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Planning for Housing Provision (ODPM Consultation Paper):
OPT Response, 9 September 2005

Summary

The Optimum Population Trust’s view is that the document is fundamentally flawed, by virtue of its misuse of the idea of sustainability, its discounting of environmental carrying capacity, its treatment of land and land supply as almost exclusively an economic issue and its neglect of environmental factors. The OPT recognises the acknowledgment by the ODPM that the paper does not “address issues concerned with the overall level of housing growth and how it is determined” but believes this fundamentally undermines its rationale. An analogy would be proposing a new global navigation system based on the concept that the earth is flat. For that reason, the OPT’s view is that the document is not “a good basis on which to plan for delivering land for housing…”

Main Points

1. Any definition of sustainability must take as its starting point the capacity of a place – whether it is the planet or a nation-state or a local authority area – to support a given size of population without serious adverse consequences. In the case of housing , this would entail decisions about population levels and their relationship to factors such as water supply, flood alleviation, sewage disposal, air quality, traffic congestion, transport and energy use and liveability or quality of life. The PHP paper does not do this. Instead it proceeds from the premiss that there is an “under-supply” – not, for example, an “over-demand” – in housing and that this must be rectified. The environmental and social constraints, it is clear, come a poor second. This is a travesty of the meaning of sustainability. It suggests that “Plan Monitor and Manage” is little different from “Predict and Provide.”

2. Throughout the paper land is viewed, and described, as a commodity, with no sense of what sort of land it is, what functions it fulfils (biodiversity, water supply, agriculture, green lungs ) and no sense either of its finitude. The implication appears to be that it is an inexhaustible commodity. This, too, vitiates the main thrust of the document.

3. This approach leads to some blinkered conclusions. For instance, it is assumed that the “mismatch” between supply and demand must be in some sense either a market failure or a fault in the planning system. The alternative conclusion – that housing (and population) in parts of the UK, notably London and the south-east, may be outstripping carrying capacity and that the planning system may be reflecting a local appreciation of this – is thereby ruled out from the beginning.

4. As evidence that this may be the case – that housing/population is outstripping carrying capacity – several independent/consultants’ reports from regions of the south-east have concluded that local infrastructure cannot cope with the housing numbers proposed. Housing and population growth are already placing immense strains on water resources, flood prevention regimes, natural habitats, air quality, transport systems; they are leading to crowding, congestion and diminution in quality of life. Seventy-six per cent of Britons, according to a YouGov poll, think the UK is overcrowded. Global density comparisons show that only four countries larger than the UK (Vietnam, the Philippines, India and Japan) have higher population densities. Only one country larger than England (Bangladesh) has a higher population density. (England’s area is half that of the UK but its density is nearly 60 per cent higher. Bangladesh is smaller in area than the UK but larger than England.) (See note on density below).

5. The OPT’s view is that any proposed housing planning system must start from a realistic assessment of an area’s carrying capacity, which must include a judgement about what human numbers are ecologically sustainable and what are not. The point of “sustainability appraisal” is that it includes the possibility of some developments being classed as unsustainable. The fact that this possibility is not considered within this paper, in the context of national housing strategy – that housing will be “sustainable”, irrespective of numbers - renders its use of the sustainability concept flexible to the point of meaninglessness. A national housing strategy, in the OPT’s view, should include a national population policy and some view of what sustainable or optimum numbers are for the UK. The OPT believes that forecast increases in the UK population to nearly 67 million by 2050, which would mean at least another 5 million houses at predicted household formation rates, will clearly exceed carrying capacity and breach any reasonable criteria of sustainability.

Note on Density

Density is a crude measure of carrying capacity or “overpopulation”. It does not, for instance, take account of lifestyle (consumption, affluence, technology): a population with greater mobility and more technology at their disposal will have greater impact than a less “developed” population. Nor does it take account of externalities – the demands transposed to other regions because they have been squeezed out of a very dense area. These may vary from demands for environmental goods and services – food, water, raw materials – to demands for relaxation, leisure, peace and quiet. One way of capturing these impacts is through ecological footprinting. Another is the size of the area of high density – research by the Campaign for the Protection of Rural England has demonstrated the incremental loss of “tranquillity” in England in recent decades through the spread of housing, development and road traffic. In a very large and very densely populated area, therefore, the effects of high densities, notably the social and psychological effects, may be greater because they are more widely spread and therefore less escapable.

This suggests we need more sophisticated measures of density. In this context it is worth noting that all the other countries mentioned on paragraph 4 above have lower per capita ecological footprints than the UK. Bangladesh, for example, the most densely populated “large” country in the world – the states with higher densities than Bangladesh tend to be very small city or island states – has a per capita footprint equivalent to one-ninth of the UK’s. It may be that in terms of what might be called effective density – density as a function of both environmental impact (as measured by ecological footprint) and overall area - England’s densities are among the very highest globally.