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GOVERNMENT MUST PLAN SUSTAINABLE HOMES - NOT JUST MORE HOUSES

Oct 26 2004

Responding to the Government's launch of an eight-week public consultation on its revised plans to provide an additional 169,800 homes in the Milton Keynes South Midlands (MKSM) area by 2021, Friends of the Earth spokesperson Paul De Zylva said:

"The only certainty about the so-called `Sustainable Communities Plan' is the vast number of new houses that will be imposed on communities and countryside with no guarantee that they won't lead to a rash of environmental and transport problems.

"Lord Rooker and Mr Prescott claim they are building communities not houses but their plan doesn't fully address the need for affordable housing and the need to control spiralling house prices."

Friends of the Earth's key concerns about the Government's latest consultation include:

1. The number and timing of houses proposed:

   Total housing growth is 169,800 to 2021 of which 106,150 is currently allowed in the current planning guidance for the three regions (East, south east and East Midlands). The extra housing planed for the MKSM area on top of this is 63,650 by 2021.

2. Affordable housing:

   The Government's consultation is still too vague about whether the proposed housing will address affordable housing need and spiralling house prices in general.

   Simply releasing more housing onto the open market will do nothing to control either because house prices are subject to complex forces other than the simple matter of supply.

   On page 15, paragraph 48 of the alterations consultation draft only aims to address affordability. It says: "Development in the Sub region should aim to make home ownership more affordable by increasing supply of the right type (of housing) in the right place."

3. Vague standards:

   The consultation is too vague in the standards it sets for building design, construction and operation. It mentions "Promoting…" (but not requiring) "…the highest standards of environmental performance" in design, build and use of new buildings. (Ref: Page 16, paragraph 50)

4. Levels of brownfield land being used for housing:

   Use of brownfield land in the Milton Keynes & South Midlands area will be 28 per cent not the 67 per cent. Lord Rooker is disingenuous when he talks about the current levels of brownfield land being used for housing. Ref: "That's why 67% of all new building is now on brownfield land compared to 56% in 1997, ODPM Release 2004/0254: 26th October 2004.

5. Public transport:

   There is a welcome proposed study into east west transport including much needed rail links although according to the latest consultation draft these initiatives seem to be being put off into the long term, especially rail, while active approval is given to more road and airport schemes: "East-West Rail possibilities east of Bedford can only be considered in the longer term" (Ref: Page 12, para 29)

6. Vague about environmental assets and green space

   There is some welcome recognition that the area's environmental assets deserve protection and that you can't have sustainable communities without green infrastructure of all types. Further certainty is required on the provision, quality, and protection and on-going maintenance of this land and amenity.

7. Reliance on consultants' studies

   A worrying development is the apparent decision by the Government to use the background work of a few consultants who carried a few studies and assessments of the area ("Growth Area Assessment" studies (GAA's)). These studies have not been the subject of public scrutiny or consultation yet according to the latest consultation, their details are now being referred to and relied on as the basis for growth in the area.

   In their panel report into the public examination of the MKSM proposals, the independent inspectors stated very clearly that "we have therefore concluded that it should be made clear that the GAAs have not pre-determined local spatial issues and have not formal planning status." (Ref: Para 1.12 of the MKSM panel report)

   Yet the Government's latest consultation states: "The overall effect of the GAA's has been to demonstrate that there is strategic capacity for growth on the scale indicated by the MKSM study, with certain minor exceptions. The site specific issues now need to be considered through the preparation of LDDs, with any site allocations being identified in Development Plan Documents (DPDs), to take forward the strategic policies of the Sub-Regional Strategy. The detail provided by the GAAs and the work undertaken for the Sub-Regional Strategy should inform the speedy production of LDDs." (Page 7, paragraph 8 of the Government's latest consultation)

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