Written evidence from the Housing Forum
(ARSS 120)
SUMMARY
Following the abolition of RSS, local spatial plans
will be the only mechanism for attracting and integrating investment
in particular places. The Housing Forum's views are:
Local decision-making on planning will require a
positive vision of place backed up by clear and robust criteria
for defining the "presumption in favour of Sustainable Development".
Save time and money by using the "Tool Kit"
we already have.
Follow through—a Planning Permission means
a duty to develop.
Incentivise development more - through tax advantages
and additional local borrowing permission.
The successful operation of localism, in the context
of the abolition of RSS and other changes, will depend on the
provision of infrastructure and on a good framework for integrated
and focussed investment by the public, private and community bodies
that are trying to promote development through the spatial planning
process.
1. Local decision-making on planning will
require a positive vision of place backed up by clear and robust
criteria for defining the "presumption in favour of Sustainable
Development"
Focusing on achieving a positive spatial vision would
be an entirely new approach for planning for housing, which has
traditionally been based on backward looking views of place deficits,
such as "meeting needs" or "balancing housing markets".
Positive plan making should be about charting the
trajectory of what a place will need to be in the future.
Localism can liberate communities and places to take
the course that is suitable for them. A positive approach to housebuilding,
which is welcomed by local people, is more likely to succeed when
full information is available, and when communities can have confidence
that the decisions made are right for their places. Such decisions
need to be focussed on the delivery of this clearly articulated
vision for spatial development, enabling decision-makers and communities
to:
Understand how a place works and what it needs—for
everyone.
Look objectively at evidence of how different types
of development may affect a place.
Generate appropriate options and carry out sustainability
appraisals of those options.
Establish publicly agreed criteria for satisfying
"the presumption in favour of sustainable development".
Ensure that the best option for development actually
happens.
Evaluate the impact of development on the place in
its entirety, and feedback the lessons learned.
A vigorous market sensitive approach needs to be
embedded in the collection of better market data and analysis
for Strategic Housing Market Assessments.
2. Save time and money by using the "Tool
Kit" we already have
We should avoid any major structural reforms of planning.
These would be a diversion of resources and political capital
from the primary task of creating investor confidence, attracting
inward investment (to UK plc and local places), and supporting
delivery. It takes time for changes to bed-in, and for developers
and councils to understand how they work, contributing to uncertainty
for investors and delays in development.
Our priority is to use the existing Sustainability
Appraisal process for the purpose for which it was originally
intended: to test the sustainability and deliverability of alternative
broad locations for development at local, district or county level.
They should now be used to set, transparently and authoritatively,
the criteria for satisfying the presumption in favour of sustainable
development under which many planning applications will now be
promoted and automatically approved. Good Sustainability Appraisals
could create greater certainty and investor confidence, sufficient
to attract the infrastructure finance that will then unlock the
"right" strategic allocations of land at district and
local level.
One simple improvement would be to make Sustainability
Appraisals the subject of their own Examination in Public. By
defining the criteria for sustainable development in this way,
the subsequent preparation of spatial plans at any level would
be quicker and more focussed on only those broad locations and
sites that can satisfy the accepted sustainability and deliverability
criteria.
3. Follow through—A Planning Permission
means a duty to develop
Not developing or delaying development of allocated
or consented land undermines decision-makers' capacity to improve
the quality of life for everyone.
Whoever conducts the planning functions, and the
broader reach of Local Enterprise Partnerships could assist in
this, a Planning Permission should carry with it a duty to develop.
This could be a powerful driver for development, along with any
of the incentives now proposed. The Housing Forum has consistently
advocated this view for several years.
Planning authorities should therefore be in a position
to intervene where there is a risk that the delivery of wellbeing
outcomes will be undermined.
4. Incentivise development more—through
tax advantages and additional local borrowing permission
A powerful incentive to bring more land forward for
development could be achieved through new tax and other fiscal
measures for landowners, communities and local councils.
A new generation of Public Private Partnerships,
such as the Placeshaping Co-Investment Partnerships, advocated
by The Housing Forum, could provide a brand for assembling the
different elements of public and private financing needed. These
approaches must be about investing not just to save, and achieve
"efficiencies" but to create new wealth.
Taxes must have the effect of discouraging short
term land price speculation and encouraging investment in long
term revenue generation from development. Speculative increases
in land values arising from planning should be recovered in proportion
to the level of investment and risk incurred by landowners prior
to trading a site in a less than optimally developed state.
Positive incentives should encourage landowners to
participate in a consortium with public enabling bodies committed
to bringing forward development. Landowners would obtain a guaranteed
minimum price for their land after development and an agreed proportion
of created value, subject to their participation in a new Voluntary
Partnership Agreement (VPA) for land development. Tax credits
should be offered to landowners who defer any land receipt and
profit-taking until the development is completed. VPAs would thus
enable Local Planning Authorities and their partners to be more
proactive in making the plan happen, and ensure that the wellbeing
outcomes required are also achieved. VPAs would provide a more
attractive, quicker and cheaper alternative to CPOs as the principal
means of acquiring a sufficient interest in land to empower public
bodies to act.
Further incentives for local communities who accept
development could be additional borrowing capacity for further
local investment through local bodies.
However well these reforms will work, they will not
address the underlying causes of "boom" and "bust"
in the housing market. A system which ensures development can
follow infrastructure and in which public spending secures a proper
return or investment is needed—in other words, to go much
further to find a solution to the increasing unaffordability of
housing and raise the political commitment of providing homes.
5. Operating Localism—the role of Infrastructure
So that local government can make the legitimate
political choices about whether to develop, or not, there needs
to be certainty and predictability about the ways that the necessary
infrastructure will be funded and delivered.
Many of the difficulties experienced in promoting
faster rates of development and achieving high quality sustainable
development stem from the lack of a common agency in spatial planning.
Central and local political leadership is needed to encourage
the flexible long term partnerships of landowners, developers,
councils and investors that are needed to make plans actually
happen.
Counties or sub-regional groupings make natural areas
that could support a new generation of locally accountable city
or county development alliances, building on the expressions of
interest in Local Enterprise Partnerships, to drive spatial plan
delivery for an area and join up all the sources of investment.
6. Accountability and Validation
Localism and the opportunity for community organisations
to participate in neighbourhood planning, and the new community
rights to buy and build also carry important public interest responsibilities.
An effective localist approach will need to ensure these local
bodies are properly constituted, and have objects that are aligned
with other public interest bodies.
Where necessary, public bodies should also be under
a duty to cooperate with them to ensure they can realise the opportunities
offered through any new legislation.
Standard company, trust, or industrial and provident
society rules and registration processes should ensure that Memoranda
and Articles of Association embody the promotion of social, economic
and environmental well being. Such a test of "validation"
to participate will also ensure objectivity in the process, and
that community bodies act in the wider public interest, and not
just their immediate self-interest.
September 2010
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