Written evidence from Essex County Council
(ARSS 117)
EXECUTIVE SUMMARY
1. It is unclear as yet as to how the abolition
of regional house building targets might affect levels of new
housing being provided in Essex.
2. The abolition of regional strategies
and the overly prescriptive policy guidance that they contained
is supported.
3. Concerns have arisen about the undue
speed with which changes were made to the planning system, the
absence of proper transitional arrangements, and lack of clear
guidance from CLG.
4. A major repercussion has been considerable
confusion and significant delays in the LDF process.
5. CLG Ministers abolished regional strategies
but did not provide local authorities with additional funding
to pick up the consequences.
6. Revocation of regional strategies has
wider policy and procedural implications than just removing targets
for new homes.
7. The attractiveness of incentives to local
people in the New Homes Bonus will be a key feature that will
determine the effectiveness of the policy.
8. The operation of the Bonus should be
open and transparent and aligned with housing proposals in local
development plans to prevent distortions in the delivery of public
policy.
9. In two-tier areas, suitable arrangements
should be put in place for both tiers to benefit from the Bonus.
10. Arrangements need to be clear for the distribution
of the Bonus in situations where growth towns are under-bounded.
11. The regional target based arrangements provided
a good service to ensure cooperation across large geographical
areas for waste management and minerals planning, and similar
arrangements should be developed in the future.
12. The role and participation of the Aggregates
Working Party and the Technical Advisory Body for Waste in the
East of England should be continued to provide technical minerals
and waste support through sharing of best practice, data collection,
arranging co-ordinated studies for consistent evidence base for
sharing, and policy making to support the Minerals and Waste Planning
Authorities.
13. There is a need for strategic-level planning
that co-ordinates development and infrastructure between different
areas, provides a wide range of environmental and climate change
policies, and ensures that the needs of the wider than local community
are properly addressed.
14. A strategic level of planning should be included
as an important part of the system, that can co-ordinate cross-boundary
planning issues and delivery, and ensure joint working across
areas for particular wide ranging issues.
15. Local economic partnerships (LEPs) could
provide a means to consider strategic matters but there is a need
for much greater clarity about their strategic planning role.
16. Arrangements should be made to archive all
evidence based material associated with the production and monitoring
of the former regional strategies, and make this available as
an internet resource.
17. There is potential that LEPs could provide
for a strategic level of research and data collection on cross
boundary issues.
18. The expanded role of the AWP and TAB in the
East of England could provide a research, data collection, collation,
and sharing information point for the administration of waste
management and minerals planning.
ESSEX COUNTY
COUNCIL
1. Essex County Council is one of the largest
county councils in England serving a resident population of 1.7
million and an extensive geographic area containing twelve districts.
It has three national and regional growth areas namely Essex Thames
Gateway, Haven Gateway, and part of the London, Stansted, Cambridge,
and Peterborough growth corridor; and a regional growth point
at Chelmsford. It has previously contributed to the production
of the East of England Plan (a regional spatial strategy) through
its participation in the work of the former East of England Regional
Assembly. On the 6 September 2010 it submitted proposals to the
Government for the creation of a new Kent & Greater Essex
Local Economic Partnership.
EXPRESSION OF
VIEWS
2. Essex County Council wishes to put the
following views before the Select Committee for consideration.
1. The implications of the abolition of regional
house building targets for levels of housing development
3. Following the abolition of regional spatial
strategies, it has been widely reported that the majority of local
authorities across the country are reconsidering house building
targets and the status of adopted development plan documents.[143]
A survey conducted by Roger Tym & Partners found that 51%
of local authorities in England expect to review LDF (Local Development
Framework) housing targets, and only 35% expect to remain with
existing targets.[144]
4. Several Essex local authorities are currently
reconsidering their housing targets. However, it is impossible
at present to report on the outcome in terms of what might be
decided or how many new homes might be involved as local authority
decisions have still yet to be made over the next few months.
Nevertheless, there has been a persistent concern in Essex that
inflated regional housing targets have been imposed on the county
without proper regard to the capacity of the local economy, transport
and infrastructure, public services, and natural environment to
cope with the growth.
5. Essex County Council supports the abolition
of regional strategies and the overly prescriptive policy guidance
that they contained. It also supports in principle the Government's
localism agenda and the transfer of executive decision making
for housing proposals down to local councils. However, concerns
have arisen about the undue speed with which changes were made
to the planning system, the absence of proper transitional arrangements,
and lack of clear guidance from CLG about how to put the major
new changes to the development plan system into effect.
6. A major repercussion of the rapid abolition
of regional strategies in Essex has been considerable confusion
and significant delays to the LDF process. Local authorities with
adopted core strategies already in place have been obliged to
consider whether they should be reviewed. Those authorities already
at or imminently approaching plan examinations have been put in
the unenviable position of having to urgently update their evidence
base at considerable cost. Other local authorities who are progressing
their draft proposals have faced major confusion and uncertainty
about how to take their plan making process forward.
7. The lack of adequate and clear CLG guidance
on how to put the new approach into effect has created a number
of uncertainties. The following issues are illustrative:
How should individual local authorities decide their
own housing figures in the absence of a regional strategy—what
evidence base, information sources, methodology, and material
considerations should be used?
What should the balance of new housing provision
be between meeting locally generated housing needs and at the
same catering for the wider pressures of housing markets and migration
patterns [ie, playing out at a strategic level involving many
local authorities]?
How can the Government's localism agenda of individual
local authorities deciding their own housing figures be reconciled
with the acknowledged need for strategic planning over wider spatial
areas (but without any administrative machinery for making executive
decisions about the latter)?
What should under-bounded local authorities do if
their future growth is situated within immediately adjoining districts
in the form of major urban extensions into them?
At what spatial level should the "localism"
agenda inform decision-making—is it at neighbourhood, town,
or whole district/borough level?
If a five year housing supply still has to be maintained
how should major speculative housing proposals be decided at the
planning application stage if the housing numbers are uncertain?
8. The new arrangements have obliged local
authorities to suddenly undertake substantial updates to their
evidence base and further rounds of public consultation which
are both time consuming and expensive. However, in an era of public
spending cuts the CLG has not provided extra funding to support
such activities even though these extra costs are brought about
by CLG Ministers' policy changes.
9. The abolition of regional strategies
has not just removed housing targets but also a strategic framework
of other policies on matters such as settlement policy, town centre
hierarchies, green infrastructure, renewable energy, transport
strategy, gypsy and traveller provision, and other issues. It
remains unclear in future how these matters at a wider strategic
scale will be administered, if at all.
10. Changes to the development plan system have
taken place in advance of the introduction of the New Homes Bonus.
At present local authorities are unable to take decisions about
the revision of housing figures without full knowledge about the
financial benefits accruing to communities from new housing. From
May 2010 to date they have been obliged to make decisions as it
were "with half the story missing".
2. The likely effectiveness of the Government's
plan to incentivise local communities to accept new housing development,
and the nature and level of the incentives which will need to
be put in place to ensure an adequate long-term supply of housing
11. Without formal documentation or precise policy
wording, and until further information is provided following the
Comprehensive Spending Review, the implementation of this proposal
cannot be adequately assessed.
12. The attractiveness of the incentives to local
people will be a key feature that will determine the effectiveness
of the policy. The benefits of development need to outweigh the
actual and perceived detrimental impacts, which could require
much greater incentives in certain areas of the Essex where the
promotion of increased new housing development would be highly
controversial.
13. The New Homes Bonus should be set up in such
a way that it is fully open and transparent so that it does not
appear that planning permission is being bought; and it also needs
to be properly aligned with the housing proposals set out in local
development plans. The latter should set out the agreed housing
strategy for a local area being subject to widespread public consultation,
sustainability appraisal, and independent testing. Operation of
the Bonus should take its lead from local development plans and
not the other way round.
14. Unless this is the case, there is concern
that the incentives promoted by the Bonus could lead to distortions
in the delivery of public policy such as,
favouring greenfield development rather than brownfield/regeneration
projects as these can often be delivered much more quickly;
favouring housing delivery in those areas with higher
Council Tax bands to maximise income;
deliberately steering housing growth to areas of
high market demand to promote dwelling completions irrespective
of the planning policy or infrastructure constraints; and
altering the dwelling mix to favour the construction
of particular dwelling types which raise more income (eg, executive
homes) contrary to the findings of local housing needs assessments.
15. The method of payment through the Bonus would
not provide initial benefits to the local community, but rather
payment that would trickle through as houses are developed. This
could dilute the effect of the bonus, and might not address the
early pressure put on local infrastructure and services to meet
the increased demand from new residents.
16. Specific guidance should be developed to
identify how income from the Bonus will be allocated to relevant
authorities. In two-tier areas, arrangements should be put in
place for both tiers to benefit from the Bonus. A county council
provides the majority of services by value but it is not clear
how it would benefit from the Bonus funding being provided.
17. Further guidance will also be required to
identify how funding will be distributed proportionately across
administrative boundaries for those local authorities that are
under-bounded. For example, a major town that is growing beyond
its boundaries into adjoining districts through urban extensions.
The town's own facilities and new housing areas would be inextricably
linked.
18. It is emphasised that the Bonus rewards local
authorities but it cannot of itself actually deliver new homes.
The UK housing market plays an important role in determining the
rate of residential completions, and social housing providers
and private developers actually deliver the new homes based on
market conditions and their own commercial judgements.
3. The arrangements which should be put in
place to ensure appropriate cooperation between local planning
authorities on matters formerly covered by regional spatial strategies
(eg waste, minerals, flooding, the natural environment, renewable
energy, &c)
19. Regional spatial strategies co-ordinated
strategic targets to ensure the adequate provision of non-energy
minerals supply and the management/disposal of waste across a
region. Without the strategic overview and target based organisation
that this function provided, there is concern that some areas
may not have sufficient waste management facilities to meet demand
and there would be a disorganised supply of minerals. The former
regional target based arrangements provided a good service to
ensure cooperation across large geographical areas, and voluntary
working arrangements between local authority groupings could take
this strategic activity forward.
20. Joint working arrangements currently exist
in the East of England through the Aggregates Working Party (AWP)
and the Technical Advisory Body for Waste (TAB). These groups
currently act only as advisory bodies with no executive powers,
policy making responsibilities or political representation, and
report to regional decision making bodies such as the East of
England Local Government Association.
21. To assist the ability of the groups to effectively
manage the responsibilities required, there would need to be a
form of statutory duty or duty to co-operate placed upon relevant
planning authorities. This could include agreements by authorities
to share the management costs of the AWP and TAB, and to take
into account policy decisions of the groups in plans developed
at the local level.
22. Providing strategic groups to assist the
management of minerals and waste across a large regional area
offers a number of benefits. The groups can provide;
cheaper overall resource base by commissioning work
to be shared by the whole area;
greater strategic organisation to improve joint working
and reduce duplication of work;
a single point of contact for industry, and an agreed
common approach to dealing with strategic matters; and
greater sharing of knowledge and expertise across
a larger area
4. The adequacy of proposals already put forward
by the Government, including a proposed duty to co-operate and
the suggestion that Local Enterprise Partnerships may fulfil a
planning function
23. The Government's proposals for the planning
system leave a substantial gap between national and local planning.
It is generally agreed[145]
that key planning issues require management at differing spatial
scales, and that many planning issues are most efficiently and
effectively dealt with at sub-national and sub-regional levels
rather than the local level. Energy, housing, waste and minerals
are examples of policy areas in which pooling of shared expertise
can be a major benefit in a cost-effective planning process.[146]
24. There is a need for strategic-level planning
that co-ordinates development and infrastructure between different
areas, provides a wide range of environmental and climate change
policies, and ensures that the needs of the wider than local community
are properly addressed.
25. Essex County Council supports the creation
of Local Enterprise Partnerships (LEPs); and has recently submitted
a proposal for a Kent & Greater Essex LEP to the Government
for approval. The Government has suggested that LEPs might want
to start "tackling issues such as planning and housing, local
transport and infrastructure priorities, employment and enterprise,
and the transition to a low carbon economy". However, CLG
Ministers appear adamant that they do not wish to see a further
tier of development plans created between the national and local
levels. Therefore, it is unclear how LEPs might tackle these strategic
planning issues other than in a very general way through voluntary
agreement.
26. Even with a statutory duty for local authorities
to co-operate emphasised within national policy, adequate co-operation
between different areas when required cannot always be guaranteed.
This requires very robust partnership working arrangements to
be put in place that can co-ordinate cross-boundary planning issues
and delivery, and ensure joint working across areas for particular
wide ranging issues.
27. Local economic partnerships (LEPs) could
provide a location to consider strategic matters such as forecasting
of housing and employment needs, and provide a wider geographical
understanding of local labour markets, economic sub-areas, migration
trends, and housing market areas to assist local areas to develop
appropriate policy responses. Strategic assistance provided by
LEPs could also assist local authorities that may not have the
specialist skills or resources to produce local housing assessments.
5. How the data and research collated by the
now-abolished Regional Local Authority Leaders' Boards should
be made available to local authorities, and what arrangements
should be put in place to ensure effective updating of that research
and collection of further research on matters crossing local authority
boundaries
28. The evidence base to the former East of England
Plan is considered an important resource that should remain available
to the general public as an internet based resource. Arrangements
should be made to archive all material associated with the production
and monitoring of the RSS.
29. As identified above, there is potential that
LEPs could provide a strategic level of research and data collection
on cross boundary issues. It is not considered necessary to continue
any further monitoring of former regional targets, therefore any
future collection of data at a strategic level should be conducted
at a scale appropriate to the needs of the area.
30. Section 3 above identified that the expanded
role of the AWP and TAB in the East of England could provide a
research, data collection, collation, and sharing information
point to assist areas to formulate policy on minerals and waste.
September 2010
143 Planning Magazine, "Alarms raised over local
target review", 6 August 2010. Back
144
Planning Magazine, "Alarms raised over local target review",
6 August 2010. Back
145
The Future of Planning Report, TCPA (Town and Country Planning
Association), 2010; POA (Planning Officers Society) Manifesto,
POA, 2010; Shaping the Future, The RTPI Manifesto for Planning,
RTPI (Royal Town Planning Institute), 2010. Back
146
The Future of Planning Report, TCPA (Town and Country Planning
Association), 2010. Back
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