Memorandum by the Brethren's Gospel Trust
(AH 56)
1. INTRODUCTION
1.1 We represent Charitable Gospel Trusts
established by Christians commonly known as "Brethren",
who have long established and growing congregations in about 100
towns and cities throughout Britain.
1.2 Congregation numbers continue to increase
with both "planting" of new assemblies and an ongoing
need for new halls in existing areas. As a result of these needs,
Trustees are active participants in the planning process, in promoting
appropriate Development Plan policies at both Regional and Local
level and in the Development Control process.
1.3 The Brethren's Christian fellowship
have an interest in the prosperity of the nation. Housing is a
subject affecting all our neighbours in the streets in which we
live; together with Brethren's employees, as well as Brethren's
households. In several cities, especially in the South-East of
England we have evidence of new household formation being delayed
by reason of inadequate supply of housing at affordable prices.
Some Brethren are currently relocating away from Greater London,
whilst retaining a presence in the area.
1.4 We are grateful for this Committee examining
this subject, in view of much having been written and debated
in both Houses which we would like to see put into practical help
for the nation as a whole. We approach this matter in the light
of our current experience and concerns for our families, rather
than as experts in this field.
1.5 Background information on the Brethren's
Christian Fellowship may be obtained from www.theexclusivebrethren.com.
2. RESPONSE TO
ISSUES RAISED
BY COMMITTEE
2.1 The potential benefits of and scope to
promote greater homeownership
We support the view expressed in the "Sustainable
Communities Plan 2003" which states "Owning a home gives
people a bigger stake in their community, as well as promoting
self-reliance". In our experience homeownership benefits
over rent in pride and care put in by owners which uplifts and
maintains neighbourhoods, so that people do not live "on
the street" but rather develop safe communities. Homeownership
provides households with what is for many their main financial
investment, which historically has steadily appreciated in value.
Home ownership, even when paying off a mortgage, provides a form
of savings, in contrast to renting which does not provide the
household with any equitable asset. In view of a convergence between
rentals and mortgage payments, we believe greater home ownership
should continue to be a public policy priority.
2.2 The extent to which home purchase tackles
social and economic inequalities and reduces poverty
We consider that homeownership immediately stimulates
a climb out of poverty. Lord Best has drawn attention to 101,000
homeless households and a huge increase in number of those between
those able to obtain social housing and those able to afford to
buy. We support current Government policies which seek to encourage
a better supply of privately built homes, including low cost market
housing; to encourage social tenants to move into homeownership
and to help tenants in Council properties to exercise the Right
to Buy.
2.3 The economic and social impact of current
house prices
We share the views expressed by Kate Barker
at Final Report paras 1.11 and 1.12 and in 0DPN Consultation Paper
"Planning for Housing Provision" : July 2005 paragraphs
12-14. In short, house prices constrain economic growth, increasing
wage costs for business and resulting in reduced availability
and mobility of labour for business employment. Social impacts
include a widening gap between homeowners and non-homeowners,
leading to greater wealth inequalities. Aspiring first time buyers
are forced to delay entry to the housing market until later in
life, hence leading to overcrowding due to suppressed household
formation and rising numbers of homeless or households in temporary
accommodation. Glen Bramley has demonstrated that only 37% of
new households could afford to buy in 2002, compared to 46% of
new households in the late 1980's. (Bramley G : Barker Inquiry
in Housing Supply—Affordability and the Intermediate Market
(2003)). We are aware of evidence of families relocating away
from London to lower-priced areas, thus assisting new generation
household formation earlier than otherwise. Further examples of
the economic and social impact of current house prices are provided
by a significant increase in long distance commuting, for example
Stansted Airport workers being bussed in from Birmingham; resulting
in unsustainable travel in terms of adverse CO2 emissions and
unnecessary road congestion. There is widespread anecdotal evidence
of constraints to economic growth due to the inability to fill
potential jobs. In some cases, work is lost to overseas locations.
2.4 The relationship between house prices
and housing supply
Numerous recent studies have highlighted the
indisputable shortfall in housing supply compared with demand.
At the opening of the Examination in Public for the East of England
Plan last week the Head of Growth Division at ODPN advised the
Panel that nationally we are currently building only four new
homes for every seven new households. In "Land for Housing"
(Joseph Rowntree Foundation :2002) we are told that current annual
average completions are under 140,000 compared to a demand for
some 225,000 new homes per annum. The constant rise in house prices
over the past six years is also well documented. However, unlike
other less constrained markets, supply has not increased to match
price rises. Comparison with other countries demonstrates that
this is abnormal (see Barker Report—Final—para 1.8).
Current rates of construction have fallen from over 300,000 dwellings
a year, in the 1960's.
2.5 Other factors influencing the affordability
of housing for sale including construction methods and fiscal
measures
Uncertainties in the wider construction and
civil engineering industry, subjected to at least 40 years of
"stop-go" policies and taxation have led to a steady
reduction in the size of the industry. The traditional "father
to son" understanding of tradesmen has largely been lost
and there is now a national skills shortage. This has been recognised
by the CITB but will take time to rectify. In the meantime, an
inability to respond to labour demands appears to have resulted
in a less flexible construction industry, in which tender prices
have risen sharply, increasing costs of housing and infrastructure
(roads, sewers, water supply and other services). Major housebuilding
proposals such as Cambourn and The Wixams (Bedfordshire) suffer
major delays due to land assembly and complex legal agreements
both under S106 of the Town and Country Planning Act and S278
if the Highways Act which delay the issue of planning permission
and the construction of access roads and bypasses. Housing schemes
are increasingly called upon to make significant financial contributions
to education, affordable housing, transport improvements and environmental
benefits for example. Increased demands for health and safety
measures reduce flexibility on site, increasing costs. Planning
constraints and competition for site releases result in increased
land prices. Policies seeking to provide a high proportion of
housing on previously developed land have been successful but
the increased time delays and costs incurred in decontamination
both mitigate against affordability. Improved building regulations
including high insulation measures also have a cost impact. Purchase
of second homes in rural areas competes with local needs and represents
poor stewardship of our national housing stock. Further competition
for homeowners arises from investors purchasing newly constructed
houses and offering these for rental. Whilst this phenomena provides
an additional home it has an adverse impact on affordability of
market housing. We consider this should be discouraged by either
taxation or primary legislation.
2.6 The scale of the Government's plans to
boost housing supply
"Sustainable Communities: building for
the future" (ODPH: 2003) sets out the Governments plans to
deliver a step change in housing supply in London and the South
East by 2016, by an additional 200,000 homes above then current
regional planning guidance. This growth is focused in London,
Thames Gateway, Ashford, Milton Keynes—South Midlands and
the London-Stansted-Cambridge corridor. London, Ashford and MKSM
subregional strategies are now in place. The East of England Plan
is at Examination in Public, testing current proposals and increased
proposals by Government against environmental capacity and infrastructure
constraints. Both the East of England Regional Assembly and South
East England Regional Assembly are, however, resisting requests
for further increased housing supply. On the other hand, recent
reports suggest local initiatives to increase housing supply in
Norwich and Haven Gateway with Government support. We are concerned
at the ability of the planning process to deliver the step change
sought in a short time frame. Other regions including South-West,
West Midlands and East Midlands are currently reviewing their
Regional Spatial Strategies, giving an opportunity for further
growth in suitable locations further from the south-east.
2.7 The relative importance of increasing
the supply of private housing as opposed to subsidised housing
Private housing is required to meet needs for
increased homeownership, thus promoting self-reliance and pride
in the community. Fiscal measures such as low cost or subsidised
mortgages for first time buyers and essential workers (nurses,
teachers, firemen) may he rendered ineffective in stabilising
house prices unless accompanied by increased housing supply. Subsidised
housing represents a burden on taxpayers, both private individuals
and through s106 agreements, the landowners. Increased proportions
of subsidised housing may result in landowners becoming reluctant
to release building land, countering Government proposals to boost
housing supply.
2.8 How the planning system should respond
to the demand for housing for sale
The planning system as currently operated in
England is "tilted" in favour of negative attitudes
including Nimbyism, excessive environmental protection and other
single interest groups who are often organised and vocal but not
necessarily representative of the population as a whole. Recent
legislation to make Inspector's recommendations binding on local
planning authorities is expected to speed up delivery of land
through the new LDF process. Current faster tracked RSS reviews
will also provide a stronger lead to local authorities. Further
reforms are expected to be announced shortly in a revised PPS3
: Housing. We would favour the reinstatement of the "double
presumption" in favour of planning permission in the absence
of a genuine availability of five years housing land together
with clear advice to local authorities that the sequential search
for sites does not extend to land releases. Brownfield land should
take precedence in site allocation, with realistic delivery times,
but where it can be demonstrated that greenfield sites will also
be needed, development must be permitted on both brownfield and
greenfield sites together. Notwithstanding the abandonment of
"Predict and Provide", it must be emphasised that "Plan,
Monitor and Manage" requires a robust and flexible plan at
the outset at both regional and local levels. In the current climate
of constrained supply of quality and experienced planning staff,
we have doubts at the ability of local authorities to respond
rapidly to enhanced market monitoring and the willingness of elected
members to deliver changes indicated by the proposed triggers.
A full and rigorous review of the justification for all "Green
Space" including Green Belt, Green Wedge is called for immediately,
to permit greater flexibility for housing land release, especially
close to conurbations.
2.9 The scale of housing development required
to influence house prices and the impact of promoting such a programme
on the natural and historical environment and infrastructure provision
We believe that the Barker recommendations for
a buffer of additional land equivalent to 20% to 40% above that
required to meet housing targets would be likely to assist in
stabilising the effects of planning and land supply on house prices.
However, as noted above there are other influences on housing
supply including labour and skills shortages and fiscal constraints.
It was forecast that by 2001 about 11% of England would be in
urban use (Breheny & Hall : TCPA : 1996). At that time about
45% of housing was being built on previously developed land. For
the past three years this has risen to 67% (Planning for Housing
Provision : ODPM : 2005) and densities have increased to 39 dph
average in 2004. There are likely to be some adverse impacts on
natural and historical environments, but in our view these tend
to be overstated and with careful regional planning, subject to
SEA, enhanced development offers commensurate environmental benefits.
For example, notwithstanding significant growth proposals the
SA/SEA for the East of England Plan states:
"The great majority of the impacts of policies
are positive. The pattern of development which the RSS seeks to
encourage are likely to make the region's environment, and quality
of life for its residents, much better than would be the case
without it."
Infrastructure includes water supply, where
innovative initiatives are required on a national basis for both
flexible methods of supply, inter-regional where appropriate,
and in terms of water economics (water saving, water recycling).
Climate change demands and greater awareness of flood risk issues
will present a challenge for protection and disposal of storm
water. However, revisions to PPG25 and forward thinking by Regional
Water Companies and the Environment Agency are already working
together for solutions. Transport infrastructure at local, regional
and national levels requires care to ensure flexible responses
which do not encourage additional travelling. Public transport
will need increased investment especially in South-East England
and other conurbations. However, in many cases this is already
required to overcome current deficits, eg. Thameslink 2000.
2.10 The regional disparities in the supply
and demand for housing and how they might be tackled
Regional disparities call for a "light
touch" from ODPM and encouragement of realistic reviews to
RSS, which we are encouraged to note are in progress in all regions.
The selective release of Green Belt and other green space, following
a national review, would provide flexibility in responding to
existing shortfalls. Government should consider extending identified
"growth areas" into the northern regions and perhaps
also to the South-West to encourage further dispersal from London
and the South-East. Further encouragement of out of South East
ports and airports could also aid regeneration, urban renaissance
and more balanced national demand and supply for housing, associated
with enhanced economic opportunities in areas such as former coalfields,
to overcome regional disparities.
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