Memorandum by Bedfordshire Councils Planning
Consortium (PGS 32)
1. THE FACTORS
THAT SHOULD
BE TAKEN
INTO ACCOUNT
IN DETERMINING
THE RATE
OF THE
SUPPLEMENT AND
THE LEVEL
AT WHICH
IT SHOULD
BE SET
We agree that there should be a tax on the profits
of the uplift in land values and that it should be fair and transparent
as there are often differences between councils as regards the
amounts of planning gain that different councils get. Councils
are often struggling with resources and the support and back up
of expertise so that a clear and transparent tax can be applied.
This will make it much easier for developers to understand the
situation and process planning applications and for the local
communities to keep their character and to benefit from the new
development.
We believe that obtaining the maximum revenue
from development should not come at the expense of sustainable
development.
The tax should be used as a tool to encourage
sustainable growth within the framework of other government policy.
It should be used to promote development in lines with PPS1 paragraph
13 section 1. "Development Plans should ensure that Sustainable
Development is pursued in an integrated fashion, in line with
the principles set out in the UK Strategy" and the UK Strategy
for Sustainable Development, Securing the Future" March 2005.
This will require the tax to be applied within a framework of
other clearly defined requirements such as energy efficiency to
the "Ecohomes Very Good Standard", accessibility by
public transport, green infrastructure and social infrastructure.
This means that National Planning guidance and Regional Planning
guidance should include standards on energy efficiency in homes,
and accessibility by public transport and green infrastructure.
When there is a clear framework through the planning system, then
the Planning Gain supplement can easily follow and support it.
The use of brownfield before greenfield should definitely be encouraged
by the tax as suggested in Box 1.1. There is a clear example in
the village of Cranfield, where a greenfield site has been built
on before a brownfield site, despite local opposition. There should
also be encouragement through the tax to build houses close to
facilities and to jobs in order to reduce the need to travel as
laid out in PPG13.
2. HOW THE
SUPPLEMENT SHOULD
REFLECT SUBSEQUENT
USES SUCH
AS SOCIAL
HOUSING
There is a serious concern about affordable
housing overall but especially in rural areas. We are very concerned
that box 5.4 says that affordable housing should be covered by
the remaining 106 agreement after the planning gain supplement
has been taken. At present affordable housing uses up most of
the planning gain from the present 106 agreement, so it would
be impossible to fund affordable housing from 106 agreements after
the Planning Gain Supplement was taken.
It was agreed by developers, councils and environmental
organisations at the Examination in Public for the MKSM SRS in
2004 that it would be impossible for developers to pay for affordable
housing and the other required infrastructure. There is considerable
need for an increase in bus-based access to new estates and to
and from villages, there is a need for more doctors, dentists,
hospitals, green infrastructure and social infrastructure. There
is a problem with producing the money to pay for all of this even
with the Planning Gain Supplement. Milton Keynes has a very successful
record of getting money from developers and is indeed quoted in
the consultation, however they have experienced a serious shortfall
in their funding for infrastructure and the East of England Regional
Assembly suspended their support of the East of England Plan as
they did not believe that there would be enough money for infrastructure.
We are also concerned that Lord Rooker's previous assurances to
the East of England Assembly that "no infrastructure meant
no development" has now been "refined" by Baroness
Andrews' paraphrased reply to EERA (Regional Planning Panel report
6 February 2006—EERA Meeting with Baroness Andrews, Growth
Areas Minister—16 January 2006) to read "the Government
recognised the difficulties to be overcome in delivering higher
rates of growth and was working hard to ensure that there would,
in the future, be a range of mechanisms, including the new planning
gain supplement to overcome these known difficulties" There
is a serious shortage of funding and though Planning Gain Supplement
can help, it does not solve the shortfall in funding.
We believe that the provision of affordable
housing should not be linked to the building of large-scale developments.
This is particularly important in rural areas where young people
want to live in the villages that they grew up in. The character
of the village would be destroyed if a large-scale development
was built, but the building of affordable housing for local people
and supporting local employment and access to jobs by other means
than cars could revitalise rural communities. In "Sustainable
Communities, Homes for All" January 2005 it says" one
of the definitions of "Sustainable communities is "Thriving
with a flourishing and diverse local economy" This is where
money from the Planning Gain supplement could be used to support
and encourage a rural economy and village life. However, the PGS
cannot cover the needed rural housing. Homes For All also states
that "The Housing Corporation is funding 4,000 homes in rural
areas by 2006" paragraph 3.36.
It is crucial if the social capital of villages
is to be supported that there is funding for affordable homes
direct from the Housing Corporation, for the people who have grown
up in the village. This funding for Affordable houses should not
be linked to money from development.
We also believe that affordable housing in towns
should not be linked to development and should be funded separately.
If this is the case then Planning Gain Supplement can be used
to enhance the whole local area by providing vital infrastructure
so that local people can see benefits to their community from
the new growth, and also be used on a more national scale. We
believe that affordable housing should be funded by the Housing
Corporation not by the Planning Gain Supplement and by section
106 agreements. This will practically mean that there will then
be enough money from PGS and section 106 agreements to provide
the hard and soft infrastructure to support decent sustainable
communities.
There are serious issues about affordable housing
on a national scale. There are concerns that although the Government
has doubled investment in social housing that the stock of social
rented accommodation is still falling. We note that in "Sustainable
Communities, Homes for All" published January 2005 it says
in paragraph 2.11 " More new social homes are now being built,
but sales of local authority and housing association properties
mean that the total stock of social housing is still falling"
and in Paragraph 1.22 "But Right to Buy does not work for
everybody and it is expensive for the taxpayer, since 1980 we
have lost 1.7 million council homes and 100,000 housing association
homes." There is a serious need still for a step change in
the provision of social rented accommodation in all areas and
PGS is not enough to solve it.
There are problems in the North of the country
in the provision of affordable housing as the attitude of developers
is there is such a low market that they are lucky to have any
developers and therefore the smallest amount of affordable housing.
Planning gain supplement will only be a creditable
tax if it can help fund infrastructure for local communities.
Affordable housing should be placed where it is needed and should
be planned by the councils and should not be dependent on the
developer.
3. HOW THE
REVENUE FROM
THE SUPPLEMENT
SHOULD BE
DISTRIBUTED AND
APPROPRIATE USES
Box 1.3 states that PGS revenue would be dedicated
to local communities. However, there are questions about the size
of the local authority. Would the PGS go to the regional authority
or would it go to the local planning authority such as Mid or
South Bedfordshire District Council, or to a county council. There
is a serious need to increase and protect local infrastructure
and it is important that the money is seen as coming back to the
local community. There will be a need for new schools, learning
and skills colleges, hospitals, green infrastructure, and good
public transport to increase accessibility and to support the
economy. It is important that town centres are supported. This
will need the money to be used at a local level. Strategic infrastructure
is often used to mean roads and there are fears that Planning
Gain supplement will be used for this rather than promoting a
safe efficient means of transport for all. We support the views
of Kate Barker that 10% of all planning gain supplement should
be spent on green infrastructure. However this is a minimum that
is needed to protect and create green spaces.
We strongly support most of the Planning gain
supplement being used for local need. However, there is a potential
that the PGS taken in the South could be used to support development
in the North as a form of taxation to make the North more attractive.
4. WHETHER AND
IF SO
HOW THE
PLANNING GAIN
SUPPLEMENT SHOULD
BE USED
TO ENCOURAGE
DEVELOPMENT OF
BROWNFIELD SITE
We believe that in all cases that brownfield
land should be built on before greenfield. In this way the centres
of towns will be preserved and it will prevent situations like
the Homefarm development of around 400 homes in Cranfield, where
a greenfield development was chosen over a Brownfield development,
against the Inspector's recommendations.
5. THE POTENTIAL
IMPACT OF
THE SUPPLEMENT
ON THE
S106 ARRANGEMENTS
NEGOTIATED THROUGH
THE PLANNING
SYSTEM
The section 106 agreements will only produce
limited funds and this could mean poorly designed housing. It
is crucial that building standards are not a voluntary code, otherwise
councils will be forced to choose between energy efficiency and
therefore the affordability of the houses as regards living expenses
and maybe environmental quality and biodiversity. Although there
is need for flexibility for different areas and characters, it
should be made easy for councils to insist on eco-homes and get
environmental standards in the design overall along the lines
of the TCPA document "Biodiversity by Design". The Environment
Agency in the East of England are stressing that there has to
be an increase of 25% of water efficiency otherwise there are
serious questions about water provision. Yet at present this is
left to councils and developers to enforce. For the remaining
section 106 agreements to be successful, there have to be clear
targets on energy and water efficiency and on green space and
biodiversity otherwise some important factors that are needed
for Sustainable Communities could be sacrificed due to lack of
funding.
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