Memorandum by Town and Country Planning
Association (TCPA) (SHC 19)
1.1 The Town and Country Planning Association
welcomes the opportunity to comment on this inquiry. The TCPA
campaigns inter alia for the reform of the UK planning system
to promote public participation and sustainable development and
for environment and development policies which improve the living
and working conditions of everyone. Amongst the TCPA's objectives
is "a decent home in a good environment for everyone who
needs it". The Association believes the UK is a long way
from achieving this aim.
1.2 The TCPA welcomed the acceptance by
the Government, in the speech by the Deputy Prime-Minister in
July, that the issues of housing and sustainable communities are
of critical importance.
2. THE OVERALL
2.1 The Deputy Prime-Minister is right in
his conclusion that there are different problems in different
parts of the country: generally, overcrowding in the south (particularly
the south east) and market failure in parts of the north.
2.2 There are two parts to the problems
in the south: a shortage of housing generally and a shortage of
affordable housing for those on lower incomes. A study carried
out from the then DETR by Entec with the TCPA, Nottingham Trent
University and Three Dragons into Affordable Housing
defined affordable housing using a series of focus groups:
"social rented housing as the first priority
and forms of intermediate housing, ie
shared ownership and
keyworker rented accommodation in addition
to, but not as a substitute for, social rented housing. Such subsidised
housing should take a whole variety of forms and tenures to widen
access to housing for those on lower or no incomes".
2.3 The need for affordable housing is not
a geographically specific phenomenon. People in all parts of the
country need to have access to housing, however, the scale and
type of need does vary between different regions. Evidence suggests
that around two-thirds of new households will be in the south
of the country, a part of the country that is already experiencing
rapid increases in house prices.
2.4 It is estimated that approximately 227,000
new homes per year will be needed over the next two decades. With
the current figures languishing at around 140,000 it is unsurprising
that house prices are rocketing along with the need for affordable
housing. The requirements for affordable housing, from the total
estimated housing need of 227,000, currently stand at around 85,000
new dwellings per year, to be met by new building, provision of
flats by conversion and possibly by acquiring vacant dwellings
and bringing them back into use. The spatial distribution of this
affordable housing varies considerably, with around 50,000 (58%)
likely to be needed in southern England.
2.5 The government needs to accept the scale
of the problem and the likely impacts such shortages will have
(see below). It also needs to recognise that much of the shortage
comes, not from homeless or very low income groups, but from those
on low to medium incomes. The keyworker debate is an important
start, but there are huge numbers of people struggling to afford
decent housing who do not fall into this category, but who would
certainly be considered keyworkers by their employers.
2.6 The definition of key workers needs
to be defined. At present key workers tend to be seen as nurses,
teachers and other public service workers, but the problem is
not confined to these groups. Employees in the private and voluntary
sectors can also be defined as "key" to the functioning
of these organisations and should be recognised as such in the
provision of housing.
2.7 The TCPA is very concerned about the
social and economic costs of failing to provide for the nation's
housing needs. A lack of affordable housing in an area will mean
that those on lower incomes will not be able to afford to live
there. The impact of this on businesses will be evidenced by the
fact that they will have difficulties in finding employees. Similarly,
schools will have difficulties in employing and retaining teachers,
which will have knock-on effects for education standards in the
area. It is essential that localities maintain an approximate
balance in relation to income groups, if they are to be sustainable
and successful in the long term.
2.8 Although the Deputy Prime-Minister clearly
recognises the reality of the housing crisis, he clearly does
not see the whole picture. He claims that the Government is meeting
the 60% brownfield target, but ignore the fact that this represents
60% of a far lower level of house building than is required.
3. ARE THE
3.1 The additional funding being made available
and the commitment from Government is likely to ease pressure
on the housing market in those areas experiencing high prices,
however, it is unlikely to significantly reduce prices unless
the money is targeted. It is also questionable whether the Government
would see significantly lower prices as desirable, however beneficial
this may be to those on lower incomes, since this would leave
large numbers of home owners with negative equity.
3.2 The additional funding could have significant
impact on house prices if channelled into selected areas, for
instance the four growth areas outlined by the Deputy Prime-Minister.
However, a number of pre-conditions would have to be met: a dedicated
agency would need to be set up (eg a Special Purpose Vehicle)
to oversee implementation; such an agency should also be required
to ensure that corresponding infrastructure was developed in parallel,
for instance public transport, retail and other community facilities.
It is likely that the funding earmarked for this will not be sufficient.
4. THE GEOGRAPHICAL
4.1 Special Purpose Vehicles (SPV) will
be critically important, particularly for the hard to develop
area of the Thames Gateway. The recognition by the Deputy Prime-Minister
of this is welcomed.
4.2 In addition, the concentration of much
of the new development into growth areas will help to achieve
more effective results. As mentioned in paragraph 3.2, if development
of new housing is built along side other facilities and takes
the form of new communities (be these free standing on urban extensions)
then real results are possible.
5. WHETHER THE
5.1 While the TCPA agrees with the principles
of the urban rennaisance and the re-use of brownfield land, we
are concerned about the intention to intervene in applications
for developments under 30 dwellings to the hectare. Such a policy
will further erode the ability of local planning authorities to
decide what is best for their particular circumstances.
5.2 Similarly, the TCPA has been a long
time supporter of the principles behind green belts, however we
do believe that in some cases the broad swathes of land designated
as green belt around cities can actually run counter to the needs
of sustainable development. The TCPA believes that green belt
designations should be reconsidered and, where necessary, boundaries
redrawn. For instance, designations could be changed to allow
for development of housing in areas where there is employment
but a shortage of housing and vice-versa. For example, releasing
land around some out of town shopping centres to allow housing
and community infrastructure to develop, or to release employment
land in towns and villages in the green belt that have become
essentially dormitory towns.
5.3 So long as the new housing is planned
in an integrated way, together with jobs, transport and other
community infrastructure, the proposals would not result in sprawl.
In fact, they would be likely to result in far more sustainable
land-use patterns and reduce the need to travel.
6.1 The three proposed new Millennium Villages
in East Ketley, Milton Keynes and Hastings . . . I don't feel
able to comment here!
7. THE BALANCE
7.1 Both housing associations and private
sector house builders are interested in providing "intermediate
market housing" particularly for key public sector workers.
Public funding should be available for these types of initiatives
as well as for low cost home ownership. There should however be
proper safeguards to ensure that either properties remain "affordable"
in perpetuity or that any funds generated from their resale are
channelled back into additional affordable housing provision.
Subsidising market housing is not advocated by the TCPA.
7.2 Social housing providers, rather than
the TCPA are better placed to advise on policy on funding distribution
across different housing tenures.
7.3 While the annual requirement for affordable
housing stands at approximately 85,000, this makes no consideration
of the backlog of unmet need. To make significant inroads into
this would require higher levels of new provision and this will
necessarily mean additional resources being made available.
7.4 It is an important factor that the cost
of land is rising rapidly, particularly in the south of the country,
and means that money made available for affordable housing is
effectively buying less and less. In addressing the affordable
housing issue therefore, there is also a need to address the wider
question of adequacy of supplythe current undersupply of
land for housing has been pushing up values (a relatively simple
7.5 The two factors, of general undersupply
of housing and insufficient resources are having a disastrous
impact on the number of affordable houses being built. The TCPA
believes that the ideal route to the provision of more affordable
housing in the UK is ultimately through a more transparent tax,
equal to a proportion of the added value accruing to a site through
its development. Such a tax would necessitate the abolition of
Circular 6/98 and apply to developments permitted whatever the
proposed use of the site (residential or commercial for example).
It is important to note however that the greater the amount required
for affordable housing from planning gain, the less will be available
for other important community facilities, transport improvements
and other measures which rely on planning gain funding.
7.6 In the absence of such a measure however
the TCPA supports steps to ensure that development for commercial
uses does not remain an option to serve the aim of avoiding fair
levels of contribution to public works such as affordable housing.
7.7 There is no evidence, of which the TCPA
is aware however, that planning systems can make good the shortfall
in the provision of housing needs. Planning gain and tax on land
value will only ever make a real contribution to affordable housing
provision if the tax is set at 100%, which history has proved
impracticable. The major contribution must come from direct provision
of housing through central government funding. It is disappointing
in this regard to note that in 2001 less than one fifth the number
of affordable units was constructed than were constructed in 1980.
7.8 The TCPA would wish to see a restriction
placed upon the number of homes owned by local authorities that
are subject to right to buy. Tenants should retain a right to
apply to be housed in properties that can (after the satisfaction
of current conditions) be bought by their occupants through right
to buy legislation. A proportion of housing that must be protected
from market forces and remain in public or Registered Social Landlord
(RSL) ownership in perpetuity. The level at which this remains,
however, could be varied in line with the Government's stated
policy to plan, monitor and manage housing and other planning
provisions. Local authorities would therefore, be in a better
position to construct housing and to make a greater contribution
to meeting housing need than at present.
8. THE EXTENT
8.1 The TCPA believes that decisions should
be taken at the most local level possible to ensure effective
planning. Over centralisation of decision making can, and does,
result in generalisations, whereas in reality problems are often
unique to a locality or differ between them.
8.2 In relation to numbers the strategic
element is of critical importance, therefore the most appropriate
tier will be the regional. Other decisions on issues such as density
would be better made at more local level, since these should be
based on local circumstances. The TCPA does not agree that developments
with densities lower than 30 dwellings per hectare should be automatically
called in by the Secretary of State.
17 DETR (2001) The Delivery of Affordable Housing
Through Planning Policy: Entec, Nottingham Trent University, TCPA,
Three Dragons. Back
Barlow J, et al (2002) Land for Housing: Current Practice
and Future Options: JRF. Back