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

Written evidence from the Housing Forum (ARSS 120)


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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Prepared 31 March 2011