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 plantheir plan may be pre-2004could
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 targetsaffordable
housing as the proportion of all homes builtand 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 periodcertainly 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 rents80% of market rentsand
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 thatpublic fundingbut 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 ownershippart-rent, part-buy schemesfor
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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