Memorandum submitted by Community and
Regional Planning Services
SUMMARY
1. This Evidence finds that:
— the "carbon footprint"
of all new dwellings and of eco-towns should be calculated to
include all energy consumption (and by implication carbon emissions)
arising from occupation, including transport use;
— all eco-towns and other new settlements
should be brought forward through the development plan process,
which includes a public and independent evaluation alongside other
options;
— all new settlements and major urban
extensions should have a defined outer boundary which, when reached,
would not be breached in pursuit of further expansion at a later
date;
— restoration of the original intention
that Green Belt boundaries, once defined in adopted development
plans, should "endure" and not be abandoned or eroded
through perceived housing pressure; and
— there is a lack of evidence that
the commitment in the Sustainable Communities Plan to maintain
the quantum of Green Belt in each English region is being fulfilled
or even monitored.
INTRODUCTION
2. Community and Regional Planning Services
is pleased to submit this evidence. Our evidence is not confidential.
3. Community and Regional Planning Services
is an independent planning consultancy operating throughout England
and offering a full range of planning advice and resources to
both public and private clients at national, regional and local
levels. In particular, we specialise in "third party"
work for small businesses, parish, town and community councils,
amenity groups and private individuals. We also undertake studies,
research and policy advice for NGOs and statutory agencies. We
provide training in the planning system through seminars and workshops.
Through all our work runs the thread of a high level of environmental
awareness and commitment together with community sensitivity.
4. Our evidence is in response to three
only of the Questions posed by the Committee, namely:
— Scale of environmental impacts of
the construction of 3M new homes.
— Greenfield and Green Belt developments.
5. This evidence does not contain a critique
of individual eco-town or other specific development proposals,
other than by way of citing examples.
6. We do not purport to represent any particular
clients or other interests in responding to the Committee's Call
for Evidence, but do so from the perspective of our lengthy experience
across a wide range of land-use planning issues.
7. We are not specifically requesting to
give oral evidence. However, should the Committee wish to call
us to go into our evidence or recommendations in more detail then
we should be pleased to attend.
REDUCING CARBON
EMISSIONS FROM
NEW HOMES
8. Under this heading we wish to make a
single point in respect of the 5th bullet-point question posed
by the Committee, namely the scale of environmental impacts of
the construction of 3M new homes.
9. Addressing energy efficiency, sources
of energy used, design/orientation issues and building standards
of a new house will clearly make a considerable difference to
carbon emissions at the margin for each new dwelling constructed.
10. Energy is also consumed, however, in
external activities by the occupants of a new house, not least
in private road transport. The extent to which such transport-related
energy consumption would be greater than it was before the occupants
moved in will necessarily depend on location. Contrary to what
the Question implies, therefore, total household energy consumption
(and consequently carbon emissions) is dependent on location.
11. But it is safe to say that, except for
those urban development sites ideally located in respect of good
public transport infrastructure, each new dwelling will cause
a net increase in transport-related emissions. There is still
a trend towards a "flight from the cities" to suburban
and rural areas where car use is higher than in more densely-populated
city and town centres where a greater number of local services
are within walking/cycling distance and where public transport
options are greater.
12. A considerable proportion of the Government's
planned 3M new houses will be in urban extensions or rural areas,
distant from city and town centres. Transport energy consumption
will therefore rise disproportionately. For completeness, such
"external" factors should be included when assessing
total environmental impacts.
ECO-TOWNS
Function
13. The site-specific information provided
in the consultation appears to be somewhat lacking in describing
the function that a particular eco-town would have, other than
for providing housing. The bidding process has resulted in a random
and opportunistic approach by developers instead of emerging from
a hierarchical analysis of what is required in each region. Hence
these important functional and spatial relationship issues have
been ignored.
14. The regional and sub-regional function
of each eco-town has to be considered:
— Is it to relieve housing pressure
on other cities and towns in the sub-region?
— Would incentives for urban regeneration
in the area be undermined?
— What proportion of residents would
be likely to work outside the town and where?
These are vital but so far unanswered questions.
Eco-towns and the development plan system
15. We believe that the Committee should
be concerned about the relationship between the eco-towns proposals
and development plans. S.37(6) of the Planning and Compulsory
Purchase Act 2004 states that:
If regard is to be had to the development plan
for the purpose of any determination to be made under the planning
Acts the determination must be made in accordance with the plan
unless material considerations indicate otherwise.
16. Para 8 of PPS1, the Government's over-arching
statement of national planning policy for England, emphasises
this by stating that:
This plan-led system, and the certainty and predictability
it aims to provide, is central to planning and plays the key role
in integrating sustainable development objectives. Where the development
plan contains relevant policies, applications for planning permission
should be determined in line with the plan, unless material considerations
indicate otherwise.
17. These quotations indicate the primacy
of the development plan, which has been Government policy for
many years. The proposals for eco-towns, as published in the consultation
document Eco-towns: Living a greener future (April 2008)
would appear largely to bypass the development plan system.
18. Some eco-towns may well come forward
on sites already earmarked for development in existing local development
plans, either adopted Local Plans or Unitary Development Plans,
or Development Plan Documents (DPDs) under the new system of Local
Development Frameworks (LDFs) introduced in 2004. However, these
would only comply with the adopted development plan if the extent
(ie boundary) of the site, the various land uses and the approximate
development quantum (number of dwellings or sq m of commercial
space) were as given in that plan.
19. In nearly all cases, however, the eco-towns
on the consultation short-list are either completely new sites
or if already identified do not fulfil the conditions set out
in the previous paragraph.
20. If a small eco-town proposal (say a
"non-strategic" site of 5,000 dwellings) is seen as
a viable means of delivering a Local Planning Authority's (LPA's)
housing requirement as already set out in the relevant Regional
Spatial Strategy (RSS), then that proposal should be submitted
and evaluated alongside other potential development sites through
the LDF process. This would include subjecting the site to public
consultation and formal Examination by an independent planning
inspector.
21. The value of this process is that it
would set the proposed new town in the context of the whole of
the LDF, through which the environmental, economic and social
consequences of the LPA's package of development proposals would
be evaluated. Eco-towns cannot be considered in isolation without
relating them to wider spatial planning for the area.
22. Furthermore, although the Government
is conducting a consultation at this stage, if the eco-towns were
not brought forward through the LDF system there would be no opportunity
for the public (especially those whose land or other interests
might be directly affected) to participate in a hearing, whereas
the Examination into the soundness of the relevant DPD would fulfil
this requirement.
23. Larger eco-town proposals (say, greater
than 5000 dwellings) would be "strategic developments"
and should therefore first be brought forward through the relevant
RSS. By this means they would be submitted to the full rigours
of the RSS consultation including the Examination-in-Public (EiP)
where they can be evaluated against other strategic options. (Even
a new settlement of 5,000 dwellings or fewer could be considered
"strategic", depending on function and location.)
24. If the larger eco-towns bypass the RSS
process, they will not be subject to any form of EiP. They would
not then be considered against other regional and sub-regional
options or set in the regional and sub-regional context. This
cannot be evaluated at the planning application stage where there
is no guarantee of a public inquiry.
25. All of this has the potential:
— to undermine the plan-led system;
— to reduce the proper evaluation of
an eco-town in its regional, sub-regional and local context; and
— to reduce or eliminate the opportunity
of a public hearing into any particular proposal.
26. An eco-town's relationship to its region,
sub-region and other towns in the area is crucial for employment,
transport, shopping, hospitals and other considerations—which
is of course where proper strategic planning comes in.
27. Where an eco-town site is not already
fully identified in an adopted or emerging development plan, then
a planning application for it should not be entertained. It would
be premature and regarded as a Departure from the plan. Yet the
Minister aims "to see the first schemes beginning construction
by 2010" (Foreword to the eco-towns consultation document).
This timescale would not permit their inclusion in development
plans.
Housing
28. Eco-towns should be used to satisfy
part of the regional and district housing requirements and not
be in addition to them. There is ambiguity in the consultation
paper: ch 3, para 3(i), on p.8, says that "they need to be
additional to existing plans", but Annex A para 6 says that
they "will| count towards future housing targets".
29. Housing requirements at the regional
level are carefully calculated using up-to-date socio-economic
and demographic data. They are subjected to rigorous testing through
the EiP, and the independent Panel makes recommendations to the
Secretary of State who has the power to make further modifications.
All this effort would becomes nullified if eco-towns were suddenly
added in on top of these "final" figures before RSSs
and LDFs had been reviewed.
30. One of the stated functions of an eco-town
is to provide affordable housing. However, as proposed in the
consultation, the latter is not always a very substantial proportion,
eg Marston, Bedfordshire: 2000 affordable houses out of a total
of up to 22,000 dwellings total, ie potentially less than 10%.
Transport
31. Sustainable transport is highlighted
as one of the key criteria (c.f. consultation paper ch 3, para
4, 3rd bullet-point, on p.9). However, the specific commentaries
for a significant number of the listed sites refer to necessary
road improvements, eg Rossington (p.34):
Improvements to the M18 may be required to handle
the extra traffic
and Curborough (p.28):
The A38, in particular, would require a strategy
to cope with additional traffic generated from the development.
32. For a new settlement to qualify as an
"eco-town" and to reach "zero-carbon" standards
(consultation paper, para 3(ii), p.9), then the whole footprint
of the development should be assessed, including the effects of
transport to and from the area outside the new town. The carbon
footprint of a new settlement is the sum of its carbon emissions
with the town fully in place and functioning. Addressing energy
efficiency, building standards and internal transport within the
eco-town is laudable, but only of limited value if transport between
it and the wider world is ignored.
33. This suggests that a much wider package
of public transport and non-car measures would need to be put
in place—once again emphasising that the relationship of
an eco-town to its local, sub-regional and regional spatial planning
context is paramount.
34. This can have positive consequences:
it does not have to be seen as a constraint. There are opportunities
for novel as well as traditional forms of non-car transport, but
they need:
— to be frequent, fast, reliable, attractive,
low-cost; and
— to follow routes which serve major
trip generators, such as schools, colleges, hospitals, shopping
areas, sports/leisure facilities and railway stations.
35. The road-dependency of former new towns
has to be broken for the eco-towns to live up to their name. Public
transport and provision for other non-car modes should be there
from first occupation in order to engender sustainable travel
lifestyles from the outset. Once residents got into the habit
of car use, it would be difficult to wean them off it even if
public transport improved later. This has inevitable funding implications.
36. Some of the eco-towns proposed have
the potential to attract commuters from large cities. Whilst this
can never be completely avoided, it is not sustainable for this
to be a primary purpose: self-sufficiency should be an aim, even
if not 100% realistically achievable. Where major commuting is
likely, then a condition for such a new town should be that it
is centred on a railway station (new or existing) directly serving
the commuters' host city. Without such a requirement, commuters
will take to their cars and thus undermine the raison d'être
of the eco-town principle. (Proximity to a railway station has
sustainable transport benefits for others, besides commuters,
of course.)
Design and layout
37. It is essential that an eco-town is
compact and that it has its services at the centre, preferably
within walking distance of the majority of dwellings. Segregated
cycleways would internally connect all parts of the town and also
with frequented destinations and other cycle networks outside
the town itself.
38. An example of a proposed eco-town which
has made it into the Government's shortlist but which is far from
compact is Marston, Bedfordshire (pp 37-8 of the consultation
document where, incidentally, the inset map is misleading as it
does not show the full extent of the linear nature of the proposals).
This site would comprise a series of "linked villages"
with no discernable centre. This is unlikely to lend itself to
the replacement of car trips by walking and cycling since all
but the most basic services will be located at a distance.
39. A new town would be more acceptable
to existing local communities if it had a defined ultimate boundary
right from the start. It might take many years to reach this limit
but once it did so, outward expansion should stop. The ultimate
outer boundary should be marked with structural landscaping including
woodland planting, which would represent a firm commitment to
this purpose as well as providing the town's residents with readily-accessible
green infrastructure.
40. No existing villages should become "swallowed
up" within the new town (or urban extension) such that they
lose their character and identity. Examples of this from Milton
Keynes should not be repeated elsewhere.
Deliverability
41. It is not only the design and layout
of a new town that has to be carefully planned, but also its delivery.
Especially where multiple developers or builders are involved
(as they always will be with the larger sites), the delivery programme
needs a high level of co-ordination.
42. A new town should grow outwards from
its centre, with as many local services provided "up front"
as possible. Other services should grow in tandem with residential
construction. This will maximise sustainability from the outset.
43. What should be avoided is piecemeal
construction, especially at the periphery of the site. All too
often, where a site is mixed greenfield and previously-developed
land, it is the greenfield development which comes forward first
as this is "easier" and suffers less from delays associated
with demolition or land remediation. But this should not be the
determinant of the order in which land is developed: the overall
functional sustainability of the new settlement should be optimised
at each phase.
GREENFIELD AND
GREEN BELT
DEVELOPMENTS
Greenfield and Green Belt land
44. Planning controls do impose constraints
on both greenfield and Green Belt land. However, the policies
are different and so will be considered separately.
45. Most LPAs outside the major urban metropolitan
areas include in their LDFs general policies to protect open countryside
from development. This is in accordance with PPS7 Sustainable
development in rural areas, and applies whether or not that countryside
has any particular landscape, biodiversity, heritage or agricultural
value.
46. It order to implement these policies,
it is necessary for a LPA to distinguish areas where countryside
protection policies apply from those within settlements where
eg infilling may be permitted. It usually does this by delineating
the different policy areas on the Proposals Map in the LDF.
47. These boundaries can, however, be reviewed
at any time and do not per se prevent the authority from allocating
a new development site on the urban fringe on land that was hitherto
subject to countryside restraint policies. The "settlement
envelope" (as it is sometimes called: other names are used)
is generally effective in controlling unplanned or speculative
development in open countryside. Exceptions are often made for
land uses directly related to a rural area, eg farm diversification.
48. Green Belt, on the other hand, is a
nationally-recognised statutory land-use designation which, whilst
it is in force, imposes strict controls on all forms of built
development (except that associated with agriculture and forestry)
in order to preserve the openness of the land.
49. Green Belt policy is set out in PPG2.
There are five purposes of including land within the Green Belt,
namely:
— to check the unrestricted sprawl
of large built-up areas;
— to prevent neighbouring towns from
merging into one another;
— to assist in safeguarding the countryside
from encroachment;
— to preserve the setting and special
character of historic towns; and
— to assist in urban regeneration,
by encouraging the recycling of derelict and other urban land.
Any area of land within the Green Belt has to
fulfil one or more of these purposes.
50. Green Belts in England are drawn around
only the major metropolitan areas plus a few historic cities such
as Cambridge, Oxford and York. There are other parts of the country
which would benefit from having Green Belts and where there is
land which would fulfil several of the set purposes, but the Government
has so far refused to sanction any completely new Green Belts.
51. Green Belts are under pressure as never
before. This is not so much from speculative development where
LPAs (and the Planning Inspectorate on appeal) generally hold
the line, but from Green Belt reviews initiated by RSSs and implemented
through LDFs.
52. RSSs are calling for the easing of the
inner boundary of many Green Belts in order to facilitate urban
expansion, on the grounds that development would otherwise "leapfrog"
the Green Belt and result in greater travelling distances especially
for commuters. To some extent, this has always happened as people
seek to move further and further away from what they see as ever-expanding
urban areas.
53. These Green Belt reviews firstly assume
that an urban extension (or new settlement) does not need to attempt
any degree of self-sufficiency; that residents will always seek
to work elsewhere and therefore that out-commuting distances should
be minimised. To plan on this basis is itself unsustainable.
54. Secondly, Green Belts should "endure"
(PPG2, para 2.8) and not be eroded every time their boundaries
prove inconvenient. "If it isn't hurting, it isn't working"!
Green Belts are one of the most popular of planning policies and
have served us well.
55. This is not to say that small local
boundary adjustments should never be made where these can be justified.
But strategic Green Belt releases fly in the face of why the designation
was originally established and should be avoided or at least minimised.
56. The Government gave an undertaking in
the Sustainable Communities Plan (Feb 2003, para 4.10):
We will protect the countryside through a target
for each region to maintain or increase the current area of land
designated as green belt land in local plans. We will use green
belt and countryside protection tools to maintain the openness
of the countryside around areas of growth and prevent urban sprawl.
(Local Plans have now been succeeded by Local
Development Frameworks, but both formed part of the statutory
development plan.)
57. The value of Green Belt is in its location
rather than its mere area. Nevertheless, this was a valuable undertaking
and one which "softened the blow" when it came to the
proposed loss of Green Belt land in the growth areas.
58. No mechanism has been set up to monitor
the loss of Green Belt or Green Belt extensions on a "per
Region" basis, and so data is not readily available on whether
this undertaking is being fulfilled. We suspect that it is not.
59. Furthermore, the commitment to use policy
tools "to maintain the openness of the countryside around
areas of growth and prevent urban sprawl" (whether Green
Belt of not) is certainly not being adhered to. To meet this would
require designated outer boundaries to be defined for growth towns,
beyond which further sprawl would be prevented. Towns such as
Ashford, Corby, Kettering, Milton Keynes, Northampton and Wellingborough—all
in growth areas—have no such defined "final" outer
growth limit. Nor is there a commitment not to seek further Green
Belt reviews at Harlow or Stevenage following those currently
being undertaken.
Environmental considerations
60. It is true that nationally-recognised
landscape, biodiversity and heritage designations (eg AONBs, SSSIs,
Registered Parks & Gardens) are taken into account, both by
developers and LPAs, when potential new development locations
are being considered. However, sites of more local importance
carry little weight.
61. Locally-designated sites, eg County
Wildlife Sites and local landscape areas, still have value locally
and, whilst not carrying as much weight as a national designation,
should still count for something rather than be dismissed as "getting
in the way" of development.
62. The new discipline of "green infrastructure"
can embrace both national and local sites/areas of landscape,
biodiversity and heritage importance whilst at the same time providing
opportunities for public access and integrating these with existing
networks. New settlements and urban extensions should incorporate
and fund green infrastructure proposals.
RECOMMENDATIONS
63. The Committee is invited:
— to recommend that the "carbon
footprint" of all new dwellings and of eco-towns be calculated
to include all energy consumption (and by implication carbon emissions)
arising from occupation, including transport use;
— to recommend that all eco-towns and
other new settlements be brought forward through the development
plan process, which includes a public and independent evaluation
alongside other options;
— to recommend that all new settlements
and major urban extensions have a defined outer boundary which,
when reached, would not be breached in pursuit of further expansion
at a later date;
— to recommend restoration of the original
intention that Green Belt boundaries, once defined in adopted
development plans, "endure" and are not abandoned or
eroded through perceived housing pressure; and
— to seek a re-statement of the commitment
by Ministers to maintain the quantum of Green Belt in each English
region and to monitor this.
GLOSSARY
| AONB | Area of Outstanding Natural Beauty
|
| DPD | Development Plan Document
|
| EiP | Examination-in-Public
|
| LDF | Local Development Framework
|
| LPA | Local Planning Authority
|
| NGO | Non-Governmental Organisation
|
| PPG | Planning Policy Guidance (Note)
|
| PPS | Planning Policy Statement
|
| RSS | Regional Spatial Strategy
|
| SSSI | Site of Special Scientific Interest
|
25 April 2008
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