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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