Memorandum submitted by The Town and Country
Planning Association (TCPA)
1. ABOUT THE
TCPA
The Town and Country Planning Association (TCPA)
is an independent charity seeking a sustainable future through
planning. The TCPA campaigns for the reform of the UK's planning
system to make it more responsive to people's needs and aspirations
and to promote sustainable development. We put social justice
and the environment at the heart of policy debate. We seek to
inspire government, industry and campaigners to take a fresh perspective
on major issues, including planning policy, housing, regeneration
and climate change. Our objectives are to:
— secure a decent, well designed home
for everyone, in a human-scale environment combining the best
features of town and country;
— empower people and communities to
influence decisions that affect them; and
— improve the planning system in accordance
with the principles of sustainable development.
2. ABOUT THE
INQUIRY
2.1 The Environmental Audit Committee is
launching an inquiry into these policies and the wider environmental
issues involved in the Government's policies for the construction
of new homes. The Committee will be looking at how well the Government's
policies on housing supply are joined up with those on sustainable
development. In particular the Committee will focus on the impacts
that house-building policy has on climate change mitigation and
adaptation. This is important not least because housing currently
contributes a quarter of the UK's carbon emissions—and because
the Government estimates that new housing (ie built after 2007)
could make up a third of the entire housing stock by 2050. EAC's
inquiry will complement the recent inquiry by CLG Committee on
existing housing and climate change.
3. SUMMARY OF
THE TCPA'S
VIEWS
— The TCPA believes the new grounds
on which the Government based its aspiration for three million
homes by 2020 are valid and justified. This level of new housing,
whether through new development or redevelopment, is urgently
required to address the chronic shortage of housing. In fact TCPA's
own publication on household formation based on demographically-based
estimates suggests a higher figure of new housing is required.
The TCPA believes that their continuing need for greater strategic
planning to lead on issues fundamental to the deliverability of
central Government policies and aspirations.
— The TCPA appreciates there are a
number of recognised compliance issues for house-builders, such
as costs associated with implementing zero carbon technology and
processes, as well as development constraints, such as availability
and location of land, in particular in areas of rural nature.
However, we are facing a very different social, cultural, economic
and environmental agenda than before. We must begin to meet the
demands of not only the present but of the foreseeable future
by taking lessons from the past and moving forward. By this the
TCPA strongly advocate a flexible approach and perspective to
planning and delivering new homes with a sensible economic appreciation
of these new imperatives.
— New imperatives must also be addressed
at the strategic level in Government. Exploring new and adapting
existing programmes, delivery models and funding streams to meet
increasing pressures on private resources must be a priority if
we are to ensure the delivery of new homes in an integrated, cohesive
and socially sustainable manner.
3.1 Impacts on Housing Numbers and Housebuilding
3.1.1 The TCPA believes the Government's
figures for new housing required are not widely discounted or
disputed given the upward nature of population change and household
formation. The main issue of contention is, however, on the deliverability
of this level of housebuilding in light of the impact of the credit
crunch on development feasibility. This is supported by latest
housebuilding completions and new-build application statistics
released by source including CLG, NHBC.
3.1.2 Impacts of Demographically-based Factors:
Whitehead and Holmans study (TCPA's Tomorrow Series Paper 5, 2006)
demonstrated that as a result of the combined effects of a greater
than previously projected growth in demographically-based factors,
including longevity, aging structure, household separations and
higher net inward migration, housing demand and need estimates
should be revised upwards. Their arguments are further supported
by recent statistics from the Office for National Statistics which
indicate that:
— in 2005 the register of deaths register
reported a fall of 3.5% for males and 3.8% for females in 2006;
— the nation is aging (16% of UK population
are aged 65 or over);
— there were 669,601 births in 2006
compared with 645,835 in 2005, an increase of 3.7%. The number
of live births has been increasing since 2001 and has reached
levels last seen in 1993; and
— net migration of about 191,000 people
in 2006. However the impacts of migration on housing demand and
need will differ region to region subject to receiving results
from regional and sub-regional household projections as part of
the regional spatial strategies.
3.1.3 Relatively little attention has been
paid to the impact of immigration on housing. But what is known
and accurate at the present time is that London remained the main
destination for migrants arriving in the UK. In 2006, the number
arriving in the SE was 81,000, up from 68,000 in 1999. The East
of England experienced the next largest inflow, with 60,000 immigrants
arriving in 2006, up 24,000 since 1999. In each of the remaining
regions, immigration increased by at least 7,000 between 1999
and 2006.
3.1.4 About a third of the projected household
growth in England over the next 15-20 years is due to net immigration,
according to Professor Christine Whitehead of LSE. Whitehead added
that in London about two-thirds of the projected increase in households
until 2021 will be due to immigration. However the recent introduction
of the Points-Based System for immigrants to work, train or study
in the UK may result in 10% fewer migrants from outside the EEA
coming to the UK. Careful monitoring of outward, as well as inward,
flows of migrants will establish a sound evidence base for population
and housing projections.
3.1.5 Impact of the Credit Crunch: Supply
side of house building remains constrained by planning, product
and construction starts. Developers' are facing rising building
costs—not just in terms of construction, materials and labour,
but also increasing infrastructure costs (such as CIL) in addition
to growing regulatory pressure (including 2016 zero carbon targets,
as discussed in section 3.2).
3.1.6 Although TCPA believes that more houses
need to be built to satisfy need and demand, we see no evidence
that increasing housing provision would address the affordability
problem adequately in the short term. These houses need to be
of a high quality and at the right locations where the existence
of residual value available through value up-lift can help to
ensure the building of truly sustainable communities.
3.1.7 It is also worrying that in the three
months from January to March 2008, there has been a significant
decrease (30%) of applications for new homes. At the same time
new build completions is 14% lower on same period last year.
3.1.8 Impact on house-building in other
development sectors: TCPA recognises the contributions to housebuilding
by developers and housing associations. Impact on capacity of
housing associations to borrow for new developments. TCPA also
recognises the important contribution by other minor players in
the development sector, including self-builders, and the need
to provide them with the necessary capacity to continue with their
housebuilding activities in times of financial difficulties.
3.1.9 In a recent TCPA journal (see Annex),
Kate Barker examined the implications for housing numbers on the
basis of housing price stagnation and lower levels of housebuilding
in the 1st quarter of 2008. While she accepted the challenges
ahead, she concluded that the current slowdown in itself does
not change the long-term case for stepping up supply—although
the precise requirement will, as ever, depend on trends in migration,
among other factors. Nor does it necessarily put achievement of
the 2016 housing numbers target out of reach. Positive contributing
factors include; greater commitment to bring forward public sector
land for regeneration, local authorities continue to work towards
finalising development plans and to invest in infrastructure necessary
for development to take place.
3.2 Reducing Carbon Emissions from new homes
and Code for Sustainable Homes
3.2.1 Government needs to issue clear, integrated
national planning policy on the imperative to build zero carbon
homes, so that everyone involved—those looking for a new
home, landowners, developers, manufacturers, builders, local authorities,
the Planning Inspectorate—can take this aim into account
in their decisions. But the TCPA believes local government is
the most appropriate mechanism to take this proposal forward.
Local government once again has a strategic role to play in planning
for the future needs of our communities by:
— demonstrating leadership in their
communities;
— providing design, development planning
and financial support through policy, regulation and financial
incentives;
— establishing partnerships to demonstrate
and invest in new technologies; and
— engaging with businesses (tenants
and landlords) and citizens to educate, raise awareness and deliver
on policy actions.
3.2.2 Decisions for implementing emissions
reduction policies must be influenced by the development's design
strategy, location and scale. For example, on-site and building-oriented
technical solutions will need to be combined with solutions which
look to the wider spatial implications, the potentials of the
street block and vicinity in the cases of business parks and retail
centres. Certainly the delivery of technologies must be planned
and enabled through the planning and building systems.
3.2.3 TCPA's publications, Sustainable energy
by design and the Community Energy best practice guide are recommended
as reference documents which give effect to the above points.
In combination with other technologies, these measures look at
passive actions such as the energy efficiency savings of heating
and lighting, as well as exploring opportunities to be proactive
by taking a forward thinking approach to decentralising energy
production with the use of renewable sources.
3.2.4 Research undertaken by Savills, into
the market for sustainable homes published in the summer of 2007,
estimated that the introduction of the Code for Sustainable Homes
could increase build costs from between £3,000 and £36,000
per dwelling depending on the level. While the costs can be considered
high, the TCPA believes that improvements in technology and requirement
for all new homes to be zero carbon by 2016 will create sufficient
economy of scale to ultimately bring down costs. In meeting these
costs, developers will recognise the inherent added values and
that building sustainable homes will need to be considered as
part of a wider package of improving the quality of new homes.
3.2.5 Existing non-domestic buildings account
for a large proportion of existing stock in our urban centres
as well as other outer-lying areas, including business parks in
the urban fringes. Therefore the TCPA believes creating and sustaining
economies of scale and scope would be key to providing financial
incentives towards greening the existing stock and achieving real
overall reductions in carbon emissions.
3.3 Eco-towns
3.3.1 In our best practice guide on urban
extensions and new settlements, the TCPA acknowledges and emphasizes
the need to protect the uniqueness of the country's rural landscapes
from harmful human intervention. The TCPA believes it is appropriate
for development and growth to be accommodated within a balanced
"portfolio" approach.
3.3.2 In the TCPA's eco-towns scoping report,
we see the eco-towns will be part of the continuing programme
to achieve the step change in the quantity and quality of housing
and communities that England needs. With Government's aspirations
to begin work on eco-town building by 2010, we envisage they will
be exemplar developments to pave the way for innovation, in particular
towards zero-carbon.
3.3.2 Therefore the TCPA fully supports
the recent decision to ask proposals for "eco-towns"
within this portfolio of development options available to planning
bodies to contribute to delivering the three million homes target.
It should be noted that the location and development of such eco
town sites would be dependent on a number of stringent environmental,
economic and community development criteria and best practice
guidance (as provided in the form of worksheet guidance produced
by the TCPA, Communities and Local Government and other respective
contributors). It would be inappropriate for the TCPA to make
specific comments regarding any of the sites in consultation at
the present time.
3.4 Greenfield and green belt developments
3.4.1 The TCPA stresses the need to clarify
and distinguish what is considered as development on greenfield
sites and what is considered as developments in the greenbelt.
Both are significantly different, and should not be used interchangeably
to mean the same thing.
3.4.2 A greenfield site is one that has
not previously developed, and therefore includes farmland, agricultural
land, parks and the like. Greenbelt is a specifically defined
area of land around and existing developed area, with a specific
purpose, as is the case with London. Greenbelt land currently
occupies about 12% of English land.
3.4.3 The TCPA seeks to classify different
types of developments on greenfield sites to those which constitute
new settlements, and those which constitute as urban extensions
to an existing town or city. Therefore uncovering the essential
role of green open space must be considered according to the relevance
of the development contexts as identified above, and within the
overall context towards achieving a sustainable community.
3.4.4 In our policy statement on Green Belts,
the TCPA recognises that containment policies are still required
but that a flexible approach to development options should be
considered where development is appropriate to the character and
needs of the local area and community. The TCPA's best practice
guide advocates for high environmental standards to be embedded
in any development proposal to maximise environmental responsiveness
in the planning and development of new settlements by the existence
of an effective network of green infrastructure.
REFERENCES TO
TCPA DOCUMENTS
Barker, K, April 2008, Supply targets and credit
turmoil in Town and Country Planning, Volume 77, No 4, London,
TCPA, pp 170-172 (Annex).
Holmans, A and Whitehead, C, October 2006, Town &
Country Planning Tomorrow Series Paper 5. More Households to
be Housed Where is the Increase in Households Coming From?,
TCPA, London.
TCPA, March 2007, Best Practice on Urban Extensions
and New Settlements. A report on emerging good practice.
TCPA and David Lock, July 2007, Eco-towns: scoping
report. Helping to deliver a step change in the quality and availability
of homes for the people of England, TCPA, London.
TCPA, November 2003, Policy Statement—Green
Belts.
TCPA, April 2006, Policy Statement—Housing
Market Renewal.
TCPA, April 2000, Policy Statement—Housing.
TCPA, June 2006, Policy Statement—Planning
for Sustainable Energy.
TCPA, September 2002, Policy Statement—New
Towns and Town Extensions.
TCPA & CHPA, March 2008, Community Energy:
Urban planning for a low carbon future.
TCPA, January 2006, Sustainable energy by design:
a guide for sustainable communities.
13 May 2008
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