Memorandum by Council for the Protection
of Rural England (CPRE) (HOU 36)
1. This paper sets out CPRE's views in response
to the call for evidence from the Housing, Planning, Local Government
and the Regions Select Committee for its current Inquiry on affordable
housing. Please note that this paper follows generally the line
of our submission to the previous Inquiry, with some changes to
take account of recent developments.
2. A number of factors have contributed
to the recent renewed interest in Government housing policy, and
planning for housing in particular. Among other things, recent
housing completions figures (which showed that housing output
was at its lowest level since 1924) have been used by a number
of interested bodies to predict a crisis in homelessness andinaccurately,
in our viewconflate a number of quite distinct issues.
Among these issues are: the overall supply of sites for housing;
affordability of market housing for key workers, in London and
the South East especially; levels of affordable housing provision
more generally; homelessness and use of temporary accommodation;
the effects of revised PPG3 Housing (2000); Green Belt
policy; and the debate over the appropriate balance between housing
on greenfield and brownfield sites.
3. Policies for the provision of new housing
are at the core of CPRE's concerns. We are interested in both
the role of the planning system per se and the contribution
of new housing to the environmental, social and economic well-being
of the countryside. We have a record of close involvement in this
issue over many years.
4. Our report Housing with Hindsight
(1996) showed that, despite significantly more private market
housing being built than had been projected, there was a dramatic
shortfall between the identified need for affordable housing and
the amount built. This means that large amounts of land identified
in plans to meet social housing need were being used to provide
market housing over and above identified need, fuelling further
imbalances in local demography and workforce composition, with
consequences for service provision. We have no reason to believe
that this state of affairs has altered significantly since then.
5. The continuing reduction in housing completions
appears to be very largely as a result of the slump in social
housing provision rather than constraints on market housing. Of
the 135,000 houses completed during 2000-01, according to the
former DTLR's figures, 86 per cent were provided by "Private
Enterprise" and around 12 per cent built by Registered Social
Landlords, with just 0.5 per cent accounted for by Local Authority
housing. The same figures show an increase in housing starts for
the first two quarters of 2001-02 over the previous year. This
compares with the situation from the mid-1950s until the mid-1970s,
when the combined housing output of local authorities and Registered
Social Landlords remained generally comparable with that of private
housebuilding (Office of National Statistics).
6. CPRE joined forces with Shelter, the
TCPA and the NHBC for a national inquiry into housing need in
rural and urban areas in 1998. Progress with changes to national
planning guidance, however, has been limited: the latest Circular
6/98 Planning for Affordable Housing and the Rural White
Paper contributed only marginal improvements in the policy framework,
some of which have not been taken up by local authorities; and
PPG3 introduced the welcome requirement for local authorities
to co-ordinate housing strategy with planning, but this has yet
to produce significant results.
7. CPRE fully acknowledges the vital importance
of adequate provision to meet identified social housing need.
We have a number of suggestions as to ways in which this issue
might be addressed without causing unnecessary harm to the countryside.
8. CPRE believes that there are dangers
in the use of the term "affordable". There is an uncertain
distinction between housing for social need and housing provided
on the open market at prices which are simply relatively more
affordable (or less out of reach) than the bulk of supply. We
therefore favour the use of the term "social housing"
rather than "affordable housing". We would strongly
support the removal of subsidised market housing from the general
definition of social/affordable housing and limiting the definition
to property available in perpetuity for letting at sub-market
rents to meet an identified need. This definition should also
be adapted to include shared ownership/rented housing, where the
tenant/part-owner may not take full possession and the property
remains in the hands of a social housing provider.
9. There is clearly higher demand for housing
at sub-market rents and prices in the South East, London and other
highly prosperous parts of the country. We emphatically do not
believe, however, that this need justifies or requires large releases
of greenfield land for new housing. There remains considerable
(underestimated) capacity for making better use of previously
used land and buildings for new housing development across the
country, including in the South East and surrounding regions (see
paragraph 13 below for more detail on urban capacity studies).
Of the approximately 750,000 empty homes in England reported by
the Empty Homes Agency, at least 327,100 are in the southern regions
of England (London, the South East, South West and East of England).
90,700 of these have been empty for more than 12 months. The recent
report of the TLR Select Committee Inquiry into empty homes highlighted
the estimated national need for 83,000 affordable dwellings per
annum to 2016, of which approximately 50,000 per annum. are required
in the southern regions of England. The Report goes on to say
"In crude terms (leaving aside issues of
price, location and quality) the long term empty homes thus represent
almost two years' worth of the required supply of affordable housing
in the four southern regions."
10. We believe that arguments that planning
constraints on greenfield housing are a significant contributory
cause of the shortage of affordable housing are deeply flawed.
Available figures, notably those used by the Urban Task Force
in its Report, indicate that: (a) land supply is ample, even in
the South East; but (b) developers are not always willing or required
to provide the sort of housing which is most needed and on sites
which have been identified. This message is reinforced by the
experience of CPRE volunteers closely involved with the planning
system across the country. While there may now be a heightened
need for social housing in some parts of the country, we see little
clear evidence of any connection between this issue and land supply
11. The recently published National Land
Use Database figures indicate, as Lord Rooker has himself acknowledged,
that the supply of previously developed urban land and buildings
is no obstacle to meeting the Government's brownfield housing
target of 60 per cent. CPRE welcomes the early achievement of
the 60 per cent target. We believe it vindicates our long-held
view that there is great potential to increase the proportion
of housing built on previously developed land. We strongly advocate
an increase in the target to at least 75 per cent. This would
not only bring benefits in terms of reducing the damage to the
countryside from greenfield housing, but also help underpin the
Government's objective of Urban Renaissance. Greater use of previously
developed land and buildings should also bring public economic
and social benefits by directing housing towards those areas where
maximum use can be made of existing infrastructure and services,
and where residents can enjoy maximum ease of access to their
12. The argument that land supply is restricting
housing supply bears little examination. The density of current
housing development continues to waste land throughout the country:
the figures for 2000-01 show an average density of housing of
around 25 dwellings per hectare (dpha). This is for a number of
reasons, but significant among them appear to be a combination
of inertia and resistance to change among local authorities and
developers, and a reluctance on the part of Government Regional
Offices to intervene to enforce national planning policy guidance.
If the sites developed for housing in 2000-01 had been developed
at an average density of 40 dpha, mid-way within the (we believe
unambitious) minimum range set out in PPG3 of 30-50 dpha, 60 per
cent more housing would have been provided on exactly the same
amount of land. This waste of land is an issue which affects the
whole country, not just the pressured South East.
13. Recent criticism of revised PPG3 Housing
(2000) that it has reduced supply of housing seems implausible,
given that most permissions last for three to five years, and
that PPG3 has been in force for barely two years and only patchily
applied by local planning authorities to date. There could conceivably
be medium-term implications for land supply where local authorities
are finding it hard to adapt from a "greenfield first"
approach to one focused on assessing, and making the most of,
urban capacity, as PPG3 requires. We believe that PPG3's immediate
effect has, however, been blunted by the reluctance of some local
authorities and the Government Regional Offices to pursue and
enforce the prescribed changes to policy and practice. We would
draw the Sub-Committee's attention to the welcome emphasis in
the Regional Governance White Paper Your Region, Your Choice
on the need for, and desirability of, greater co-ordination
between assessment of housing need, housing investment strategies
and planning policy and practice at the regional level. We believe
the new Public Service Agreement relating to protection of the
countryside, announced in July, also has an important role to
play in guiding co-ordinated activity.
14. Far from reducing the planning system's
ability to provide for social housing need, PPG3 contains clear
advice on co-ordinating local authority housing and planning strategies.
This requirement has, however, so far had little discernible effect
on local authority practice, and is one of a number of areas where
much greater Government attention to delivery is required.
15. PPG3 also requires all local authorities
to carry out a full urban capacity study before any land allocations
are made for housing. This is necessary to ensure that maximum
use of previously land and buildings before greenfield sites are
released, following the sequential approach. Although some local
authorities (eg Plymouth) have made great progress with such studies,
others have been slow to comply. Even where Urban Capacity Studies
have been carried out, in a number of cases these have been of
doubtful quality, throwing into question the validity of their
findings and giving rise to the suspicion that they have significantly
underestimated the potential for supply.
16. We would also highlight the following
issues in the context of the Sub-Committee's Inquiry.
We believe there are grave dangers
inherent in simplistic approaches to this problem, such as confusing
simple market demand for housing with housing need.
There has been a widespread failure
by local authorities and providers to make full use of the tools
already available to them, as indicated most recently by the former
DTLR's own research Delivering Affordable Housing through Planning
Policy (February 2002).
We would like to see stronger promotion
of the ways in which planning could help secure more affordable
housing, eg though clear policies in development plans for the
percentage of affordable housing to be required of developers,
and full implementation of PPG3 Housing.
We would encourage the Committee
to explore examples of local authorities where good practice is
being followed in PPG3eg in reviewing plans, removing of
unsuitable greenfield sites, applying the sequential test, actively
promoting the re-use of previously used urban land and buildings,
requiring higher density development and integrating housing strategies
with planning policiesto show that progress is possible.
The restatement in the Rural White
Paper of support for a one-for-one (market/affordable) housing
policy requirement appears to have had little noticeable effect,
and needs to be made use of by all local planning authorities
that have rural areas.
We warmly welcome the increased funding
recently announced by the Chancellor in the Comprehensive Spending
Review. However, we believe that the importance of providing proper
funding for social housing, including setting the spending limits
for providers at realistic levels within which they can work,
has been neither sufficiently acknowledged nor acted upon by successive
Governments, and more needs to be done, including through reforms
to the planning system (see below), to address the other factors
(eg the hope value for market housing development) which determine
the effectiveness of spending on social housing.
We believe there is a pressing need
for effective integration of housing investment and planning strategies
at the regional and local levels, including the setting of regional
targets for the provision of affordable housing. The Housing Corporation,
particular, needs radically to improve its communication and collaboration
with local planning authorities.
We welcome the Government's decision,
announced in July, not to proceed with proposals to fund social
housing provision through development tariffs. There was an acute
danger that the mooted higher tariffs for greenfield sites, while
designed to encourage regeneration, would serve as a perverse
incentive to local authorities to allow greenfield development
in order to gain funds to spend on unrelated activities. We see
a future role for improved planning gain arrangements, but the
objectives to be secured by expected planning obligations should
be clearly agreed and set out in development plans first, and
draft section 106 agreements open to public scrutiny at an early
stage of negotiation. We believe that the simplest and most effective
option is much stronger use and application of planning conditions
and a duty on local planning authorities to enforce them. This
should be addressed in the Government's forthcoming proposals
for reform of local planning and enforcement powers and procedures.
Possible mechanisms to promote the
allocation of sites in development plans specifically to meet
social housing needs as part of mixed communities, eg along the
lines recently proposed by the Countryside Agency (sites of social
diversity), should be seriously considered.