Memorandum by the National Housing Federation
(SHC 09)
The National Housing Federation represents nearly
1,400 independent, not for profit social housing providers in
England. The Federation's members include housing associations,
co-ops, trusts and stock transfer organisations, and they own
and/or manage more than 1.8 million homes provided for affordable
rent, supported housing and low cost home ownership, and deliver
an increasingly diverse range of community and regeneration services.
The large majority of the Federation's members are registered
with the Housing Corporation. The Federation welcomes the opportunity
to submit evidence to the Select Committee's Planning for Sustainable
Housing and Communities Inquiry.
The Urban Affairs Sub Committee and the ODPM
Select Committee are undertaking three major inquiries that are
core to the future work of housing associations and housing providers
generally. Whilst the inquiries are interlinked, there are clearly
discrete issues that the Committee wishes to explore. Each issue
is important and warrant the inquiry called, but the Federation
believes that there are common policy themes that bond the three,
which are as follows:
Housing and regeneration resources:
a fair, rational and transparent allocation process;
Planning for mixed, balanced sustainable
neighbourhoods;
Decent neighbourhoods: management
and renewal.
In the text that follows, evidence is submitted
on the specific questions asked, in the context of the broad themes
set out above.
THE OVERALL
SCALE OF
HOUSE BUILDING
REQUIRED
The Federation recommended in its Spending Review
submission that to meet housing need, £1.7 billion additional
funds be made available to help build an additional 40,000 new
social homes annually above baseline production. This is in the
context of research by Alan Holmans1 (detailed in the Federation's
earlier Affordable Housing Evidence) that forecast a need for
between 80,000-85,000 additional affordable homes in England each
year between 1996-2016. We recognised that this figure may have
proven difficult for the Government to accept, given competing
priorities, and consequently submitted a revised option that would
create an additional 20,000 new social homes annually on top of
the core programme.
These affordable housing figures sit within
the context of a total annual need for new housing of 225-230,000
units of all tenures forecast in the Holmans study. Based on these
projections (using 1996 household figures) around 36% of new provision
would need to be affordable. However for each year that social
housing provision lags below the level needed, the scale of intervention
required to address the affordable housing deficit grows. More
recent forecasts using year 2000 population statistics as a baseline
indicate that by 2021, at current levels of production, more than
three million people will not have access to a separate dwelling.2
The Federation supports the view of economists
and house builders that there is an overall undersupply of housing
to be addressed. We believe however that to address the housing
crisis, the planning system must facilitate increased housing
supply for the full spectrum of household incomes. The Federation
in partnership with other housing and planning organisations has
submitted separate evidence to the Select Committee on the role
of planning obligations in providing affordable housing. It is
our view that the whilst planning obligations can act to moderate
the commercial goal of private house builders of optimising their
margins through development for the high income end of the housing
market, planning policy could go further by making the presumption
that each residential development must address the housing requirements
of a range of income groups.
We believe that the housing crisis will continue
to deepen without effective intervention through planning policy,
land use strategies and public subsidy to ensure that social and
intermediate housing supply is adequately increased as overall
supply grows.
ARE THE
PROPOSALS LIKELY
TO SIGNIFICANTLY
REDUCE HOUSE
PRICES
Analysts believe that the current boom in house
prices is as a result of both long-term and short-term effects.
A substantial and sustained annual increase in supply of new homes
would be expected to improve affordability over the longer-term
by restoring the relationship between prices and net demand. We
leave it to economists to comment on whether the proposals for
200,000 new homes in the growth areas in the south east will have
any impact on house prices either in the short or longer-term.
Undersupply of homes relative to household formation
rates is a long-term problem that impacts on house prices, but
it is not the only factor at play. It is more likely that the
current boom is as much driven by low interest rates and labour
market conditions than by supply constraints alone. As a result
monetary and fiscal policy may have greater potential to tackle
short-term affordability concerns, while housing supply will be
more likely to impact on longer-term price levels.
THE GEOGRAPHICAL
DISTRIBUTION OF
NEW HOUSING
We believe that it is important to make a distinction
between the distribution of additional core housing provision
planned to increase supply in line with long-term projections
of demand, and the geographical targeting of shorter-term initiatives
that respond to dysfunctional markets. Furthermore, different
geographical locations would be expected to have differing projections
of demand for housing sub markets based on household incomes and
employment patterns. The Federation believes that Regional Development
Agencies should be actively involved with other regional agencies
in developing forecasts and spatial strategies to enable housing
to be distributed where employment opportunities are strongest.
We believe that Regional Housing Statements and Regional Planning
Guidance often provide a helpful picture of the geographical distribution
required for new housing, however it is clear that these documents
do not generally translate as regional housing strategies.
Regional agenciesprincipally Regional
Planning Bodieshave a role to play in deciding the strategic
regional needs for individual local authority areas and they must
be considered accordingly. The Government's recent support for
annual regional planning house building targets to be met is welcomed,
but there must be similar support for the social and economic
infrastructure that new communities need. This will be a crucial
to the sustainability of the significant housing investment that
the Government is committed to both in the strategic sites in
the south and the housing market restructuring areas of the midlands
and the north.
In the context of the Spending Review announcement
and focus on the four strategic sites in the South East, we have
concerns that other areas of high demand will be neglected. The
strategic sites may present problems of access for new communities,
particularly for those who are unwilling to move from their familial,
social and employment networks. We would recommend the inclusion
of smaller scale development areas within established locations,
as well as the longer-term strategic development of the proposed
sites requiring additional infrastructure.
We welcome government's recognition of the need
to plan for larger scale development to meet longer-term demand
for new housing. However we do not believe that the housing crisis
within many established communities will be remedied in the short-term
as a result of these developments. We therefore believe that resources
should be made available to support strategies for affordable
housing provision in line with regional and sub-regional priorities.
To aid this we have proposed a transparent and fair allocation
mechanism that we have described in detail in our submission to
the Affordable Housing Inquiry. The Federation believes that the
introduction of this "three pots" approach will lead
to a fairer, more rational and transparent approach to housing
and regeneration resource allocation, and would call on the Government
to introduce this for 2004-05 to distribute resources announced
in the Spending Review 2002.
WHETHER THE
PROPOSALS WILL
PROMOTE HIGH
QUALITY SUSTAINABLE
COMMUNITIES WHILST
AVOIDING POORLY
DESIGNED URBAN
SPRAWL
Generally we believe that the Government's proposals
have the potential to avoid poorly designed urban sprawl, but
this is dependent on the attitudes of local planning authorities,
what sites are available/earmarked for development, the manner
in which the ODPM uses its power to intervene in planning decisions,
local politics, the quality of negotiations with house builders,
and many other factors. Our view is that:
Concentrating a substantial element
of new development in designated expansion areas will tend towards
reduction of urban sprawl elsewhere.
Further opportunities for major provision
could also be identified within established high demand locations,
including by the transfer of redundant public sector land and
buildings to agencies such as English Partnerships to provide
a more sustainable mix of housing than through sale on the open
market.
A concerted effort to increase densities
to 30-50 homes per hectare will also reduce urban sprawl, provided
the policy is implemented vigorously.
Making best use of larger strategic
sites through master planning will help mitigate urban sprawl.
The change to Local Development Frameworks
also provides an opportunity for local planning authorities to
manage the siting of development in a more systematic way.
Avoiding urban sprawl requires the ODPM to publish
clear guidance on planning and ensure its guidance is implemented.
We also agree that effective land assembly initiatives have the
potential to minimise the need for greenfield development.
The creation of high quality sustainable communities
is more complicated and will be influenced by factors beyond the
ODPM's proposals. In particular:
The quality of the local infrastructure
or proposals to improve the infrastructure to match needs created
by new development, particularly schools and transport.
The tenure mix on developments and
avoiding mono-tenure development. This will require a change of
view by some local authorities on nomination agreements. At the
moment 100% nomination agreements often contribute to later sustainability
problems on estates.
The availability of work within a
reasonable distance of new housing.
The quality and effectiveness of
Local Strategic Partnerships.
Resources and local capacity of housing
associations to be able to offer education, training and employment
schemes and other economic, social and environmental development
projects in more deprived communities.
There are many examples of good practice guidance
to support these aims, most notably English Partnerships' Urban
Design Compendium3 and various CABE publications including their
companion guide to PPG3.4 Sadly the valuable recommendations of
these reports carry no weight in the planning process and leave
many housing developments failing to live up to policy or expectations
for sustainable homes for the 21st century. We believe that adherence
to the principles set out in these documents would avoid poorly
designed urban sprawl.
Higher density housing and mixed used development
also clearly has a role to play here. Capital Gains: Making
High Density Housing Work in London5 was commissioned by the
London Housing Federation and highlighted four critical factors
for success. Residents valued:
Accessible and attractive locations
with good transport links.
Comparatively low occupancy levels
and child densities.
Effective onsite management of the
development and its environs.
Good housing design that addressed
security; sound insulation; dwelling size; good quality open space;
and, privacy.
It is essential that adequate arrangements be
made for appropriate management and maintenance of higher density
housing, otherwise management problems that have characterised
such developments in the past, will happen similarly to those
of the future.
In addressing issues of quality and sustainability
in these new communities it will be important to use the opportunity
of a blank canvas to consider longer term aspirations and standards
not just for housing, but also for the provision of local services
and amenities. We would like to highlight two particular examples
where we believe that sustainability can be optimised. The first
is in requiring new housing design to incorporate more flexible
and adaptable space standards and technology in anticipation of
lifestyle, working patterns and occupancy changes. The second
is in seeking to deliver a greater proportion of mixed-use development
within the planning system so that local amenities can support
reduced car use. It is important to recognise that provision of
local facilities within a short distance of the home is usually
only sustainable with higher densities of housing development.
English Partnerships, the RDAs, and local authorities
all have a role in assembling sites and packaging development
opportunities in a way which offers the right tenure mix to help
produce sustainability. We also hope that they will use their
enabling roles actively promote the delivery of other local amenities
to complement new housing.
THE BALANCE
OF NEW
DEVELOPMENT BETWEEN
HOUSING FOR
SALE AND
SOCIAL HOUSING
Again we believe that it is important here to
distinguish between short-term intervention to tackle the growing
housing crisis, and development to meet the longer-term projections
of demand for housing for different income groups. We explored
this earlier in this submission in our comments on the overall
scale of house building required. We would stress that any longer
term programme needs to be balanced between the requirements of
key workers, some of whom may be able to afford low cost home
ownership and sub market rents, and the continuing need for conventional
rented housing.
We would see the Challenge Fund announced for
2003-04 as a vehicle for this dual approach and would recommend
that half the 4,000 units produced should be for key workers,
with the other half for conventional housing. Broadly speaking,
we estimate that the core Approved Development Programme will
build around 19,400 units. However, we would emphasise that even
when the Challenge Fund and additional Approved Development Programme
resources are put together, the total number of additional homes
it will produce in England will not make a significant inroad
into the 40,000 further affordable homes per annum needed above
the baseline.
The decision on how resources should be balanced
should rely on a robust housing needs assessment that considers
current demand for all tenures of housing within the local planning
authority' boundaries, and use those considerations to estimate
future demand. There will be considerable local information available
that will enable local authorities to gather in the relevant information,
such as the local authority's housing register (which will include
people in temporary accommodation), local land and house prices,
key worker needs, etc.
The balance should be primarily driven by the
present and future local needs of an area, with attention given
to regional priorities. However, research has shown that many
housing needs assessments are not robust, and have not taken account
of the popularity of low cost home ownership schemes. Similarly,
it is likely that assessments would not have taken into account
the recent support for key worker accommodation. Striking the
right balance will involve taking account of local needs as evidenced
by the assessment, the strategic priorities of the funding agencythe
Housing Corporationand the ability of housing associations
to identify sites for particular uses. Over-riding these factors
should be a commitment to developing and sustaining mixed, balanced
sustainable communities. Mixing tenures of new housing within
each development is a singularly important means to achieving
this.
THE EXTENT
TO WHICH
DECISIONS SHOULD
BE TAKEN
BY CENTRAL
OR LOCAL
GOVERNMENT
Throughout this and our other recent submissions,
the Federation has supported the principle of regional strategy
development, which should be informed by locally based needs assessments.
We recognise however that delivery of these regional strategies
requires resource allocation and therefore usually requires support
from central government.
The major exception to this approach should
be in the planning and delivery of strategic infrastructure that
fits more appropriately with central government rather than regional
or local government. The planning and delivery timescale for these
facilities, whether for transport, health or education infrastructure,
mean their regional economic or housing strategies must identify
prerequisite facilities upon which their plans depend. Government
must in turn commit to support or decline to progress the supporting
infrastructure at the earliest spending review or budget round,
triggering tailoring of the regional strategy.
In order for delivery timescales for both housing
and infrastructure to be accelerated, it may be necessary for
local planning powers to be suspended using proven approaches
such as zoning or new town designations. Whilst some may not welcome
these approaches, we believe that radical action is needed at
least in the short-term to deliver modern infrastructure on which
economic sustainability depends, and to tackle the growing housing
crisis.
REFERENCES
1 Holmans, Alan, 2001, Housing Demand
and Need in England 1996-2016, National Housing Federation
and the Town and Country Planning Association.
2 Stewart, John, 2002, Building a Crisis:
housing under-supply in England, House Builders Federation.
3 Llewelyn-Davis and Alan Baxter Associates,
2000, Urban Design Compendium, English Partnership and
the Housing Corporation.
4 CABE, 2001, Better Places to Live by
Design: a companion guide to PPG3, Department for Transport
Local Government & the Regions.
5 Cope, Helen, 2002, Capital Gains: making
high density housing work in London, London Housing Federation.
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