Memorandum from the Royal Town Planning
Institute
INTRODUCTION
1. The report of the Barker Review of Housing
Supply, published by HM Treasury in March 2004, concluded that
a very substantial increase in annual new house completions in
England was required if Treasury objectives were to be met. The
Environmental Audit Select Committee is concerned by the environmental
implications of an annual increase in house completions of almost
100%—from 125,000 to 245,000—and has decided to hold
this inquiry to consider how future building programmes can be
made truly sustainable and take full account of environmental
objectives.
2. The inquiry will look into the environmental
implications of the Barker Review in particular, and Government
policy for sustainable housing in general. The Committee is concerned
about the Review's suggestion that economic considerations (with
regard to new housing) may have to overrule environmental objectives.
The issues of specific concern to the Committee are:
— are the conclusions of the Barker
Review compatible with the general principles of sustainable development
and the Government's own sustainable development objectives?
— 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?
— 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 in the planning system in the Barker
Review have a positive or a negative effect on the environment?
— 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?
— is it possible to ensure materials and
resources used, and waste produced, during building do not have
a harmful impact on the environment?
— 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?
— how will it be possible to ensure a sustainable
infrastructure, including transport and water supply, which will
be necessary to support any extensive house building, is put in
place?
— 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?
GENERAL COMMENTS
3. This submission takes the form of introductory
comments followed by brief answers to each of the above eight
questions where these are within the professional competence of
the Institute. As much of this inquiry is centred on the outcome
of the Barker Review, the Institute's evidence to that review
is attached as Appendix 1. We would be happy to amplify the points
made in the current submission, in oral evidence, if this would
be helpful to the Committee's inquiry.
4. The Institute is generally supportive of the
outcome of the Barker Review, particularly its recognition that
more housing—and especially affordable housing—is
required. While the Barker Review approached the problem from
a different direction, there is nothing new in this conclusion.
For the past ten years, successive Governments have been aware
of the challenge of a substantial growth in the number of households
in the UK (as distinct from growth in the population as a whole),
but have failed to meet this by delivery of sufficient new housing.
Figures have varied in different studies and projections, but
an "average" requirement of, say, 5 million new houses,
over a 20-25 year period, produces the same order of annual programme
as that envisaged by Barker.
5. While supporting Barker's main conclusions,
the Institute can also identify with the Committee's environmental
concerns. The issues here are not new either, and it has to be
acknowledged that the Government has brought forward a number
of policies designed to address environmental issues. For example—the
requirement for 60% of all new housing development to be on brownfield
sites; higher densities; and maximum rather than minimum car parking
standards—are intended to reduce the total amount of land,
and especially greenfield land, required to accommodate the necessary
new housing. Meanwhile, the effective prohibition of new development
in floodplains recognises the impacts if floodplains are not allowed
to maintain their natural capacity to ameliorate the effects of
flooding.
6. Local planning authorities have generally
pursued these policies with enthusiasm, and, alongside them, have
sought to drive up design and environmental standards in new housing.
In the new system of development plans, introduced by the 2004
Planning and Compulsory Purchase Act, sustainability appraisals
are mandatory. Combined with the strategic environmental assessment
of plans and programmes, necessary under the EU Directive from
July 2004, we can look to future new housing allocations to be
much more sustainable than some might have been in the past. What
we cannot be so certain about is that new housing sites will be
delivered any more quickly than in the past.
7. This is clearly another tension within the
planning system. Few could disagree that the greater emphasis
on environmental assessment and sustainability appraisal will
lead to development proposals that are more sustainable environmentally,
economically and socially, but the price of greater community
involvement, and a plan-making process that is more considered,
will be seen in some quarters as unacceptable delay in implementing
development—the criticism that the planning system is slowing
the delivery of housing. We would repudiate such criticisms.
8. What remains lacking under the new development
planning arrangements is a robust overall strategy at the national
level to shape regional and local housing distribution and provision.
Such a national housing strategy should be an integral part of
a UK Spatial Development Framework (UKSDF)—something for
which the Institute has argued the case with Government for some
years, but so far without success. Such a strategy might have
been at the centre of the Barker Review, than the rather narrower
focus on economic objectives. Logically, housing figures should
cascade from a national distribution to regional spatial strategies
and on to local development frameworks taking into account local
needs and capacity. Under past arrangements, this cascade has
become disjointed as a result of debates on housing numbers and
distribution being re-opened at each successive level in the plan
hierarchy. Revised testing arrangements and binding recommendations
should make the new development planning arrangements more effective
in this respect, but the continuing absence of a national framework
is to be regretted.
DETAILED COMMENTS
Are the conclusions of the Barker Review compatible
with the general principles of sustainable development and the
Government's own sustainable development objectives?
9. Yes, in general terms. The Barker Review suggests
nothing new in terms of the size of the necessary housebuilding
programme (see paragraph 4, above). The figures are broadly comparable
with the projections of the last 10 years or so, but do represent
a scale of programme that we have not yet been able to deliver
in recent times.
10. In the Committee's terms of reference
for this inquiry, "sustainable development" and "environment"/"environmental
implications" seem to be used almost as though they are interchangeable.
There is a need to clarify whether the Committee's concerns are
with the narrower environmental implications of the increase in
housebuilding recommended in the Barker Review, or with its impact
on the broader concept of sustainable development. In A Better
Quality of Life: A Strategy for Sustainable Development in the
UK, the Government identifies four strands of sustainable
development. These are listed in the consultation draft of PPS
1: Creating Sustainable Communities as:
— maintenance of high and stable levels
of economic growth and employment;
— social progress which recognises
the needs of everyone;
— effective protection of the environment;
and
— the prudent use of natural resources.
While the Institute has always taken issue with
the Government over the implication that priority should be given
to "high and stable levels of economic growth", Draft
PPS 1 does state that "Planning for sustainable development
should ensure that these four aims are tackled in an integrated
way . . ." In other words, we have to remember that sustainable
development is about more than protection and enhancement of the
environment, and that, in the context of this inquiry, providing
a decent home for everyone that needs one can rightly be regarded
as a central objective of sustainable development.
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?
11. In view of the foregoing, it could be
argued that this question takes too narrow a view of sustainable
development—the issues are wider than just "environment".
The Institute sees a clear need for "an overarching national
strategy", but with the wider brief of addressing issues
of regional imbalance, and laying down a framework for the development
of sustainable communities, transport and infrastructure across
the country. This would be the role of the UKSDF (referred to
in paragraph 8, above).
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 in the planning system in the Barker Review have
a positive or a negative effect on the environment?
12. The Institute would argue that the new
planning system embodied in the 2004 Planning and Compulsory Purchase
Act, should be well-equipped to ensure that the environmental
implications of future house building are fully addressed (see
paragraphs 5 and 6, above). However, while the mandatory sustainability
appraisals should ensure that the most sustainable locations are
selected for new and expanded communities, they will not be able,
specifically, to address issues of sustainable construction, greater
use of secondary materials, or energy efficiency. These are matters
for other regimes, particularly the Building Regulations (see
paragraph 17, below).
13. We believe that the Barker recommendations
for changes to the planning system—many of which the Institute
can readily support—would be fairly neutral in terms of
their effect on the environment and on the sustainability of new
housing in general. The recommendations are wide-ranging. Some
are procedural or administrative, such as the proposal to combine
regional planning and housing boards, which can only be seen to
be sensible in terms of better integration. Others are concerned
with the provision of better technical advice to local planning
authorities (LPAs), such as those about mechanisms for incorporating
market conditions into assessments of housing requirements. The
recommendation that LPAs should allocate a "buffer of land
to improve their plan's responsiveness to changes in demand"
might be seen as anti-sustainable. It should be remembered, however,
that LPAs have long been required to ensure that there is a five
year supply of housing land beyond the plan period, and that land
allocated as Barker's "buffer" will itself have to be
included in the development options that are subjected to sustainability
appraisal. On the other side of the coin, the suggestion that
"planning guidance should be amended to advise regional and
local planning authorities on assessing the value of land to society"
can be seen as positively pro-sustainability.
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?
14. Clearly, a number of significant allocations
of land for housing are already "in the pipeline", and
development of these sites will proceed as planning permissions
are granted. New allocations will be handled through the development
planning system introduced by the Planning and Compulsory Purchase
Act (with commencement of the relevant provisions of the Act expected
within the next two months). Broad locations for new housing,
but not site-specific allocations, will be established through
regional spatial strategies (RSSs), following consultation with
regional stakeholders and local communities. It will then be the
role of local development frameworks (LDFs) to detail sites and
their boundaries, in conformity with the RSS proposals. This,
again, must be done with the ongoing involvement of local communities.
15. Sustainable communities require variety in
house types, sizes and tenures, and a full range of community
and social facilities, employment, transport and other infrastructure.
These can only be provided through sound planning at the local
level. However, outside the major growth areas in the South East
of England already identified by the Government—Thames Gateway,
Milton Keynes/South Midlands, Ashford and the M11 Corridor—it
is improbable that very large new communities will need to be
developed. Much of the new housing elsewhere will be provided
on smaller scale, infill or brownfield sites. Nevertheless, local
planning in these areas will be similarly challenging. It will
involve extensive dialogue with existing communities, often on
complex issues, and will need to ensure that while maximum use
is made of existing facilities and infrastructure, gaps in provision
are identified and filled.
16. Current Government policy, set out in PPG
25: Development and Flood Risk, generally discourages development
in flood plains. However, there is an increasing understanding
of the dynamics of floods and flooding, and the "downstream"
effects of developing in floodplains are now a prominent consideration.
Undeveloped, the floodplain provides a natural reservoir for flood
water, allowing it to be released downstream slowly as floods
subside. Where flood defences (themselves built to protect development
in the floodplain) prevent this natural process, flood water proceeds
downstream more rapidly, increasing the risks of inundation.
Is it possible to ensure materials and resources
used, and waste produced, during building do not have a harmful
impact on the environment?
17. This brings in the "prudent use of natural
resources" strand of sustainable development. It is not an
issue that can be directly influenced by the operation of the
planning system, but clearly is one that has the potential to
affect society as a whole. The object must be to maximise the
use of recycled materials and so reduce the need for "new"
aggregates and other building materials. In the longer term, market
forces will determine outcomes. In the meantime financial incentives
may be required to encourage recycling and the re-use of materials.
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?
18. The Institute would not wish to make
detailed comments on Building Regulations. However, there have
been a number of changes in recent years that can be regarded
as steps in the right direction in terms of increasing the sustainability
of new development. We have in mind the raising of standards of
insulation, or the encouragement given to the adoption of sustainable
drainage solutions, though this stops short of a mandatory requirement.
In many areas, however, the Regulations stop well short of the
requirements in other parts of northern Europe. This seems to
be an area where a significant contribution to greater sustainability
could be made relatively quickly.
How will it be possible to ensure a sustainable
infrastructure, including transport and water supply, which will
be necessary to support any extensive house building, is put in
place?
19. This has always been somewhat problematic
because of the number of players involved in the planning and
delivery of infrastructure for major developments, each with their
own programmes and priorities. The Planning and Compulsory Purchase
Act marks a move away from traditional land-use planning to broader,
more inclusive spatial planning with greater emphases on delivery
and monitoring than before. This should help bring the players
together, and make it more likely that they will all "sing
from the same hymn sheet".
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?
20. The Egan Review—Skills for Sustainable
Communities—had much to say about culture change and the
development of "generic skill sets, including leadership,
teamwork, communication, project management and partnership working"
in order to create sustainable communities. As the body responsible
for the accreditation of training for planners, the Institute
has welcomed and endorsed the call for collaboration between the
built environment professions and other stakeholders—these
accord well with our own New Vision and the work of our Education
Commission, which reported last year—and indicated a willingness
to work with Government and other stakeholders in bringing the
Egan recommendations to fruition.
21. This, however, is likely to take some time.
In the meantime, the reality is that most LPAs are severely under-resourced
as well as under-skilled. The shortage of resources and skills
affects performance across the whole of plan-making and development
control and is far from limited to ensuring that "new housing
meets "environmental objectives".
June 2004
| 
