Memorandum by Devon County Council (AH
36)
SUMMARY
Introduction/Current Housing Situation in Devon
— The issue of affordable housing remains
of concern to the County Council. Through partnership working
and use of Council Tax funding from second homes, Devon is working
to address needs. Data setting out the severity of the issue is
contained in Appendix 1. The impact of high house prices is compounded
by lower than average earnings. In migration will sustain housing
demand for the future and the popularity of the County for retirement
and second homes further exacerbates the problem.
The Need for an Integrated Strategic Approach
— Devon supports a housing and planning
framework that takes account of both the needs of the housing
market and sustainability objectives—with a greater emphasis
on understanding the nature of interventions required that housing
market assessment suggests and more clarity regarding the use
of market indicators alongside sustainable development objectives.
— Greater emphasis and guidance is
required on the complementary role of housing and planning strategies
at all levels.
— Clarity of purpose around the role
of housing need assessment, local targeted housing need assessment
and other more locally based survey work needs to be reflected
in guidance and good practice if duplication of effort is to be
avoided.
— Guidance needs to be sensitive to
more localised market scenarios and reflect the cross boundary
relationships that often exist between neighbouring authorities.
Current proposals are too simplistic—and do not adequately
address all forms of land supply [such as windfall sites].
— Timely provision of infrastructure
is another facet of sustainable development—private developers
cannot fund all requirements especially where strategic proposals
are implemented.
— Opportunities to capture land value
through s106 mechanisms is greater in urban areas, placing a greater
reliance on public subsidy in more rural areas. It is to such
sites that subsidy should be steered.
Locally Integrated Approaches
— The County Council supports an integrated
approach, as evidenced by community approaches to regeneration
and housing delivery [see Appendix 2 for case studies].
— A more formal recognition in policy
of the role played by community and village plans in bringing
forward housing proposals would be welcomed.
— Greater certainty concerning the
availability of public subsidy for rural housing, and fast tracking
of planning appeals involving affordable housing would help.
Monitoring of Housing Supply & Release of
Land
— National guidance should establish
common methodology and frameworks/definitions for monitoring to
allow for comparison between regional and local areas.
National Policy and its Impacts
— Although an area of high housing
demand, the strategic spatial response in the south west needs
to be more attuned to the dispersed settlement pattern than national
policy promotes.
— Housing market assessment methodology
needs to take account of remote rural areas with no obvious urban
focus.
— There is a need for more research
to understand the financial and fiscal measures that might impact
on the market and to "rural proof" decisions across
ministries that impact on rural housing.
INTRODUCTION
This evidence is submitted by Devon County Council.
The Council has been concerned for a number of years about the
housing situation in the County and has been actively pursuing
initiatives in partnership with housing authorities and other
organisations to improve the consistency of housing policy, and
the effectiveness of delivery. The County Council is an active
member of both the Devon Strategic Housing Group and the Rural
Housing Partnership, and contributes financially to three Devon-wide
housing posts: the Affordable Housing Co-ordinator, the Devon
Homelessness Strategy Officer; and the Rural Housing Enabler.
Devon County Council has made available up to £3.9 million
of Council Tax/second homes money to assist delivery and co-ordination
of affordable housing [2004-05]. For the period 2005-06 money
raised from Council Tax on second homes will continue to be made
available to the housing sector. Around half the sum is being
returned to Local Authorities to assist their housing programmes,
while the remainder will be directed to housing priorities identified
through the Local Area Agreement and LPSA2.
The evidence below is divided into several sections.
1. The current housing situation in Devon.
2. The need for an integrated approach to
housing solutions.
3. Monitoring housing supply and the release
of land.
4. National policy and co-ordination.
Appendix 1: Data
Appendix 2: Case Studies
1. THE CURRENT
HOUSING SITUATION
IN DEVON
[SEE APPENDIX
1]
1.1 Devon is one of the most sparsely populated
Counties in England, with few urban areas of any significant size
and a population which is largely resident in smaller market towns
and village communities. Of the 422 parishes 97% have a population
of less than 10,000 and 74% have a population of less than 1,000.
The largest urban area is the city of Exeter [population 111,100].
The Unitary Authorities of Torbay and Plymouth [populations 130,000
and 241,000 respectively] also exert a considerable influence
over rural Devon, particularly in terms of their job markets,
but their size and scale is still small by regional and national
standards.
1.2 The affordability of housing is an issue
across the whole County, although the severity of the situation
varies. House prices have risen dramatically since 1999 but it
is the combination of this with lower than average earnings that
creates the pattern of affordability. Recent work for the Joseph
Rowntree Foundation89[89]
shows that of the 37 authorities nationally where the average
house prices to incomes of younger working households exceeds
5.5:1, 16 were in the South West. The list includes the Devon
Districts of South Hams, Teignbridge, West Devon, North Devon
and the Unitary Authority of Torbay. The introductory remarks
to the report say:
". . . it is important not to lose sight
of the profound implications that the lack of affordable housing
to buy, as well as to rent, will have for rural communities, because,
even if it were possible to meet the needs of those in the `social
housing' market, there would still be a very significant shortfall
of affordable homes. Those people in the `intermediate' market
. . . would normally look to the open market to meet their housing
needs. If there is no such `intermediate' housing available and
they are effectively forced to leave the area to find suitable
housing, then rural communities are likely to become more socially
and economically polarised, and, consequently, less sustainable
. . ."
1.3 The situation in rural areas is also
made more acute by the general lack of smaller, cheaper houses
in the overall housing stock. Anecdotally there is evidence of
first time buyers, especially in the South Hams area reportedly
looking to the relatively cheaper housing in Plymouth as a means
of securing a foothold on the housing ladder. The pressure on
the housing market is reflected in numbers of households which
are on the housing register, and the numbers of homelessness acceptances.
1.4 Demographic and housing forecasts for
Devon indicate a sustained demand for housing. Population growth
is driven by in-migration. Longer term migration forecasts prepared
for the Regional Assembly suggest that in the period 2001-26 the
population [of Devon, Torbay and Plymouth] is expected to grow
by 9.2%, with household growth rates—driven by falling household
size and changing lifestyle—rising by 22.2%. The popularity
of the County as a retirement and holiday destination places additional
demands on the housing market. At the time of the 2001 census
over a third of East Devon's population was over 60; in South
Hams 11% of household spaces were a second home, illustrating
the attractiveness of coast and countryside.
1.5 To help meet housing demand and to support
districts in their planning and housing authority roles, the Devon
Structure Plan has been reviewed to 2016. [90]This
sets out housing supply figures for Local Plans and Local Development
Frameworks reflecting the policies and proposals of Regional Planning
Guidance. [91]The
policies of the Structure Plan promote a sustainable approach
to development, with an emphasis on the role of the principal
urban areas and the creation of self sufficient, viable market
towns and rural communities. Proposals require development plans
to deliver around 4,370 dwellings a year, including two new communities
to help address the housing needs of the Exeter and Plymouth sub
regions.
1.6 Progress in preparing Local Plans and
Local Development Frameworks has varied across Devon, but all
districts have now begun work on rolling forward their plans and
proposals to 2016. Annual housing completions have followed a
cyclical pattern fluctuating around RPG10 levels of provision.
Over the period 1995-2003 around 95% of RPG10 provision was achieved.
Completion rates are currently close to regional requirements.
2. THE NEED
FOR AN
INTEGRATED STRATEGIC
APPROACH
2.1 The County Council welcomed the Government's
proposals to merge Regional Planning and Housing Bodies. The preparation
of Regional Spatial Strategy and Regional Housing Strategy needs
to be aligned and complementary, drawing on the same evidence
base to support proposals and policies. In addition, the role
that housing plays in economic development should be reflected
in Regional Economic Strategies. A clear "audit trail"
of linkages between housing and planning strategies is required
down to the local level with more effort made to ensure Local
Authority Housing Strategies and Local Development Frameworks
are developed in an integrated fashion.
2.2 A plan led "whole market"
approach to housing delivery is supported, with clear links between
homes [numbers, types, mix], jobs, facilities, services and infrastructure.
This is in line with the Government's objective of creating sustainable
communities where people actively choose to live, and lies at
the heart of both urban and rural policy initiatives.
2.3 The Barker Review was a welcome overview
of the housing market from an economic perspective. The role of
the planning system has traditionally been to ensure development
is directed to, or controlled at, locations so that a range of
sustainability objectives can be met. This points to a more considered
role for the planning system in reconciling competing objectives
in the interest of the community as a whole, and positive intervention
to secure affordable housing for those unable to compete on the
open market. The use of market information to signal the release
of land does not have regard to the wider issues of "balanced"
development—in particular the desire to locate housing close
to employment and areas of employment potential, in locations
where opportunities for sustainable transport can be maximised.
At its most extreme the release of land in response to demand
could result in consolidation of existing consumer preferences,
with adverse impact on communities and the environment in both
high and low demand areas. "Planning for Sustainable Communities"
recognises that the market on its own is not able to capture the
externalities of development, but is unclear as to the balance
that should be drawn between responding to the market and meeting
social and environmental objectives. There is a distinction between
addressing housing demand and meeting need for housing.
2.4 Housing market area assessments are
being developed in Devon, based on housing market area profiles
identified for the Regional Housing Body by DTZ Pieda. [92]The
role of these assessments and their use, is as yet not fully developed,
with final guidance awaited. There is a need for guidance on housing
related work to be complementary—with scope for different
tiers of assessment to "nest" within each other, and
for different local authorities to reflect a possible range of
market scenarios that mirrors their local circumstances. The emphasis
in the draft guidance on the Local Development Framework—and
the focus on land release in response to market scenarios at the
district level, does not allow for situations where sub markets
of both high and low demand may co-exist within one administrative
boundary, or where for example, high demand areas adjacent to
a district require the release of land in another. Where such
situations exist, joint Local Development Documents should be
promoted. Adequate forward planning and availability of readily
available land is supported, but more guidance on the role of
windfall sites in land management and land supply is also required.
2.5 An integrated approach to planning and
housing demands that development and associated infrastructure
proceeds hand in hand. The current practice of developer obligations
secured through s106 arrangements leads to competing demands for
infrastructure contributions. There are real conflicts between
securing infrastructure investment and delivering affordable housing
in new development—and this does have potential economic
implications where the delivery of strategic proposals is concerned
[Devon's new communities for example]. Affordable housing has
become the greatest draw on resources—leaving less for schools,
roads, public transport etc. and the investment that is required
to make communities "work". A decision by Government,
of the means it wishes to pursue to capture planning gain would
assist.
2.6 The availability of public subsidy for
housing is particularly important in a rural County such as Devon.
The opportunity to capture land value through s106 mechanisms
is greater in the larger urban areas where affordable housing
can often be delivered without the need for public subsidy. In
the market towns and rural areas the scale of development is lower,
sites are smaller and the possibility of delivering appreciable
levels of affordable housing is more dependant on public subsidy.
It is to sites such as this that public subsidy should be steered.
2.7 In summary:
— Devon supports a housing and planning
framework that takes account of both the needs of the housing
market and sustainability objectives—with a greater emphasis
on understanding the nature of interventions required that housing
market assessment suggests and more clarity regarding the use
of market indicators alongside sustainable development objectives.
— Greater emphasis and guidance is
required on the complementary role of housing and planning strategies
at all levels.
— Clarity of purpose around the role
of housing need assessment, local targeted housing need assessment
and other more locally based survey work needs to be reflected
in guidance and good practice if duplication of effort is to be
avoided.
— Guidance needs to be sensitive to
more localised market scenarios and reflect the cross boundary
relationships that often exist between neighbouring authorities.
Current proposals are too simplistic—and do not adequately
address all forms of land supply [such as windfall sites].
— Timely provision of infrastructure
is another facet of sustainable development—private developers
cannot fund all requirements especially where strategic proposals
are implemented.
— Opportunities to capture land value
through s106 mechanisms is greater in urban areas, placing a greater
reliance on public subsidy in more rural areas. It is to such
sites that subsidy should be steered.
3. LOCALLY INTEGRATED
APPROACHES
3.1 The reform of the planning system has
given the Community Strategy a role in articulating a vision for
the local authority—a significant step given the spatial
emphasis to the new look development plan. The Devon Community
Strategy[93]
has three headline challenges: Not enough homes at affordable
prices; making sure all our children and young people get the
best start in life; and, climate change. The Devon Rural Strategy[94]
contains an objective "enabling communities to plan and lead
their own development to meet and integrate local physical, social
and spiritual needs for a healthy and safe living environment"
as well as the more specific objective of "developing measures
aimed at providing an adequate and diverse stock of affordable
homes."
3.2 Work to address these issues is being
taken forward in a number of ways. Measures to improve the supply
of housing are embedded in Devon's Strategic Plan and are reflected
as a cross cutting theme in the Local Area Agreement. A priority
set out in Devon's LPSA2 agreement aims to reduce youth homelessness
by 50%. Settlements have been prioritised for regeneration and
community capacity building work, and the County Council plays
a role in assisting local people to develop community and village
plans. Ideas are being taken forward to capture the value of community
assets of all types [land, labour, capital] through the establishment
of community land trusts and community asset management. Extracts
from the County Councils Regeneration Role and Action Plan[95]
illustrating this approach are set out in Appendix 2. Regeneration
in this context is seen as a process—an important element
of which is the consensus gained through active participation
in finding local solutions to local problems. Where there has
been this type of approach, and it can be validated, considerable
weight should be given to the proposals coming forward and more
formal recognition [in Local Development Frameworks and development
control decisions] given to the plans prepared.
3.3 At the local level, success usually
depends on speedy decisions by the relevant players and continuity
of funding to realise longer term objectives. In the context of
community development funding packages are usually dependant on
partnership contributions; where the planning system delays implementation
of a proposal, such funding commitment is difficult to sustain.
Similarly, delayed planning consent can mean Housing Corporation
funding is lost. Delays in decision making are not the fault of
Local Authorities alone. Fast tracking affordable housing proposals
through the appeal and "call in" procedures would help.
3.4 In summary:
— The County Council supports an integrated
approach, as evidenced by community approaches to regeneration
and housing delivery.
— A more formal recognition in policy
of the role played by community and village plans in bringing
forward housing proposals would be welcomed.
— Greater certainty concerning the
availability of public subsidy for rural housing, and fast tracking
of planning appeals involving affordable housing would help.
4. MONITORING
OF HOUSING
SUPPLY AND
RELEASE OF
LAND
4.1 The key to a successful evidence base
for developing housing policy and proposals lies in robust monitoring
systems, consistently and coherently applied to underpin strategy
and delivery at all levels in the system. An agreed national methodology
for collecting and collating data is required, to a common timetable
that correlates as far as possible with major reviews of Regional
Spatial Strategy. The current work to define core output indicators
for the monitoring of Local Development Frameworks should be extended
to the housing field, to enable comparability of information interregionally,
and between market areas. The establishment of a monitoring base
will assist in decision making and help to distinguish between
longer term and short term cyclical market conditions.
4.2 Similar concerns surround the comparability
and aggregation of studies at the regional and local level. Studies
such as housing market assessment, land availability studies would
benefit from methodology that includes clear definitions and outputs
that have some commonality.
4.3 In summary:
— National guidance should establish
common methodology and frameworks/definitions for monitoring to
allow for comparison between regional and local areas.
5. NATIONAL POLICY
AND ITS
IMPACTS
5.1 The situation in Devon, where the housing
market is strong, places it in a similar position to the south
east in terms of housing affordability and housing demand. However,
as highlighted in section 1, the nature of the area is very different,
with land use reflecting the historic importance of agriculture,
resulting in the dispersed development pattern where services
and facilities are largely centred on market and coastal towns.
5.2 The opportunities for meeting housing
demand are therefore different to the situation in the growth
areas of the south east, where a close network of towns means
a concentration of housing close to urban facilities and transport
is easier to achieve. National policy preferences for urban concentration
underplay the realities of life in rural counties where the need
for affordable housing is high, yet the application of national
policy through Regional Spatial Strategy restricts greenfield
supply. Many of the rural households requiring affordable housing
are already living and working in the countryside and are essential
to the social and economic fabric of their communities. The emerging
Regional Spatial Strategy for the South West, [96]in
response to consultation, is proposing a development strategy
that allows for greater sensitivity in dealing with development
across the region, in response to sub regional requirements. The
Assembly's concern about affordable housing supply is reflected
in a resolution taken at its meeting on 21 October 2005 supporting
the inclusion of proposals in Regional Spatial Strategy that could
push the percentage of affordable housing on development sites
to 60% where appropriate. Debate is continuing regarding the correct
balance of development in the period to 2026 between urban and
rural locations, with the County Council supportive of a development
distribution that will permit some development of a suitable scale
in key settlements in rural areas, against a longer term trajectory
that seeks to move the proportion of new development in favour
of urban locations.
5.3 The mapping of housing market areas
and their housing issues, on to this spatial pattern leads to
some concerns. The definition of housing market areas, largely
based on travel to work patterns, draws on the functional relationships
between larger urban areas and their surrounding hinterlands.
In Devon, the northern and north western part of the County is
characterised by a more polycentric pattern of development, with
housing market profiling suggesting the area is a loose collection
of more localised sub markets. This characteristic is shared with
neighbouring North Cornwall and is, no doubt, a function of remote
rurality in locations without a dominant urban area. Demand for
market housing across these areas is strong [Torridge, the most
rural of Devon's districts, had the largest percentage population
increase—13.2%—in Devon between the 1991 and 2001],
pointing to a need to make sure that development in these very
rural areas is of the right type. Housing market assessment methodology,
and guidance relating to land supply, needs to offer guidance
for these types of locations. In rural areas, the definition of
lower site thresholds, above which affordable housing will be
sought, may not always be helpful. A preferable test would be
the viability of a site to deliver affordable housing, regardless
of size.
5.4 The planning system alone cannot re-balance
the housing market, which is driven by the investment decisions
of individuals. Further research is required to understand the
possible financial and fiscal mechanisms that might impact positively
on land supply and to review the impact of decisions across different
sectors of government on the housing situation. The example of
SIPP proposals and its potential impact on home ownership is a
case in point.
5.5 In summary:
— Although an area of high housing
demand, the strategic spatial response in the south west needs
to be more attuned to the dispersed settlement pattern than national
policy promotes.
— Housing market assessment methodology
needs to take account of remote rural areas with no obvious urban
focus.
— There is a need for more research
to understand the financial and fiscal measures that might impact
on the market and to "rural proof" decisions across
ministries that impact on rural housing.
89 Affordability and the Intermediate Housing Market:
Local measures for all local authority areas in Great Britain-Steve
Wilcox for the Joseph Rowntree Foundation 2005. Back
90
Devon to 2016: Devon Structure Plan Authorities [Devon County
Council, Torbay Council, Plymouth City Council, Dartmoor National
Park Authority], adopted October 2004. Back
91
Regional Planning Guidance for the South West [RPG10] September
2001. Back
92
Analysis of sub regional Housing Markets in the South West: DTZ
Pieda Consulting for the SW Regional Housing Body, September 2004. Back
93
A Community Strategy for Devon: Devon Strategic Partnership 2004. Back
94
Devon Rural Strategy: Devon Strategic Partnership, July 2003. Back
95
Regeneration Role and Action Plan for Devon County Council: Devon
County Council, December 2004. Back
96
See www.southwest-ra.gov.uk for the latest draft-available as
Regional Assembly meeting papers for 21 October. Back
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