INTRODUCTION

  1.  This submission outlines CPRE's views on the Deputy Prime Minister's statement on housing and planning on 18 July, and associated matters. We have welcomed much of this statement, in particular the boost it gives to the Government's commitment to the role of planning in managing new development. We also welcomed the focus on urban renaissance and meeting the need for affordable housing. CPRE believes that we have barely begun to realise the potential for urban renewal. There is still too much reluctance among local planning authorities, developers and the Government to reduce greenfield housing and foster urban renewal in order to build sustainable communities.

  2.  In line with the matters of interest set out by the Committee, this submission addresses the following issues:

—  The lack of a clear relationship between housebuilding levels and house prices;

—  The need for more effective implementation of Planning Policy Guidance note (PPG) 3 Housing;

—  Our concerns about the determination of housing levels in the four proposed "growth areas" in the South East;

—  The need for increased provision of affordable housing;

—  The importance of effective action to tackle areas of low demand and abandonment.

HOUSE PRICES

  3.  Some commentators have suggested recently that house prices are high and rising due to a decline in the rate of housebuilding caused by constraints imposed by the planning system. CPRE believes that the available evidence does not support the view that there is a straightforward correlation between land availability, levels of housebuilding and house prices. House prices rose throughout the 1980s despite the wide availability of land. And there is no hard evidence that the supply of land is currently restricted. On the contrary, house prices appear to be closely related to the availability of cheap finance, including the promotion of mortgages combined with relatively low interest rates.

  4.  Moreover, we believe that the argument that planning constraints on greenfield housing are a significant cause of the shortage of housing, including affordable housing, is 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—it was estimated that nationally the planning system had earmarked enough greenfield land to provide 658,000 houses; but b) housebuilders are not always willing or required to provide the sort of housing which is needed.

  5.  Even if some kind of clear relationship can be shown to exist between housebuilding rates, land availability and house prices, we do not believe that increasing the availability of land would have a significant effect. Such studies as exist suggest that large scale releases of greenfield land would result in only a marginal drop in house prices. It is clear that the effect on prices would be nothing like that needed to bring the price of housing within the reach of key workers in London and the South East.

IMPLEMENTING PPG3

  6.  CPRE welcomed the publication of Planning Policy Guidance note (PPG) 3 Housing in March 2000 and the Government's promise to "radically alter the way in which we build new homes in this country". We are concerned, however, that there has been a distinct lack of progress in implementing the new policy framework. Sprawl Patrol, our first year report on the implementation of PPG3, found that weak action by Government Regional Offices and inertia in many local planning authorities was obstructing the clear intent of Ministers to put an end to urban sprawl. The report found that:

—  half of local authorities had not undertaken a study of the capacity of their brownfield sites;

—  three quarters of authorities had not reviewed policies on density, design, parking standards or the scope for re-allocating employment sites; and

—  almost half of local authorities had continued to give planning permission for low density housing development in flat contradiction to Government policy.

  7.  A more recent analysis by CPRE examines the use by Government of powers to call-in applications for housing on greenfield land under the Town and Country Planning (Residential Development on Greenfield Land) (England) Direction 2000 (the "Greenfield Direction"). We found that while more applications were referred to Government Regional Offices in PPG3's second year of operation, fewer greenfield housing applications were actually called-in for decision by an independent Inspector or the Secretary of State.

  8.  CPRE welcomes the announcement in the Deputy Prime Minister's July Statement of the intention to introduce a new "Density Direction". This will enable the Government to intervene in planning applications for housing which involve a density of less than 30 dwellings per hectare (dpha)—the bottom of the 30-50 dpha range advocated in PPG3. There is clear evidence that we are still building houses at wastefully low densities. Land use change statistics released by the Office of the Deputy Prime Minister in May 2002 reveal that the average density of dwellings built between 1997 and 20001 across England was 25 dpha (ranging from an average of 52 dpha in London to 22 dpha in Yorkshire and the Humber and the East of England).

  9.  The new Density Direction should help promote the more efficient use of land, but only if implemented more effectively than the Greenfield Direction—and applied throughout England. CPRE has been concerned at suggestions that the new Density Direction will only apply in London and the South East, despite the fact that average densities of new dwellings built are well below the range advocated in PPG3 in all regions, excluding London.

  10.  CPRE believes that if we are to promote sustainable communities it is imperative that new housing is built at significantly higher densities throughout the country. Evidence shows that public transport is less viable in low-density developments and car dependency is higher, so traffic and the resulting congestion and pollution are increased. With good design, densities of between 30 and 50 dwellings per hectare should still provide ample room for decent-sized family homes with gardens.

  11.  Finally on the implementation of PPG3, CPRE believes there is a pressing need to adopt a more challenging national target for the reuse of brownfield land for housing. We welcomed the news in May that last year 6 per cent of new homes in England had been built on previously used land or by converting existing buildings. This means that the Government's target of 60% has been achieved seven years ahead of schedule, without, we would argue, the effective implementation of PPG3 or the "drying up" of brownfield capacity.

  12.  In fact, brownfield capacity appears to be growing. Figures released by the Office of the Deputy Prime Minister in September this year reveal that while 21% of the previously-developed land in 1998 had been redeveloped by 2001, new brownfield sites which had come available in the same period amounted to around 29% of the 1998 stock of previously-developed land. Moreover, in a response to a Parliamentary Question in July, it was revealed that 135, or 37%, local authorities, have not made a return updating the data on previously-used sites, including many urban authorities. This means that there is likely to be even more brownfield land available in practice than the figures released suggest.

  13.  While it is encouraging that we are moving in the right direction, we need and can do much better if we are to prevent an increase in the amount of brownfield land and and secure the creation of sustainable communities. CPRE is pressing for a national target of at least 75% of new housing on brownfield land in order to maximise the contribution of housing to urban renewal and protect the countryside from unnecessary urban sprawl.

THE "GROWTH AREAS" IN THE SOUTH EAST

  14.  CPRE broadly welcomed the more managed approach to housing provision set out in Regional Planning Guidance for the South East (RPG9). We supported a baseline annual rate of provision of around 33,000 dwellings, with a contingency to increase provision up to 39,000 each year (the figure finally adopted in RPG9), as long as a number of conditions were met by Government, including:

—  Providing the resources to meet the region's annual requirement for 18-19,000 affordable homes;

—  Introducing a fiscal measures to promote urban over greenfield development;

—  Providing local authoriites with the powers necessary to influence housing size, type, mix and tenure;

—  Requiring local authorities to reduce substantially the area of rural land earmarked for housing development.

  15.  Regarding the proposed "growth areas", CPRE has expressed strong support for the proposed regeneration of the Thames Gateway, provided this does not add to pressure for development in the Green Belt or on environmentally sensitive sites. We have raised serious concerns, however, about the potential for expansion in relation to the other three areas identified in RPG9—Ashford, the Milton Keynes sub-region, and the "London-Stansted-Cambridge" sub-region. In particular:

—  we do not believe that it has yet been demonstrated that major new growth is necessary in these areas;

—  there is little sign that any development which may be necessary will deliver high quality development and sustainable communities; and

—  we fear that growth in these areas would undermine efforts to promote the regeneration of previously-used land within the Thames Gateway.

  16.  These three locations are described in the RPG as "potential growth areas" subject to further studies to "examine the need and scope for additional growth". CPRE has sought to play a constructive role in the studies, but we remain unconvinced of the need or capacity for major new housing expansion in these locations outside the urban areas. We are disturbed, therefore, that the Deputy Prime Minister in his July statement appeared to pre-empt the outcome when he stated that the studies "are nearing completion and show how economic development will increase the number of homes we need. Over the coming months, taking account of these studies, I will work with regional and local partners in each of the four areas to establish where, at what scale and how quickly growth can be achieved. Overall, we estimate that at least 200,000 new homes could be created in the growth areas."

  17.  CPRE has particular concerns about the identification of the "London-Stansted-Cambridge" sub-region as a potential growth area. We believe that adequate land has already been earmarked for development in this area for the foreseeable future. Further growth in this area risks turning the M11 into a corridor of development, rather than one of movement, and could repeat the problems we have seen in the M4 area including congestion, pressure for development in the Green Belt, and sprawling, low density development.

  18.  Concerning the Milton Keynes sub-region, CPRE is keen to see future development in this area making full use of previously-used and under-used land within built up areas. The Milton Keynes and South Midlands Study examines a large area encompassing Northamptonshire, Bedfordshire, Luton, Milton Keynes and the Aylesbury Vale. The Study proposes a combined strategy of urban concentration and corridor development (based on the Midland Main Line and a `potential' East-West rail corridor to the south) which would entail 6,000-8,000 ha of additional residential development land. (This is on top of existing commitments which the Study estimates would accommodate 127,000 new dwellings—equivalent to more than 16 years supply at past completion rates, and significantly more if average density can be increased to comply with PPG3). CPRE does not believe this proposed strategy will be sufficient to ensure full and effective use of existing urban capacity in the sub-region, or to avoid further, damaging low-density, car dependent urban sprawl.

  19.  Ashford has already experienced major expansion over the past 30 or so years and there remain substantial allocations of land for housing and other development which have yet to be taken up. The "Ashford's Future" study which is not completed proposes three scenarios for growth which, it is stated, would require between 600 and 1,200 ha of additional land for housing and employment. This compares with Ashford's existing urban footprint of 1,570 ha.

  20.  CPRE has raised serious concerns about the environmental implications of such significant levels of expansion in the Ashford area. Major new development is likely to place unsustainable demands on scarce water resources, seriously affect the floodplain to the south of the town, and could increase out-commuting from the area without a better mix of employment and housing. The priority should be to deliver a step change in the quality, design, density and environmental efficiency of any new development. This should emerge from an "enquiry by design" process, as pioneered by the Prince's Foundation supported by CPRE, for considering future options for urban extensions.

AFFORDABLE HOUSING

  21.  CPRE remains concerned about the lack of sufficient affordable or social housing in many parts of the country. We believe that the provision of social housing, which is available in perpetuity for letting at sub-marked rents to meet identified need, is the only way to meet the vast bulk of affordable housing needs. It is important, however, that the cause of this underprovision is correctly identified. We do not believe, as some have suggested, that this problem is due to constraints imposed by the planning system on greenfield housing. The problem is more to do with inadequate funding and the resulting dramatic decline in the proportion of social housing built over the the past 20 years, together with the leakage of stock from the social housing sector through the right to buy. If we are to build sustainable communities in the South East and in other parts of the country, it is vital that we achieve a better balance between social housing and private market provision in all new development.

  22.  As we have indicated in submissions to earlier inquiries by the Committee, the planning system has been ill-equipped to ensure that the housing built actually meets needs. CPRE's 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 and the development of sustainable communities. We have no reason to believe that this state of affairs has altered significantly since then.

  23.  There is a pressing need to secure greater coordination between housing need assessments, social housing investment strategies and planning policy and practice at the regional and local levels. PPG3 promotes this approach, along with proactive policies in development plans to require a significant proportion of new housing on development sites to be affordable, but this appears to have had a limited effect so far on local authority practice. There are particular issues which need to be addressed in connection with the provision of social housing in rural areas, including the failure and flaws inherent in the exceptions policy and the weak implementation of the one-for-one (market/affordable) housing requirement promoted in the Rural White Paper. We believe these are areas which require much greater Government attention to delivery. While we welcome the increased funding announced in this year's Comprehensive Spending Review, there is an urgent need to find ways of improving the effectiveness of spending on social housing.

LOW DEMAND AREAS

  24.  Effective strategies to tackle areas of low housing demand and abandonment should be central to the planning of sustainable housing and communities. Real progress in increasing the proportion of new housing on previously developed land and through refurbishing existing buildings in many parts of the country depends to a large extent on addressing this issue. CPRE therefore welcomes the Government's Market Renewal Pathfinder initiative to tackle low demand for housing in deprived areas. We are concerned, however, that the scale of the problem is not matched by the £2.66 million public funding which is being devoted to nine market renewal pathfinders which have been identified. CPRE believes that there are many more declining areas which are crying out for public intervention and resources. We would urge the Government to extend and expand its efforts to tackle the problems associated with the decline of housing estates and to learn the lessons from these cases so that we will not face similar problems in the future associated with the housing we are constructing today. In addressing this issue, it is also important that the Government explores ways of promoting more balanced regional development to take pressure of the over-heated South East and direct economic growth and investment to areas in need, as outlined in CPRE's report Even Regions, Greener Growth.