I very much enjoyed the chance to see so many of you at our AGM at the end of last month.
It proved to be an excellent opportunity to bring the industry together and talk about issues of mutual concern. I do hope you felt that it was a useful exchange of news and information, and a chance to extend business contacts. I certainly appreciate the efforts so many of you made - not least those who travelled across the country to be in London - for making the day such a success.
HEADLINE ISSUES
Zero carbon homes: local authority target-setting autonomy
As you know, I have become seriously concerned by mounting evidence that local and regional authorities are seeking to adopt their own building standards or advance the timetable for achieving zero carbon homes. Such a multiplicity of different local approaches will inevitably complicate and slow down industry efforts to develop the best means of achieving higher standards of environmental performance with the clear risk of adversely affecting housing supply as a consequence.
Housing Minister Yvette Cooper MP did, of course, address this issue in her remarks to our annual lunch last month. She recognised industry concern and reiterated her view that local authorities should only be able to go further and faster than the national timetable where they could demonstrate through a properly adopted plan policy that this would not prejudice housing delivery.
Given the vital importance of the Government holding firm against local pressures, I have written to the Communities and Local Government Secretary, Ruth Kelly MP, highlighting our grave concerns and asking her to consider how we can find a way of ensuring adherence to sensible national standards in the cause of the optimum outcome. The evidence base that we are collating from you and other members will help substantiate our case for a realistic and achievable rate of progress. I will continue to represent our concerns on this issue strongly to the Secretary of State, Ministers and senior officials.
Callcutt Review of Housebuilding Delivery
Our submission to the Review's Call for Evidence outlined the priority conditions for achieving the 200,000 quality, zero-carbon homes target:
an adequate supply of land with implementable planning permission,
adequate infrastructure,
the ability to build homes people want to buy,
competitive returns for shareholders,
residual land values that bring forward land for housing development,
and a reduction in the complexity and cost of regulation.
Issues such as skills, construction methods, materials or finance will not present insurmountable barriers because they are largely within the control of the house building industry and its suppliers.
There is already a range of business models delivering housing and the Government should not attempt to 'pick winners'. Ensuring the best models emerge and prosper in a market economy requires allowing investors and development companies to take risks, innovate and adapt to changing market and regulatory conditions.
Central Government's role should be to ensure that policy and regulation do not create barriers to achieving the housing target or to new entrants, and to leave a level playing field on which companies can compete.
One important theme of HBF's submission is our growing concern about the complexity and cost of policy and regulation. The escalating cost impact on land values is already constraining housing output, even before we take into account the zero-carbon target and PGS. A recent report for English Partnerships put the cost of achieving Code Level 5 at £26,000 to £36,000 per 'traditional' dwelling, a land cost of £1.0-1.4 million per hectare at current densities. Zero-carbon homes, at Code Level 6, will cost even more.
We will continue to work to influence John Callcutt and his Review team as they progress towards their autumn deadline.
Home Information Packs (HIPs)
We have now added a set of frequently asked questions and answers to the HBF website based on the work we have undertaken to date to assist members with the introduction of HIPs from 1 June. We are continuing to receive inquiries from members about detailed issues on HIPs and Energy Performance Certificates (EPCs) and are asking the CLG to provide advice on these.
CAMPAIGNS UPDATE
HBF Launches Wales Manifesto
HBF launched a Manifesto for Wales to coincide with the Assembly elections on 3 May. Copies were sent to all candidates and the Western Mail carried a feature article in my name on 25 April summarising our priorities for future Welsh housing and planning policy. I am keen that we maintain engagement with the new Assembly Government following the elections and our Manifesto will provide a good basis for dialogue - to address growing affordability problems through adequate supply and to seek a practical approach to achieving the higher sustainability standards sought by Welsh politicians.
Thames Basin Heaths Special Protection Area (SPA)
Following preliminary discussions with CLG, we hope to meet Government officials and other key parties in May to discuss how early effect can be given to the implementation of the EiP Assessor's recommendations for modified mitigation standards to enable new development close to the SPA to proceed. We will liaise closely with members on what emerges from these discussions. It remains a high priority for me to resolve this serious and longstanding problem.
EXTERNAL AND ECONOMIC ISSUES
Housing Production Barriers Group
This new Group, chaired by Rod MacEachrane, met for the first time last week. It is developing its work programme with members of the Group agreeing that meeting the 200,000 zero-carbon target by 2016 will present major production challenges for the industry. I will keep HBF members informed of the Group's progress in the coming months.
Customer satisfaction
We are concerned to learn that DTI Trade Minister Ian McCartney MP has announced a Government review into regulation and consumer redress across the whole property sector. Officials are in the process of drawing up terms of reference for the review which will start in the summer. The review was a response to pressure from the Liberal Democrats to expand the coverage of the Consumers, Estate Agents and Redress Bill by making it compulsory for anyone developing and directly selling new homes to belong to a customer redress scheme. HBF has written to DTI officials seeking more information about the review
Political engagement
The Major Home Builders Group had a wide-ranging discussion over dinner with Shadow Housing Minister, Michael Gove MP. It proved a very useful opportunity to discuss how public policy could promote a more positive environment for housing supply. Michael Gove made it clear that he would welcome further input into Conservative Party policymaking.
HBF has established a good relationship whereby the Shadow Minister is in regular receipt of our submissions and details of our policy positions. We look forward this summer to the publication of the Conservative Party's six policy review groups - not least the ones on economic competitiveness, quality of life and social justice.
PLANNING
Supplementary Planning Documents
Many of you, I know, are being faced with local planning authorities bringing forward new policies or requirements through supplementary planning documents (SPD) rather than through the proper, formal adoption of development plan documents (DPDs) as part of the local development plan.
While HBF is sometimes consulted directly on draft SPDs, because the process for their production and adoption is less formal than for DPDs, this is not always the case. We are, therefore, reliant on members bringing these emerging documents to our attention and thank you for continuing to do so.
We discussed this worrying and increasing abuse of the planning policy system at a recent meeting with CLG officials. We supplied evidence of a number of examples from around the country of where we thought SPD had been used to introduce new policy, above and beyond that contained in the adopted development plans. These examples fell within three broad categories; detailed S106 requirements; levels of affordable housing provision and the environmental performance of buildings, including renewable energy.
We are of course pursuing the environmental issues separately with CLG as part of our discussions on the draft PPS on climate change. As you know, we are currently collating as much evidence of such emerging LPA requirements as possible for a more detailed discussion with the Minister and officials and I would welcome your continued help on this matter.
More generally, the policy requirement set out in PPS12: Development Plans states clearly that "matters covered in supplementary planning documents must relate to policies in a development plan document or saved policy in a development plan". A SPD must not, therefore, introduce new policy requirements. Unfortunately, although CLG recognise that some abuse is taking place they seem powerless take action against it.
Our experience is that while we have been quick to notify the relevant Government Office of SPDs that appear to disregard this rule, there is nothing to stop a LPA from adopting such a document, even in the face of objections from the Government Office. CLG advise that the only test for whether the requirements of the document are reasonable should be through the appeal process when the weight that has been placed on the SPD in decision making is tested. We are, therefore, currently gathering further evidence of appeals that have made this consideration.
It is clear that CLG is not keen to be overly prescriptive, preferring to allow local flexibility and interpretation of policy requirements. However, in the light of our representations, the Department is considering reviewing the guidance on use of SPDs later this year.
We will continue to collect evidence of LPAs who persist in bringing forward new policy via SPD. We are grateful to members who continue to bring examples to our attention.
TECHNICAL ISSUES
Building Regulations
The final reports on 'Achieving Building Standards' and 'The Future of Building Control' have been issued by CLG. These are part of a programme of work to consider the current situation of Building Regulations, how they are managed and maintained, and to identify what might be done to improve them.
The evidence base contained in this report has been provided by the major stakeholders and includes HBF's views on regulation simplification. We are expecting to see a full consultation paper later in the year.
Key Consultations
Both 'Building A Greener Future: Towards Zero Carbon Development' and 'Water Efficiency in New Buildings' closed in early March and we are awaiting the Government's response to them both.
Code for Sustainable Homes
This came into force on 10 April and the Technical Guidance is now available. We are however still awaiting the revised Green Guide.
Innovate for Homes
We have enough submissions for the next round and these will be vetted in the next few weeks with a view to putting the best ones forward to the Housebuilder Panel.
Manual for Streets
This replacement for DB32 was launched on 29 March and there are still places available to participate in the seminars in Newcastle, Taunton, Cardiff, Coventry and Manchester (for which HBF members can claim a discount). If you are interested, please contact the Institution of Highways and Transportation (www.iht.org) who are organising the events. The document replaces DB32 and has a more flexible, team-based approach to highway design. HBF is confident that its adoption will facilitate better relations between highway engineers and planners.
As ever, please do not hesitate to get in touch with me or the senior management team here at St James's Street if we can help further.
Stewart Baseley
Executive Chairman