Response of the Local Government Association
1. As the newly-formed unified voice of local government in England and Wales the Local Government Association welcomes the opportunity to comment on the Department of the Environment Green Paper `Household Growth: where shall we live?' (cmnd. 3471). The Green Paper addresses issues no less fundamental than the future of our cities, towns and countryside. It rightly argues that theonly way to protect the countryside from excessive development and unacceptable environmental damage is to seek to ensure that the maximum use is made of existing buildings and previously-developed land in existing settlements to accommodate the expected future increase in households.
2. The Association strongy supports the statement in paragraph 4.30 that rural areas must not become the `dumping ground' for housing which urban areas are unable to accommodate. It is crucial that this `protectionist' approach is properly integrated with a wider regeneration focus which aims to foster sustainable rural comunities and raise quality of life in these areas.
3. Although the wider issue of how to improve quality of life in both rural and urban areas is referred to, the Green Paper is too narrowly focused on planning issues - primarily the designation of land for new housing development. It considers, but fails adequately to address, the implications for housing policy and regeneration. It does little more than note the significance of education, health and transport policy to the regeneration agenda and is altogether silent on the relevance of national economic policy.
4. Yet the Green Paper proposes to halt or reverse a drift of population from north to south and from urban to suburban and rural areas which has been underway for at least half a century. This has been driven by economic and social forces and unless they are understood and harnessed, there is little prospect of slowing their operation or putting them into reverse.
5. Given the importance of these issues and the deep-seated nature of the forces at work, it is questionable whether the twenty-five year horizon adopted for the Green Paper is adequate. It may militate against key strategic decisions on matters like the future of the green belt and new towns which could not be avoided if a longer, perhaps fifty year, planning horizon were under consideration. The Green Paper also contents itself with minor changes to the planning framework when arguably major changes to the strategic planning framework and the power available to planning authorities may be necessary to deliver the Green Paper objectives.
6. In this response, the Local Government Association is able to do little more than to highlight the shortcomings of the Green Paper and indicate the work that will need to be carried out in order to facilitate an adequately-informed national debate on the issues raised by it. Some of the specific questions posed by the Green Paper, for example, the proportion of new housing development which it will be practicable to seek to secure on previously used urban sites, cannot adequately be answered until this further work has been carried out.
Consequently, this response does not seek to address systematically each of the specific questions posed in the Green Paper. Rather it seeks to identify the work which needs to be undertaken before these and other relevant questions may be answered. The LGA will be carrying out work on some of these issues with a view to issuing a further and more substantial contribution to the debate in the summer.
The Household Projections
7. The Association accepts the household projections as the best basis on which to plan at a national level. But it questions whether they are reliable at a local or regional level given their sensitivity to the assumption that existing migration patterns will continue. Since an objective of the Green Paper is that existing migration patterns should not continue, their use at local level must be tempered by considerations of local capacity and the extent to which migrational choices are capable of being influenced.
8. The Association believes that an objective of central and local government policy should be to secure decent housing for everyone. This implies that the need for subsidised housing is ultimately derived by estimating the proportion of new households and potential new households who cannot afford to buy a decent home on the open market. Consequently, we do not accept that it is appropriate to seek to provide homes only for those households capable of exercising an effective market demand for them. However, the location of social housing is a crucial issue addressed later in this response.
Implications for Housing Policy
9. The primary focus of the Green Paper is on the availability of land for new housing developments. The condition, occupancy and potential of the existing housing stock is considered in passing, but there is no critical assessment of the contribution - or lack of it - made by the governments existing housing policy towards achieving the Green Paper objectives. For example:
-- There is no assessment of the steps necessary to maximise the contribution which could be made towards meeting the anticipated demand for housing by the 800,000 existing empty homes, 700,000 of which are privately owned.
-- The abolition of the mandatory renovation grant system, and the continued restriction of local authority capital allocations for assistance to the owners of private housing.
-- Until recently, Housing Corporation investment priorities created incentives for housing associations to focus investment on green field sites rather than brown field urban development or acquisition and improvement of existing dwellings. Whilst the housing corporation has recently adopted a target that 50% of new development should be in connection with regeneration projects it is too early as yet to judge whether this policy has been successful.
10. Two-thirds or more of the future demand for new housing will come from existing or prospective home owners, most of whom will not be newly-forming households. Influencing their choices about where to live will be crucial to achieving the objectives of the Green Paper. These households are the more affluent and, except for elderly existing owner occupiers trading down, are very likely to be in employment. They are precisely the households who have led the flight from the cities and the drift from north to south which the Green Paper seeks to halt or reverse.
Yet the Green Paper section on `Influencing Migration' only considers planning measures such as restricting the designation of land for housing. Some research is proposed on migration patterns between regions and local areas, but locational decisions within local authority areas may well be equally important - the Green Paper notes that 60% of moves in 1991 were within the local authority area.
11. There has been some pioneering work in London and local authorities such as Birmingham on what influences locational decision by home buyers, which suggests that there may be a significant role for local authorities in influencing these decisions. The LGA sees the development of this strategic role in housing as one of the keys to securing the Green Paper objectives.
12. Although as much as 40% of the new housing development may need to be in the form of subsidised housing for rent, it would be disastrous to allow market forces free reign over the allocation of housing sites between market and social housing.
The most likely outcome of such an approach would be the inappropriate designation of `undesirable' urban sites for social housing, leading to the intensified concentration of deprived households in particular urban areas.Similarly, in some suburban and rural areas, the demand for housing may price out affordable social housing leading to parallel nightmare scenarios of single tenure ghettos in both urban and rural areas.
13. Measures are therefore needed both to encourage home owners back to what are currently undesirable or marginal urban areas, with the corollary that adequate powers are also needed for the designation of land for low costhousing in `desirable' suburban and rural locations. The provisions in DoE Circular 13/96 on Affordable Housing will further restrict the ability of local authorities to secure social housing in smaller suburban and rural sites thus will work against achievement of a key objective of the Green Paper.
14. In common with most other writing on this subject, the Green Paper genuflects towards the advantages of `mixed communities' without ever addressing what these are or how the benefits of a social mix contribute towards creating a successful and sustainable community. It is virtually certain that there is no one pattern, and also likely that the tenure mix in such areas is not the only defining issue.
Implications for Regeneration Policy
15. There is considerable anecdotal evidence which suggests that the poor quality of the urban environment has contributed substantially to the flight from urban areas. Crime, poor schools and poor local environmental quality may have been as significant, if not more significant, factors than the availability of appropriate housing in motivating a move to the suburbs or beyond. In its discussion of these issues, the Green Paper lists current government initiatives in relation to the urban environment, but once again fails to make any assessment of their adequacy to deliver the Green Paper's objectives.
16. Given the Green Paper's emphasis on using an `aspirational' target for increased housebuilding in urban areas, coupled with the continued unpopularity of these areas, improved approaches for tackling urban decay will be essential in order to prevent such areas becoming ghettoes of `social housing'. The local authority associations have previously recognised the need for such a new approach to tackle comprehensively the economic, social and environmental problems which particularly face urban areas.
The Associations' 1996 paper `A New Deal for Regeneration' set out a mechanism for delivering holistic solutions to urban problems based on the concepts of partnership and the need for a strategic approach. It also attempts to address the key weaknesses of the current system including a fragmentation of responsibility, lack of transparency and accountability, centralisation of decision-making, and a method of resource allocation which fails to adequately reflect the needs of particularly disadvantaged areas. The key elements of the suggested approach are:
-- the preparation of a comprehensive, holistic strategy for the area concerned, which can then provide a framework within which individual area-focused and thematic initiatives and programmes can be pursued;
-- the involvement of all relevant organisations, agencies
and interests in the preparation and implementation of the strategy;
-- the introduction of a way of securing the contribution of relevant agencies including central government, and their mainline spending programmes, to the implementation of the agreed strategy.
17. In implementing the approach, local authorities would lead in the preparation of comprehensive regeneration strategies for their areas, which would be produced in partnership with all other local partners.
Central Government would be a key partner in the strategy, becoming a signatory to it and committing itself and its agencies to delivering and funding those elements for which it is responsible. The Association believes it is only by applying such an approach and more effectively targeting the funds of a range of agencies to locally identified needs, that adequate improvements to quality of life inurban areas can be achieved.
In addition to implementing the New Deal approach as outlined above, the Association supports the proposal of the UK Round Table on Sustainable Development; Sub-Group on Housing and Urban Capacity, for and Urban White Paper which could deal comprehensively with the range of issues likely to face urban areas within an overall framework of sustainable development.
The Planning System
18. Although it must play an important role in addressing the challenge posed by the household projections, the planning system on its own will be inadequate. This is particularly true of the need to tackle strong decentralisation pressures on housing and employment and reverse what has become known as `the flight from the city'.
19. However, the Association considers that there are areas where the planning system could be strengthened to enable it to play a more effective role in responding to the household debate. The following examples in particular are worthy of further investigation:
-- stronger regional planning to identify a strategic policy direction (see section below);
-- the introduction of targets for social housing in Regional Planning Guidance (RPG) and development plans (following the example of the West Midlands);
-- a review of the timescale for RPG and development plans and timescales extended to a least 2011, and preferably 2016;
-- greater use of phasing in development plans to prevent sites being `cherry picked' (see below);
-- use of `sequential approach' to the development of housing land;
-- a thorough review of the role of green belts in the context of accommodating long-term development needs in a sustainable way. The Association endorsesthe view of the Planning Officer Societies in their response to the Green paper, that any decisions on amending Green Belt boundaries should follow examination through RPG and structure plan processes of the extent to which housing needs can realistically be met within previously developed areas.
Implications for Regional Planning
20. The Association supports the view taken by the Green Paper that no single option can provide a blueprint for accommodating household growth across the country; a range of solutions to accommodating the necessary level of future development will be required. The regional perspective will be crucial to provide a strategic view to what is a strategic issue, and will enable full consideration to be given to rural areas, country towns and villages as well asmetropolitan areas and cities.
It can also provide a means to assess the extent to which previously used land in towns and cities can meet the future housing needs. In 1996 the then Local Authority Associations set up a working group together with English Regional Associations to
develop ideas on how regional planning could be improved. The report of this working group will be published in the summer.
21. The Association strongly believe that there is a need to strengthen the process of regional planning to reflect the whole range of key interests, including local authorities, Integrated Regional Offices of central government, the business community, and environmental pressure groups.
However, in order to play a full role in addressing the household growth
issue, it also considers that regional planning needs to be improved in terms of outcome.
22. Setting aside the issue of whether more formal and accountable regional governmental structures may be established in the future, the Association argues regional planning should be improved and reformed to providethe following characteristics:
-- a longer timescale of 20-25 years with shorter-term `Regional Business Plan' documents (covering perhaps 4 years) operating in parallel and acting as guides to resource bidding and infrastructure investment decisions. The former would be prepared on a five year basis, whilst the latter could be rolled forward annually;
-- wider involvement by interested parties, including use of `roundtable' conferences to discuss the issues;
-- a mechanism for testing the emerging draft regional strategy which is endorsed by all participants, ideally a formal or informal Examination in Public-type hearing;
-- in terms of content regional planning should set out a strategic vision for creating sustainable patterns of development at the regional level. In addition to addressing regional housing patterns, it should address matters such as transport, employment patterns, waste management and strategic resource use. The housing element of regional planning would need to take account of the housing projections but also include issues such as need and affordability, and be informed by accurate information setting out the capacity of the region's social and physical infrastructure to support future development.
Mechanisms, Implementation and Resources
23. The Green Paper asks whether existing mechanisms are adequate to bring about the patterns of new housing development in response to the projected growth in households up to 2016. It is important to recognise that no national blueprint will be applicable and that local factors (eg urban capacity and housing need) will necessarily lead to local solutions. In this context, there are a range of mechanisms which will need to be further examined in order to provide the necessary tools to allow authorities to adequately address the issue.
24. Whilst there is a strong case for land allocations in structure, Unitary Development and local plans looking further forward than at present (eg to 15-20 years), there is also a strong case for restricting the release of this land to a timespan of 5-6 years which would therefore be more capable of being accurately forecast. The phasing of land release would need to be subject to an Annual Monitoring Statement which would be produced by both the strategic and local planning authority and which served to review need and supply. This would also need to be linked to annual land surveys which assessed changes in capacity. This approach has been recommended by the West Midlands Regional Forum of local authorities and would need to be subject to further examination.
25. In addition to the use of the planning system there is a need to explore other mechanisms which may be more effective in achievinggreater brownfield and development for housing. The Association supports the call of the Housing and Urban Capacity Sub Group of the UK Round Table on Sustainable Development in their report published in February 1997 for the use of fiscal instruments to be reviewed.
This review should include such suggestions as a levy on greenfield sites, with an element of the proceeds earmarked to subsidise brownfield site development, as proposed by the Civic Trust and the use of subsidies for urban land assembly.
26. Many of the Association's member local authorities have pointed out that the brownfield sites which have been brought back into productive use to date have generally been the easier ones. This has also been endorsed by the recent TCPA inquiry into the subject. The Green Paper is silent on the issue of where resources will be found to fund the substantial reclamation programme on the more `difficult' sites in order to achieve the overall 60% aspirational target for brownfield site development. The suggestion above that a Greenfield Levy is investigated may help in this respect. Targeted spending will also be required to improve the amenity of areas surrounding the housing land itself.
27. In addition, there is also the wider issue of the resources which willbe necessary to make urban areas attractive in order to prevent, and hopefully reverse, trends in population decentralisation. These resources will need to be ploughed into a whole range of areas designed to improve the quality of urban living such as education, public transport and community safety. The Association's suggested approach regeneration as outlined in paragraphs 14-16 above, offers a means of `bending' mainstream funding programmes to better address needs as identified in the most disadvantaged areas.
28. In conclusion the Association applauds the Department's initiative in starting the debate on how the challenge posed by future household growth projections can best be met. This response can only give a brief summary of the areas where the Association considers that work needs to be taken further, or to be commenced, to adequately address this crucial issue.
The Association would therefore welcome the opportunity to discuss the ideas set out in the response further with the Department as this work progresses.