Select Committee on Transport, Local Government and the Regions Memoranda

Memorandum by Places for People Group (PGP 30)



  The Places for People Group is a major residential property owner and developer. Within the Group are Housing Associations providing affordable housing for general and specific needs, companies that provide homes for market rent and outright sale and companies specialising in providing employment and training opportunities. The Group owns and/or manages about 53,000 properties for rent and shared ownership in over 200 Local Authority areas in England, Scotland and Wales and has a substantial development programme. We are a major customer of the planning process. We have submitted a response to the Planning Green Paper to the DTLR.


  The whole purpose of the Group is to provide sustainable places for people to live. This includes ensuring access to all the services and facilities, including jobs, that they need, not just providing housing. The Group's composition has been developed so that all of the requirements of regeneration and development of sustainable communities can be provided. We are also involved in "Masterplanning" exercises for major regeneration proposals where solutions will be delivered by a variety of parties.


  We agree with the Government's analysis that the current planning system is largely failing to deliver. Quality of service differs widely between authorities. Some are good, others are not. The planning system is generally not trusted by the public, and high profile cases recently re-enforce the view that decisions are not always made in the best interest of the local community. In particular, community consultation is not effective either in the forward planning process, where it is very difficult to galvanise opinion on strategic matters, or in development control, where the vast majority of public involvement is to object to development, rather than play a positive role in the process.


  We generally support the Government's proposals for change. Specific issues are noted below.

  4.1.  Reformed Local Planning Framework. The proposals should work better than the current system, but detailed guidance must be issued relating to periods for review, timetables for production etc, to ensure that the plans remain "live" documents as far as is possible. The position of authorities during the period of change also needs to be clarified—plans on the current framework will need updating to avoid them becoming hopelessly irrelevant.

  4.2.  The Role of Regional Planning Bodies. The degree of effective democratic control; over these bodies may be queried, but there certainly is a need for strategic planning on a Regional and Sub-Regional basis.

  4.3.  The Procedures for major development projects. (note—we comment on general development projects as described in paragraphs 5.39-5.42, not major national infrastructure projects). The proposal for pre-application consultation to replace outline consents on significant development schemes is very positive. Working up a proposal in partnership with the Authority, to a clearly agreed brief and timetable would be of benefit. The agreement of detailed proposals for community consultation would need to be timetabled to avoid excessive delay. The role of Masterplanning in these cases can be very beneficial. We are the "preferred partners" in the Masterplanning exercise currently starting at Walker Riverside in Newcastle and the approach there is a very positive one. Masterplanning enables considered consultation and the use of techniques such as "Planning for Real" that facilitate positive engagement by members of the community. Particular skills are needed for Masterplanning and the trust of the local community and developers is vital. We contend that such exercises are more likely to be fruitful if led by parties out with the Local Authority. Bodies such as major RSLs have both the development and community consultation skills (in-house or with others) needed and can be seen as separate from the Local Authority and developers, so can establish a position of neutrality early in the process. We understand the need to balance the different pressures in the process, and, most significantly, we are used to being interested in the sustainability of the outcome in the longer term.

  4.4  Changes to Planning Obligations. The intention to improve the transparency of the process is welcomed. The Tariff system seems to be the best or the options outlined. Local flexibility must be given, but the policies of each LA must be clearly set out so that developers and the public have confidence in the system. Some benchmarking on the way flexibility is used might be useful. Accounting for the use of the obligation "income" is vital. The emphasis on provision of affordable housing as a first choice where demand is high is welcome—but realistic demand analysis is needed. Where affordable housing is provided, authorities should have the ablity to specify the tenure of the housing to be provided (rent, shared ownership or sale) and to specify in high demand areas that it should be managed by a regulated landlord to ensure it stays "affordable"—first sales at initial discounts do little to assist the lower paid when they get sold on in a rising open market.

  We strongly support the concept of mixed tenure communities and so would support strong guidance that affordable housing is to be provided "on site" wherever feasible. In higher demand areas, it is the ability to access sites that compromises ability to deliver affordable housing, so a "cash" obligation might not be beneficial. Where RSLs are used to deliver an affordable housing element, they should be involved in the process from an early stage—too often the "affordable element" is decided late in the day, and the recipient RSL has no influence on location on the site, built form or environs. All of these can have a significant impact on sustainability. We do NOT generally support the idea floated in paragraph 4.24 that whole sites might be reserved for affordable housing. This might be appropriate for small sites in a few high demand areas where affordable housing is very scarce and the wider neighbourhood of mixed character will result, but our approach is that for sites of any significance, a mixture of tenures on the site is more sustainable.

  4.5  Compulsory Purchase Orders. The proposals are generally helpful. CPOs for planning purposes will be needed to assist area regeneration. The use of a "loss" payment over market value will assist the process, but the extra cost should not be borne by the subsequent development proposals if it will exceed the site value.

  4.6  Effects of changes. There is much detail yet to be resolved, but generally we believe the changes have the potential to deliver more certainty and faster decisions. The decisions should also be better ones if the detailed implementation is correct. The potential is there for better public consultation, but winning the trust of the public will not be an easy process. In particular, the proposals for involvement in major infrastructure decisions will need to be sensitively managed.

  4.7  Planning's contribution to the urban renaissance. In general, the planning process has been a brake on development and regeneration of many urban areas. Under-resourcing and ineffective systems have meant that effort has had to be concentrated in development control, which is totally reactive, rather than in active forward planning, partnership building and focused regeneration activity. If the proposed changes can deliver a speedier and more effective development control system and a more responsive and flexible forward planning process, planning could play a positive role in the much-needed urban renaissance. But it will only be able to achieve this if it is properly resourced and officers and members engage with communities. The statutory role of planning in determining applications and the advocacy and community capacity building roles may conflict with each other. The catalyst and promoter of regeneration and renaissance may need to be a third party, as has proved fruitful in the Masterplanning exercises described above.

David Cowans

Group Chief Executive

David Shaw

Gp Director, Procurement and Development

Bill Taylor

Strategy and Support Manager

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