Memorandum submitted by the Royal Town
Planning Institute
INTRODUCTION
1. The Royal Town Planning Institute (RTPI)
is pleased to provide evidence to this important inquiry. We have
a clear recognition of the importance of housing in this country
and of the crisis that we face if adequate, decent housing is
not provided. The RTPI is a learned and learning society representing
over 19,000 chartered town planners. Following the adoption of
its New Vision for Planning and its merger with ROOM (the National
Council for Housing and Planning), the Institute is taking a more
direct interest in housing issues and, in particular, the relationships
between policies and practice in housing with those in planning
and regeneration.
GENERAL COMMENTS
2. As the terms of reference of the Committee's
inquiry recognise, sustainability in housing development applies
at a number of levels:
— the new houses themselves must be
sustainable. Construction standards must maximise sustainability—the
use of robust materials with a long life expectancy; the use of
secondary materials wherever practical; high levels of insulation
and fuel efficiency; and the adoption of sustainable water management
in terms of both consumption/re-use and drainage;
— at the local level, new housing should
be built in the most sustainable locations. This means not only
maximising the use of brownfield sites, but the selection of locations—such
as on the edge of existing in urban areas, or in transport corridors—that
reduce the need to travel and maximise the use of existing infrastructure;
and
— it is the regional distribution of
new housing that provides perhaps the greatest challenge. It must
be the antithesis of sustainability to demolish housing in the
northern regions of England—with the waste, social and economic
upheaval, and under-use of existing infrastructure that this represents—while
struggling to replace these houses and the infrastructure they
require in the South East.
3. In broad terms, the Government has recognised
the need for construction to be more sustainable, and for new
housing to be built in more sustainable locations. It could, however,
be doing much more to encourage faster progress in these directions.
In contrast, this Government, like most of its predecessors over
the past 70 years, has been unwilling or unable to develop policies
to address the disparities in regional economic growth that would
help ensure a more sustainable future for the country as a whole.
4. These issues are explored in greater
detail in answering the questions posed by the Committee's inquiry.
DETAILED COMMENTS
A. THE CODE FOR SUSTAINABLE BUILDINGS
(1) Can a voluntary Code
possibly deliver the degree of change needed in the building industry
to achieve well-designed, energy efficient buildings which have
minimal impact on the local environment?
5. The Institute believes that this question
can be considered from two viewpoints. One school of thought may
suggest that consensus is better than coercion, and that entering
into a partnership with the building industry is more likely to
bring success in the long term. The converse is that the volume
housebuilders are only likely to follow a voluntary code if this
can be sold to the customer and thus make money for the shareholders.
On balance, we feel that this leaves too much to chance, and that
mandatory requirements in the Building Regulations are the only
certain way of ensuring compliance with the higher standards demanded
by more sustainable construction.
6. The Code, in the first instance at least,
will relate only to new build housing—a tiny fraction of
overall housing supply, if the code is to be of true value, methods
of enforcing the standards on existing housing stock must be considered
a priority for Government thinking.
7. The Codes emphasis is on environmental
issues and the prudent use of resources, whereas to deliver the
wider aims of sustainability it should also relate to the social
and economic issues involved in new housebuilding.
(2) Is the Government doing enough to
promote the Code, with the industry and the general public, ahead
of its imminent introduction early in 2006?
7. At present, many consider the Code to
be too vague and ambiguous. If it is to meet the Government's
aspirations, its content requires clarification, and should be
consulted upon widely. Only with this degree of "ownership"
is a voluntary code likely to be successful.
8. Thinking "outside the box",
the Government might consider including the delivery of the standards
set out in the proposed Code as a BVPI target for local planning
authorities. This may be a little unkind to LPAs, but they would
be more likely to "encourage" developers to adopt the
Code if their performance was being monitored alongside that of
the developer.
(3) Should the Government be introducing
fiscal measures to reward higher building quality and greater
environmental performance?
9. Governments always find an attraction
in financial incentives to achieve their objectives. In this instance,
however, the probable complexity of any fiscal arrangements, the
associated bureaucracy, and the overlap with the role of the Building
Regulations in setting standards for building work reduce the
attractiveness of the proposition. The Institute is frustrated
by the slow progress in bringing the Building Regulations up to
date in terms of sustainable building, and would urge the Government
to concentrate on this route.
B: SUSTAINABLE COMMUNITIES: HOMES FOR ALL
(4) Does the ODPM
Five Year Plan—"Sustainable Communities: Homes for
All"—demonstrate a greater recognition of, and greater
commitment to tackling, the impact of increased house building
on the environment, or does it merely pay lip service to it?
10. The headline figures do suggest progress
towards reducing the environmental impact of new housebuilding.
According to the ODPM's own figures, 70% of new dwellings completed
in 2004 were built on previously-developed land, and the average
density of new development was 40 dwellings per hectare which
does represent progress in limiting the environmental impact of
new housebuilding. However, as previously mentioned, it is important
to remember that sustainability is more than purely environmental
constraints.
11. It is probably unnecessary to remind
the Committee of the scale of the required housebuilding. While
the Barker Review might have approached the problem from a different
direction—compared with earlier analyses of the new housing
requirement in England—there is nothing new in the scale
of its broad projections. For more than 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 demand by delivery of sufficient new housing. Figures
have varied slightly in successive studies and projections, but
an average requirement of, say, five million new houses, over
a 20-25 year period, produces the same order of annual programme
as that suggested by Kate Barker.
12. One of the Institute's greatest concerns
over current Government thinking on where best development of
this magnitude can be accommodated is an unrealistic adherence
to the inflexible, 50-year old green belt policy, about to be
reinforced by the Town and Country Planning (Green Belt) Direction
(the subject of recent consultation by ODPM). As they stand, the
policies set out in PPG 2—Green Belts are simplistic, inflexible,
and often damaging to the cause of sustainable development. (The
Scottish Executive has consulted on a review of green belt policy
in Scotland a direction worth considering in England by ODPM as
part of an update to PPG 2.) In her final report, Kate Barker
noted that—"The general principle of containing urban
sprawl through greenbelt designation should be preserved. However,
planning authorities should show greater flexibility in using
their existing powers to change greenbelt designations where this
would avoid perverse environmental impacts elsewhere". This
has a resonance with the Institute's own discussion paper—Modernising
Green Belts—published in May 2002, where we restated
the Institute's "longstanding and continuing broad support
for the policy, but argued the case for a fundamental review—a
modernisation—to bring green belt policy into line with
the changing planning policy agenda, and embrace fully the principles
of sustainable development."
13. We need to look afresh as the rationale
and effectiveness of protectionist policies. Green belt policies
have fallen behind current thinking, particularly with regard
to sustainability. The maintenance of existing green belt policy
simply trades one set of environmental principles for another.
Instead of blindly defending the old policy, we would like to
see Government promoting a wide-ranging debate—based on
real evidence—on the merits and deficiencies of current
policy in the context of the sustainability agenda. A flexible,
more dynamic approach to green space policy is needed. We cannot
afford to undermine the creation of sustainable places by maintaining,
at all costs, a "belt" of green space that exists on
the borders of our towns and cities. A "sustainable community"
may mean different things to different people, but the context
of such new development, and its integration with existing places,
is crucial. Existing green belt policy inhibits the potential
to strengthen the links between urban density and public transport,
stifles regeneration opportunities, and impacts negatively on
the preservation of green spaces for recreation.
14. The environmental impact, and overall
sustainability, of new housing allocations have to be given a
thorough examination under the provisions of the Planning and
Compulsory Purchase Act, 2004. The Act makes mandatory a sustainability
appraisal (SA) of the policies and proposals in both regional
spatial strategies (RSSs) (which determine the general location
of major new housing development) and local development frameworks
(LDFs) (which make site-specific allocations). In the case of
LDFs the thoroughness and effectiveness of the SA will be major
considerations in assessing the soundness of the plan as a whole
when it is subjected to independent examination. (Recently published
ODPM guidance makes clear that the process of sustainability appraisal
must incorporate the requirements of the EU Strategic Environmental
Assessment (SEA) Directive.)
(5) To what extent does the Five Year Plan
address the environmental implications of the geographical distribution
of demolition versus new build?
15. In the Institute's view, Sustainable
Communities: Homes for All fails to address the environmental—or
the social, economic and resource - implications of the geographical
distribution of demolition versus new build. Government policy
indicates that the majority of the new build is to be located
in the South East, principally in the designated Growth Areas,
while demolition is earmarked primarily in the three northern
regions. While some of the housing to be demolished has reached
the end of its useful life, the majority is in good order or could
be made so with relatively modest refurbishment. The reasons for
demolition are either social or economic. The former could have
been addressed by locally-based neighbourhood regeneration schemes,
the absence of which might be attributed to lack of local initiative
or resource constraints. The latter reflects the Government's
continued failure to address regional disparities in England,
and especially the continuing relatively poor economic performance
of the North compared with the South.
16. The environmental implications of the
concentration of growth—and especially of housing—in
the South East have been exaggerated. The Barker Review calculated
that even if the whole of the projected new housing requirement
were to be built in London and the South East, the urban area
would represent only 1% more of the total land area than at present.
The Institute would argue that the real problems in the South
East are centred around a lack of adequate infrastructure and
local political will, rather than an excess of development.
17. The proposals set out in Sustainable
Communities: Homes for All for mass demolition in areas where
markets are failing, constitutes poor forward thinking by Government,
in social, economic, environmental and resource terms, it appears
to the institute to be a waste. Instead of addressing the local
issues that are causing market failure, through positive regeneration
schemes, Government is taking the route of large scale demolition,
in areas that are in need of regeneration, and promoting house
building in areas of demand and existing pressure.
18. In our submission to the Committee's
previous inquiry—Housing: Building a Sustainable Future—in
June, 2004, we underlined the case for preparation, by Government,
of a UK Spatial Development Framework (UKSDF). We remain of the
view that this is a vital tool for addressing the present imbalance
in regional economies in England. Inter alia, a UKSDF would indicate
a planned pattern of development across the UK as a whole, the
major infrastructure projects necessary to service this development,
and their programming. The conventional wisdom appears to be that
economic activity—and thus housing—gravitates to the
South East because that is where it is nearest its market. But
with an increasingly global economy, this view is scarcely capable
of substantiation. Given adequate communications, such as the
often mooted north-south high speed rail route, the distance between
the North East of England—or even the North East of Scotland—and
the South East of England becomes almost an irrelevance in global
terms. And set against this is the increasing congestion and difficulty
of movement of people or goods in the South East.
C. LPS2020
(6) The Government
has consulted on the new construction standard for dwellings (LPS2020).
On the basis of that consultation is it possible to determine
whether the new standard will be a positive force for change and
add value to the construction process?
18. No Comments.
D. INFRASTRUCTURE
(7) Is the Government
doing enough to secure sufficient funds for the timely provision
of infrastructure, such as transport links, schools and hospitals
in the four Growth Areas?
19. The Institute believes that the Government
has given insufficient commitment to the provision of the infrastructure
needed to support the level of housebuilding in the Growth Areas,
and that the lack of investment will hold back achievement of
the Sustainable Communities Plan. Two examples lend weight
to this view:
— the Barker Review cited 40,000 dwellings,
in the South East, that had planning permission but were not being
built because of shortcomings in infrastructure provision; and
— the East of England Regional Assembly
effectively disowned its own draft RSS, immediately after it had
approved it, because it did not think that the Government was
committed to funding the necessary infrastructure in the M11 Corridor
Growth Area.
20. The Institute is campaigning for greater
recognition of the vital importance of infrastructure, and more
"joined-up" Government to co-ordinate, prioritise and
deliver. We believe that the biggest problem in the Growth Areas
is not the lack of environmental capacity to handle the planned
housing growth but the historic and current underinvestment in
infrastructure, especially in transport.
(8) Are the water companies doing enough
to secure the supply of water resources to the four Growth Areas?
And is concern about security of water supply, in the South East
of England in particular, a valid one or simply a knee-jerk reaction
to a few hot, dry summers?
21. We are not qualified to judge the performance
of the water companies, however, clearly, there are concerns about
the effect of climate change, but whether the combination of warmer,
drier summers and wetter, stormier winters will result in less
annual rainfall does not appear to have been established. Probable
long term changes in the distribution of rainfall across the year
do, however, put the capacity of water storage facilities under
the microscope.
22. Addressing the effects of climate change,
to which this question alludes, is yet another area where the
Government, from the Prime Minister down, has been strong on words
but, to date, weak on action.
(9) Is there sufficient effort being made
by the Government, the Environment Agency and the water companies
to educate people about water efficiency?
23. The answer is probably "no",
but it is necessary to take a long term view on issues of this
nature. A sustained public education programme is required, on
a par with that to discourage smoking. In the meantime, much more
can be done to take the decision away from the consumer. The standard
fitting, in new or refurbished houses, of taps that turn themselves
off, and WCs, showers, washing machines, dishwashers, etc that
use less water, would go a long way towards reducing water consumption.
Add to that the savings from rainwater harvesting and the re-use
of grey water that could be made mandatory through adjustments
to the Building Regulations, and much progress could be made relatively
quickly.
November 2005
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