are consistent with sustainable development principles. The level of growth set out in the Sustainable Communities Plan presents a significant and timely opportunity to improve the quality of development and ensure it delivers a net gain for the economic, social and environmental interests of the areas identified for growth. Exemplar sustainable communities should be created in the Growth Areas with the lessons learnt applied to development in other parts of the country.

9.  The level of housing development proposed in the Sustainable Communities Plan and by the Barker review would have significant and far-reaching environmental implications. These implications must be fully and properly addressed and we welcome the Select Committee's Enquiry and the opportunity to contribute to the debate. Large-scale housing development impacts on all aspects of our natural environment—our landscape, heritage and biodiversity interests and affects the use of natural resources such as energy sources, water, and minerals resources. It affects the character and identity of settlements and quality of life of existing residents. The challenge is to find solutions to our housing needs in ways that minimise environmental impacts, prevent environmental pollution and congestion and enhance the quality of life for new and existing communities. The Countryside Agency's view is that a sustainable housing policy that meet needs for housing in both rural and urban areas can and should be developed in ways that deliver environmental, social and economic benefits to the areas concerned. We expand upon this further in our responses to the questions set out in the Select Committee's invitation to submit evidence below.

Are the conclusions of the Barker Review compatible with the general principles of sustainable development and the Government's own sustainable development objectives?

10.  The UK strategy for sustainable development—A better quality of life (1999) sets out four objectives, which should be met at the same time:

—  Social progress which recognises the needs of everyone;

—  Effective protection of the environment;

—  Prudent use of natural resources;

—  Maintenance of high and stable levels of economic growth and employment.

11.  Other principles set out in the 1999 strategy include the need to take a long term perspective to protect the interests of future generations, the need to respect environmental limits to avoid serious or irreversible damage and the application of the precautionary and polluter pays principles. The Government is currently consulting on a new strategy for sustainable development. It should reaffirm these key principles and the need for all Government policies to uphold them. These principles should form the basis of a sustainable housing policy.

12.  The planning system has an important role to play in delivering sustainable development. This is reflected in the Planning and Compulsory Purchase Act, which requires regional and local plans to be prepared with a view to contributing to the achievement of sustainable development. Draft Planning Policy Statement 1 sets out how this should be done, stating that the four aims of sustainable development should be tackled in an integrated way. We welcome the emphasis on an integrated approach to sustainable development although we consider that the wording of draft PPS1 could be strengthened.

13.  The Barker Review report makes various references to the need to "balance" economic, social and environmental objectives and make "trade offs" between them. Sustainable development requires that economic, social and environmental objectives should be met together and we reject the assumption that economic imperatives should over-rule environmental objectives. We should recognise that the environment is an asset that contributes significantly to the economic and social well being of the UK. Protection and enhancement of our environment and wise use of our natural resources is therefore fundamental to the future prosperity of Britain.

14.  The Countryside Agency believes that to be sustainable, all development should deliver a net gain (or at least a neutral effect) for the social, economic and environmental interests of the area, with no significant losses to any of them. This means protecting our precious natural assets—our finest landscapes and important heritage and biodiversity interests from development that would adversely affect them. It means mitigating or compensating those losses that will not be significant through the use of planning conditions and obligations, for instance, by providing new landscape features or recreation facilities offering equivalent or greater benefits to those lost. In addition, it means delivering community and environmental benefits to the people affected by development. In short it means, securing the types of development that the Countryside Agency terms "good enough to approve".

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?

15.  The Countryside Agency agrees that environmental objectives are integral to a sustainable building programme. The Government is currently reviewing its sustainable development strategy. This should form the starting point of all Government policies and underpin a sustainable housing policy. If the environmental aspects are properly addressed in the review of this strategy, then there should be no need for a further national strategy to ensure that the environment is fully considered in any future building programme. Forthcoming Government guidance on strategic environmental assessment and sustainability appraisal together with guidance on the process and content of the new planning system should ensure that environmental issues are properly incorporated in new regional spatial strategies and local development documents. More specific environmental guidance targeted at those involved in the delivery of new housing including developers and financiers might also be useful.

Is the current planning system robust enough to ensure that the environmental implications of building projects are fully taken into account? How can the planning system be used to increase the building of more sustainable housing? Would the proposed changes to the planning system in the Barker Review have a positive or negative effect on the environment?

16.  We consider the planning system has an important role to play in increasing the supply of housing in ways that are consistent with sustainable development. The Countryside Agency supports the plan-led system and endorses the principles underpinning the reform of the planning system, particularly the need to make the system more visionary, spatially based and inclusive. We have commented in detail on the proposed changes to the planning system and revisions of government planning policy and guidance (particularly PPS1, PPS7 and changes to PPG3 and proposals to amend the system of planning obligations).

17.  Significant changes are envisaged to the planning system that will make the system more responsive to meeting housing needs. The emphasis on spatial planning, "front loading" of the system, greater community and stakeholder involvement and the emphasis on the "soundness" of the plan together with speedier plan revisions will help bring forward suitable sites for development and should help reduce resistance to development. It is important to ensure that the desire to speed up the planning system is not pursued at the expense of measures to improve quality. We believe that the significant changes to the planning system arising from the Planning and Compulsory Purchase Act together with the enormous culture change that will be required to bring the changes into effect needs time to be implemented properly. In addition, local planning authorities will need considerable resources, support and further guidance to operate the new system effectively.

18.  The Countryside Agency does not support recommendations in the Barker review report that would undermine the plan led system or frustrate the implementation of the planning reforms. Some of the recommendations in the Barker report seem to be leading us back to a "predict and provide" system of planning. In particular, we strongly disagree with the recommendation (recommendation 9) that an additional 20-40 % of land should be allocated ass a buffer to improve the plan's responsiveness to changes in demand. The "plan, monitor and manage" approach together with more frequent plan reviews should be sufficient to ensure that additional housing sites can be brought forward if required to meet identified local housing needs.

19.  ODPM is preparing a package of guidance to support the introduction of the new planning system. Guidance on the requirements of Sustainability Appraisal and Strategic Environmental Assessment will be particularly useful in ensuring that the environmental implications of new development are properly considered. We have already advised ODPM that PPS1 should be strengthened in respect of sustainable development requirements; accompanying guidance setting out the standards that development should meet would be useful. The Countryside Agency, English Nature, English Heritage and the Environment Agency will also be publishing guidance on how sustainability interests can best be addressed in Regional Spatial Strategies and Local Development Frameworks.

20.  Where the planning system can and should go further is in promoting quality development. One of the Countryside Agency's key planning principles[1] is that we should consider what development is needed as well as where it should go with plans considering not just the traditional location of development but the nature of that development too. We believe that development proposals should be determined on the basis of are they "good enough to approve" rather than are they "bad enough to refuse".

21.  Our definition of high quality is about more than building design. The quality of development includes its scale, its location, its mix of uses, its energy and resource efficiency and its long -term flexibility to adapt to changing needs and circumstances. The Countryside Agency promotes an approach that seeks to re-connect the design and construction of new buildings with the environment and promote modern, sustainable, high quality buildings that accept and enhance local character.[2] The planning system has an important role in setting out the standards that development should meet. Local Development Documents should set out the criteria that a development must meet in the locality if it is to be good enough to approve. These criteria will vary, reflecting the differing needs and characteristics of different parts of the plan area, with more stringent criteria applied to development in designated areas.

22.  There are various tools and techniques that can be used as part of the planning process to improve and promote quality development. Development briefs, master plans, design guides and design codes can all have a role to play in setting out the detailed requirements and standards that development should meet. New style area action plans and supplementary planning documents will set out proposals for particular areas. All local stakeholders including developers and local communities should be involved in the preparation of these documents to ensure they reflect local needs and circumstances and are realistic and deliverable. Developers will welcome the certainty that a strong planning framework provides, and will be able to incorporate requirements into development proposals from the outset and reflect them in the price they pay for the land. Local residents are more likely to accept development in their areas if they are involved in the process and are confident of valuable, substantial community benefits as a result. We should be planning developments that residents will enthusiastically welcome rather than oppose.

 23.  Some examples of the tools and techniques promoted by the Countryside Agency to improve the quality of development are set out in Annex 2. The Government should emphasise the importance of quality development and local distinctiveness in planning guidance and refer to the range of tools and techniques that can be used and the bodies that can offer advice to achieve this.

24.  There are currently few examples of genuinely high quality sustainable communities being built. The Millennium Communities, National Trust and Joseph Rowntree Foundation are leading the way in creating exemplar developments but more needs to be done to mainstream these types of developments and encourage the private sector to adopt innovative approaches. New initiatives such as the strategic green infrastructure approach being taken in the Milton Keynes and South Midlands sub-region, which proposes a network of multifunctional greenspace as an integral part of the planned growth, should be adopted more widely. We should learn and apply the lessons from these new initiatives together with those from the Garden Cities and the best of the new towns.

Where will the proposed new housing be built? What are the implications for land-use and flood risk of the large- scale proposed building projects?

25.  The Barker Review takes a macro-economic perspective and does not take into account the regional and local variations in housing needs and differences in housing markets across the UK. Indeed, a spatial perspective is entirely lacking from the report. It is important that account is taken not only of the differences in regional housing markets and levels and type of housing needs but also of regional and local geographies (including settlement patterns), environmental conditions and constraints. The spatial implications of the proposals will, therefore, need to be rigorously assessed at the regional, sub-regional and local levels.

26.  There should be no "one size fits all" approach to determining the amount or location of development and it is important that simplistic assumptions about settlement hierarchies and appropriate locations for development are avoided. Policies should be based on a robust local evidence base that identifies local needs and fully considers the spatial implications of locating development in particular areas.[3] If we are serious about creating truly sustainable new communities rather than dormitory settlements (with residents commuting long distances to larger urban areas to meet their employment and service needs) we should encourage development in those locations where demonstrable local sustainability benefits will result. This approach is equally applicable to the inner city and rural settlements.

27.  The Countryside Agency broadly supports the sequential approach to the allocation of land for housing development set out in Planning Policy Guidance Note 3 (PPG3). We agree that the majority of new housing development should take place within existing urban areas (including market towns), maximising the use of appropriate previously developed land and buildings and increasing housing densities in order to support the urban renaissance and reduce pressure on the countryside for new development. Government should redouble its efforts to promote the urban renaissance, applying the lessons of successful regeneration in cities like Leeds and Birmingham elsewhere.

28.  Sustainable urban extensions will be needed in many areas once brownfield sites are built out or where little previously developed land exists. We accept that this might involve minor revisions to Green Belt boundaries where this would result in the most sustainable option for development in a particular locality. Any boundary changes should go hand in hand with significant environmental enhancement of the land in the rest of the green belt. There may also be opportunities to create new high quality self- contained settlements in areas with little environmental interest and excellent public transport potential.

29.  Much of our future housing (and other) development needs will have to be met within the rural urban fringe as sites within urban areas are built out. The Countryside Agency, in association with Groundwork, recently published for consultation its vision for the rural urban fringe entitled Unlocking the potential of the rural urban fringe (2004) (copy attached). This sets out our view of a rural urban fringe that is attractive, accessible, diverse and multi- functional. It serves the needs of both urban and rural communities, strengthens the links between town and country and contributes fully towards sustainable development. We consider there is considerable potential to create exemplar developments within these areas, genuinely sustainable communities that retain the qualities of the countryside on which they are built, enhance their rural setting and provide their residents with a well-planned environmental infrastructure, green spaces and links to their surrounding countryside. We are working within the Growth Areas to demonstrate how quality sustainable development can be achieved in practice.

30.  We must also ensure that the housing needs of rural areas, which often lack brownfield sites, are met. Development should be promoted in market towns where this would support local sustainable development objectives (for example reinforcing a town's role as a local service centre or bringing tangible regeneration benefits). A substantial level of increased housing development may be appropriate in some market towns where clear local benefits can result. An appropriate scale and type of development should also be permitted within and adjacent to villages in order to meet local needs, especially for affordable housing and to help stem the decline of local services. We welcome the Government's proposal (set out in proposed amendments to PPG3 Housing) to enable local planning authorities to allocate sites for affordable housing.

31.  The protection and enhancement of our finest landscapes as an environmental asset for future generations is an important element of sustainable development. In considering appropriate locations for new housing development, proper account must be taken of our nationally designated landscapes- our National Parks and Areas of Outstanding Natural Beauty. It is Government policy that the conservation of the natural beauty of the countryside in these areas should be given the highest level of protection (PPG7, paragraph 4.2) and that major development should only take place in exceptional circumstances (PPG7, paragraph 4.5). Within the regions proposed for significant growth in the Sustainable Communities Plan (South East, Eastern and Eastern Regions) there are fourteen Areas of Outstanding Natural Beauty (AONBS) and two proposed National Parks (New Forest and South Downs). Any development affecting these areas should be of the highest possible quality with stringent quality criteria set out in Local Development Documents. Opportunities should also be taken to ensure that development in the Growth Areas brings benefits to communities within protected areas and that local needs, especially for affordable housing, are met.

32.  It is important that the rural impacts of the Barker review and the Sustainable Communities Plan are fully considered and that all policies and proposals are "rural proofed". We have highlighted above the opportunities for accommodating appropriate growth within the rural urban fringe alongside significant environmental enhancement and the need to ensure rural housing requirements are met. In addition we will need to consider the effects on those rural communities lying beyond the areas planned for growth and the opportunities for those communities to share in the benefits of growth, rather than suffer the adverse consequences of pollution and congestion. We are currently studying the impacts of the proposed Ashford Growth Areas on the surrounding rural communities. Some rural impacts of the proposed growth are identified in Annex A.

33.  Transport policies also have a fundamental role in creating sustainable communities. Planning and transport policies should work together in a way that contributes to improved accessibility rather than increased mobility.[4] New housing developments should be located in places with good public transport links (or where such links can be provided), and walking and cycling access should be strengthened. The most sustainable transport options should be available from the earliest stages of new developments as it is harder to encourage change once car-dependent lifestyles have been established. The provision of adequate local facilities and attractive, easily accessible open spaces should be incorporated into the design of all new developments to reduce the need to travel for everyday services and recreational activities. Transport should be planned as a network, where various modes provide access to a range of local services and facilities. Innovative solutions such as demand responsive transport and mobile services should be included as part of the package.

34.  Large-scale proposed building projects would have considerable flood risk and water resources implications. We commend the evidence of the Environment Agency on these issues to the Select Committee.

Are the building regulations as they stand capable of ensuring that new housing is truly sustainable in the long term? How could they be improved? Could greater use be made of existing environmental standards for housing?

35.  The Building Regulations have the potential to considerably improve the sustainability of individual buildings, supporting and complementing the planning system's role in influencing the overall design and layout of developments. The current Building Regulations already deliver some sustainability objectives, such as energy conservation although this could be strengthened. Sustainability considerations should be explicitly brought within the scope of the Building Regulations with the regulations broadened to address issues such as water efficiency and the re-use and recycling of materials. The use of environmental standards such as the BRE "ecohomes" is becoming more common and should be adopted more widely. For instance, the Housing Corporation requires that all social housing schemes it funds use a sustainability indicators toolkit and achieve a "good" ecohomes rating. Development in the Growth Areas should set an example with all development meeting the ecohomes "very good" or "excellent" rating. We commend the recent report of the Sustainable Buildings Task Group "Better buildings-better lives" to the Select Committee and urge Government to strongly consider its recommendations on improving the environmental performance of buildings and introducing a national Code for Sustainable Building.

How will it be possible to ensure a sustainable infrastructure, including transport and water supply, which will be necessary to support any extensive housebuilding, is put in place?

36.  It is vital that transport and other infrastructure is delivered as an integral part of new development and provided at the same time as the housing development. Infrastructure will need to be delivered via a combination of public and private sector funding. The proposals set out in the Barker Review, such as the Community Infrastructure Fund, will need further exploration. Much stronger and more productive mechanisms should be developed to pass significant infrastructure contributions direct to local communities, eg via parish and town councils, to spend on transport and other improvements that the community wants. The new `spatial planning' approach should be used ensure that there is greater partnership working and policy co-ordination amongst the various infrastructure providers and that investment decisions support spatial strategies. Regional Development Agencies have an important role to play here.

37.  The Barker review recommends the introduction of a Planning-gain supplement (recommendation 26) to extract some of the windfall gain that accrues to landowners from the sale of their land for residential development together with the scaling back of Section 106 agreements to cover direct impact mitigation and affordable housing (recommendation 24). We strongly support the principle that the community should share in the benefits of development. The benefit of this proposed tax should be mainly received by the local community affected by the development, rather than disappear into Treasury general funds.

38.  We consider that planning obligations have considerable potential to be used as a more effective and positive planning tool that secures both the sustainable elements of a scheme and off-site compensatory provision. They should be used to deliver significant local community and environmental benefits to help encourage local communities to accept, or even welcome, development in their areas. Community Forests, such as the Forest of Marston Vale, for example, are using developer contributions to secure substantial environmental regeneration benefits. This should be the norm. We are opposed to standard tariffs that will do little to deliver local benefits or increase the sustainability of development proposals. We await further Government consultation on reforms to the system of planning obligations.

Do those involved in housing supply, both in the public and private sector, have the necessary skills and training to ensure new housing meets environmental objectives? If not, how can the knowledge base of those involved in the planning and building process be improved?

39.  No. Emphasis should be placed on ensuring all those involved in delivering housing development have the necessary skills, training and expertise. There is a need to broaden the skills base and connect up the various professionals involved in the process. The skills and resources needed by local communities to get more involved in planning for the future of their areas should also be considered. Current initiatives, such as the Egan Review, the RTPI's education initiative and the Government's drive to recruit more planners should assist. It is especially important that environmental education and awareness is increased so that the environment is seen as an asset rather than a constraint to development.

May 2004



1   See our planning statement, Planning Tomorrow's Countryside CA 60, 2000, copy attached. Back

2   See Towards a new vernacular, a report to the Countryside Agency, Architype 2003. Back

3   Recent research for the Countryside Agency (Land Use Consultants/SERRL/Emma Delow- The role of rural settlements as service centres (January 2004) challenges simplistic assumptions about locating development in larger settlements in order to help retain local services and facilities, underlining the importance of basing policies for development on a detailed local evidence base and understanding of how settlements function. Back

4   The Countryside Agency's transport policies are set out in Transport in Tomorrow's Countryside 2003. Back


 
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