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	<title>Chris Brown Blog</title>
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	<description>Just another dev.wordpress-mu.co.uk Blogs site</description>
	<lastBuildDate>Mon, 28 May 2012 10:49:34 +0000</lastBuildDate>
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		<title>Blog – Custom and Community Building – Disruptive Innovation</title>
		<link>http://chrisbrown.regen.net/2012/05/28/blog-custom-and-community-building-disruptive-innovation/</link>
		<comments>http://chrisbrown.regen.net/2012/05/28/blog-custom-and-community-building-disruptive-innovation/#comments</comments>
		<pubDate>Mon, 28 May 2012 09:12:02 +0000</pubDate>
		<dc:creator>chrisbrown</dc:creator>
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		<guid isPermaLink="false">http://wordpress.hbpl.co.uk/chrisbrown/?p=462</guid>
		<description><![CDATA[<p>The last couple of weeks have been something of a revelation for me as three different parts of my work have come together in an unexpected way.</p>
<p><span id="more-462"></span></p>
<p>The starting point was a visit to Almere, a new town about half an hour by train from Amsterdam, which is now my new ‘Must See’ recommendation – yes even better than Malmo Western Harbour!</p>
<p><a href="http://chrisbrown.regen.net/2012/05/28/blog-custom-and-community-building-disruptive-innovation/" class="more-link">Read more &#187;</a></p>
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			<content:encoded><![CDATA[<p>The last couple of weeks have been something of a revelation for me as three different parts of my work have come together in an unexpected way.</p>
<p><span id="more-462"></span></p>
<p>The starting point was a visit to Almere, a new town about half an hour by train from Amsterdam, which is now my new ‘Must See’ recommendation – yes even better than Malmo Western Harbour!</p>
<p>I went with a small party including Grant Shapps, Kevin McCloud (the Government’s new Custom Build champion), Pat Richie from HCA and a variety of housing associations, custom build enablers and local authorities all organised brilliantly by Ted Stevens of the National Self Build Association and the British Embassy in the Hague.</p>
<p>I was pretty cynical before my visit having heard less than complimentary things about Almere’s masterplanning experiments which made it sound on a par with Milton Keynes for urban place-making (no offense MK but I like my urban a bit more urban).</p>
<div id="attachment_463" class="wp-caption alignright" style="width: 310px"><a href="http://chrisbrown.regen.net/files/Almere-Street.jpg"><img class="size-medium wp-image-463" src="http://chrisbrown.regen.net/files/Almere-Street-300x224.jpg" alt="" width="300" height="224" /></a><p class="wp-caption-text">Almere Homeruskwartier street</p></div>
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<p>But I was blown away by the Homeruskwartier neighbourhood. We witnessed a really attractive place being created very rapidly by a wide range of people to very high standards. And best of all there wasn’t a single volume developer involved.</p>
<div class="mceTemp">The story of Custom Build in Almere is much more nuanced than the UK understanding of Self Build. This is not a process that requires people to have skills in bricklaying or joinery. The basic process is that the local authority land owner produces an urban design, puts in the roads and basic infrastructure and, critically, makes the decision to sell the land in individual building plots and not as a site sale of hundreds of plots.</div>
<p>Also importantly, the prices of the plots are fixed (based on a market valuation) and are sold on a first come first served basis to individuals and groups that want to build their own homes.</p>
<p>These people come in all shapes, sizes and preferences. About half of them want a standard kit home that they can customise (many more options than the standard housebuilder off plan sales). The other half want to completely design their home although even in this group about three quarters of the homes are based on pre-designed foundations and structure. Only about 15% overall go for a fully architect designed home.</p>
<div id="attachment_464" class="wp-caption alignleft" style="width: 310px"><a href="http://chrisbrown.regen.net/files/Almere-IBBA.jpg"><img class="size-medium wp-image-464 " src="http://chrisbrown.regen.net/files/Almere-IBBA-300x224.jpg" alt="" width="300" height="224" /></a><p class="wp-caption-text">I Build Almere Affordably Shared Ownership Homes</p></div>
<p>Once a plot has been reserved the purchaser will go to a ‘Market Day’ where various designers and contractors will compete to supply the customer’s home. And the customer will often employ an adviser and a site monitor to help them along the way.</p>
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<p>And this process applies to affordable homes too with people on low incomes (£16,000 &#8211; £29,000) being able to go through the same process on a shared ownership basis.</p>
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<p>And it’s worth mentioning that the mixed use neighbourhood centre was being delivered in the same way including the central market hall which was being designed for a group of market traders who would all rent  their own stall within a market hall that they jointly owned.</p>
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<div class="mceTemp">Interestingly, the key message that the Mayor of Almere, a former government minister, and all of his team, wanted us to get about this approach was that it delivered huge benefits in community cohesion. The largest party by number of seats in Almere is the far right party that recently brought down the Dutch government and about half the people moving into the neighbourhood were immigrants to the Netherlands so it was a hot issue in the city.  However, it was clear that individuals and groups that custom build their homes have a much greater stake in the neighbourhood. The NSBA statistics suggest that these people, on average, live in their homes five times longer than if they just buy an existing home.</div>
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<dt><a href="http://chrisbrown.regen.net/files/Almere-Mixed-Use.jpg"><img class=" wp-image-465" src="http://chrisbrown.regen.net/files/Almere-Mixed-Use-224x300.jpg" alt="" width="224" height="300" /></a></dt>
<dd>Model of Individual Mixed Use Plot Schemes in Neighbourhood Centre</dd>
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<p>This communal approach to property development was beautifully captured by the Community Land Trust Network Annual Conference this week. In particular the CLTs shortlisted for <a href="http://www.communitylandtrusts.org.uk/news-list/2012_CLT_Annual_Conference">the annual awards</a>were incredibly inspirational.</p>
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<dt><a href="http://chrisbrown.regen.net/files/Home-Baked.jpg"><img class="size-medium wp-image-466" src="http://chrisbrown.regen.net/files/Home-Baked-224x300.jpg" alt="" width="224" height="300" /></a></dt>
<dd>Home Baked CLT in Anfield, Liverpool</dd>
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<p>The first award went to Home Baked in Anfield which I was lucky enough to visit a couple of weeks ago and they were just one of the many groups that are delivering housing for local people and huge amounts of community cohesion, happiness and well-being around the country. Group custom build, whether affordable by CLTs or market by CLTs or other groups feels like an idea whose time has come.</p>
<p>I know I shouldn’t but I can’t resist mentioning that igloo picked up the award, as joint winners, for Exceptional Support to the CLT Sector. This may be the award I am most proud of and it may be the most satisfying because CLTs are an incredibly direct way to increase happiness and well-being in a community.</p>
<p>Custom Build and CLTs potentially represent disruptive innovation in the house building sector. Between the early 1990s and the mid 2000s, the market share of the top 11 firms doubled to around 45% of all dwelling sales. In contrast 80% of Austrian homes are Custom Build. The difference is primarily down to the behaviour of public sector land owners. If the public sector sells sites for hundreds of homes we will get volume house builders, if in individual plots, Custom Builders. Given the scale of public land disposal at present, a simple policy decision is all that is required to disrupt the market.</p>
<p>In practice, despite the clear well-being benefits, I think what we will see is a small portfolio of HCA and local authority sites being delivered in this way. While this is welcome it neither optimises the benefit nor satisfies the market and, more importantly, what would be best would be for small Custom Build sites to be made available throughout urban areas. All our neighbourhoods need a core of people committed to their communities and Custom Build is one way of doing this.</p>
<p>Local Authorities often seem to find it too difficult, or too much trouble, to bring the small infill sites they own to the market. In part this is because we tend to measure the financial costs and receipts rather than the social costs and benefits. If we knew, and could measure, the value of the latter, Custom Build and CLTs would be a no-brainer policy priority. And this innovation would disrupt our current volume house-builder dominated housing market forever.</p>
<p>The third connection in this story has been the work the UK Green Building Council has been doing on disruptive innovation in their sector. This has exposed large numbers of people in the industry to innovation techniques. Its conclusions are being launched this week so more about the details here next week I hope.</p>
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		<title>The New Politics of Regeneration and Planning?</title>
		<link>http://chrisbrown.regen.net/2012/05/08/the-new-politics-of-regeneration-and-planning/</link>
		<comments>http://chrisbrown.regen.net/2012/05/08/the-new-politics-of-regeneration-and-planning/#comments</comments>
		<pubDate>Tue, 08 May 2012 09:06:53 +0000</pubDate>
		<dc:creator>chrisbrown</dc:creator>
				<category><![CDATA[Uncategorized]]></category>

		<guid isPermaLink="false">http://wordpress.hbpl.co.uk/chrisbrown/?p=459</guid>
		<description><![CDATA[<p>I’m not a great fan of party politics, usually taking the view ‘Don’t vote it only encourages them’. Neither am I a great fan of elections (in which the low turnouts suggest I am not alone) because the Purdah period inevitable creates disruption in the smooth running of regeneration projects.</p>
<p><a href="http://chrisbrown.regen.net/2012/05/08/the-new-politics-of-regeneration-and-planning/" class="more-link">Read more &#187;</a></p>
]]></description>
			<content:encoded><![CDATA[<p>I’m not a great fan of party politics, usually taking the view ‘Don’t vote it only encourages them’. Neither am I a great fan of elections (in which the low turnouts suggest I am not alone) because the Purdah period inevitable creates disruption in the smooth running of regeneration projects.</p>
<p>But politics are important. It’s how priorities are decided and in the worlds of planning and regeneration priorities are everything.</p>
<p>I have always tried to avoid having public private partnerships where the public representatives are politicians because I believe that effective operation of vehicles is best when the directors are governed exclusively by the still relatively new and poorly understood <a href="http://corporate-responsibility.org/wp/wp-content/uploads/2009/09/directors_guidance_final.pdf">Companies Act directors’ responsibilities</a>. Politicians inevitably are under other pressures and it is both unfair and, in my experience, naïve, to expect them to ignore politics at the boardroom table.</p>
<p>I’m also a fan of strong government. Manchester City Council shows the benefits of having secure politicians who can take long term decisions without the threat of losing their seats or being undermined by internecine party strife. However this situation can generate complacency and, in politics, internal power struggles can break out at any time.</p>
<p>Glasgowhas been difficult politically over recent years and my initial feeling about the local election result (where Labour, somewhat unexpectedly, secured its position) is that the council has had a healthy kick in the rear. However there are still rivalries within the Labour party and it will be interesting to see how the SNP run Scottish Government behaves towards the city in coming months. That relationship has also been tinged with politics over the years.</p>
<p>A city that is often compared to Glasgowis Liverpool. I sit on the board of the <a href="http://www.chrysalisfund.co.uk/">Chrysalis Fund</a> with the newly elected mayor of Liverpool, Joe Anderson who, following the loss of most of the mayoral referenda, is likely to be one of a select band for a while. Joe seems to have the ability to work with politicians from different political backgrounds which seems to be a requirement for a successful mayor where central government will periodically have different politics. His early <a href="http://www.communities.gov.uk/statements/corporate/2084341">City Deal</a> was an example of this expertise.</p>
<p>The chat in thenorth westis mainly about how the city region is where the mayor is needed (as inLondon) and it will be interesting to see if the city regions, that are now operating much more cohesively, go down this route.</p>
<p>Leicesterjumped the gun last year in the current round of new mayors and elected as mayor Peter Soulsby for whom I have a lot of respect and he has certainly shaken things up in the city. It will be interesting to compare how Peter, Joe and Boris get on over the next few years because, although they are all mayors, they are operating in entirely different contexts (single city, borough in a city region and city region respectively) though in all three they have some huge regeneration issues to tackle.</p>
<p>On the subject of mayors, I take the view that it is all about the qualities of the individual. It is an extraordinarily hard job but one of its big advantages seems to be the ability to put in place a governance structure that can function better than the traditional chief executive/cabinet structure.</p>
<p>When you get a good mayor and good deputy mayors, the late Simon Milton inLondonsprings to mind, you can get extremely good outcomes.</p>
<p>But this is not an automatic outcome of having a mayor and while I respect Michael Heseltine’s advocacy of big city mayors I suspect that it is inevitable that some will not succeed. However the Government will be keen, despite the politics, to support the city mayors and I would expect to see there being rewards for those cities with mayors over the coming years.</p>
<p>Bristolis next on the list as the only city to vote to have a mayor in the current round of referenda and I will be fascinated to see who emerges from that contest in the autumn. As we saw inLondon, in is incredibly difficult to gain traction in these contests without a party machine behind you but I do think the independent mayor has a lot of potential advantages. It could be argued thatLondonhas really only had independent mayors and that both have been successful.</p>
<p>I’m not sure whether <a href="http://en.wikipedia.org/wiki/George_Ferguson_(architect)">George Ferguson</a> is going to stand as an independent or as a party backed mayoral candidate inBristol but from the point of view of planning and regeneration, inevitably one of the main areas of focus for a city mayor, he would be an extraordinarily excellent choice. I do think expertise is an advantage in a job and George would certainly bring that, together with a passion for the city and great empathy with its citizens.</p>
<p>Another politician with these skills is back on the scene today. Sir Albert Bore is back inBirmingham. Albert gets regeneration and it will be fascinating to see how he is able to respond to the huge challenges inBirminghamin the current fiscal and political climate.</p>
<p>So as we go back to work after the bank holiday, while politicians in hung councils are cutting their deals and while political groups are choosing their leaders and cabinet members, let’s remember the people in deprived communities for whom the choices of priorities and the competence of governance have real meaning and impact on their lives.</p>
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		<title>Planning System – Fit For Purpose?</title>
		<link>http://chrisbrown.regen.net/2012/04/30/planning-system-fit-for-purpose/</link>
		<comments>http://chrisbrown.regen.net/2012/04/30/planning-system-fit-for-purpose/#comments</comments>
		<pubDate>Mon, 30 Apr 2012 17:51:14 +0000</pubDate>
		<dc:creator>chrisbrown</dc:creator>
				<category><![CDATA[Uncategorized]]></category>

		<guid isPermaLink="false">http://wordpress.hbpl.co.uk/chrisbrown/?p=456</guid>
		<description><![CDATA[<p>I&#8217;m slowly coming the conclusion that the planning system is not fit for purpose any more.</p>
<p>This is not because it has accreted and atrophied over the decades (though it has) or because I disagree with any of the Government&#8217;s policy choices.</p>
<p><a href="http://chrisbrown.regen.net/2012/04/30/planning-system-fit-for-purpose/" class="more-link">Read more &#187;</a></p>
]]></description>
			<content:encoded><![CDATA[<p>I&#8217;m slowly coming the conclusion that the planning system is not fit for purpose any more.</p>
<p>This is not because it has accreted and atrophied over the decades (though it has) or because I disagree with any of the Government&#8217;s policy choices.</p>
<p>It is because the problems the system was designed to deal with, like separating homes from noxious industries, are not the problems of today. In some ways the emphasis on sustainability in the NPPF reflects this but is it a new use too far for an aging machine?</p>
<p>Many of the planners who have grown up with the current system and earn their livings from it will defend it vigorously, lauding its successes while perhaps accepting the need for gentle evolution.</p>
<p>But there comes a time when disruptive evolutionary change is need and it can happen surprisingly quickly, whether it be economic evolution like the death of Kodak or ecological evolution like the extinction of the dinosaurs.</p>
<p>As the economy has evolved, the problems we face have changed to include climate change, making creative industry competitive places (likeTechCity), delivering quality housing and places, public transport and digital communication, biodiversity, well-being, quality of life and community inequality and regeneration.</p>
<p>The problems many people want solving are how to get the details of the places they live in and use right &#8211; supporting the artisan local or social producer/retailer, creating outdoor places to stroll, lean, sit or lie around and chat, taming the car, making development well designed, making things grow in urban areas, making sure local people have affordable homes close to their families including commissioning them themselves as Custom Build or Community Land Trusts and so on.</p>
<p>The planning system, as practiced today, is pretty rubbish at these kinds of tasks.</p>
<p>Some of the old planning style problems still exist, like where to put noxious incinerators (or waste to energy plants as we now call them) or where to build infrastructure but it feels like the challenges of place governance have evolved a lot faster than the planning legislation designed to facilitate them.</p>
<p>Critics of the planning system have got a pretty bad press recently as the accusations about &#8216;enemies of enterprise&#8217; have been exposed as spurious. But I wouldn&#8217;t expect the suggestion that the system is scrapped and replaced with something else to be welcomed.</p>
<p>If nothing else, people will rightly point to the risks involved in radical change in this highly contested area.</p>
<p>It would be a start to have an open discussion about what is important today to people, the planet and the economy and how we might design a system to best achieve these objectives. As an example, Tom Bloxham’s ideas about a design led system deserve wider debate.</p>
<p>Although it may not seem like it at times, there is a pretty wide consensus that a social (or regulated) market economy, where evidence based policies seek to mitigate negative externalities, can give the least bad outcomes.</p>
<p>The bigger contest then is over the nature of regulation and generally comes down to how best to achieve a balance between private and public benefit.</p>
<p>And a large part of the problem is who gets to define the public benefit. The diversity of people&#8217;s needs and desires is so wide that consensus or dictatorial approaches don’t work, while purely market approaches generate collateral damage.</p>
<p>Democracy increasingly, in the UK and US in particular (fans of Borgen may see contrasts elsewhere), seems to lead to divided electorates. As a society we end up having to choose between just two options in the middle ground. Many want to find solutions that work for us as individuals rather than average solutions that don’t work for anyone.</p>
<p>Let&#8217;s take an example, local park design. There are a large number of differing preferences. Looking at flowers, skate boarding, barbecues, bird song, dog walking, sun bathing, listening to music, football, picnics&#8230;..you get the picture.</p>
<p>Parks tend to evolve slowly and change is often based on binary decision making. Does the majority prefer option A or option B. Public consultation of the ‘here is our plan – what do you think about it’ variety, as we have recently experienced in Bermondsey, doesn’t necessarily create a well used park.</p>
<p>It seems self evident that it would be better to find ways in which as many as possible of the uses people want to put parks to can be accommodated through the day and the year. Optimising the intensity and quality of use of the park seems to be the route to maximising the well-being of the community which is probably the outcome most people would seek.</p>
<p>The best new parks work like this but so many others don&#8217;t.</p>
<p>The cultures, governance and decision making processes that result in diverse outcomes, and mutual tolerance for these outcomes, probably have benefits for well being as well as for economic competitiveness.</p>
<p>But we tend towards an adversarial, binary and top down approach.</p>
<p>A different example might be the Green Belt. Too often the undeveloped countryside around urban areas is degraded by a combination of urban users and property speculators.</p>
<p>We should be able to achieve a much greater intensity and quality of use of these areas. Combining recreation, horticulture and agriculture and biodiversity is possible with good governance. But our current planning system just doesn&#8217;t provide the tools or the mechanisms. Or if it does, they aren&#8217;t being used.</p>
<p>I&#8217;ve heard examples this week of city administrations outside the UK creating four different visions for the city to encourage debate about what people want. Many of our cities don&#8217;t even have one vision.</p>
<p>If we did have visions for the neighbourhoods, towns and cities that we want to live in, and if we then tried to work out how to get from where we are today to where we want to be, I can guarantee that we wouldn’t invent our current planning system to get us there.</p>
<p>I&#8217;ve also been looking at some of the Dutch and Scandinavian new town and new urban district examples this week. New towns provide great learning opportunities. Generally they tell us that whatever era of masterplanning was fashionable at the time has proven to be arrogantly inappropriate, often within a decade or two.</p>
<p>There is a <a href="http://www.newtowninstitute.org/spip.php?article642">fascinating exhibition</a> just opened in <a href="http://www.travelintelligence.com/travel-writing/almere-last-exit-utopia">Almere</a>, Europe’s fastest growing new town, that illustrates the failure of wave after wave of arrogant masterplanners from Corbusier to Koolhaas. In the UK we have learnt our lessons the hard way on this (Cumbernauld or Skelmersdale anyone) and as we begin to contemplate the idea of local village communities welcoming in new towns under the Government’s latest garden city planning <a href="http://www.ft.com/cms/s/0/0a5df742-7510-11e1-90d1-00144feab49a.html">consultation</a> we would do well to consider these lessons.</p>
<p>As we move towards these garden city new towns, which have the potential <a href="http://conservativehome.blogs.com/thecolumnists/2012/03/jill-kirby-instead-of-improving-our-towns-and-cities-the-government-is-choosing-to-spoil-our-country.html">to split</a> the Conservative Party again on a planning issue, it may be time to think radically about what a workable system, to deliver the places people want, might look like.</p>
<p>The latest <a href="http://english.almere.nl/local_government/almereprinciples">Almere</a> experiment, <em><a href="http://www.guardian.co.uk/money/2011/nov/25/self-build-go-dutch">Homeruskwartier</a>,</em> is a form of neighbourhood <a href="http://blogs.hbr.org/cs/2011/02/co-creation.html">co-creation</a> where the professional urban designers lay down the infrastructure and set some simple rules and individuals or groups of custom builders get on and design their own homes within this context.</p>
<p>These are ideas that appeal to libertarians, the largest political party by number of seats in Almere is the far right Freedom Party that recently brought down the Dutch government, but do they create the kinds of places that are best for people, the planet and the economy? More on that in few weeks time.</p>
<p>What would a system for delivering the places people want look like? Who would make the choices and what would they be? What tools and processes would those people need?</p>
<p>The NPPF feels like a good holding pattern for now but it also feels like a resting place that gives us time to work on the radical transformative change we need.</p>
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		<title>Blog – Custom Building the Big Society</title>
		<link>http://chrisbrown.regen.net/2012/04/22/blog-custom-building-the-big-society/</link>
		<comments>http://chrisbrown.regen.net/2012/04/22/blog-custom-building-the-big-society/#comments</comments>
		<pubDate>Sun, 22 Apr 2012 14:02:43 +0000</pubDate>
		<dc:creator>chrisbrown</dc:creator>
				<category><![CDATA[Uncategorized]]></category>

		<guid isPermaLink="false">http://wordpress.hbpl.co.uk/chrisbrown/?p=452</guid>
		<description><![CDATA[<p>As the NewBuy debacle continues to <a href="http://www.telegraph.co.uk/finance/personalfinance/borrowing/mortgages/9215067/Mortgage-lenders-undermining-NewBuy-scheme-by-charging-high-rates-say-builders.html">embarrass</a> Government (and the HBF), Grant Shapps staged a publicity offensive at No. 10 to try and win back the Daily Mail readers after the Conservatory Tax debacle.</p>
<p><a href="http://chrisbrown.regen.net/2012/04/22/blog-custom-building-the-big-society/" class="more-link">Read more &#187;</a></p>
]]></description>
			<content:encoded><![CDATA[<p>As the NewBuy debacle continues to <a href="http://www.telegraph.co.uk/finance/personalfinance/borrowing/mortgages/9215067/Mortgage-lenders-undermining-NewBuy-scheme-by-charging-high-rates-say-builders.html">embarrass</a> Government (and the HBF), Grant Shapps staged a publicity offensive at No. 10 to try and win back the Daily Mail readers after the Conservatory Tax debacle.</p>
<p><span id="more-452"></span></p>
<p>Surrounded by a host of media stars (and other less glittering personalities) Grant launched……a <a href="http://www.selfbuildportal.org.uk/">website</a>.</p>
<p>But at least the website was set in the context of a <a href="http://www.communities.gov.uk/news/newsroom/21329641">reasonably joined up strategy</a> which combines specific provisions in the NPPF that require local authorities to plan for custom (or self) build, with a small amount of public money (£30m to be administered by HCA as the Custom Build Fund, and likely to be used primarily as bridging finance to help encourage mortgage lenders into the market, and encouragement to public sector land owners to make provision for Custom Build when disposing of land.</p>
<p>So it’s worth considering the extent to which these initiatives will be effective in delivering more custom build.</p>
<p>Starting with the NPPF, the key provision says ‘local planning authorities should plan for a mix of housing based on …. the needs of different groups in the community (such as, …. people wishing to build their own homes)’.</p>
<p>The sentiment is clear but one does wonder exactly how this will be delivered through local plans. Custom Build is neither a separate Use Class nor a separate tenure so it will be interesting to see how local authorities can use the planning system to ensure that custom build happens.</p>
<p>It would be nice to be able to describe the Custom Build Revolving Fund but alas the No.10 launch came rather too soon for the fund which is apparently not yet ready to go. There is increasing cynicism in the market about the effort and resources both Government and HCA are putting behind this part of the initiative. It was also revealed as part of the <a href="http://www.nasba.org.uk/images/pdf/nasba_sbwpipp_2012_lowres.pdf">progress report</a> on the implementation of the Self Build Action Plan that market expectations are for a substantial increase in mortgage lending to the Custom Build sector although it wasn’t clear whether this was despite the fund or predicated on it.</p>
<p>Public land disposal looks like a much more direct way to deliver Custom Build and HCA are piloting some disposals on a handful of sites as are a small number of local authorities. But so much of the wider system continues to discriminate against self build. The new HCA Delivery Partner Panel tender explicitly excludes small sites and the vast majority of public land disposals, by not requiring an element of Custom Build, effectively discriminate against it.</p>
<p>We are great fans of Custom Build at igloo and are promoting it on a number of sites around the country. We think that many home buyers are frustrated by the standard products of the large volume housebuilders and that the involvement of the owner occupier buyer in the design process produces better results in both home and place design. In particular we are strong supporters of urban community land trust developments, recently inEast Londonand Bermondsey, where strongly motivated groups of local people have got together to make affordable housing available in their communities.</p>
<p>But to achieve the benefits that group Custom Build in particular can deliver requires nothing short of a radical transformation in the UK house buying and house building culture and industry. In our study visits to other countries inEuropewhere this approach is common, indeed dominant, we can see the huge difference in industry structure between there and here.</p>
<p>And there are market factors that are give custom build a competitive disadvantage when compared with the volume house builder driven model.</p>
<p>Where large sites (on which most homes in theUKare built) are sold unserviced and undivided, for the maximum up front cash payment, it is impossible for group custom builders to buy. These sites are effectively only available to larger volume housebuilders whose capital base allows them to go through planning and provide the infrastructure before dealing parts of the sites between each other.</p>
<p>The housebuilders business model then depends (at least when land markets aren’t rising, which is how they actually make most of their money through the market cycle) on building a standard cost minimised product using volume discounts from their supply chain.</p>
<p>It’s not dissimilar from the car industry and you can argue that there are sufficient builders, sufficient product range and a large enough second hand market to cater for most tastes.</p>
<p>But that clearly isn’t the whole story. Not many people want to design and build their own car (or maybe they do but it clearly isn’t an easy proposition) but huge numbers want to design and build their own home. And still more want to have the opportunity to make their neighbourhood better. Those great urban innovators, Urban Splash, tried to unlock this particular door in their New Islington scheme in partnership with HCA and Manchester City Council but for a first experiment the timing was awful and the project fell over the cliff edge of the property market collapse.</p>
<p>One of the lessons of that experience is probably that the role of an enabling Custom Build organisation is critical. But the benefits of getting this approach right can be seen in places likeBorneoIslandin theEasternIslandsinAmsterdam.</p>
<p>Custom Build already produces housing volumes in the UKthat place it up with the biggest volume builders but it is <a href="http://www.nasba.org.uk/images/pdf/evidence_research.pdf">miles behind</a> the market shares in the leading European countries.</p>
<p>And the housebuilders may be prepared to make Custom Build available as a way of ensuring that they keep the politicians onside and prevent powerful Custom Build competitors from entering the land market.</p>
<p>But public sector land owners could have the greatest impact. They could sell land in ways that make it easier for Custom Build to purchase by marketing it first to group and individual Custom Builders and to Custom Build intermediaries and by selling it in smaller serviced plots with outline planning on Build Now Pay Later terms and by signposting sources of support for Custom Builders.</p>
<p>If the public sector chose to do this locally and to include Community Land Trusts they could transform the levels of community capital, particularly in urban areas. And by removing the housebuilders development profit from the equation they would probably achieve higher land values as well.</p>
<p>That does sound like a powerful way to Custom Build the Big Society.</p>
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		<title>NPPF Omnishambles?</title>
		<link>http://chrisbrown.regen.net/2012/04/18/nppf-omnishambles/</link>
		<comments>http://chrisbrown.regen.net/2012/04/18/nppf-omnishambles/#comments</comments>
		<pubDate>Wed, 18 Apr 2012 21:55:20 +0000</pubDate>
		<dc:creator>chrisbrown</dc:creator>
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		<guid isPermaLink="false">http://wordpress.hbpl.co.uk/chrisbrown/?p=445</guid>
		<description><![CDATA[<p>Government’s apparent inability to make its big political ideas workable on the ground is a source of huge frustration for politicians and citizens alike. So why is it so difficult? Or why do omnishambles occur?</p>
<p><a href="http://chrisbrown.regen.net/2012/04/18/nppf-omnishambles/" class="more-link">Read more &#187;</a></p>
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			<content:encoded><![CDATA[<p>Government’s apparent inability to make its big political ideas workable on the ground is a source of huge frustration for politicians and citizens alike. So why is it so difficult? Or why do omnishambles occur?</p>
<p><span id="more-445"></span></p>
<p>&nbsp;</p>
<p>In part it is about Government having too many conflicting objectives, each enthusiastically espoused by competing sections of the electorate, the party or the government machine.</p>
<p>These tensions inevitably create delivery compromise, confusion and conflict.</p>
<p>Compromises, confusions and conflicts are more obvious currently as there are both competing political views within the Conservative Party and between the coalition partners.</p>
<p>But success in most things usually derives from clear and simple ideas.</p>
<p>In the world of regeneration and planning we can see big ideas around Big Society, Small Business, Social Enterprise, Localism and Philanthropy competing with ideas about Austerity, Increasing Taxation, Reducing Spending and Growth.</p>
<p>A topical example of this is developing around the NPPF. While the immediate battle over the document itself is over, the battle to influence local plans has only just begun. The Instituteof Economic Affairs(a right wing think tank) fired the first salvo (or perhaps a very delayed shot from the earlier battle) as they released a <a href="http://www.iea.org.uk/sites/default/files/in-the-media/files/Abundance%20of%20Land%20Shortage%20of%20Housing.pdf">report</a> calling for more house building (yawn). Some may wonder about the wisdom of giving these one sided ‘reports’ the oxygen of publicity but there is a lovely irony in the one sided way this document attacks its opponents for being one sided.</p>
<p>Behind the scenes the environmental organisations are working hard to find ways to support local communities in producing their neighbourhood plans (for which Government support seems to be in disarray at the moment) and to local authorities to produce and update defensible local plans. This will be hard for local authorities currently starved of cash and it will be interesting to see how voters react to those authorities that get unpopular planning appeal decisions because of inadequate local plans.</p>
<p>There was a lovely <a href="http://andrewlainton.wordpress.com/2012/04/18/bermondsey-councillors-nppf-confusion-over-money-shop-application-a-case-study-for-all-councillors-planorak">example</a> of the political absurdity of the planning system in my local neighbourhood in Bermondsey recently. Both political parties (LibDem and Labour) joined forces to oppose a planning application for a pay day loans shop on the grounds that it was an inappropriate use in a deprived area and they cited the NPPF definition of sustainable development as backing their decision.</p>
<p>Any appeal of this refusal decision seems bound to succeed but given that the councillors took the decision on the basis of widespread local public support and a cross party consensus that pay day loans companies need regulating it feels like something is going wrong with government’s ability to regulate to deliver popular public good through the planning system.</p>
<p>An international contrast to dysfunctional policy delivery in the UK, in the field urban philanthropy, was highlighted during the row about tax relief caps on charitable donations this week as I was introduced to a Danish organisation called <a href="http://www.realdania.dk/english.aspx">Realdania</a>. They were formed from the charitable foundations of two large financial institutions and do amazing work in improving public realm and restoring historic buildings in Denmark. A bit like <a href="http://www.caissedesdepots.fr/en/en/home.html">CdC</a> inFrance it is one of those organisations you wish you had in theUK. Imagine what the reputation of the banks might be if they poured billions into making the country a better place. And imagine how much better policy delivery would be with a competent third sector deliverer.</p>
<p>And, in yet another example, Big Society was brought into focus by the reaction of Frank Field to the news that in someLondonboroughs nearly half of new social housing lettings are to nonUKborn nationals. Frank introduced a private members bill earlier this year which included what I think are best described as ‘deserving poor’ provisions for social housing allocation. The idea that that using social housing allocations to build community cohesion by adding criteria that favour local connections and good tenancy behaviours has good social returns on investment seems to have pretty widespread support across the political spectrum and seems to be a vote winner locally. However many local authorities seem to find it hard to adopt this approach.</p>
<p>And finally, although there are a myriad of other examples, the Green Deal policy has already been severely buffeted by the ridiculous but incredibly powerful Daily Mail Conservatory Tax attack, a full six months before its launch, reflecting the power of a small group of climate change deniers to destabilise cross party consensus policy.</p>
<p>There seems to be a gap in the market for someone to create a ‘do-tank’ that creates effective large scale delivery models for policies that are supported by a broad political consensus. Perhaps people can suggest other examples but beyond the Young Foundation and some of the specialists like new economics foundation I am struggling for examples.</p>
<p>Maybe the key to effective government is to pick a small number of simple but powerful policies with strong cross party consensus and to focus on creating delivery models that are generated by people with delivery experience who aren’t distracted by politics and media commentary.</p>
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		<title>Bored with the NPPF?</title>
		<link>http://chrisbrown.regen.net/2012/04/01/bored-with-the-nppf/</link>
		<comments>http://chrisbrown.regen.net/2012/04/01/bored-with-the-nppf/#comments</comments>
		<pubDate>Sun, 01 Apr 2012 20:02:57 +0000</pubDate>
		<dc:creator>chrisbrown</dc:creator>
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		<guid isPermaLink="false">http://wordpress.hbpl.co.uk/chrisbrown/index.php?p=439</guid>
		<description><![CDATA[<p>It’s quite possible that everyone is now bored with the infinite number of opinions and interpretative battles that multitudinous skim readers have been firing across the virtual ether.</p>
<p><span id="more-439"></span></p>
<p>The one clear conclusion seemed to be that many planning applications will be fought out against opposing interpretations of the NPPF at the various levels of debate from neighbourhood forum to local planning committee to appeal hearing and, in a small number of cases where the opponents are sufficiently well financed, in the courts.</p>
<p><a href="http://chrisbrown.regen.net/2012/04/01/bored-with-the-nppf/" class="more-link">Read more &#187;</a></p>
]]></description>
			<content:encoded><![CDATA[<p>It’s quite possible that everyone is now bored with the infinite number of opinions and interpretative battles that multitudinous skim readers have been firing across the virtual ether.</p>
<p><span id="more-439"></span></p>
<p>The one clear conclusion seemed to be that many planning applications will be fought out against opposing interpretations of the NPPF at the various levels of debate from neighbourhood forum to local planning committee to appeal hearing and, in a small number of cases where the opponents are sufficiently well financed, in the courts.</p>
<p>I rather love the Escher like (Pseuds’ corner here I come) definition (or is it Alice in Wonderland or Humpty Dumpty) of sustainable development being ‘The policies in paragraphs 18 to 219, taken as a whole..’. This helpfully excludes the references to Brundtland and the UK Sustainable Development Strategy definitions so we can presumably ignore them as simple spin. And of course it was particularly wonderful that an unchecked typo crept into the document and the reference to the UN Brundtland resolution actually became a reference to a declaration about troops in Cyprus (you couldn’t have made that one up!).</p>
<p>So there you go children (by which I primarily mean planning lawyers for whom Christmas has come early), argue that presumption out.</p>
<p>In a weekus horribilus for the Government where they were overwhelmed by Granny, Bedroom and Pasty Taxes, Donor Dinners, Petrol Panic, the Bradford Spring and NewBuy Nonsense (yes it turns out Government (and their trusted advisors the HBF) should have waited for the banks to be ready before they launched NewBuy because the discrimination against the local builders that build 55% of the UK’s homes is being magnified by the day as the banks are not yet able to let them into the scheme). Well never let it be said Government weren’t warned.</p>
<p>In a week when the headlines have focused on Government incompetence the NPPF almost looks like a remarkable triumph.</p>
<p>The supporters of more development welcomed it even before the minister stood up in the House to announce it (in a cynical piece of PR spin organisations like BPF got embargoed copies while MPs had to question Greg Clark based on guesswork and the environmental groups were left for an hour before they could get the document from the website and start reading it to be able to respond to media enquiries).</p>
<p>After some rapid skim reading the opponents of the draft cautiously welcomed the new (though presumably not final, given the errors) version and after a night of analysis they mainly concluded that there was nothing to be gained in continuing the battle and decided to claim victory and make peace with Government.</p>
<p>The consensus of the more considered analysis of experts was that while the final version of the NPPF was an improvement on the draft, it was both more developer friendly and more open to legal challenge that the previous planning system. The critical importance of local and neighbourhood plans was also highlighted.</p>
<p>Many concluded that it would take time before we could determine its impact and while this may sound like a cop out it seems likely to be true.</p>
<p>My particular interest is the impact on urban regeneration in England from the policies on brownfield, mixed use, communities, design, deprivation and well-being.</p>
<p>Let’s start with the good news. The section most people seem to think is the strongest is the section on design. As has been discussed here before, design is a key issue for the Conservative Party in the shires where well designed residential developments (particularly those that eschew modernism and reflect historic vernacular) are occasionally welcomed into villages and small towns. This is presumably where David Cameron’s new found enthusiasm for Garden Cities (by which he means small towns) comes from.</p>
<p>The Garden City proposals (or Ecotown Mark about 4 I think) are yet to hit us and it is more than slightly bizarre that the layout principles judged a hundred years ago as appropriate to replace Victorian slums, before the car became popular, and which gave us the 70 foot privacy distance beloved of urbanists (allegedly the distance a Victorian male would see the female nipple as blurred) are being slated for a come back. Urban design has moved on and we know more than we did then. For example we have invented antibiotics (the separation distance was thought to allow sunlight to kill germs) and we now know about climate change.</p>
<p>Clearly we could do much better than Ecotowns (as Gordon Brown so memorably put it – ‘and we will build the roads to get to them’!!). Sustainable urban neighbourhoods for example would be a start, and it must be a concern that the Garden City route will be used in a way that undermines regeneration, as many of the New Towns did.</p>
<p>The rest of the NPPF news is more mixed. There are a fair few mentions of communities which are variously described as inclusive and mixed and mixed and balanced which gives some clues as to what is desired but it will be fun, yawn, to listen to the lawyers debating the meanings of these words when it comes to affordable housing.</p>
<p>There is also encouragement for mixed use, the promotion of which is part of one of the 12 core planning principles.</p>
<p>The value of mixed use is explained as: ‘opportunities for meetings between members of the community who might not otherwise come into contact with each other, including through mixed-use developments, strong neighbourhood centres and active street frontages which bring together those who work, live and play in the vicinity’.</p>
<p>This is definitely one of the advantages of mixed use in certain circumstances but if it is a core planning principle that presumably means that mono use developments of all kinds can be consigned to history – goodbye mega retail mall and business park. If I could believe this I could be quite optimistic about the impact of the NPPF but my guess is that this is just one of the unexpected consequences of abbreviating and editing planning policy and no doubt the lawyers will run rings round it before we start seeing lots of housing by Westfield.</p>
<p>Another of the 12 core planning principles includes: ‘encourage the effective use of land by reusing land that has been previously developed (brownfield land), provided that it is not of high environmental value’.</p>
<p>The brownfield policy is set out as ‘Planning policies and decisions should encourage the effective use of land by re-using land that has been previously developed (brownfield land), provided that it is not of high environmental value. Local planning authorities may continue to consider the case for setting a locally appropriate target for the use of brownfield land.’</p>
<p>This is very much not a ‘brownfield first’ policy (even in the Green Belt where it is one of a number of exceptions to the ban on development). If it was there would be a sequential test approach where brownfield land is to be used before green fields. Local authorities can go there with their local plans but those without plans will not be able to pray available brownfield sites in their defence.</p>
<p>Oh and the definition of ‘brownfield’ specifically excludes gardens (echos of the suburban garden grabbing vote catcher) but given that the policy isn’t ‘brownfield first’ it should be possible for local authorities and neighbourhoods to have local and neighbourhood plans that, through sequential testing, produce a more sustainable urban form that works for walking, cycling and public transport without the need for cars.</p>
<p>Somewhat oddly, there is mention of deprivation in the plan making section where councils are encouraged to identify ‘locations of deprivation which may benefit from planned remedial action’. Bizarrely this is in the section on the business evidence base – presumably they aren’t referring to deprived businesses?</p>
<p>Well-being is also mentioned but not with the vigour one might expect of a Prime Minister committed to measuring this crucial outcome of public policy although it is included as part of the social pillar of sustainable development. Local planning authorities are encouraged to take account of any information about relevant barriers to improving health and well-being. Hardly earth shattering.</p>
<p>It just doesn’t seem terribly joined up with some of the big political issues for this Government like the response to the Riots. This week also saw the <a href="http://www.communities.gov.uk/news/corporate/2118077">announcement</a> about the initial take up of the funding targeted on some of the 120,000 families identified as ‘troubled’ by the Prime Minister. Step forward Norfolk as one of the first wave of recipients – not perhaps the most obvious area the regeneration world would have prioritised.</p>
<p>The troubled families response didn&#8217;t make the headlines but is a critical initiative, though potentially one that may also fail through rushed and inadequate implementation. The Riots panel suggested that rather than the Governments 120,000 families the number may be more like 500,000 as Adam Branson discusses<a href="http://regenandrenewal.regen.net/2012/03/trouble-defining-troubled/"> here.</a></p>
<p>All of this highlights the complexity of urban regeneration. Even the saint like Vince Cable, at the Centre for Cities Post Budget debate this week, focused on skills, connectivity and freeing up local government in his prescription for regeneration (were he lucky enough to be Secretary of State for Communities – cue smiles all round) and explicitly turned against physical regeneration despite the evidence that only an holistic approach to regeneration works.</p>
<p>The NPPF is a critical element in urban regeneration and I was interested to see that at one point #NPPF was top trending in the UK on Twitter. For those that don’t understand what that means don’t worry. Twitter is a bit like the old guy with the sandwich board predicting that the end of the world is nigh and shouting at passers by. For this purpose it means that there are lots of people with sandwich boards and they are all shouting at the moon about planning at the same time. What were the chances of that with thousands of pages to read?</p>
<p>I wonder though if this is a sign of things to come. Will the NPPF become a political battleground in the future? Will political parties propose competing visions for England in their manifestos and follow this up with specific redrafting proposals?</p>
<p>I note that the first reaction of those good people at Policy Exchange was that the Government will have to revisit the NPPF and I also saw that the Labour Party, in a really weak first reaction, are raising the potential that it might cause widespread delay and chaos in delivering growth.</p>
<p>Now if I am honest, what I had hoped for was a couple of competing visions of our Green and Pleasant land. Surely there is a difference between the ‘building over the Green Belt and anywhere else wealthy people can drive their gas guzzler to’ vision and say the ‘smart growth, compact urban neighbourhood’ vision promoted by people like Lord Rogers.</p>
<p>Perhaps the problem is that these competing visions do not fit comfortably with the still tribal nature of party politics. Good design is one area where there seems to be substantial consensus, perhaps because developers seem to find it so difficult to deliver consistently and perhaps because it is a bit like apple pie.</p>
<p>Now if we were to suggest competing visions of Poundbury against Cumbernauld we might get the voters interested in what we are talking about.</p>
<p>There has already been a fair bit of telly coverage along these lines and I wonder if the TV channels will feel able to commission a series on the big planning issues. Are Garden Cities the best model for new housing in the era of planet threatening climate change for example? Is our future about the car or the pedestrian, about the business park or the mixed use neighbourhood?</p>
<p>Perhaps while the planning consultants and lawyers are off enjoying their golden years the rest of us can debate what it is we want planning (and developers) to deliver for us and for our children.</p>
<p>Bored with the NPPF? We are now. Or are we?</p>
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		<title>Disrupting Property Markets – A Green Week</title>
		<link>http://chrisbrown.regen.net/2012/03/26/disrupting-property-markets-%e2%80%93-a-green-week/</link>
		<comments>http://chrisbrown.regen.net/2012/03/26/disrupting-property-markets-%e2%80%93-a-green-week/#comments</comments>
		<pubDate>Mon, 26 Mar 2012 21:00:53 +0000</pubDate>
		<dc:creator>chrisbrown</dc:creator>
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		<guid isPermaLink="false">http://wordpress.hbpl.co.uk/chrisbrown/index.php?p=432</guid>
		<description><![CDATA[<p>It’s been a Green Week this week and I feel that I have glimpsed the future, and for most existing property industry organisations the future looks pretty scary.<br />
<span id="more-432"></span>The UK Green Buildings Council is undertaking some action research into innovation that involves some of the UK’s biggest organisations involved in the built environment.</p>
<p><a href="http://chrisbrown.regen.net/2012/03/26/disrupting-property-markets-%e2%80%93-a-green-week/" class="more-link">Read more &#187;</a></p>
]]></description>
			<content:encoded><![CDATA[<p>It’s been a Green Week this week and I feel that I have glimpsed the future, and for most existing property industry organisations the future looks pretty scary.<br />
<span id="more-432"></span>The UK Green Buildings Council is undertaking some action research into innovation that involves some of the UK’s biggest organisations involved in the built environment.</p>
<p>The built environment industry in the UK has not had a great record at innovation and in particular at disruptive innovation that transforms markets. The comparison with the best innovators in Japan, China, Germany and Scandinavia is stark.</p>
<p>At a dinner for the CEOs of many of the leaders of the UK industry it was interesting to hear how the senior management of companies like Kodak had failed to identify the changing behaviour of their customers ending up with their rapid spiral into bankruptcy.</p>
<p>It was also encouraging to see the speed with which the firms and products that bankrupted Kodak, like Apple and Flickr, that developed the disruptive technologies, grew and prospered.</p>
<p>The spotlight fell on Marks and Spencer whose Plan A move towards sustainability has achieved substantial cost savings as well as creating substantially more sustainable big box format stores. But there was a view that these stores could well turn out to be an expensive legacy as online delivery, a substantial reduction in car usage and increased local food supply chains quickly leave them looking out-dated and out of place. One of the comments during the evening anticipated the end of Marks and Spencer stores.</p>
<p>The innovation experts in the room pointed out that disruptive technologies and business models are usually initially developed in small niche markets that are unattractive to the dominant incumbents.</p>
<p>Ecobuild this week was full of new ways of generating power – particularly solar and heat pumps – currently only a relatively minority sport in the UK (although renewable energy is passing 50% of output at times in some countries). As oil prices rise (higher on average this year than ever before) the idea that we will have major firms that make their money by generating and selling as much fossil fuel power as possible to consumers seems increasingly likely to become an extinct business model.</p>
<p>Similarly the idea that we will have buildings that leak energy from multitudinous orifices seems to be of the past and as we overcome the challenge of insulating, and therefore heating our buildings sustainably, so the spotlight will turn on to the carbon that is expended in building them and that is consumed in the electrical gadgetry inside them.</p>
<p>It will also fall on the extent to which we utilise the embodied carbon in the buildings (and therefore the buildings themselves) and also on to the carbon we use to get to and from the buildings. Business Parks and out of town retail on major road junctions will be a thing of the past unless the UK car fleet goes electric <strong>and</strong> we have a smart grid <strong>and</strong> our electricity generation is 100% renewable. Quite an investment gamble!</p>
<p>One of the big ideas that is gaining traction is the idea of collaborative consumption of buildings. We currently use buildings on average only about 30% of the time. But we have many examples from the rise of home working (as evidenced by Regus’s good results for virtual clients this week) to the familiar hotels and café bar/coffices, that show how we can keep buildings utilised at much higher rates (ie for longer periods of the day, week and year). While your lounge at home is empty your alternate lounge in the coffee bar is full and many coffee bars stay full from 7 in the morning until late into the night.</p>
<p>These kinds of ideas are now being explored by Adaptive Futures (Loughborough University) and particularly at the moment by their <a href="http://adaptablefutures.com/competition">student design competition</a>.</p>
<p>Similar ideas are also bubbling in the <a href="http://www.ukgbc.org/content/%E2%80%98industry-business-plan%E2%80%99">UKGBC innovation process</a> which is producing some examples of the type of disruptive innovation that will be needed to meet the challenge of climate change.</p>
<p>These collaborative consumption ideas are common place in other parts of our lives with all of us being familiar with the idea of car hire and increasingly with the idea of car clubs that are growing strongly throughout the country. This is another of those unattractive market niche examples as car clubs were originally targeted at urban professionals, a market niche that looked unattractive to the car manufacturers who were increasingly making money from 4x4s. Rachel Botsman, who co-wrote <a href="http://collaborativeconsumption.com/">the bible</a> on collaborative consumption with Roo Rogers, was a much appreciated speaker at Ecobuild.</p>
<p>On a less optimistic note there was widespread scepticism at Ecobuild about the likely success of the Green Deal. In part I suspect this is because Government has overhyped its prospects.</p>
<p>At its heart, Green Deal is simply a scheme to remove one of the barriers to retrofit, the need to finance the up front costs (despite the fact that they will pay back in energy savings for those who are not fuel poor). For the fuel poor, <a href="http://www.decc.gov.uk/assets/decc/11/funding-support/fuel-poverty/4663-fuel-poverty-final-report-summary.pdf">John Hills’ recent report</a> is an excellent exposition on the policies needed. Essentially he concludes that we must fund the eco-retrofit of all homes (and that ECO is far from sufficient funding to get the job done).</p>
<p>There remain many other barriers to eco-retrofit including the hassle factor of letting builders into your building, the costs of related work like decoration, the need to get many parties to agree in multi-occupied buildings and so on.</p>
<p>Some of these ideas flowed through my work in Haringey on the Carbon Commission and its link to regenerating Tottenham this week.</p>
<p>There are a couple of big ideas emerging here. The first is that the most effective way to maximise the take up of retrofit is through word of mouth recommendation from neighbours (ideally followed by a single retrofit contract on identical homes at the same time). Where community action like this can be combined with creating access for the unemployed to training and employment for the new jobs created, particularly in areas like Tottenham, it is not really surprising that there is enormous community enthusiasm.</p>
<p>The challenge will be to find ways to enable communities to best become expert and organised at doing this. This may require making meeting spaces available, financially and organisationally supporting community training and creating financing mechanisms.</p>
<p>If this works, the community will become the sales force for Green Deal (and ECO) and will take the revenue from the sales they generate, either as up front cash, a share of the ongoing payments or as improved energy efficiency.</p>
<p>The second big idea is that local authorities should become Green Deal providers. Although local authorities often do not have trusted brands locally, by becoming Green Deal Providers they can access Green Deal funding which can then be channelled through trusted local SME installers (and local job creators) to the buildings identified by community action.</p>
<p>It will be interesting to see if this model proves to be more successful than the private sector ‘double glazing salesman led’ model that seems to be the current preference of Government. If it does the retrofit market may be disrupted before it has started.</p>
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		<title>Regeneration Funding &#8211; The Only Game in Town?</title>
		<link>http://chrisbrown.regen.net/2012/03/19/regeneration-funding-the-only-game-in-town/</link>
		<comments>http://chrisbrown.regen.net/2012/03/19/regeneration-funding-the-only-game-in-town/#comments</comments>
		<pubDate>Mon, 19 Mar 2012 10:02:41 +0000</pubDate>
		<dc:creator>chrisbrown</dc:creator>
				<category><![CDATA[Uncategorized]]></category>

		<guid isPermaLink="false">http://wordpress.hbpl.co.uk/chrisbrown/index.php?p=427</guid>
		<description><![CDATA[<p>The launch of <a href="http://www.chrysalisfund.co.uk/">The Chrysalis Fund</a> in Liverpool City Region this week brings to seven (if my arithmetic is working) Joint European Support for Sustainable Investment in City Areas (JESSICA) funds operational in the UK with around £500m of funds (out of about £2.5 Bn worth of funds across the EU – don’t quote me on the exact numbers, I’m in blog mode). There are a couple more in the UK trying to get in under the wire (the money needs to be spent by the end of 2015) so the final total may be around 10.</p>
<p><a href="http://chrisbrown.regen.net/2012/03/19/regeneration-funding-the-only-game-in-town/" class="more-link">Read more &#187;</a></p>
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			<content:encoded><![CDATA[<p>The launch of <a href="http://www.chrysalisfund.co.uk/">The Chrysalis Fund</a> in Liverpool City Region this week brings to seven (if my arithmetic is working) Joint European Support for Sustainable Investment in City Areas (JESSICA) funds operational in the UK with around £500m of funds (out of about £2.5 Bn worth of funds across the EU – don’t quote me on the exact numbers, I’m in blog mode). There are a couple more in the UK trying to get in under the wire (the money needs to be spent by the end of 2015) so the final total may be around 10.</p>
<p><span id="more-427"></span></p>
<p>These JESSICA funds are what Brussels calls Financial Engineering Instruments and what we might call revolving investment funds. They make loans, and occasionally provide equity and guarantees, at competitive rates, for property and energy efficiency projects (sustainable urban development) that are viable and likely to pay back the loan with a bit of interest.</p>
<p>It’s been a long journey from the initial idea dreamt up in Brussels in the middle of the last boom, through almost complete disinterest (based on extreme lack of understanding) by UK Government to the drive of a few devolved administrations, regions and cities, and individual champions therein, that have had the vision to drive these funds through.</p>
<p>The funds have arrived at an interesting time.</p>
<p>On one level they started as an answer looking for a problem (and as I’m told Jessica derives from the Hebrew for foresight this seems appropriate). By the time they arrived they found the problem, and it was massive. The lending markets for property development in deprived areas had completely stopped working and these funds became the only game in town. They are competitive and flexible and as the banking markets continue to tighten these advantages get bigger and bigger.</p>
<p>But they can’t work miracles.</p>
<p>There are two fundamental challenges, which some in positions of power are still in almost complete denial about.</p>
<p>The first is that project eligibility in some places is very narrow because the European Regional Development Fund (ERDF) Operational Programmes were narrowly drawn without a real understanding of what would be needed to make JESSICA work. Similarly the original rules for financial engineering instruments and their interplay with various of the other EU rules made operations almost impossible. Some progress has been made on this though.</p>
<p>The second is that the property market is still very weak. Job creating development outside of London is often unviable as yields have risen and rents have fallen at the same time.</p>
<p>The public authorities are getting their heads around this and starting to use the available tools (funds for infrastructure like the Growing Places Fund, the Regional Growth Fund, public sector leases and guarantees, mainstream ERDF grant and so on) to get eligible projects to viability to allow them to be funded by developers and banks with the JESSICA funds filling the gap between the senior debt banks will lend and the equity developers can invest.</p>
<p>It will be interesting to see how much of the allocated money the funds manage to invest before the deadline but the great prize is that once the money has been invested and returned, the eligibility constraints fall away and a much wider range of regeneration projects can be funded.</p>
<p>And what does the longer term future look like? The Communities Select Committee has recently announced an <a href="http://www.parliament.uk/business/committees/committees-a-z/commons-select/communities-and-local-government-committee/news/erdf---tor">inquiry into ERDF</a> and no doubt they will be thinking about the next programme (2014 – 2020) which is currently wending its way through the EU machinery.</p>
<p>It is uncertain how much money will head towards the UK in the next programme as the problems of Eastern Europe are so much greater than ours (or at least, arithmetically their average GDP is lower – acute neighbourhood level deprivation seems invisible from the distance of Brussels &#8211; but it is clear that there will be a much greater focus on Financial Engineering Instruments than we have seen before. Cities are fighting to maintain a chunk of the available funds for urban regeneration and look likely to get something although energy efficiency and renewables and innovation and SME competitiveness are likely to be the major themes.</p>
<p>There has been a huge learning curve in the UK and around Europe from the JESSICA set up process but it would not be beyond the Commission to throw it all away. The challenge is how to learn the lessons of the last five years and to recast the EU rules to make setting up and operating effective revolving urban investment funds easy.</p>
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		<title>Procuring Prosperous Place-making</title>
		<link>http://chrisbrown.regen.net/2012/03/11/procuring-prosperous-place-making/</link>
		<comments>http://chrisbrown.regen.net/2012/03/11/procuring-prosperous-place-making/#comments</comments>
		<pubDate>Sun, 11 Mar 2012 19:44:01 +0000</pubDate>
		<dc:creator>chrisbrown</dc:creator>
				<category><![CDATA[Uncategorized]]></category>

		<guid isPermaLink="false">http://wordpress.hbpl.co.uk/chrisbrown/index.php?p=422</guid>
		<description><![CDATA[<p>The P word (Procurement) has entered regeneration parlance over the last three decades and created a new industry, similar to the health and safety industry, with a risk averse culture, a huge ability to say NO and virtually no capacity to innovate.</p>
<p><a href="http://chrisbrown.regen.net/2012/03/11/procuring-prosperous-place-making/" class="more-link">Read more &#187;</a></p>
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			<content:encoded><![CDATA[<p>The P word (Procurement) has entered regeneration parlance over the last three decades and created a new industry, similar to the health and safety industry, with a risk averse culture, a huge ability to say NO and virtually no capacity to innovate.</p>
<p><span id="more-422"></span></p>
<p>But cracks may finally be starting to appear in this edifice.</p>
<p>Last week saw the final Lords stage for the Public Services (Social Value) Bill that moves local authorities from having the power to take economic, social and environmental well-being of their communities into account when letting public contracts to being required to take these factors into account in procuring public services.</p>
<p>This is also a fundamental step in implementing the predator/producer or responsible capitalism approach (terminology dependent on your political positioning) to public procurement markets.</p>
<p>Public procurement is very significant in private markets and the standards required in public procurement often become standard practice in private sector procurement and businesses that are successful in public procurement can create a competitive advantage in other markets – outsourcing being the most obvious recent example.</p>
<p>The new Act may also drive a change in culture from the one created by the Public Contracts Regulations 2006 – The UK’s version of the requirements of European Council Directive <a title="Go to item of legislation" href="http://www.legislation.gov.uk/european/directive/1989/0665">89/665/<acronym>EEC</acronym></a> (currently in the <a href="http://www.cabinetoffice.gov.uk/resource-library/procurement-policy-note-modernising-public-procurement-rules">process of change</a>)- where contract bidding pre-qualification often started with the need to pass some numeric threshold (amount of professional indemnity insurance or number of staff say) rather than a quality threshold. The Government <a href="http://www.cabinetoffice.gov.uk/resource-library/procurement-policy-note-0112-use-pre-qualification-questionnaires">changed this</a> to an extent earlier this year.</p>
<p>Ironically 2006 was also when the <a href="http://www.defra.gov.uk/publications/files/pb11710-procuring-the-future-060607.pdf">Sustainable Procurement Task Force</a> (SPTF) reported. In the foreword to that report its chairman, Sir Neville Simms, said ‘imagine a government that is committed to sustainable development, that wants to create a strong, healthy and just society, here and overseas, that endeavours to live within environmental limits and wants to move towards a more sustainable economy. If that government could harness the purchasing power of [its] business, imagine what an impact it could have.’ Well yes, just imagine….</p>
<p>In design procurement, the Regulations led, financial box ticking approach has tended to mean that large architecture firms, who have long since lost any design flair possessed by their original partners (I could name names but just cast your eye down the AJ100 list (based on size not quality), secure much of the public sector work. As a result many public buildings have not achieved high design quality during this period.</p>
<p>Schools have been something of an exception to this as procurement has valued design quality and private sector PFI providers have employed multiple high quality architects in their bids (although there have been fall outs and tears and reversion to lowest cost, lowest quality, on occasion). Still the appearance of schools on Stirling Prize shortlists together with the odd winner (emphasis on the word odd) has shown that this approach can be successful. This trend was brought to a juddering halt following the last general election as the ‘cost of everything, value of nothing’ brigade gained control of the asylum.</p>
<p>In the place-making world we have long since moved on, in most places, from the local authority estates team who would put a city council ‘for sale’ board up and wait for offers. We have for some time in the world of developer procurement (or sale of publicly owned development land depending on your point of view) seen the use of evaluation matrices that take into account non financial issues and give them a score which is balanced with the financial bid.</p>
<p>In an infamous example a few years ago, two different Regional Development Agencies put two similar inner urban, brownfield, canal side sites on the market in two different core cities at the same time. One had an evaluation matrix that was 50% money and 50% social, design and sustainability and in the other it was 98% money and 2% design.</p>
<p>Needless to say, the second of these procurements got the horrendous scheme it deserved (which luckily didn’t go ahead as it was downed by the property crash).</p>
<p>The Public Services (Social Value) Act is not the last word in this move down the path to better procurement and it has taken a long time to get even this far since the SPTF said ‘Sustainable procurement – in short using procurement to support wider social, economic and environmental objectives, in ways that offer real long-term benefits, is how the public sector should be spending taxpayers money. Anything less means that today’s taxpayer and the future citizen are both being short-changed.’</p>
<p>The policy landscape is littered with abandoned good intentions in relation to these aspirations as the procurement industry has outlived political enthusiasm and reverted to type again and again. The simple message, that procurement is about maximising value, not minimising cost, keeps getting lost.</p>
<p>Even now, Government has deliberately removed procurements of works from the scope proposed by the Bill’s sponsor, Tory MP Chris White, although in the debate the minister emphasised that the Government supported the principles in relation to all procurement.</p>
<p>The minister specifically drew attention to the <a href="http://www.communities.gov.uk/publications/localgovernment/bestvaluestatguidance">Best Value Guidance</a> issued to local authorities by Eric Pickles at the end of last year. This guidance says ‘authorities should consider overall value, including economic, environmental and social value’ when considering contracts.</p>
<p>The political thrust of the current approach is pretty narrow and primarily about seeking to promote the interests of social enterprises and small business rather than to capture wider concepts of social return on investment. There are many gaps in the Government approach that mean that many Government agencies and Government policies (like Big Society and Localism more widely or community land trusts for example) are not specifically covered.</p>
<p>There are a variety of other changes that could be usefully be made on the journey towards responsible capitalism.</p>
<p>One of the potential changes would be to the culture of the public procurement industry. In the same way that Daniel Moylan, the Conservative councillor in Kensington and Chelsea, showed great courage in driving through a hugely important and innovative change in highway design (Kensington High Street) the same leadership will be required to resist the naysayers in the procurement industry.</p>
<p>In London at the moment the procurement of repairs and maintenance of public housing looks likely to be undertaken on a pan London basis. This could easily spell the end for the smaller, more locally based firms who give so much to their local communities including the recruitment and training of local workers from deprived communities and the support of local community organisations. A very sophisticated approach to procurement (unlike, for example, the approach to procuring the Work Programme) will be required to maximise the social, economic and environmental value of this procurement and many are questioning whether the political consensus exists to achieve this.</p>
<p>In many places current practice seems to be to only have faith in the financial element of bids, to minimise the proportion of scoring of non financial value and for the process of evaluation of the non financial aspects to be massaged to secure the ‘desired’ result or to be undertaken by unqualified staff.</p>
<p>There is lots of helpful (if obtuse) old school guidance around including from the former Office of Government Commerce on <a href="http://webarchive.nationalarchives.gov.uk/20110822131357/http:/www.ogc.gov.uk/documents/PPN_1210_Public_Procurement_Rules_Development_Agreements_and_s106_Planning_Agreements_Updated_and_Additional_Guidance_.pdf">development agreements</a>, the <a href="http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:31997Y0710(01):EN:HTML">EU Land Sale Directive</a>, <a href="http://www.homesandcommunities.co.uk/dpp">HCA Delivery Partner Panel</a> and the <a href="http://www.communities.gov.uk/publications/planningandbuilding/circularlocalgovernment">General Disposal Consent</a> that shows numerous ways in which developers can be procured simply and how non financial considerations can be taken into account but the procurement industry tends to add multiple layers of obfuscation and poor practice that produces bad results.</p>
<p>There have been some small signs this week of hope that new people with energy and commitment are going to enter this field.</p>
<p>Bioregional is promoting its One Planet Open Source approach which is finding supporters amongst local authorities who are seeking to use it in a variety of ways including in the procurement of developers for public land.</p>
<p>Similarly the new head of Design Council CABE has announced that they will be looking to be able to give procurement advice which will no doubt cover both design and developer procurement.</p>
<p>And finally the Royal Institute of British Architects will shortly be publishing a report that deals with the abject state of British procurement and proposes routes forward towards a better approach.</p>
<p>Back in 2006 the SPTF did not cover the procurement of developers for public land because it didn’t show up as one of the big areas of public spend (in place-making the public sector receive cash and the private sector spends it). In 2012 the Public Services (Social Value) Act does not cover works procurement or land disposal.</p>
<p>This leaves a nice gap to be filled by an entrepreneurial organisation. A guide to best practice developer procurement to optimise financial, social, economic and environmental outcomes from place-making that supports local political leadership and is successful in transforming procurement industry culture would hit the spot nicely.</p>
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		<title>Planning and the Major House Builder ‘Benefit Junkies’</title>
		<link>http://chrisbrown.regen.net/2012/02/28/planning-and-the-major-house-builder-%e2%80%98benefit-junkies%e2%80%99/</link>
		<comments>http://chrisbrown.regen.net/2012/02/28/planning-and-the-major-house-builder-%e2%80%98benefit-junkies%e2%80%99/#comments</comments>
		<pubDate>Tue, 28 Feb 2012 08:35:57 +0000</pubDate>
		<dc:creator>chrisbrown</dc:creator>
				<category><![CDATA[Uncategorized]]></category>

		<guid isPermaLink="false">http://wordpress.hbpl.co.uk/chrisbrown/index.php?p=418</guid>
		<description><![CDATA[<p>The planning systems in the UK don’t make development happen. Plans do not deliver infrastructure, or serviced sites or affordable housing subsidy (to name just a few fundamental flaws in the system). Basically plans do little more than curb the worst negative impacts of the market on the planet and society (still a really valuable contribution).</p>
<p><a href="http://chrisbrown.regen.net/2012/02/28/planning-and-the-major-house-builder-%e2%80%98benefit-junkies%e2%80%99/" class="more-link">Read more &#187;</a></p>
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			<content:encoded><![CDATA[<p>The planning systems in the UK don’t make development happen. Plans do not deliver infrastructure, or serviced sites or affordable housing subsidy (to name just a few fundamental flaws in the system). Basically plans do little more than curb the worst negative impacts of the market on the planet and society (still a really valuable contribution).</p>
<p><span id="more-418"></span></p>
<p>In current market circumstances where there is a fundamental market failure in the financial markets, planning is almost completely emasculated.</p>
<p>In this context, if we wanted to boost house building for example, in order to deliver growth (and homes), what would we do?</p>
<p>Despite some Government rhetoric the answer has little to do with planning.</p>
<p>Government, in particular Grant Shapps, recognises this and the big push at the moment is to underwrite mortgages in an effort to get banks and building societies lending again in greater numbers with deposits less than an average of 20%. The new, Government underwritten scheme, due to launch next month, has been branded NewBuy. It’s there already on a major housebuilder website near you.</p>
<p>So what will be the impact of NewBuy on the housing market?</p>
<p>NewBuy is likely to increase the attractiveness of new build homes (it is not available on second hand) as it will enable purchasers without large deposits to buy. But these purchasers live somewhere at the moment, in rented accommodation, in smaller homes, with parents or sharing.</p>
<p>Those who own their existing home will have to sell to someone who will need a large deposit and these chains will inevitably slow the impact of NewBuy. Some forecasters are suggesting that NewBuy will only be used on around 15% of new home purchases (currently running at about 100,000 pa).</p>
<p>We have sites where 50% of purchasers are currently cash buyers (without mortgages) but even so 15% appears low as there doesn’t appear to be much incentive not to take the NewBuy option if it is available (it is not available on properties over £500,000) other perhaps than to go for the previous (rationed) scheme (FirstBuy – where the purchaser has a 5% deposit but only borrows 75% of the value with Government and the builder providing a loan for the balance).</p>
<p>Those moving from rented will make homes available for others but it is possible that NewBuy may put a dent in the current resurgence of Buy to Let if the recent shift away from owner occupation is temporarily reversed. NewBuy should increase the proportion of owner occupation in new build developments (which in the boom, in apartment buildings, was averaging less than 50% in many places).</p>
<p>Those currently living with families who take up NewBuy will probably just be skipping the rental step and this will further diminish the demand for Buy to Let rentals.</p>
<p>If, as Capital Economics suggest, NewBuy simply uses up a fixed pot of available mortgage capital then its impact will be primarily market distorting although it may have a positive short term impact on house building numbers and therefore on growth which is probably Government’s main objective. The outcome will depend in large part on the view the FSA takes on the capital banks will be required to put aside for this lending.</p>
<p>The economics of this was one of the issues raised in a recent report on quoted housebuilders from Collins Stewart Hawkpoint (CSH) who initiated their coverage of the house building sector with a fascinating <a href="http://dcms.collinsstewarthawkpoint.com/researchnotes/15d09a167715489eb3d54f75aae0f968.pdf">analysis</a>.</p>
<p>One great quote from the CSH report on the subject of NewBuy and government shared equity schemes is ‘It could be argued that these serial quick fixes have made major housebuilders over-reliant on state aid. Among our industry sources are smaller private builders. A director of one complained that his company and others are largely frozen out of the main schemes and complained that the aid packages are turning some of the majors into what he described as “benefit junkies”.’</p>
<p>The NewBuy local builder discrimination controversy jumped to another level this week when it became clear that the scheme managers, JLT, were refusing (in England) to make application forms available to small builders.</p>
<p>Government has passed the contact details of the small builders that have asked it for information to the HBF and asked HBF to manage the communications with them. One person close to the situation commented that this is a bit like asking the fox to look after the chickens! HBF’s latest <a href="http://www.hbf.co.uk/fileadmin/documents/briefings/HBF_Member_Briefing_NewBuy_21.02.12.pdf">communication</a> is much less detailed than the information being made available directly to the smaller local builders in Scotland.</p>
<p>With a prospective launch date of 12<sup>th</sup> March and with currently only the top 20 or so builders able to apply to join the scheme it does look like the Government is giving the large house builders a valuable opportunity to mop up the market demand while the smaller local builder is discriminated against. This after, as CSH suggests, the last Government baled some of them out at the height of the recession.</p>
<p>Small, local builders are a surprisingly large group. There appear to be about 18,000 of them and they produce more than half of the homes built in the UK so it does seem counter productive to freeze them out of the market and potentially threaten them with bankruptcy as they see their cash flow disappear as purchasers rationally turn to the big builders offering the 95% mortgages underwritten by the Government.</p>
<p>As might be imagined, they are not happy as illustrated by a couple of quotes from members of the Local Developers Forum: who described the scheme as ‘fundamentally unfair against the previously outlined principles of the scheme being open to small residential developers’ and ‘it seems extremely unfair that smaller housebuilders are left to try and catch up with the process at the end while the bigger ones get a head start’.</p>
<p>CSH raised a number of big question marks over the large quoted housebuilders and raised some interesting issues for planners.</p>
<p>They identified the black hole in house builders’ accounts created by the current lack of a ‘mark to market’ requirement on housebuilders land banks (which probably also applies to their equity share loans) that has been discussed here previously and that results in flattered balance sheets. This was one of the factors underlying the bearish CSH attitude to house builders’ shares.</p>
<p>On the planning front their bombshell view is that there is no housing shortage. This view is based on a careful analysis of the DCLG supply figures which are heavily dependent on an assumption of falling household size. This is assumed to be a driver but CSH suggest that it is an outcome from building more houses and making mortgage finance readily available. They also point out that household size in the UK is at the EU average and the suggestion is that it could just as easily start to increase due to the mortgage shortage (indeed there is some evidence that this is already happening).</p>
<p>CSH suggest that house builders deliberately peddle the housing shortage line to help ramp up the political pressure to get land with planning permission (they have certainly achieved that under successive governments) and, perhaps more importantly, to convince investors of the underlying investment story in the housebuilding industry.</p>
<p>Interestingly CSH advocate short land banks from an investment perspective and point out that the shortest land banks (with planning permission) of the builders they looked at are 3.6 and 3.7 years. The average is 5.3 years.</p>
<p>This seems to chime both with the National Trust and CPRE arguments on the NPPF and with local authority five year local plan housing land allocations.</p>
<p>Although CSH don’t cover it in depth, there is a similar issue with affordable housing waiting lists. Subsidised housing is outside the market and therefore does not adjust to effective demand as quickly as market housing. It is also in almost infinite demand (for the economists – I know this isn’t theoretically correct but for practical purposes bear with me) because almost everyone would prefer to pay much less for their home if they could.</p>
<p>If you have children and want or need a bigger subsidised home you put your name on the waiting list. The vast majority of people on waiting lists are not homeless. There are also large numbers of under occupied subsidised homes. Something that would help is for people whose kids have left home to move to somewhere smaller and release homes for people having kids. It is also probably true in most places that the impact of Right to Buy has resulted in a real shortage of larger sized subsidised homes but this is a much smaller scale of problem (though still acute) than adding up waiting lists would suggest.</p>
<p>CSH also identified the entry into the market of contractors like Bouygues and Skanska. This was something encouraged by the HCA in their setting up of the Delivery Partner Panels although the original idea that contractors would build for sale to housing associations and to Build to Rent Private Rented Sector funds hasn’t yet really been tested. The original idea, that the big housebuilders’ balance sheets were constrained and that by building in this way on public land (with contractor margins of say 3% compared with 20% for developers) larger numbers of lower cost homes could be built, still seems sound.</p>
<p>CSH also noted that commercial real estate firms were increasingly involving themselves in residential and this trend seems to be continuing although at lower levels because these developers primarily have competitive advantage on large scale apartment buildings in urban areas where the volume builders’ box building supply chain scale economics are less pronounced.</p>
<p>CSH didn’t really touch on the reduction in competition from the debt funded small urban developers. This, now zombie, group crashed and burned spectacularly in 2008/9 when HBoS melted down and their return seems unlikely in the short term (CSH are still worried about problems from the eurozone). However if the eurozone problems recede then as mortgage availability improves so, presumably, will debt funded competition.</p>
<p>So planning may not have the answers to achieving growth through increasing housing supply but Government intervention in the markets also looks to be problematic.</p>
<p>It’s going to be an ‘interesting’ few months, for the ‘benefit junkie’ large house builders, for their smaller, local competitors, for the economy and for the planning system.</p>
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