Symposium on Sustainability

SoS was an idea which grew out of Green Drinks where people wanted more focused discussions and aiming for some kind of output.  We (slightly changing groups of about ten people) have met 4 times to discuss the format, flooding, Zero Carbon Britain, and a response to the Oxford City Council draft Housing Strategy.  One member prepares a paper which is then discussed for about 2 hours and the paper is amended to reflect that discussion (possibly involving conversations with others) before being submitted in the case of a consultation or filed as part of the SoS archive.  The discussions are non-attributable to enable those with academic reputations, affiliations or employment concerns to protect are free to voice their opinions. At the risk of making this Blog too long, I attach the paper sent to the Council that includes some ideas of what sustainable housing might look like.

Draft Housing Strategy 2015 – 2018

Response from Symposium on Sustainability – Oxford

SoS –Oxford is a group of people with a deep interest and no little understanding of the principles and practice of sustainability.  It produces briefing papers and responses to consultations that are intended to assist those involved in formulating policy and taking decision in areas impacting on the economy, society and the environment. The purpose of SoS is to analyse a subject in order to provide ideas and recommendations based on good evidence. Not all the proposals would be agreed by all participants of the symposium and papers might not be fully consistent or comprehensive. 

1          Comments on the Draft Strategy

There is no evidence in this document that the Council has any or sufficient recognition that the normal ways of delivering houses will do anything but perpetuate the existing problems of scarcity,  unaffordability and unsocial housing.

Oxford will not meet its claim or aspiration to be a ‘World class city’ for ‘everyone’, if it does not follow the many international (and few domestic)  examples of forms of housing that can be seen to be more sustainable in terms of affordability (in provision and operation), sociability and environmental impact.

In the ‘Foreword‘  to the Strategy there is nothing new to address the existing imbalance of the size of households and houses which is a major cause of  unsustainable levels of under-occupancy.  The ‘housing offer’ described in the Strategy aims to attract households as part of the ‘delivery of innovation-led growth’, but includes no equivalent innovation in terms of housing delivery.

There is no substance behind the priority to ‘support sustainable communities’.

Extra Care Homes are regarded as the necessary response to the perceived need to increase housing for the elderly.   The Council should be looking to build housing ‘suitable’ for the elderly but not specifically for them.  Care has to be carried out in the community – a cliché, but one with a substantial truth[1] that housing has to be designed to facilitate care, as the formal systems will be generally unaffordable.  This is reflected in the current problems being experienced in hospitals being unable to discharge (mostly) elderly patients into a caring home environment.

Discussion with health providers should have identified the important role that co-housing could play in wellbeing  - one form of housing suitable for but not exclusive to the elderly.

‘Increase housing choice for households on average incomes’, should have identified the areas which are under-provided eg self-building and co-housing that could be relatively affordable.  Many councils are keeping registers of potential self-builders that could sensibly include potential co-housers.

2          What are the factors that influence the sustainability of housing?

Issues

Shortage - not enough units or space to meet demand

Under-occupation - 75% of dwellings have one and more often two or more spare bedrooms.

Energy efficiency – housing accounts for about 20% of existing GHG emissions and will have to get to zero or below by 2050.

Affordability – measures should address the price of land for housing and both prices to sale (currently about twelve times average salaries) and rent levels (that are unaffordable at 60% or 80% of current open market levels) should also be brought down.  Affordability includes running costs as well as purchase price and/rent.

Anti-social Housing - housing has been designed to pander to privacy and has made neighbourly contact unnecessarily difficult.

Accessibility - housing should be well connected to work and facilities/services without depending on the car

3          Recommendations

Although this is a consultation on ‘Housing’, as has happened in Westminster, the planning and housing briefs have been combined because there is no sensible separation of responsibilities when looking for ways of making the new and existing housing stock more sustainable.

Shortage  & under-occupation - make better use of existing housing stock by encouraging right-sizing within Lifetime Neighbourhoods, and explore potential for sub-division of over-large houses.  Lifetime Neighbourhoods are designed to provide a mix of dwelling sizes and types within an area so that choice is no longer a constraint on being able to move a short distance within an area to maintain economic ands social links.  This principle should be given precedence over Lifetime Homes that are designed to encourage aging in a dwelling that might be larger than required to meet housing need. 

Empty homes (300 to 400 in the City) and second homes (>1000) are another form of under-occupation that should be addressed.  If these levels can’t be reduced then tax measures should be considered so that local areas do not suffer from the reduction in available housing and the lack of demand for local services. The shortage of housing of the right type and size is so critical in the City that the potential of compulsory purchase powers should be evaluated and used or threatened where the public objective would be to provide more sustainable housing.

Down-sizing –  To enable this specific part of right-sizing applicable to older smaller households in large dwellings, new housing should be predominantly small units, but with scope to share space and have some with generous gardens.  Some older households would be more willing to down-size if there was space to keep and possibly share books, tools, furniture, guest accommodation etc as in co-housing.  This process is so fundamental to achieving a better and more sustainable balance between the sizes of household and housing, that it could prove a good investment to appoint a facilitator or enabler looking at the physical conditions and availability of smaller and larger houses, their locations, investment issues (what to do with any equity released?), family circumstances, health issues, the particular issues surrounding flats, parking and gardens etc

New building - Self-building and/or finishing could increase supply with Government wanting this to exceed historic levels of about 10%.  This form of housing conflates supply and demand and provides opportunities for building skills and communities.  It can also result in relatively affordable housing  which could be acknowledged in planning policy and quotas of affordable housing.   Involvement in self-building could include some of those least able to house themselves in the conventional ways. There might be partners in the City able to assemble groups of people with, or prepared to learn, the necessary energy and/or skills.

The Council is concerned about the number of 2 bedroomed flats being built and the small number of 3 and even 4 bedroomed houses.  However, this might not be a problem if moves to the 2 bedroomed flats are releasing larger dwellings? This would be more likely if the Council addressed all the issues implied by downsizing and the small dwellings were designed accordingly.

The Council should continue to press the neighboring districts to cooperate in the supply of housing land (inc possibility of Green Belt land and potential urban extensions).   At the same time the Council could take note of the initiatives being taken by Cherwell DC in respect of self-building and community land trusts.

The Council should, and encourage others, to be transparent in terms of land ownership and opportunities to build, so that access is increased to people and organisations currently being excluded from the systems of housing and land supply. This transparency should be extended, through open-book accounting to all building projects to ensure that all new schemes are providing the necessary affordable housing and sustainable infrastructure.

The Council should actively consider building more houses, but only along sustainable lines (see these SoS recommendations).

Anti-social housing – for too long traditional housing models have pandered to privacy (and resulting loneliness).  New housing should be predominantly terraced to facilitate informal neighbourly inter-action. While other forms of housing (eg flats) might be similarly thermally efficient, terraced houses might have the greatest potential to engender neighbourliness.  Purpose-built co-housing would be intentionally neighbourly and designed to be companionable.  The Council might see that, in Oxford, there are models of congenial collegiate housing/living around courts or quadrangles that could be extended into housing outside the academic community. 

There does not seem to be any place for detached (or even semi-detached) housing in the supply of new social and sustainable housing.

Energy efficiency - all new residential development must be zero carbon or preferably carbon negative. This implies predominantly but not exclusively south facing terraced housing (to reduce the proportion of external walls) with the main emphasis on the fabric/airtightness that will not be amenable to upgrading at a later date, and with the potential to be equipped with the most efficient PV and solar thermal panels. If Oxford wants to be an exemplar, it should be noted that there are already Passivhaus regions (standards 3x higher than the proposed UK zero carbon standard for 2016) with an estimate of minimal extra cost over traditional build.  Energy efficiency has been embraced by many co-housing groups as a shared ethic and could be more energy efficient in construction and use.

The existing housing stock will be the greatest challenge in terms of energy efficiency and the Council should explore methods of deep green retrofits for its own housing and have effective policies in its development plans to ensure upgrading of existing properties when applications are received for alterations and extensions (eg see Merton Rule or potential of  upgrading existing buildings as an ‘allowable solution’ for zero carbon houses).

Water – covered by the Code for Sustainable Homes (being wound down), but not adequately by the Building Regulations, is very important in a city where flooding is becoming an increasingly heavy cost to residents and businesses.   All new developments should be maximizing the on-site drainage to minimse the scale and speed of any run-off.

Affordability – The Strategy should challenge current market forces.  Land for housing should be purchased at existing use values with a small uplift  (see Lyons Review).  Genuine affordability requires this to be provided as ‘affordable’ based on local wage levels without public subsidies that are not material planning matters being outside planning control (eg housing benefit -  currently £23.8billion/annum, grant to RPs, Help to Buy, 20% Starter Home exception etc).  Self- building and/or finishing would contribute to affordability.  By making efficient use of buildings and land (and by keeping exclusive use to a minimum)  co-housing would be more economic to build and, more importantly, in occupation.

To concentrate on ‘affordable living’ as opposed to ‘affordable housing’ would underline the importance of running costs (eg water and energy) as fundamental  to affordability.

Right to Buy – wherever possible OCC should seek to remove or limit this right from its housing stock or when involved with other RPs.  This is a fundamental aspect of community land trusts that could be partnered for this, and other purposes,

Rental sector  - Affordable rents would be related and tied (ie 35%) to average earnings and not fixed as a percentage (ie 60%) of private rents.  The Shelter (or even Labour Party manifesto) proposals for affordable rents should be considered.  Is there a role for the Council in addressing the growth of buy-to-let?

Innovation –  The starting point for change must be an acknowledgement that the current system is not working and that systemic and innovative changes are necessary.  The Council should be assisting in the setting up of housing coops and community land trusts (where Right to Buy is excluded) and, possibly, an Oxford Community Housing Fund?  The Council might have to look abroad and/or to the social innovators within the area for ideas that could make the difference rather than perpetuate failed models.

Accessibility – the location and type of housing has a significant influence over car ownership and use.  Both could be substantially reduced by insisting on developer funded to a car clubs for all new development and made accessible to neighbouring areas.  Oxford already has a low carbon car club(s) and this should be a requirement of all new examples.  This would be a good fit with co-housing where car dependency and use are reduced through the mix of uses on the site.

4          Conclusions

The essential components of sustainable housing listed and discussed above indicate that there is an urgent need for systemic change in the provision of housing. There cannot be a 2.5% annual growth of housing (ie the SHMA projection) at the same time as a 6% (Committee on Climate Change estimate) or 10% (Tyndall Institute estimate) annual reductions in carbon emissions unless the housing sector (new and existing stock) becomes much more energy efficient

The Housing Strategy and related development plans/SPD should include policies that would support both self-building and co-housing.   Housing and planning strategies without the necessary enabling policies would be inadequate and unsound, as housing needs would be increased rather than be met, and the Strategy would not be contributing to the achievement of sustainable development.

Housing (especially for the elderly) has become a fundamental aspect of social and health care – and implicated in the severe problems being faced in discharging patients from hospitals. This should be one of the main drivers in prioritizing and providing housing which is more companionable.  There should be more attention paid on Lifetime Neighbourhoods than providing a greater proportion of Lifetime Homes.

The Building Regulations cannot be relied on to ensure that new and retrofitted housing will be sustainable. The Council should ensure that the form of housing (eg there is no place for detached housing that is intrinsically thermally inefficient and makes social interaction unnecessarily difficult) lends itself to sustainable construction and living.

Affordability is a major factor in the City (this should be considered as affordable living rather than simply the cost of purchase or rent).  This requires a concerted attempt to establish the real costs of provision and ensuring that the profit from the land does not erode the sustainability (inc community benefits and provision of affordable housing) without clear justification.

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[1] Generation Strain IPPR 2014

Oxford Real Farming Conference - affordable land

Timetabled as an alternative to the Oxford Farming Conference that caters to the industrial agricultural businesses, in its sixth year the ORFC attracted 650 delegates that makes it bigger (and better?) than its older brother.  DanthePlan was not scheduled to speak but had many chances to offer opinions on what the planning system could and should be doing to help in the renaissance of farming in the UK.
It seems that almost as much energy is being spent on trying to avoid any engaging with the planning system as fighting one of those exhausting and often futile battles with LPAs and Inspectors on the issue of "essential need" for a dwelling in the countryside.  Yurts, caravans, Charter 7, Wales (although somebody explained that welsh planners were not a soft touch) were a few of the ways to avoid having to face up to the problems of providing on farm accommodation.  My response is that it is the (urgent) job of those representing the 'real farming' movement to educate the planners.  The main reason for the lack of empathy and positive response to the needs of real farming is the lack of constructive engagement.  Endless appeals could be fought for isolated dwellings but the only way to normalise 'real farming' would be through development plan policies. That means responding to consultations on local plans and neighbourhood plans (or get onto parish councils/neighbourhood forums) and getting supportive policies into plans under local food and/or sustainable development.

All this has been rehearsed in earlier Blogs (ie one or two of the affordable housing quota being reserved for agricultural workers together with land left over from the housing development).  However, when a delegate claimed that land prices were going 'through the roof', I was reminded odf another important aspect to the role of town and country planning. 
Until 1992 there was no such thing as an 'affordable house'. After a high court judge had agreed that the affordability of a dwelling to a local person was a material planning consideration this has become a staple in development plans and government policy - notwithstanding that affordability has been corrupted by non-planning matters on the demand side (Help to Buy, Housing Benefit, Funding for Lending, grant to RPs, the bank of mum and dad).  I would love to see this challenged to allow the court to consider whether it is the house that should be delivered at a cost related to a multiple (eg 3.5) of average local wages.  In the meantime there will the opportunity for an LPA to argue that access to affordable land is as important to access to affordable housing and require landowner developers to provide land at affordable prices.  I hope that the real farming movement can provide the 'public interest' case to justify such an intervention by the planning system.  This will be one of the points for discussion at the RTPI SE Branch meeting in the Spring.

Personal Note

I always thought that my disappointment with the British planning system was rooted in my professional belief that it could have and must now do much better in ensuring new development is sustainable (ie "consume its own smoke') and act as a driver to make all existing development in town and country more sustainable. However, I can now add my own disappointment with the planning system.
We have lived in the same village for the last 35 years and were able to move once from a small terraced house built for agricultural workers, but then taken over by the rural district council and then sold off. This move was to a 4 bedroomed house that I designed and had built while we lived in a caravan in the garden.  This propelled us several steps up the housing ladder so that the house would fetch about £600k with or without the plot that is currently the subject of a planning application (for a small two-bedroomed house with a potentially self - contained ground floor).  I am told not to even think about building this out and moving in.
So what are our options.  There are virtually no two bedroomed or even small three bedroomed houses except those for social rent (in the [private sector most have been extended into 4 bedders).  This problem should be solved by the three developers looking to build 250 dwellings in the village over the next few years.  The first application is in (for 73 units) and there are a few 2 bedroomed properties (and all for rent of equity share).  There are  quite a number of three bedroomed properties but few are south facing (not just a personal preference) and the gardens are tiny. The District Council carried out research that showed that 97% of new dwellings would need to be 1 or 2 bedroomed to meet the needs of small and contracting household size. The inadequately explained compromise in the Local Plan was 50% one and two bedroomed dwellings.  The village local housing needs survey found 24 out of those expressing a need wanting 2 bedroomed properties. The neighbourhood plan cites the Office of National Statistics and that 80% of the dwellings have one or usually more spare bedrooms.

Why are the developers so resistant to building new dwellings attractive to potential downsizers?  Many will want smaller houses (self-contained on the ground floor) but many will also want decent gardens.

So this 73 house development is presented as 'sustainable development' in a highly car dependent village (parking provision above maximum standards), with few terraced houses, few south facing, no opportunities reserved for co-housing or self-building and nothing above Code for Sustainable Homes level 3.

I found it  relatively easy to find accommodation as a student, then as a young planner and as a singleton and then as part of a young family.  The real problems are being experienced wanting to take a step down the housing ladder and the planners seem to be unable or reluctant to help.  The application for the new housing estate will be determined in early summer (when the relevant NDP in which the site is allocated will have been made or set aside).  This Blog will then describe whether the planners have decided to do anything to accommodate the needs for downsizers in a sustainable way.

Creating a new step onto the property ladder to buy votes?

Apologies for the length of this blog but it includes a response to a Government consultation that readers are welcome to copy, critique or amend. Replies by 6 February 2015 to:

starterhomesconsultation@communities.gsi.gov.uk

 

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/387297/141215_starter_homes_final_formatted_with_signatures.pdf

Stepping onto the property ladder

Enabling more low cost, high quality Starter Homes for first time buyers

Consultation Response

I have worked as a professional planner for the last 40 years in the private, public and voluntary sectors. I have also taught both planning and housing at Oxford University Department of Continuing Education  and been a member of a parish council engaged in the preparation of a neighbourhood development plan.

Background

1.    The following response is based on the premise that Government has failed to deal with the fundamental and systemic problem with housing supply that is the cost of land for housing. By feeding the demand side, Government has effectively passed public money into the pockets of landowners. As often as Government repeats the phrase ‘hardworking’ to describe the intended beneficiaries of housing policy, it should include ‘undeserving’ to describe the owners of land on which planning permission is granted.

2.    When, in 1992,  the High Court found there to be a material difference between an affordable home and one that was sold in the open market, this would have related to the building itself, and not to some unpredictable and often politically inspired public subsidy unrelated to planning controls.  A genuinely affordable home should not be one that is only made affordable through Help to Buy, Starter Home exception, Funding for Lending, grant to Registered Providers or Housing Benefit. These subsidies have served to raise the cost of building land and the price (and rent) of housing.  If the Government address the question of land prices, the only complaints from house-builders, who find themselves squeezed between the price paid for land and reasonable demands for infrastructure, would be from those holding land bought at inflated prices. Notwithstanding the perverse effect of raising land prices and the cost of housing, if asked, the Courts could find that in the exercise of planning control ‘affordable housing’ should not include pubic subsidy (on the demand side).

3.    There is a more difficult question about home ownership. It seems unlikely that much more than two thirds of the population will ever be in the position to own their own home.  Just as Germany has been responsible in this country for providing the best railways, water supply, power supply and grocers, it also has the best models for housing in the 21^st century (especially co-housing, group self-build, infrastructure provision and energy efficiency).  This very successful country prospers despite a substantially lower level of owner-occupancy.  In fact there is a growing need to encourage mobility (that would come from a larger rental sector) to effect a  better balance between the size of households and houses.  The 80% level of under-occupation is unsustainable and partly responsible for the assumed requirement to build 250,000 new units a year.

4.    At para 2 there is a claim that the reform to stamp duty will reduce the price of houses, when the evidence since the Autumn Statement shows that this change to the demand side has already raised the price of houses.

5.    The proposal also flies in the face of the findings of the All Part Parliamentary Group on Housing and Care for Older People, The affordability of retirement housing 2014, that takes a systemic view of housing and explains why the most effective way to deal with problems of housing supply and affordability is not with starter homes, but homes for right- or down-sizers. This would create mobility in the market that would release smaller homes for first time buyers.

6.    It is counter-productive to relieve more sites and housing from supporting affordable housing and infrastructure costs.  Subsidising house-buying to penalise the social and affordable renting sector has no net benefit. The failure to contribute to essential infrastructure will produce housing without the necessary improvements to public services; schools, public transport and recreation.  The Government has already introduced this form of free-riding for self-building and small site development at the same time as service providers are facing severe cutbacks.

7.    There will not be a ready supply of these discrete brownfield sites, and those that are not currently being developed are likely to have substantial clean-up costs. Pointing to under-used sites is an invitation to businesses to scale back operations and employment (just as the right to change from B1 to C3 has reduced local job opportunities). A curious aspect of the proposal is the premise that brownfield sites could be treated like ‘exception sites’ that would not normally receive permission. In fact the kind of site being described is that which would already be looked at favourably and should not have the land cost discounted in the way of rural exception sites. In fact the inclination of the Secretary of State to grant permission on greenfield sites outside the existing built up area of towns and villages has severely limited the availability of rural ‘exception sites’ that were previously seen as having little or no hope value.

8.    The fact that an urban  site is not identified for housing usually means that it does not need to be identified as it would be approved on its merits (eg within a built up area and previously developed). These windfall sites are not ‘additional’, but allowed for in the development plan land supply figures.  The starter homes create demands that will not be covered by other housing on allocated sites which, by law, can only be expected to meet their own proportional needs.

9.    Government should stop making piecemeal changes to a complex planning and housing system.  The proposed changes will have any number of unintended consequences, perverse incentives and unfairness, without actually providing the good quality homes, sustainable communities and urban environments that are desperately needed.

10. Government should take into account the fact that in the era of neighbourhood plans, any changes to the planning system that should be embedded in democratically prepared development plans, has to be addressed by parish councils with very limited resources and expertise. 

Questions

Q1: Do you agree in principle with the idea of a new national Starter Homes exception site planning policy to deliver more new low cost homes for first time buyers?

No, the idea is fundamentally flawed.  This proposal is more tinkering and not based on a systemic view. By ignoring  the main cause of house price inflation,  which is the cost of building land,  would result in this public subsidy (primarily and ironically  from affordable housing provision through s106 and contributions  to essential local services through CIL) being an added to those already being passed on to landowners (eg Help to Buy, Funding for Lending, Housing Benefit and grants to Registered Providers).

Q2: Do you agree that the Starter Homes exception site policy should focus solely on commercial and industrial brownfield land which has not been identified for housing?

This proposal exposes the lack of understanding of how the planning system actually works.  The kind of site being described is not ‘exceptional’ in the sense of a rural site which would be unlikely to receive permission,  but would be  windfall sites that are allowed in accordance with criteria based policies – and allowed for in housing supply figures.   Support for  the redevelopment of commercial and brownfield  land  will reduce the opportunities for local employment (as is occurring  through the relaxation of the GPDO)

Q3: Do you agree that the types of land most suitable for Starter Homes will be under-utilised or non-viable sites currently (or formerly) in commercial or industrial use?

This requirement would introduce the perverse incentive of businesses to scale down their operations and a need (impossibility) to define ‘under-utilisation’ and ‘viability’ in local and neighbourhood plans.

Q4: Do you consider it necessary to avoid Starter Homes developments in isolated locations, or where there would be conflicts with key protections in the National Planning Policy Framework?

No housing should be built in isolated and unsustainable locations.  The need to build in existing settlements is not for landscape protection reasons but primarily to enable social inclusion.

Q5: Do you agree that the Starter Homes exception site policy should allow at the planning authority’s discretion a small proportion of market homes to be included when they are necessary for the financial viability of the Starter Homes site?

This is another over complicated mechanism for which the local planning authority is completely unprepared.  Affordability and viability should start with the valuation of development land at existing use value with a small but attractive uplift (see Lyons Review)

Q6: Do you agree starter homes secured through the Starter Homes exception site policy should only be offered for sale or occupation to young first time buyers?

Age is a ‘category error’ at both ends of life.  It hides the wide variety of personal circumstances.  Limiting a subsidy to under-forties and first time buyers misses those hardworking people in broken homes (sometimes with young children)  who are in housing need. There are couples of very different ages who may or may not be actually intending to live together.  All generations should be living together and not receive inducements to live apart.

 

Q7: Do you think there are sufficient existing mechanisms in place to police this policy?

No.  Planning departments will be subject to severe cutbacks (one of the vulnerable services not ring fenced) and should not be given additional responsibilities.  The best way of delivering houses would be to stop the  tinkering which limits the effectiveness of local government, and central government should deal at national level with ‘affordability’ by addressing the cost of development land.

Q8: What is the most appropriate length for a restriction on the sale of a starter home at open market value? How should the sliding scale be set?

If there is a sliding scale there is no reason to worry about the length of the taper.  However, the principle of Starter Homes introduces the need for strict definitions (individual or shared responsibility of singles, couples or triples) which will then intrude on the freedom of people to choose whether or not  to continue to live together.

Q9: Do you agree that guidance should make clear it is inappropriate for Starter Homes exception site projects to be subject to section 106 contributions for affordable housing and tariffs?

No.  There should be no further exemptions from s106 (including affordable housing)  that, by definition and case  law, can only be  required  if necessary and fairly related to the development and/or in accordance with the development plan.  Exemptions imply a public subsidy being paid to the landowners and freeloading by the Starter Home development at the expense of the private and social/affordable rental sector.

Q10: Do you agree that Starter Homes exception site projects should be exempt from the payment of the Community Infrastructure Levy?

No.  There should be no further exemptions from CIL which has been methodically worked out and examined  on what is required to pay for local infrastructure and must be justified as  necessary and fairly related to the development and/or in accordance with the development plan.  Exemptions imply a public subsidy being paid to the landowners and freeloading by the Starter Home development at the expense of other housing providers and occupiers. The assumption that occupiers can simply use services provided by other new development is wrong and legally flawed.  Other new development would only have provided that which was necessary for its own needs (eg school places, bus services, Citizen Advice provision and recreational facilities). Exemptions would deprive parish councils of the funds necessary to enhance facilities to make locations more sustainable.

Q11: Do you have any views on how this register should work and the information it should contain?

LPAs should usefully be keeping registers for self-builders, group self-builders and potential co-housers. Another register with individuals and possibly related people of different and increasing ages and possibly local needs implies careful judgements (possibly by panels or committee), appeal procedures and possibly judicial review of mistakes or apparently unreasonable decisions. All this at the time of severe cutbacks?

Q12: What kind of vanguard programme would be most helpful to support the roll out of Starter Homes?

The Starter Home exception is misconceived as it is a replacement for the failure to tackle land prices as the fundamental key to affordability. In the case of necessary systemic changes there should no need for  ‘vanguards’,  which is a mechanism suited for changes where Government anticipates problems.  There are enough difficulties with the proposals to know that problems will arise without these being uncovered by vanguards or trial and error.  For example vanguards would have to be those authorities in the process of review of their local plans so that these could include the many definitions on which the proposals are predicated; what would comprise an exception site which would or would not be a normally occurring windfall, decision-making and appeal procedure and  fair but flexible eligibility criteria.  Introducing these novel and potentially contentious policies would delay the approval of new and replacement development plans and their implementation.

The proposal of a Design Advisory Panels (there is no question dedicated to this?) should be abandoned. There is a very carefully constructed Building for Life scheme operating with the support of LPAs and housebuilders.  There are design guides produced by LPAs and (unfortunately) more design guidance in neighbourhood plans. The last thing that is required is more design guidance especially from higher levels.

Transition and planning

When asked how the draft local plan would help the transition to a low carbon economy (between 6% and 10% carbon emissions reduction per year - towards the higher end unless starting now) and accommodate about 40% growth in houses (as per Strategic Housing Market Assessment - SHMA) and jobs (Local Enterprise Partnership guess) and associated infrastructure over the next 15 years, the responsible councillor said that it would and could not. When asked why the Lyons Review had not incorporated recommendations as to how new housing would be zero carbon the representative from the planning profession suggested that this would have made the report unwieldy.  It seems transition towns or carbon descent is proving too difficult for planning and planners.

However, the statutory framework of the Climate Change Act and associated budgets (50% reductions by 2050 and 60% by 2030) give us no choice.  It would be extraordinary, and nobody has suggested, that the use of land and buildings would be unaffected by this scale of change. What is lacking is the vision or imagination to identify the changes that would enable the transition to take place without social trauma if not revolution.  I am afraid that the planning system is backward looking and mired in conventions that have delivered and continue to deliver urban developments almost all of which will require adaptation to a low and close to zero carbon economy.

A backcasting exercise (VIBAT 2006 UCL/Halcow) demonstrated that a low carbon (ie 40% of existing) transport system would require the national speed limit to be reduced to about 50mph.  It would be very helpful to have an equivalent backcasting for the housing system.  It seems unlikely that 70 million people will be able to live a zero carbon lifestyle in this country in 2050 unless under-occupation has been reduced from 80% to negligible proportions. If commuting will be less than today why are we intent on building more roads and railways?  If houses will be carbon neutral or negative, why are houses being built to CSH 3 in 2014? If we will be eating a greater proportion of food from the local area why are houses being built on Best and Most Versatile Land and no houses being provided in the urban fringe for the increased workforce?

When asked whether the planning system should be responsible for widening the opportunities for co-housing and self-building a very senior and influential planner suggested that this was not a priority (divert from the priority of concentrating on building 250,000 units per year).

If the current planning system is badly placed (laws and policy) and staffed (competence and imagination) to facilitate the necessary transition then we should say so and leave the job to other planners.  While keeping up the pretense that we are doing something (effective) about it,  those better placed and with greater competence are being excluded.

Exemptions from zero carbon homes consultation

This is the link for the current consultation on exemptions from the commitment to zero carbon homes by 2016 (already not strictly zero carbon)

https://www.gov.uk/government/consultations/next-steps-to-zero-carbon-homes-small-sites-exemption

Please look at it and reply to DCLG by 7 January 2015.   My thoughts are as set out below. It is not the proposed exemption that will make the difference but the repeated signal that the Government does not " get it" when it comes to carbon reductions.  The main point is the false dichotomy set up to excuse the inadequate attempts at carbon reductions as, to take effective action, might threaten economic growth.  In fact it is not paying for carbon reductions which might undermine GDP but a low carbon economy, if it were ever achieved, is likely to be one where growth in GDP would not be discernible.  There might well be growth in all sorts of more worthwhile ways.  Anyway I am sure that the DCLG would welcome more reaction to its consultation.

Consultation

Next steps to zero carbon homes: small sites exemption

Introduction

This consultation is fundamentally about carbon emissions but lacks the understanding necessary to produce a coherent and effective policy.  Two basic elements are missing from the analysis:

1.   The building sector (including residential development) is possibly the only and definitely the easiest sector within which to achieve early reductions consistent with the statutory (ie 80%) cuts in carbon emissions required by 2050.  In fact residential development has the potential for 100% + carbon emission cuts – “carbon negative” or “solar positive”.  This will be essential to meet the overall targets as there is no workable plan for agriculture, industry, power generation, and transport (including aviation and shipping) to meet the necessary  80% savings.

2.   It is not the level of carbon emissions in 2050 that will matter. What are required are substantial reductions as early as possible. The 6% annual reductions that might be sufficient if achieved now, will very soon reach 10% (already the minimum necessary according to the Tyndall Institute).  Whilst with existing technology and knowhow, housing has the potential to reduce its contribution to carbon emissions, even this is proving to be very challenging particularly in respect of the 22million  existing homes.  This emphasises the need not to add to the burden and to move towards carbon negative building to make up for the challenges in other sectors and the problems with the Green Deal and the massive stock of solid wall houses.

3.   Paras 8 and 25 set up a false dichotomy between economic growth and reducing carbon.  There will be no recognisable economy in a Country with more than 2 degrees of planetry warming.  In other words economic growth has to be defined and, if necessary, adjusted, to be compatible with carbon reductions known to be necessary to limit warming 2 degrees (350 to 400 ppm).

Very little weight should be given to responses received to the 6 questions in this consultation that are not based on the premises that the housing sector must make a disproportionate contribution to carbon emissions particularly in the immediate future during which other sectors are needing to research, innovate and develop.  The only evidence that that zero carbon housing would not be compatible with the Climate Change Act is that even higher standards might be required – without delay.

Question 1 should the exemption be targeted at site size, developer size, or a combination of both? Is there any evidence to support the choice made?  The consultation makes a compelling case for having no exemptions by describing the various traps and false and perverse incentives which arise when thresholds are created.  The occupiers of the house will not know that their heating bill is higher because of the number of builders employed in its construction or the number or size of dwellings on the site.  Passivhaus developments are often relatively small and the extra cost (est 12% as the industry matures) is recovered in 7 years.

Question 2 – if the Government chose a site size exemption, what level should this be set and why?  There is no ‘carbon reduction’ argument or justification for any exemption.  The Government would like to see more small builders and sees building standards as a brake on their growth.  If exemptions succeed in the growth of this sector then an increasing and  substantial number of sub-standard dwellings would be built – all adding to a burden that will have to made good.  As there should be no pretence that any of these houses will actually be upgraded, where will this locked-in deficit be recovered by 2050 and beyond?

There are many good planning reasons for large sites to be developed in phases (CIL has already caused this – a positive but unintended incentive) and areas reserved for self/group – builders or finishers. Similar reservations could be made for relatively small builders. Thresholds in the proposed regulations would complicate and interfere with these desirable trends.

Question 3 – if the Government chose a developer size exemption, what criteria should it apply and why?

Same as above –exemptions from zero carbon (or carbon negative) in the housing sector, will never be made good.

Question 4 – What do you think the scope of the exemption should cover? An exemption for the allowable solutions scheme only, or an additional exemption from Building Regulations requirements? Do you have any evidence to support the choice between these options?

It may be that,  “29.The Government’s preferred approach is to exempt small sites from the allowable solutions component only.” and it is essential that at least the new houses are all built to zero carbon.  However, even If it is only the allowable solutions that are relaxed then there must be a programme for how this deficit is made good without delay.   As allowable solutions should be concentrated on reducing carbon from housing (eg building materials, associated infrastructure and electricity/heat) any exemptions will make it impossible for the housing sector to achieve the necessary quick and deep carbon emission reductions.

Question 5 – What are your views on the proposed review period for the exemption? All regulations can be reviewed.  There would be no obvious positive or perverse incentives for the industry to reduce emissions faster and deeper if a review period was set up at the outset. If no exemptions should be made in the first place the industry will quickly adapt – it is the large scale developers that are least adaptable and agile.

Question 6(?) – Do you have any further evidence that would help inform the impact assessment?

It is essential to remember that the purpose of zero carbon housing is to incentivise faster and deeper reductions in carbon emissions from the building and occupation of housing.  There is no reason why the industry would not adapt to a positive, coherent and lasting regulatory regime. There is no time in the house-building sector for the prevarication implied by this consultation.  Exemptions will create unintended and possibly perverse incentives that would detract from the industry’s job of delivering new housing that would not add to the problem of carbon reductions in this sector and across the board.

Planning, carbon reduction and low hanging fruit

I have just read through  draft Local Plan that is intended to guide development in an English rural area (three market towns and about 30 villages) over the next 15 years.  This is the period that carbon emissions must be reduced by 60% in accordance with the Climate Change Act.  It is also a period during which 20,000 houses are expected to be built with a proportionate level of employment growth (and commuting).   The 4th carbon budget is based on annual carbon reductions of about 6% aimed at getting to 80% reductions by 2050, while the Tyndall Institute already regard between 8% and 10% to be necessary (looking at 90% reductions and seeking to secure these earlier rather than later).

My modest contribution to this debate is to raise a couple of questions to which I am not hearing any answers.

1.   Assuming we are not deluding ourselves that immediate annual savings  of about 6% can be achieved -  why are carbon emissions still rising?

2.   If even early reductions are not being achieved - ie those most affordable and using existing technologies - what hope is there to achieve cuts with expensive and not yet available technologies?

So back to the Local Plan, substantial levels of carbon emissions are attributable to housing, transport, energy production and food supply all of which can be controlled to some extent by planning policies. It would be surprising if a world (or rural English district) emitting 60% less carbon would look very much the same as now.  However, looking at the Plan, the only certainty is that there will be more buildings and roads.  There may be a few more solar panels and somewhat less agricultural land.  The 'low hanging carbon fruit' of carbon negative/solar plus buildings, low energy car clubs, a step change increase in bus travel and cycling (based on privileging buses/ and cycling over cars through investment and regulation), supporting local food production/processing/ distribution, and using new housing (small, south facing terraces) to reduce under-occupancy,  is all being left on the tree. It must be doubtful that even these measures could achieve more than modest carbon reductions without significant behavioural change which remains taboo.

Without the first signs that the planning system has understood the gravity of the situation, and the challenge of 6% plus annual carbon reductions, the planned growth in housing and jobs in this district and elsewhere looks very much like resulting in a proportionate growth in carbon emissions (including those resulting from building/construction).  However, new houses and jobs are needed and could and should act as the drivers of change to a low carbon society/economy.  It seems that the current operators of the planning system are not up to this task but,  of course, the same questions need to be asked of our politicians and public.