Memorandum submitted by Campaign to Protect
Rural England
INTRODUCTION AND
SUMMARY
1. The Campaign to Protect Rural England
(CPRE) welcomes the Committee's decision to carry out an inquiry
into this important subject. We recognise that we need more homes
to house a growing number of households. Since new housing has
the greatest impact of all development in terms of land-take and
associated activity, it is vital that new homes are provided in
a way which minimises harm to the environment.
2. CPRE believes that housing development
should never be considered in isolation, but in the context of
broader objectives for conserving and enhancing the built and
natural environment, regenerating urban areas and securing more
sustainable patterns of development.
3. Key points we raise in our submission
are as follows:
— we need bolder targets and measures
to secure high environmental standards in all development and
address the wider footprint of development, including landscape
impacts and carbon emissions arising from transport as well as
built form;
— action is urgently needed to raise
environmental standards in existing homes, such as reducing VAT
on buildings repair and maintenance and providing grants for householders
to improve the environmental performance of their home;
— compared with the amount of development
already planned or expected to come forward under the Government's
Growth Points initiative, the contribution of eco-towns to meeting
housing needs is small;
— current housing plans pose a major
threat to the Green Belt;
— much more remains to be done to make
use of the potential for meeting housing needs through recycling
brownfield land and buildings, such as raising the target for
the proportion of homes built on brownfield land to at least 75%;
and
— in pursuing the eco-towns initiative
in the manner which it has done so far, the Government risks undermining
the planning system.
Is the target for all new homes to be zero-carbon
by 2016 on track to be achieved? Does the Government need to do
any more to deliver this target?
4. In order to meet this target, progressive
tightening of mandatory energy efficiency standards will be vital.
We believe that raising requirements for private housing developments
to the equivalent standard required of social housing developments
would make the target much more achievable. There would be other
benefits too, notably lower costs secured as a result of economies
of scale. This would also enable registered social landlords to
potentially buy more properties they are offered by the private
sector than they can currently, because these would meet their
minimum requirements.
5. Far more could be achieved by adopting
a more joined up approach between regulatory regimes, such as
building regulations and planning controls, to minimise energy
requirements through good urban and architectural design and mixed
use, and a stronger focus on re-using buildings and urban brownfield
land. We do not believe the answer lies in adopting "a tick
box approach" or replacing the planning system with a licensing
regime, since we need to both raise minimum standards and foster
innovation and best practice. We need strong planning policies,
local, regional and national, and higher building control standards.
Crucially, planning authorities should be encouraged to cover
some matters dealt with under building regulations within their
Local Development Framework, eg as supplementary planning guidance,
something national policy currently discourages them from doing.
How should "zero-carbon" be defined?
What role should carbon offsets play in meeting this target?
6. While we do not offer a definition of
zero-carbon we believe it is vital that a "whole-life"
approach is taken. This should ensure that any definition takes
into account carbon emissions in construction and throughout all
stages of a building's life, from extraction, manufacture and
transportation of building materials and waste through to use
and disposal.
7. In assessing carbon emissions associated
with new development, it is vital to consider the wider footprint
of development, including CO2 arising from transport during the
lifetime of the development. New development often generates significant
traffic, with the amount varying considerably depending on the
type of development and where it takes place. Taking into account
carbon emissions associated with transport would give a more accurate
picture of CO2 emissions arising from new development. We urge
the Committee to consider how this might be reflected as part
of a broader "zero carbon" measure.
8. We believe offsets are best avoided since
they only delay, rather than avoid, the need to act at some time
in future. Instead, we suggest the Committee explores the role
"carbon quotas" might play in future in securing changes
in behaviour, among individuals and businesses, which are urgently
needed and ways in which these might be introduced.
What is the likely scale of environmental impacts
of the construction of 3 million new homes? How should these impacts
be reported? What should be the role of central Government in
minimising them?
9. The scale of environmental impacts will
depend to a major extent on where homes are built as well as how
they are constructed. Impacts are likely to be smaller where the
emphasis is on re-use and conversion of existing buildings and
the majority of development takes place on urban brownfield sites.
For example, the embodied CO2 of a refurbished home is considerably
lower compared with that of a new home (15 and 50 tonnes, respectively—see
New tricks with old bricks, Empty Homes Agency, 2008).
The layout and built form of development are also important, since
terraces and apartments are generally more energy efficient than
detached dwellings. Space heating accounts for the largest proportion
of energy use in homes, therefore it is important that the built
form minimises energy use. Higher densities and optimising layout
and orientation in mixed use to minimise energy use are ways in
which the planning system could assist in promoting more energy
efficient development. (CPRE's forthcoming report proximity
principle ights some of the benefits of compact, higher density
development).
10. With regard to how impacts are reported,
CPRE believes that landscape, urban intrusion, resources, including
energy, minerals and water supply, quality and flooding should
be among impacts considered.
11. Central Government has a crucial role
to play in minimising environmental impacts through a combination
of regulation, planning policy and fiscal measures and incentives
which positively encourage households, business and local authorities
to take the necessary action. It is vital that Government policies
are consistent with, rather than undermine each other, as is often
the case currently (see—How green is your region? CPRE,
2007). Among measures needed are:
— grants for householders to make environmental
improvements to their land and property;
— support and encouragement from Government
to local planning authorities to draw up strong local planning
policies to manage development pressures in their area in a way
that addresses environmental challenges, rather than exacerbates
them;
— a requirement for the National Housing
and Planning Advice Unit to improve its spatial planning expertise
and develop a better understanding of the role of planning in
delivering environmentally sustainable housing; and
— a lower rate of VAT on the repair
and maintenance of buildings.
As currently envisaged, how big a contribution
will eco-towns make to reducing the environmental impacts of housing
in England, both in their own right, and in the development of
design and techniques that could be rolled out in other developments?
12. This initiative provides an excellent
opportunity for planning authorities and developers to put forward
innovative schemes, but the locations must be right. Eco-towns
will represent at most just 7% of the three million new homes
the Government seeks to build by 2020. To keep the impacts of
climate change within manageable parameters, CPRE believes we
need to achieve an 80% reduction in carbon emissions (on 1990
levels) by 2050. Urgent consideration should therefore be given
to improving the environmental performance of all development.
Since up to 70% of today's homes will still be around in 2050,
gains to be achieved from raising environmental standards in existing
homes are arguably greater. In terms of numbers, homes built as
part of the Government's Growth Points initiative may be far more
significant than eco-towns: it is essential that these are built
to an equally high environmental standard.
13. We understand from the Department for
Communities and Local Government that some of the suggestions
put forward as part of the eco-town bidding process are truly
ground-breaking. At present, there is limited information available
on the shortlisted schemes. We look forward to hearing about these
in due course. Many of the techniques to be used are no doubt
currently available and these we believe should be rolled out
to all development sooner. We see no reason why the Government
should wait for eco-towns to be built before demanding higher
environmental standards of all developments.
14. CPRE is particularly concerned that
transport arrangements for eco towns are sustainable. The Government
has said eco-towns are to be stand-alone developments, but we
believe developers, retailers and residents should not have to
rely on road travel. There is currently a lack of evidence demonstrating
that schemes will offer truly sustainable models of living and
working. It would be a pity if environmental gains from achieving
zero-carbon homes are lost because those living in the 5,000 to
20,000 new homes at each town rely primarily on cars to travel
to school, work and for their leisure activities. This will make
it harder for the Government to achieve commitments under the
Climate Change Bill.
15. There is also growing concern that eco-towns
may distract from the urgent task of urban regeneration, given
the slowdown in the housing market and developers' preference
for green fields. For example, Cambridgeshire Horizons, the organisation
responsible for housing growth in the Cambridge Sub-region, has
warned that a new settlement at Hanley Grange would make it difficult
for them to deliver on existing planned sites, including Northstowe,
by diverting resources away from these areas. Similar fears have
been expressed by the Leicester Regeneration Company and City
Council and in West Sussex by Arun District Council concerned
that an eco-town at Ford airfield would harm regeneration in Bognor
Regis.
16. Lessons from eco-towns will be of limited
relevance elsewhere unless they address difficult challenges,
such as land remediation and car dependency. Regenerating derelict
land and bringing back into use empty buildings should arguably
take priority over creating new settlements from scratch. Most
new development will, or should continue to take place within
and around existing settlements, where much of the infrastructure
is already in place or can be provided easily. This suggests the
need for exemplar schemes based around urban renaissance, such
as "eco extensions" or "eco-quarters". One
example we recommend the Committee consider is the Bioregional,
Quintain scheme which is to be developed around Brighton Station
according to "one planet" principles.
17. A serious concern for CPRE is that so
much of the eco-towns process appears to lie outside the established
planning system. Under changes to planning rules brought about
by the 2004 Act the "development plan" consists of the
regional spatial strategy and local development framework. These
plans provide the basis for planning decisions, they foster consensus
and provide certainty to decision makers, business and communities
about the level and location of new development. The normal procedure
is for the principle of major developments to be established through
the development plan. In pursuing the eco-towns initiative in
the manner it has done, the Government is jeopardising the achievement
of these plans and sidelining the considerable time and effort
communities, business and planners have put into drawing them
up. This is the antithesis of good planning and crucially, for
the purposes of this inquiry, unlikely to foster sustainable development.
To what extent do, and should, planning controls
protect greenfield and green belt land from development of new
housing? How adequately are environmental considerations (for
instance, biodiversity and rural landscapes) being taken into
account in deciding the location of new developments?
18. There is growing evidence to suggest
that greenfield land is less well protected than it has been in
the past and is facing more pressure for development than ever
before. Much of this threat is the direct result of disturbing
changes to planning policy, predicated on an assumption that the
housing market will remain as strong as it has been in recent
years despite the recent downturn. Particularly worrying is the
emphasis that PPS3 Housing places on allocating land to meet housing
targets, without recognising the contribution windfall sites make
to housing land supply and the implicit assumption that building
more homes will solve affordability problems when evidence demonstrates
demand-side factors have more influence on prices (Building on
Barker, CPRE, 2005; Planning for housing affordability, CPRE,
2007). Equally worrying is that PPS3 does not allow planning authorities
to "phase" site release to control greenfield development,
except where housebuilding is on course to meet targets.
19. Kate Barker in her review of housing
supply acknowledged that developers prefer greenfield sites and
referred to the phenomenon of "brownfield land market failure".
Unfortunately, she offered few solutions. With more land allocated
than the market needs, it seems very likely that developers will
"cherry pick" more profitable greenfield sites, in preference
to brownfield locations; and windfall sites may not come forward,
or may do so at a slower rate. Under the current approach we risk
returning to the situation which prevailed when the Urban Task
Force reported in the late 1990s, characterised by the twin problem
of greenfield sprawl and urban decline.
20. CPRE has always accepted the need for
some greenfield development, but only where other more sustainable
options are first considered. The National Land Use Database (NLUD)
identifies enough brownfield land suitable for housing in England
for more than a million homes. Evidence suggests much more land
is available than this, since NLUD excludes sites of less than
0.25 hectares. Research carried out by Llewelyn Davies Yeang for
CPRE (Untapped Potential, 2007) looked at a sample of urban
capacity studies, in rural, urban and mixed areas. It found that
local authorities seriously underestimate the amount of brownfield
land available, small sites in particular tended to be underestimated.
The study revealed enough small brownfield sites in pedsheds in
London for around 60,000 homes. It is important to remember that
brownfield sites are a renewable rather than finite resource.
Green Belt
21. CPRE believes that that the Green Belt
continues to require the strongest protection from inappropriate
development. The role of the Green Belt in encouraging regeneration
in our largest and most historic cities, and in preventing sprawl,
has long been acknowledged. The role of the Green Belt in protecting
beautiful and productive countryside has not been sufficiently
appreciated by the Government or other groups. We welcome the
acknowledgement by Natural England, in their recently adopted
policy paper on Housing Growth and Green Infrastructure, of the
important role that Green Belts play in encouraging urban regeneration.
We are, however, disappointed that this policy paper makes no
reference to the countryside protection function of Green Belts.
We would expect the Government's statutory conservation advisor
to acknowledge this important role.
22. Regional planning bodies and local planning
authorities face growing pressure from Ministers and government
regional offices to review Green Belt boundaries, despite the
clear statement in the Government's Planning Policy Guidance note
2 (PPG2, 1995) that "the essential characteristic of Green
Belts is their permanence". We are concerned by growing evidence
which suggests that housing demand is being seen as an "exceptional
circumstance" justifying Green Belt boundary reviews. CPRE
is aware of at least 37 separate reviews either currently in progress
or envisaged in draft regional plans across the country. The most
significant are in the East of England, South West and West Midlands.
In these and most cases, the main reason for the reviews is to
accommodate increased levels of housing development. In the North
West, Green Belt is to be reviewed to accommodate expansion at
two airports. In the South West and West Midlands there appears
to be little commitment in practice to ensuring that brownfield
sites are developed before major development in the Green Belt
is considered, as PPG2 also calls for.
Planning policy
23. We believe the Government's current
approach to planning for housing is seriously flawed. While we
welcome improvements to national planning policy on matters relating
to affordable housing and design, the weakening of the sequential
approach which gave priority to urban brownfield land throughout
all stages of the development process, from the initial search
for land through to site allocation and release, is a serious
cause for concern. The current approach in PPS3 contrasts with
the groundbreaking approach in earlier planning guidance which
saw housebuilding rates rising while the efficiency with which
land was developed also improved. Three quarters of new homes
are now built on brownfield sites and the average density of development
stands at 40 dwellings per hectare, compared with 56% and 25 dph
respectively in 1997. These achievements demonstrate that "a
brownfield first" approach is no obstacle to development.
Under the current approach, with its focus on allocating land
to accommodate national housing targets, targets which themselves
may not be able to be met under current market conditions, we
fear these achievements will be lost.
24. The benefits of taking a proactive approach
to identifying, releasing and developing brownfield urban sites
are well established and embraced by leading practitioners (Untapped
Potential, CPRE, 2007). John Calcutt in his review of housebuilding
(2007) recognised this potential and challenged the industry to
do better. As a matter of urgency we believe the Government needs
to look again at planning policy to ensure that the focus remains
on making best use of brownfield land regardless of wider conditions
in the housing market and rate of housebuilding. A test of how
robust planning policy is should be that sustainable outcomes
remain possible whatever rate housebuilders build homes. Consideration
should also be given to raising the national target for the proportion
of homes that should be built on brownfield sites from the current
60% to at least 75%.
25. Windfall sites (ie unallocated brownfield
sites) are a crucial part of housing land supply in many areas.
For example, regional monitoring shows 70% of homes in the south
west in 2006 were built on windfall sites. It makes no sense to
discourage planning authorities from taking into account windfall
sites when calculating how much land to allocate, as PPS3 currently
does (Will they work? Planners' views on Government proposals
on planning for housing, CPRE, 2005). It is vital that planning
authorities take account of windfall sites they expect to come
forward and that they use this evidence when calculating how much
land to allocate in their LDF. In our view, national policy should
positively encourage planning authorities to use phasing to control
greenfield land release and to assess realistic windfall potential
as an integral part of land supply. We urge the Committee to make
recommendations to Government on these matters.
26. However much land local authorities
allocate for development, developers only build when market conditions
are right. There are now serious doubts about the housebuilding
industry's capacity to meet national targets in the light of current
market conditions. Relaxing planning controls may increase development
in some areas, but at a price, since it will become more difficult
to attract development in other areas. The answer is not to relax
planning controls, as the NHPAU recently called for, since this
only increases uncertainty, creating confusion and delay. Last
year saw housing starts fall for the first time for seven years.
Evidence shows that land is being made available through the planning
system with provision in adopted and emerging RSSs now standing
at around 210,000 homes a year. Research commissioned by CPRE
on the relationship between house prices, housebuilding and land
supply, found that housebuilding was not keeping pace despite
increasing land allocations being made by local authorities (Planning
for Housing Affordability, CPRE, 2007). The study concluded
the prime determinant of house prices was ability to pay.
27. CPRE is worried that the slow progress
in moving over to the new system of local development frameworks
and pressure that planning authorities are under (draft PPS12
and PPS3) to approve development where no up to date plan is in
place is hampering their ability to ensure development adequately
addresses environmental challenges. This approach is the antithesis
of good planning, making it more likely that schemes will be approved
on an ad hoc basis, rather than for sound planning reasons. We
face the prospect of a return to "planning by appeal"
unless the Government takes steps to empower local authorities
to take the necessary action to ensure development is properly
planned in the light of local circumstances and priorities.
28. CPRE publications referred to in this
submission are listed below:
How green is your region? 2007
Planning for housing affordability, 2007
Will they work? Planners' views on Government
proposals on planning for housing, 2005
April 2008
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