Abolition of Regional Spatial Strategies: a planning vacuum? - Communities and Local Government Committee Contents


Examination of Witnesses (Questions 218-239)

Q218 Chair: Good afternoon. Thank you very much for coming and sending in written evidence to us so far. For the sake of our records, could you begin by identifying yourselves and the organisations you represent?

Kay Boycott: I am Kay Boycott from Shelter.

Cameron Watt: I am Cameron Watt from the National Housing Federation.

Steve Hinsley: I am Steve Hinsley from Tetlow King, planning consultants.

Chair: Thank you very much indeed. We may at some stage have a vote, in which case we will have to suspend the Committee and leave you here. We return in due course. We will try to get back as soon as we can. We will be no longer than 15 minutes.

Sitting suspended for a Division in the House.

  On resuming

Q219 Chair: It was a reasonably appropriate point to have the break anyway; we were about to start the questions. The evidence you have submitted to us raises fairly fundamental concerns that you have that, if nothing is done to change it, the new arrangements could lead to a very substantial reduction in the number of new homes being built, particularly in the south of England. Is that a fair resumé of the position as you see it?

Cameron Watt: Yes. I think that the abrupt abolition of the regional spatial strategies without the new planning system being in its place, particularly the incentives, means that there is, as previous witnesses have detailed, a very worrying void in the planning system at the moment. I think that in the short to medium term there could be a big fall-off in the delivery of all homes, including affordable ones. The National Housing Federation's consultants, Tetlow King, have done extensive evidence-gathering on this and throughout the southern regions. My colleague Steve Hinsley may be able to elaborate.

Steve Hinsley: The work we did on behalf of the federation began shortly after the announcement by Eric Pickles of the intention to abolish the RSS. The work we did was a telephone survey of local authorities to find out their reaction to that announcement in terms of their housing numbers. We have continued to update those assessments since the first one in July. Our first assessment found 85,000 homes no longer being planned for, rising to 100,000 on 2 September; early in October authorities indicated 160,000; and the most recent assessment we have undertaken is 182,000. I think that shows not only the scale of the planned losses but also the speed at which those numbers have fallen away.

Q220 Chair: Can anything be done in the short term to deal with this fairly critical issue? Obviously, the Government will not reinvent regional spatial strategies and go back to where they came from, but is there something that can be done particularly in terms of affordable housing to stop the crisis getting worse?

Cameron Watt: I think there is a need for the transitional arrangements the likes of Barratt and the Home Builders Federation have been calling for to help prevent a further hiatus between now and 2012 with the passing of the localism Bill and the new national planning framework, and to give local authorities time to develop new-style local plans. There is a need for transitional arrangements and we would support many of those that have been advocated by our colleagues from the private house builders. As we have set out in the summary of our recommendations, I think Grant Shapps has spoken about the national definition of sustainable development and a presumption in favour of it where clearly local authorities are seen to be dragging their heels. I think that to develop a national definition of sustainable development in favour of granting planning permission in the case of those local authorities that are dragging their feet to the greatest extent and do not have in place an up-to-date plan—their plan may be pre-2004—could help.

On affordable housing specifically, perhaps our biggest concern at the moment is that the planning system continues to deliver affordable housing but local authorities set themselves and deliver stretching affordable housing targets—affordable housing as the proportion of all homes built—and also continue to support affordable housing through planning gain. About 40% of all new affordable homes are wholly or partly dependent on planning gain contributions from private developers. Two thirds of affordable homes are delivered on section 106 sites. We are still waiting to see the details of the Government's reforms to section 106, with perhaps a new tariff system, but if we do not have continued support through planning gain for affordable housing we will not be able to deliver more homes and the 155,000 affordable homes that Government want us to deliver over the next spending period.

Kay Boycott: I think the economic and planning aspects have been covered, but a lot of this is about changing behaviour. There has been a lot of conversation about, and we look forward to seeing the accountability and transparency measures around the new proposals, but we would not want those to wait until then. It is quite important that not just the NHF commissioning people look at what is happening but that it is brought forward before the new changes come in so we know what is happening to local authorities and what they are committing to.

Earlier this year Shelter did a local housing watch that looked at housing need and delivery over the past three years of affordable housing against that. It was not without its contentiousness, so we need to have those debates now so we can get an understanding of what is happening out there on a quarter-by-quarter basis, because as these units disappear and the capacity disappears we will not get it back quickly. I think that needs to be pulled forward because transparency and accountability will start to drive behaviour among local authorities.

Q221 David Heyes: Changing behaviour underlies my question. The Government seem to believe that local authorities freed from the imposition of regional spatial strategies will become more responsive local needs and that will lead to more housing. Clearly, from what you say, you do not believe that to be the case.

Kay Boycott: We are talking about lots of different authorities and behaviours and going down to parish councils. Some people will; some people won't. The figure we always come back to is the two thirds of the population who support affordable housing and the 41% who will say they are much more likely to support if it is not in their area. This is the crux of it. There is an awareness and general acceptance among large swathes of the population that we need more affordable houses. There is a sense that that will be good, but then we get down to their local patch. Clearly, it is a rational response. For a lot of people the perceived risk of development to their personal wealth is quite a rational one. We have very different segments of people who need to be convinced.

In the previous session lots of things were said about how you can sell development or make it appealing to communities. I think that to talk about communities in the broadest sense is not particularly helpful. We need to recognise that there are very different drivers depending on where you are on the housing ladder, your demographics and where you think you will be in five years' time. Accountability and transparency is just one matter, but another is a much better understanding of it and making that appeal to local communities.

Q222 David Heyes: Clearly, variable responses from different places and different local authorities are a factor here. Cameron, do you have a view on whether we can achieve a change in the way local authorities behave as a result of the changes that have been made?

Cameron Watt: I think local communities and councils can be convinced to accept more homes, but it will take a long period—certainly a longer period than the next comprehensive spending review. Obviously, the key driver Government see in encouraging local authorities to accept more homes is the New Homes Bonus. I am sure we will come on to discuss that in more detail, but we are not convinced that at the current levels envisaged that will drive local authorities and local communities to accept significantly more homes, so we are very worried about it.

Q223 David Heyes: Is the Government's proposal to build 150,000 houses over the next four years more or less likely under the changed system?

Cameron Watt: I think the changes to the planning system may make that more difficult. The federation still believes that the Government's top-down central target of 155,000 new affordable homes over the next CSR period is deliverable. About half those will be from existing commitments at current grant rates, but obviously a lot of those homes will depend on new intermediate rents—80% of market rents—and we do not think it is appropriate to make up for the huge cuts in capital subsidy for affordable housing, which is 63% in real terms over the next spending period, by increasing rents for some of the most vulnerable in society. The Government are committed to tackling the disincentives to work in the benefit system, but tripling the rent of a lot of low income families' rents will create a benefits trap from which it will be much more difficult for them to escape. Our initial modelling suggests that the household income of a two-parent family with a couple of kids perhaps may need to increase to £50,000 under the new rents to make it worth them moving from welfare to work. Clearly, that is a massive concern.

Q224 Heidi Alexander: Steve, in your research with local authorities have you asked any questions about those that are in the process of developing their core strategies given the abolition of the regional spatial strategies? Are you seeing any changes to the targets for the percentage of affordable homes that should be delivered as a percentage of the total? I just wonder whether given the absence of regional spatial strategies, there are some local authorities that say that rather than go for 35% they will go for 25%.

Steve Hinsley: The research we have carried out has not looked at that specifically. What has happened is that the overall numbers have been cut for the next stage of the core strategy consultation process. Within that, I have not seen any evidence for a change in the percentage of affordable housing looked at on a district-wide basis, but that is very much a high-level position. Quite often, more detail of how much affordable housing is sought on individual sites comes in other parts of the LDF suite of documents. I have not seen any signs of that.

Cameron Watt: Clearly, there needs to be some flexibility to market conditions to ensure that private developers can continue to build homes. I think planners need to be sensitive to private house builders' viability issues, but what we don't want is the new system being changed during difficult market conditions so that effectively private developers can get away with significantly less by way of affordable housing contributions, because obviously we hope and expect that the market will soon pick up. It is important that when the market does pick up, private developers continue to provide a very significant amount of affordable housing as part of the value uplift to ensure we can house the 4.5 million people who languish on social housing waiting lists.

Steve Hinsley: If I may just comment on the 155,000, Cameron has spoken about the resources for that—public funding—but we have to remember that those houses have to be built on land somewhere, and that land must be in the right place. As Cameron says, that land is usually provided on the back of private development, which adds an additional subsidy. That is the process that has been working and will continue.

Cameron Watt: As well as providing a cash equivalent value, the section 106 deals have ensured that we have had more mixed communities with private open market housing being mixed in with some social rented housing but also shared ownership—part-rent, part-buy schemes—for the missing middle, or those on moderate incomes who wouldn't get a social home and couldn't buy in the open market. In addition to providing a cash equivalent value, section 106 is really important to mixed communities.

Q225 Bob Blackman: Moving on to the New Homes Bonus, what changes to the scheme do you think need to be undertaken to make it a bigger incentive for local authorities? Kay, I accept that from your perspective you probably want a definition of what affordable housing is, but can we just look at what incentives should be there to encourage local authorities to develop affordable housing?

Kay Boycott: The first small point is that the first 70,000 homes that will receive the New Homes Bonus are homes that are already planned for, so it would be quite difficult to look at whether or not those have been incentivised. One thing I am quite keen to explore is whether the level of the New Homes Bonus, which will ultimately be the thing that incentivises or not, is enough. We will not be able to test that until quite far out. I think it is very important that there is already a date set for the review of it. A lot of the benefits of the New Homes Bonus come in the later years, by which point will you know whether or not it has worked? What is the review period? There is definitely a question to be asked about how we are to assess whether or not it is working and over what time period.

At this point, we cannot say, having done the modelling, whether it will work and incentivise. I am sure Cameron can talk about some of the modelling his organisation has done that suggests that initially it will not be enough in the absence of other incentives for local authorities, which comes back to how appealing it is to the local population and what else is happening in the local economy. I think it is very difficult to say in isolation whether it will work, but the first tens of thousands of homes on which it is being paid are already committed to.

Cameron Watt: In common with the overwhelming majority of representations that you have had in this inquiry, we do not believe that the overall pot for the New Homes Bonus will enable local authorities to be incentivised effectively to accept significantly more homes, so we think that more resources are needed for it. The federation welcomes the principle of incentivising communities and councils to accept more homes.

Q226 Bob Blackman: I accept what you say, but we already have that in evidence. The key issue is: have the Government got it right in terms of the incentives for affordable housing? Could they take away those incentives at the top end and not bother with housing for private sale but give greater encouragement for the development of affordable housing?

Kay Boycott: Perhaps this is the time to come in with a definition of affordable housing. This is where Cameron and I may diverge. If low-cost home ownership or those sorts of schemes are included in this, Shelter has recently produced a report that shows that a lot of that is not targeted at the lowest-income families and most vulnerable. There is a group that is completely excluded from low-cost home ownership, and in some areas low-cost home ownership is being used to subsidise people who could afford market housing. We are very concerned about the definition of affordable housing. In these times of constrained spending, Government subsidy should go to the most vulnerable and those who need greatest help with housing affordability, which leads you to social housing.

Cameron Watt: I think it makes sense to incentivise all housing, particularly as a lot of affordable housing delivery is dependent on private sector delivery. I think that to give the bonus to all new housing development makes sense. The additional premium for affordable housing delivery could perhaps be increased. As we have discussed, housing development in many parts of the country is unpopular, and affordable housing in some areas even more so. At the moment there is a proposal for a 125% bonus for affordable housing. I think a bonus of about 150% might well be more effective. We do need more for affordable housing and flexibility so that if the New Homes Bonus generally is not delivering the amount of housing that is needed the pot can be increased as soon as possible by top-slicing more formula grant.

One of our concerns is that the New Homes Bonus will perhaps disadvantage parts of the country where there are less buoyant housing markets, perhaps in the midlands and the north and some of the housing market renewal pathfinder areas. Obviously, for open market housing the proposal is that the New Homes Bonus will be paid on net additions, which could affect local authorities in regeneration areas. I think the totality of the spending review announcements will disadvantage poorer parts of the country over more affluent ones, so when the consultation document is published shortly, we will be looking at the proposals and the impact assessments to ensure that the New Homes Bonus does not seriously disadvantage local authorities in less affluent parts of the country.

Q227 Bob Blackman: Kay was talking about low-cost housing. What is your view on that?

Cameron Watt: I think that grant-subsidised shared ownership schemes, part-rent and part-buy, that our members provide have provided tens of thousands of affordable homes to people who would not in any way be eligible for a social home but are completely failed by the market and priced out of it. The typical household income of shared ownership purchasers is around £27,000 to £28,000; it is bang in the middle of the income scale. Private developers have developed their own shared equity products but in most circumstances these are much less affordable than housing associations' shared ownership schemes. I think that if we are serious about supporting the aspirations of the majority of the population to become home owners we need continued investment in shared ownership to provide for a broader range of housing needs.

Kay Boycott: One other point on the New Homes Bonus is that, until the detail is published, we have concerns about whether or not it will incentivise against the building of family sized homes for which there is need in a lot of places.

Q228 Heidi Alexander: To what extent do you think the New Homes Bonus will offset reductions in the HCA and social housing budgets?

Cameron Watt: I do not think it will offset the reductions in the budget. Obviously, the overwhelming majority of new affordable homes are built by housing associations that take Government grant and match it with their own resources and private developer section 106 contributions. Although the New Homes Bonus is welcome in terms of encouraging local authorities to plan for more housing, it will go to the local authority so it will not make up that shortfall.

Q229 George Freeman: I represent a rural area where affordable housing is a huge issue, average income is below £20,000 and the real issue is jobs with houses; for elderly folk it is care with houses; and for youngsters it is access to services with houses. Given that the county council is responsible for care, transport and education and the parish councils tend to be the places where local opposition takes root on the basis of "What's in it for us?" can you comment on what you think would be an appropriate split of whatever moneys are available in a rural area as between parish, district and county?

Cameron Watt: My understanding is that at the moment the proposal is for 80% of the New Homes Bonus in two-tier areas to go to the lower tier authority, the district which is the housing and planning authority, and 20% to the county. That seems to be an appropriate division of the New Homes Bonus, because we need the local planning authorities to be properly incentivised. I think that if a significant proportion is reserved for the parish council that will seriously disincentivise the planning authority. It needs to be more sensitive to the bonus from granting more planning permissions. I think there are other ways in which you can encourage and persuade local parish councils to accept more homes on small exception site developments of five or 10 houses. You can persuade them on a whole range of grounds about the sustainability of the community, keeping local shops and pubs alive, and keeping the character of the village as it is. I do not necessarily think that the New Homes Bonus should be used to incentivise individual parish councils in rural areas.

Kay Boycott: We are talking about what will incentivise people with widely different housing needs whether that is demographically or in terms of the areas. One of the things we will look for when the proposals are published is that there has been some work done to model what will happen and what will incentivise. It is not something that an organisation like Shelter can take on. The NHF have done some, but we hope that CLG will have done some of that work.

Q230 George Freeman: Are you making the case that there might be a different regime in different parts of the country?

Kay Boycott: We know from the work we have done in local campaigns and talking to people about how development is done over the years that it varies wildly. If you are in a rural area, a market renewal area, in London or the broader south-east the things that incentivise people are very different. It is very easy to talk about the finances and you can be a little more national about those; you can talk about the general economy. However, when it comes to what will get people in that local community to be incentivised, a lot of those things are emotional rather than rational. If the emotional ones don't work then the New Homes Bonus is, as I understand it, designed to create a financial incentive to overcome those barriers, and the amount needed will be very different depending on the degree of opposition in that area. It may not even be opposition but apathy. We do not know the detailed proposals but we know that getting local community support is a very tailored process, which is the point about localism.

Q231 James Morris: Turning to local enterprise partnerships and the need for strategic planning, do you see LEPs as having a role in developing housing planning, or not?

Cameron Watt: The National Housing Federation's view is that it is important to continue strategic planning because, as already discussed, the aggregate of a snapshot of immediate need in local areas over the nation will not produce an accurate overall level of housing need. We think that strategic planning needs to be upheld and that is why both the federation and Shelter were signatories to the letter sent to Eric Pickles by the new coalition led by the RTPI and Strategic Planning calling for a continuation of strategic planning under the new regime. We believe that LEPs should be charged with developing a planning and housing strategy and that should include a robust assessment of housing need, including affordable housing. I think that in terms of upholding housing delivery generally, what is more important than a strategic role for LEPs is that local authorities under the new-style local plans that they are charged with developing have to conduct a robust and credible assessment of housing need and demand across their areas and have some obligation to meet it. That assessment of need by individual local authorities will produce more homes than the strategic planning element of LEPs, although I believe that role of LEPs will provide a fuller, rounder picture of housing need.

Q232 James Morris: You are saying on the one hand that you believe local enterprise partnerships need some form of strategic development. Is it powers with which they need to be imbued, or do they need to collaborate on the production of plans for those specific areas that LEPs cover? I am not quite clear.

Cameron Watt: I think powers would help so that when local authorities themselves come together and identify the broad level and distribution of development across their sub­regions they together agree a housing target and they are bound to deliver the target to which they have committed themselves. I think a statutory basis with some powers would be helpful.

Kay Boycott: What we look for is the ability to hold people accountable. What worries us is: is part going to the LEP, is part going to local authorities, is part going to sit with the national plan? What about county councils and parish councils? Where is the point at which we can hold local politicians to account for the delivery of affordable homes? In a way, it does not matter where it sits as long as those people collaborate, it is based on housing need and they come together in a timely way to make the decisions, but being very clear it does not mean that in five years' time everybody can point to everybody else about why it went wrong.

Q233 James Morris: Is there a need for powers imbued in the LEP to make that happen, or do you conceive of a situation where local authorities are able to collaborate to achieve this without there being some kind of statutory body in existence at sub­regional level?

Kay Boycott: Without knowing what the proposals are for the local authorities it is very difficult to say.

Steve Hinsley: Following on from that point, the difficulty is that in the past local authorities have been expected to work in a loose relationship with each other. If we look at examples of their coming up with an answer at the end of the day, it has not worked very well. If we take the example of Bristol and authorities there, they just do not get on and there is a hiatus and inertia in going forward. There need to be some powers. Linked to that is the point Cameron made that local authorities need new guidance on how to carry out housing needs assessments. The indications are that we are going back to the situation 15 years ago, when each district council carried out a housing needs assessment for its own borough or district, but the question is: how do you look at the wider area and those districts and boroughs that join? How do you look at the opportunities in the wider planning sense and where the housing should go relative to need and constraints? I think that is the level that needs to be handled very carefully, because I do not think that to go back to the old style of district-wide surveys is the answer.

Q234 Simon Danczuk: I want to pick up a point made by Cameron. I got the impression you were saying that LEPs were best placed to provide that strategic planning role, but my question is: do you think they are that well placed in terms of the make-up of who will sit on LEPs and their geographic boundaries? Do you think that is an adequate level at which that strategic planning process should take place?

Cameron Watt: That remains to be seen. As far as opportunities for strategic planning going forward are concerned, LEPs seem to be the only show in town, so I think strategic planning through LEPs is better than no strategic planning. In terms of the areas that they cover, obviously there are concerns that LEPs will often not cover natural housing market areas and therefore the potential value of the strategic planning that they do could be limited by that. At the moment we have had some strategic planning by local authorities through the Homes and Communities Agency single conversation process that has been undertaken in the past two years to direct affordable housing and other investment. I think there is a question about how the local investment partnerships that have resulted from the HCA single conversation process will interact with LEPs.

Obviously, there are also issues about democratic accountability. We need to ensure that LEPs are truly representative of the areas they cover and it is not just business interests that are represented. I am encouraged by the indications by the Minister of State for Decentralisation that he would see civil society representation and social enterprise representation on LEPs as a norm and an expectation. As major providers of affordable housing obviously we would be calling for housing associations to have a role in many LEPs.

Q235 Simon Danczuk: Everybody seems to agree that we need to collect data and carry out housing needs analyses at local authority level, but who should take on the responsibility to build that up into a bigger picture, perhaps up to a sub-regional or regional level? In addition, Shelter in particular has made a big play of openness in terms of data collected by local authorities. Would you say something on that point?

Kay Boycott: Referring to the work we did earlier this year looking at the SHMAs, a lot of local authorities already don't have the in-house capability to do those and they can cost significant amounts of money, so there is a cost saving and capability conversation to be had if it is 70,000 per local authority and accumulates. First, I think there will be a cost saving by having national expertise about how those should be done. At the moment, they are complex and not very accessible documents. To get to affordable housing need, for example, usually you have to go to page 197 to find it. They are not updated very often. If you think about how the housing market has changed since 2005 and 2006 when many of these were done, they are not particularly dynamic. They are very complex documents, but we really need to have a conversation about dynamism, ability to do them and cost. In our view there needs to be a role for central Government to do that basically to save costs and streamline them and get them done faster and achieve that cumulative understanding. That is the local authority. But if the current process is repeated, we think it will introduce yet another huge hiatus into it.

Cameron Watt: "Open Source Planning", which is the blueprint for the current planning reforms, envisages local authorities providing individual neighbourhoods with quite detailed evidence on housing need, including affordable housing, at local level. I think the federation's concern is that with the abolition of the National Housing Planning Advice Unit and of leaders' boards, overstretched local authorities, particularly the rural ones, may not have the capacity to produce meaningful evidence themselves from scratch and that could seriously hinder implementation of the bottom-up vision of "Open Source Planning". CLG has said it has made good arrangements for the data that were previously collected by regional leaders' boards to be looked after and updated by other organisations. I believe that for the south-west the data have been deposited with the British Library, which to me does not suggest that these are living, active data sets that will made freely available to local authorities to help inform their new-style local plans. We have real concerns that the evidence base for local authorities to develop their new housing numbers just won't be there.

Steve Hinsley: I think that the information to support any kind of primary housing need survey is there but it needs to be maintained. Secondary data is very important. Just to reiterate what Cameron said, that needs to be maintained in a proper sense and I think it really can be only for Government to ensure that is kept up to date.

Q236 George Freeman: I want to ask about the housing federation's quite striking views in its evidence about the role of LEPs. My understanding hitherto has been that the Government see the local enterprise partnerships as setting out an economic vision for their areas. In my own area it might be: where are the growth industries in the next 10 to 15 years or so? What infrastructure do we need to support them, with the planning authorities doing the housing to support that? Mr Watt, you make the case that you see the LEP making an assessment of housing need and setting out how the partners intend to meet it in a way that would be binding once agreed. It is very interesting that you say the LEPs should have powers to aid cooperation over implementation. That sounds like a blueprint, for better or worse, for the LEPs to become the strategic planning authority. I am interested in whether that is really what you suggest, because that is quite different from the vision of LEPs pushed by the Government. I am interested in whether I have understood correctly that you see the LEPs basically as the strategic planning authority.

Cameron Watt: They would be a strategic planning authority. Obviously, different messages have been put forward from Government on how they envisage the LEPs working and what powers they might have. In previous documents before the Local Growth White Paper it was clearly said that Government envisaged that they would have potentially a strategic housing and planning role. Obviously, the housing element now seems to be downplayed, but if LEPs are setting out a spatial vision, for example, for economic development particularly in rural areas that may not be successful if there is not the housing provided to support it. Therefore, it seems to make sense for housing to be planned alongside strategic economic development in infrastructure. We think that binding powers are one option that should be seriously looked at because, obviously, if local authorities themselves have come together and set out a vision for the future and made commitments to meet identified housing needs themselves clearly those commitments must be meaningful.

Q237 George Freeman: Can you give an example of what you mean by powers to aid cooperation over implementation? What do you have in mind?

Cameron Watt: Obviously, if the LEP has set out a housing number across its sub­region and the local authority is not allocating nearly enough sites for housing then perhaps the LEP could compel the local authority itself to allocate sufficient land to meet the housing needs that that local authority and other LEP partners have identified as essential.

Q238 Chair: I pick up the issue of the evidence base for assessments of housing need in an area. Mr Donson from Barratt Development spoke about the potential for housing need in an area being 5,000, give or take a couple of hundred either way, but the local authority's knee-jerk reaction might be only 1,000, and therefore there is need for clear guidance about how that evidence base is calculated by the local authority and to get consistency across the country. Do you see that important? Should it be something stronger than guidance if local authorities have to comply with it?

Kay Boycott: If we want to look at different local authorities and compare them on a fair basis, housing need must be where you start from. How are people delivering against housing need as opposed to how many units do they deliver? We would argue very strongly that there needs to be a consistent methodology. That will need some quite hard conversations about the difference between housing need, housing demand and housing aspiration, which brings us to the question: what is our vision for housing going forward? Someone quite rightly said that housing need versus housing market were quite different things. We believe that there will need to be guidance because of the importance of different tenures, if nothing else. Over the past few years we have looked at the growth of the private rented sector. All the indications are that private renting will continue to grow, so how will that be dealt with in strategic housing market assessments, in addition to looking at other tenures and potentially new tenures that are evolving? We think it should be consistent and tied in with a long-term vision for housing.

Cameron Watt: The revised planning policy statement on housing published by the Coalition Government in June, I think, reiterated that local authorities had to have housing numbers based on sound evidence and the SHMAs and SHLAs having a key role in that. But the current strategic housing market assessment guidance is over three years out of date and was clearly written for the former year of regional spatial strategies, so it is important that with the new national planning framework, with potentially a new PPS3 being issued, new guidance is issued centrally to help local authorities ensure that they robustly and accurately identify housing need. I think that process should be as consistent as possible across the country so it is right therefore for local authorities, having identified need on their own patches, to come together through LEPs and have a meaningful conversation, and also for individuals to hold their local authorities to account on whether they are accurately identifying housing need and planning to meet it.

Kay Boycott: Part of the reason for doing it is that if you are communicating with communities about the need for housing and building it needs to be based on something they recognise. The number one concern of people is about affordability, so SHMA or whatever it is needs to look at those issues in order to be able to articulate them back to the local community, whereas if it is all over the place it may be some of those are missed and those communication opportunities are also lost.

Q239 Chair: Do you think there is a role for central Government in taking a wider overview of the assessments of need that are being done individually by local authorities, or collectively in some way through a LEP or another arrangement, and monitoring the total in aggregate that is being agreed by local authorities and matching it against the Government's own assessment of housing need at national level?

Kay Boycott: I would have thought it would be very difficult for national Government to do any investment decisions in the next CSR if they do not have a view about housing need and the relative priority of housing without having some sort of aggregate view. The National Housing and Planning Advisory Unit is no longer providing that data. Previously, Shelter did reports with Cambridge. I am not sure that is sufficient given the level of housing need facing the country.

Cameron Watt: I think it is vital that when local authorities identify housing need at local level, by whatever means, inspectors should be able to continue to check the new local plans that they have developed to see whether the needs that those local authorities have themselves identified are credible and the numbers are adequate; otherwise, some authorities may abuse their new freedoms and revise their housing numbers significantly downwards even though there is significant unmet need at local level.

Chair: Thank you very much indeed for your time and the evidence you have given us.


 
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