INTRODUCTION

  1.  The Town and Country Planning Association (TCPA) welcomes the opportunity to provide the Environment, Transport and Regional Affairs Committee with a memorandum on the public consultation draft of the revised Planning Policy Guidance Note 3—Housing.

  2.  The TCPA campaigns for the reform of the UK's planning system to make it more responsive to people's needs and for planning which promotes development that is sustainable in terms of the social, economic and environmental well-being of all.

  3.  The TCPA occupies a unique position, overlapping with those involved in profession planning, the development industry, the environment movement, academic and research institutions and those concerned with social justice. Founded by Sir Ebenezer Howard in 1899 to promote the idea of the Garden City, the TCPA is Britain's oldest charity concerned with planning and the built environment.

  4.  The TCPA has been at the forefront of the debate concerning the type and location of new housing that will be needed to meet the projected increase in households over the next 25 years. In 1996 we published a region-by-region examination of the implications of the household projections.[1] In 1998 we published a further series of reports which sought to investigate the constraints and opportunities for brownfield development in cities.[2] We gave evidence to the Environment Select Committee's previous inquiry into housing, and have recently commenced a major new project, (supported by the Department of the Environment, Transport and the Regions and a wide range of private sector concerns) entitled The People: Where Will They Work? [3] This research will examine the effect of changing patterns of employment on housing provision.

POINTS OF SUPPORT

  5.  The TCPA supports many of the aspirations identified in the draft. We endorse in particular the call for development of more sustainable patterns of settlement which deliver accessibility by public transport (paragraph 4) and the implication (paragraph 7) that regional, county and unitary authority forecast housing requirements, once agreed, should be more rigorously adhered to in forward planning. We have a long history of support for mixed-use development and mixed communities (paragraphs 9-12 and 57). We have argued, based on our own research findings, that land recycling targets should relate to the amount of recyclable, "brownfield" land available to individual local authorities (paragraph 21) rather than to any single national target such as the 60 per cent brownfield figure presently adopted by the Government. We have drawn attention to the importance of integrating decisions on planning and transport and exploiting opportunities to promote growth within public transport corridors (paragraph 60), whether inside urban areas or on greenfield sites (paragraph 24). We welcome the emphasis on quality and good design (paragraphs 47 to 51).

  6.  However, there are some observations in the draft which we endorse but which need amplification or qualification:

(a)  We entirely agree that open space is vitally important in the urban environment (paragraphs 52 to 54) and would add that gardens, both in public parks and those attached to individual private houses in urban and suburban areas, make an important contribution to a sustainable environment. They do this through their value as social amenities and through their contribution to biodiversity, which is often greater than that offered by today's agricultural land.

(b)  We support the case for flexibility about Green Belt boundaries where their alteration would allow more sustainable development to take place (paragraph 59) but would observe that this is more often likely to be the case than the draft implies.

(c)  We are particularly pleased to see acknowledgement of the problem of "town cramming" and the need to avoid it (paragraph 36) but regret the lack of guidance as to how the proposed "urban capacity studies" (paragraph 37) are to be undertaken and by what criteria "capacity" is to be judged. We are wary of the effect that the anticipation of "windfall site" numbers can have by reducing the need to plan ahead and by raising development densities to levels which may make more areas unattractive to families and other households. Any kind of "target" for windfall sites increases the likelihood of inappropriate and over-dense developments being permitted.

(d)  We support the emphasis on provision of affordable housing (paragraphs 13 to 16) but regard as inadequate the references to how such a need might be defined. The key ratios between local income levels and house prices or rents need to be identified regionally or sub-regionally. Otherwise there could be wide differences in how neighbouring authorities treat the matter, with serious consequences for housing demand and supply in some areas but not in others and for migration rates between local authority areas.

GENERAL COMMENTS

  7.  The TCPA is deeply concerned that Planning Policy Guidance on the subject of housing should take so little account of people's expressed desires in terms of the internal space, external surroundings, location and density of the housing they would like to occupy. Undefined catch-all terms like "a decent home" and reference to "adequate choice" are insufficient. Popular aspirations in the housing field are well documented by numerous public surveys and research[4] and should only be ignored or over-ridden for indisputable, proven and compelling reasons. In crucial policy areas such convincing rationale is lacking, notably in the supposed need to save green fields from development, and in the drive for higher development densities for the sake of the efficiency of transport systems.

  8.  The TCPA believes that the "threat" to the countryside from people wanting houses with gardens is greatly exaggerated, the extent of urbanised land being likely to increase by only two or three percentage points even if most of the housing needed over the next quarter century were to be built at generously low densities. It is also clear that the relationship between greater urban density and savings in land and energy-use is most pronounced at the sort of medium densities the TCPA has advocated for virtually the entire century of its existence[5].

  9.  The TCPA takes the view that the matter of housing location should not be divorced from where economic growth, and therefore the availability of new jobs, is occurring. The PPG refers to this matter (paragraph 5) but does not draw attention to any possible implications for the achievement of recycled land targets.

  10.  The draft is unclear about the level of public intervention required to achieve appropriate mixes of housing types, to assemble large development or redevelopment sites, and to phase the release of land for development. Local planning authorities are not equipped to direct the housing market in detail.

  11.  The emphasis on using land designated for employment to build housing may be realistic in certain urban areas where there is clearly an excess of such land, but could be counterproductive in rural locations where there is a shortage of potential employment land. In some cases it could run counter to the goal of mixed development (paragraph 4) and the need for homes and workplaces to be closer to each other. The TCPA argues that rural development is important and should not always be inhibited in the cause of furthering urban regeneration. One fifth of the population live in rural areas and can face severe disadvantage for lack of housing, economic development and jobs.

  12.  The TCPA finds the draft unconvincing on the sequential approach to housing development. We advocate a "portfolio" approach to housing land allocation, under which an appropriate variety of housing land both in and out of urban areas is used, regulated by phasing tailored to local circumstances. An overriding priority exclusively for developing previously used urban land is not practicable or realistic. We fear a build-up of housing need in some areas, followed by a rush of ill-considered land releases in order to catch up on the backlog of demand, as has happened in the past.

  13.  The TCPA takes the view that any kind of sequential approach to housing land is a matter for the planning authority to apply in allocating land and in phasing land releases. The onus should not be placed upon developers, who cannot regard land that they neither own nor control as "available" to them for development. The statement that "expeditious and sympathetic handling" of planning applications will be available to proposals to develop phased, recycled, land in urban areas (paragraph 28) implies that similarly designated greenfield sites will not be similarly treated. This is unacceptable: the planning system should promise "expeditious and sympathetic handling" of all planning applications.

  14.  No definition is offered of the "realistic unrealised potential to develop on suitable previously-used sites" (paragraph 29), nor any indication of how an application is to judge the matter other than by reference to the development plan. An application that is in conformity with the plan or which is accompanied by convincing reasons for departing from it is entitled by law to sympathetic treatment.

  15.  The review of conditions on outstanding planning permissions to take account of new circumstances (paragraph 45) is rational, but the threat to withdraw the permissions unilaterally is fraught with difficulties. These decisions must be taken at the local level.

THE DENSITY OF DEVELOPMENT

  16.  Research shows that savings of land or gains in sustainability are marginal above a medium density of approximately 37 dwellings to the hectare (about 15 to the acre). This finding is outlined in our recent discussion paper Sustainable Cities or Town Cramming?, a copy of which is appended to this memorandum[6]. Higher densities are rarely justified unless in limited areas around transport nodes and the suggestion of "over 50 per hectare" (paragraph 40) we would regard as excessive except in special circumstances certainly unsuitable for households with children and not the preferred choice of most other households. We do not understand the draft's use of the term "too much" in connection with lower density housing development (paragraph 8) but we accept that in the majority of cases very low densities (of less than 20 per hectare or 8 per acre) will not be appropriate for sustainability reasons, nor indeed desirable for the creation of liveable communities in which many trips should be walkable or cyclable.

  17.  We regard the supply of good quality houses with gardens, which can be achieved at both low and medium densities, as reflecting the desires of a high proportion of the population, which should only be frustrated for very good reasons. The latent hostility harboured by many people in positions of power and influence towards what they loftily dismiss as "suburban" environments and lifestyles does not constitute such a good reason. Nor do unsubstantiated assertions about the need for high densities in order to meet the demands of sustainability or to "save" green fields. Except in cases of landscapes worth protecting for their beauty or amenity value, the supposed "loss" of countryside involved in developing previously undeveloped land has to be balanced against the social benefit of housing people properly near their places of work, shopping, entertainment etc.

  18.  We do no accept that it is impossible to build at medium densities without becoming an entirely car-dependent society. The Garden City experience proves the point. Many variables other than density are involved, not least the better mixing of land uses, adequate investment in public transport, internet shopping, home delivery services, road pricing aimed at commuter traffic, and a range of other disincentives to excessive car use. We would point out that some of the earliest modern (ie 20th century) suburbs grew in response to extensions of urban rail networks.

  19.  We fully endorse the need for urban regeneration, but do not believe that very high residential densities are necessarily always appropriate. The life and prosperity of the whole extent of our cities will not be revived by redevelopment at the densities, and with the range of activities, to be found in city centres. If this is the approach adopted, those in a position to do so will continue to move away in search of the greater space and security, the healthier surroundings and the better services associated with lower density living environments. Contrary to the reference in paragraph 38 to the supposed fact that there can be "loss of population in cities through redevelopment at lower densities", we would contend that the outward movement of people (a less loaded term than "loss") gives the opportunity for lower density redevelopment, but is not usually caused by it.

CAR PARKING

  20.  We agree that excessive off-street parking provision may add unnecessarily to the cost and land-requirements of new housing. But we suggest that its under-utilisation (paragraph 42) arises as much from the underprovision of space in the home and the spillover of household uses—particularly storage—into the garage as from lack of a vehicle, though research evidence on the point seems to be lacking.

  21.  We would argue that the real target of planning policies should be car use rather than car ownership (paragraph 40), though we are aware of the complex relationship between the two. In the context of policies to make the inner city as attractive a place to live as out-of-city, we believe it would be a mistake to discriminate against car ownership in the cities, while leaving it as easy as ever elsewhere. Too many of the affluent, who are needed to make mixed and thriving city communities, would simply regard the impossibility or difficulty of keeping their car as a major disincentive to urban living.

DEVELOPING OUTSIDE URBAN AREAS

  22.  The TCPA is disappointed by the draft's treatment of this subject. We agree, of course, that "not all development can take place within urban areas" (paragraph 55). But we would go further and add "neither should it". Developments on greenfields, whether in town extensions, village expansions or new settlements (all of them in our view part of the "portfolio") are necessary for urban restructuring at both the individual town and city level and at the sub-regional and city-regional scales. This will make all our urban areas liveable once more and create those functioning networks and hierarchies of settlements we call "sociable cities".[7]

  23.  Approaching our settlement problems with the intention of cramming as much development as possible into existing urban areas and only then considering where else to allow it is to ignore the rapidly changing overall economic and social situation of the country, only part of which involves making something liveable out of the nineteenth century metropolitan industrial conurbations. We would argue that making smaller places prosperous, attractive, successful and well related to existing larger urban areas can help rather than hinder urban regeneration.

  24.  We recognise that urban extensions will be useful where they can use existing physical and social infrastructure (paragraph 58). But we would urge that the PPG includes warnings about the possible effects on existing settlements to which this solution is applied. The add-on estate is notorious for cutting people off from their nearby countryside. Even extensions should have a minimal green barrier between themselves and the original settlement and, most importantly, strive for a degree of self-containment and mixture of uses. New dormitory suburbs should be out of the question and (as stated in paragraph 57) adequate shops, employment and services must be provided. As long as such developments are linked to the centres of their "parent" settlement by public transport, and car use for the purpose is severely restrained, we can see advantages in their being further detached, if only perhaps by a mile. Overgrowth of an "original" settlement by a sequence of accretions would thus be avoided.

  25.  However, we do not see why discussion of expansion and infill should be limited to villages. Small and medium size towns may, in our view, sometimes be appropriate for significant expansion—even into a major new settlement.

  26.  It is not acceptable that the new draft PPG3 shows prejudice against new settlements, much as its predecessor document did. Why is it necessary, for example, to cite the cost as a negative factor in their consideration, when no other major development form in the whole document is mentioned in this connection? If there were any question of public subsidy it might be relevant. But since the only prospects are either for the private sector to take the matter up (as it has in many recent cases) or for the public sector to become involved (with appropriation of development value under the New Towns Act) it can be assumed that new settlements are always a viable form of development.

  27.  Making new settlement proposals meet a special set of conditions (paragraph 64) is entirely irrational. All major forms of development should be subject to the same tests. The TCPA supports the idea that new settlements should be big enough to provide desirable town services and exploit a public transport corridor. But the stipulation that they must always make use of previously developed land is unworkable. Of course some redundant airfields may be appropriately located, in which case their use would make sense. But it must be the case that sometimes a new settlement may be a very good way of accommodating some expected greenfield developments which would otherwise be scattered around many different places. And the proposal that a new settlement should be allowed only if there is no more sustainable alternative is also a restrictive condition not applied to any other form of development.

  28.  It is also disturbing to find the suggestion (paragraphs 64 and 65) that while regional plans should be the mechanism for bringing forward new settlement proposals, which the TCPA also thinks desirable, all tiers of plan-making are expected to agree to a proposal. This is an unworkable restraint on regional strategic planning. While it is to be hoped that the recipient district council will be persuaded of the advantages of the proposal, this can hardly be assumed. It would be entirely unacceptable if coherent and publicly beneficial regional housing and planning strategies were to founder on the veto of just one bottom-tier council. We take the view that any major new settlement or New Town proposal affecting more than one county or unitary authority needs to appear in Regional Planning Guidance. But smaller proposals affecting only a single county or district might be adopted through a county structure plan, a unitary development plan or a district plan.

CONCLUSION

  29.  The Town and Country Planning Association is concerned that this draft PPG, despite its protestations to the contrary, does not reflect a proper determination that everyone should be housed to a level which at least reflects their reasonable aspirations. Like the former version, it is far too ready to accept that sustainability and other factors are justifications for our continuing underachievement in the housing field. We believe we can have both a rigorous application of soundly based sustainable development principles and a standard of planned housing provision that significantly improves the living environment of everyone.

TCPA

18 May 1999

2   Breheny M and Ross A (1998) Urban Housing Capacity and the Sustainable City TCPA (7 reports). Back

3   Breheny M (1999, forthcoming) The People: Where Will They Work? TCPA. Back

4   For example, Hooper A, Dunmore A and Hughes M (1998) Home Alone Housing Research Foundation. Back

5   Hall P (1999) Sustainable Cities or Town Cramming? TCPA. THE SEQUENTIAL APPROACH Back

6   Hall, op cit. Back

7   Hall P and Ward C (1998) Sociable Cities John Wiley & Sons. Back