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


Written evidence from Bedfordshire Councils Planning Consortium (ARSS 10)

There is a mantra that Government, and Local Authorities would be well advised to underpin everything they do if we are not to lurch from crisis to crisis

"There are finite resources, which need managing effectively, infinite spending is not an option"

We welcome the removal of the housing targets with the revocation of the RSSs, as this has resulted in development in areas like Milton Keynes that will, like the developments of the 1960's, cast a long shadow due to their density, build and architectural quality, and failure to address research based human requirements of home and community. We would refer to-the House of Commons Environmental Audit Committee March 2006—Sustainable Housing. A Follow Up Report—Conclusions and Recommendations

35.  We remain deeply "concerned that ODP M is determined to build new homes first, and then worry later, if at all, about how the supporting infrastructure can be provided The communities that are created as a result of such a short sighted policy will be anything but sustainable",

48.  The need to build new homes is seen as an absolute imperative and is used by the Government as a mandate to sweep aside any concerns that people may have about the environmental impacts of those plans. We find it deeply worrying that there is no appetite within the OPDM to take on the building sector and guarantee that these homes will be built to sufficiently high energy efficiency and environmental standards. What we find reprehensible is the clear signal from Government that it really does not matter that these homes are going to be built before supporting infrastructure is in place. And we reject the implication that the people .for whom these new communities are intended will be so grateful to have a home, that they will be prepared to put up with substandard communities rather than sustainable communities.

Whilst there were elements of cross boundary regional planning that were valued by communities, the imposition of unelected Regional Assemblies/Delivery Vehicles and the housing target culture of the last 10 years undermined this. We recall well how identified key growth areas were driven ahead of the regional assembly planning process, even to the point of setting up government development agencies with development control power. We recall how when it was felt the RA were not providing the targets wanted how the NHPAU was set up and immediately after the EE Plan was published, it was required to review, with a view to increasing the housing targets both during the lifetime and after the plan period, and to test the NHPAU vastly increased housing targets that this body put forward.

The last Government in a simplistic way used developers to try and build its way out of an affordable homes crisis and rising house prices boom, whose causes were multi faceted, including Right to Buy (and the inability of councils to use receipts to provide affordable homes until 2008), the unsustainable lending/credit boom, uncontrolled immigration, change from industrial to service industry/small business, a perception that everyone has a right to own their homes etc. Instead of taking the opportunity of an expanding economy to deal with the issue by dealing effectively with those underlying causes and setting in place long term measures that would ensure the delivery, and more importantly the retention of affordable housing and perhaps most importantly ensuring that infrastructure and jobs were in place to support development. In comparison with European countries we are a small island. It is unsustainable to keep building at a cost to food security, environment and climate change—a more root and branch solution needs to found.

We hope this Government will take advantage of the current financial position and credit squeeze to do what the previous government(s) should have done, Below we set out briefly suggestions for consideration:

1.  Planning for Communities by Communities (town or rural)

We were encouraged by this Government's espoused intent of incentivising Local Planning Authorities to plan and build with the involvement and support of communities. Whilst there will always be those who want no development, most would be happy to be involved in planning development that fits with the local community and meets the needs and aspirations of residents in town or village. Many of our members live in rural communities and would support small affordable developments that are appropriately and sensitively planned in terms of location and design, to be part of the community and remain affordable—unlike the tack on council estates of the 50/60s, and now the 21st First century.

However there is much in the existing planning legislation that disadvantages ppropriate and sustainable development that is supported by co-ordinated infrastructure requirements eg PPS25 with its requirement for a rolling five year land supply.

We are extremely concerned that the DCLG letter of the 24 June in respect of LEPs having a role in planning and housing as well as infrastructure and jobs is just a downsizing of the RSS/RES model, and that the espoused localism is just espousal, with no substance. We are also concerned that LPAs are being required to put forward outline proposals for LEPs by the 6 September before the-White Paper or draft Localism Bill has been published in order that they can make informed choices.

However we are of the view that local Community planned housing and economic development should be supported (not led) by cross boundary, and cross regional infrastructure planning that is driven by bottom up community planning. Particularly as the mindset of many planning officers and councillors remains focussed on housing targets, ignoring the fact that many authorities are in infrastructure deficit.

2.  LPA audit and assessment of existing empty residential and employment sites

We would like to see up to date registers kept by Local Planning Authorities of empty residential and employment sites and assessed plans to bring them back into use. In addition for the Government to give this a higher priority with incentives provided to LPAs as well as increasing existing powers to address this situation. A large number of authorities do little more than wait till a privately or publicly owned property is seriously affecting the surrounding area—in particular with employment sites where, following assessment in respect of predicted employment site requirements, a change of use could be considered. There are too many examples in towns, cities and indeed rural communities of owners, public OT private, allowing property to fall into disrepair, with the subsequent social consequences. Developers obviously prefer green field or cleared sites for development—but it is quite nonsensical that areas of towns, cities and villages fall into dereliction, sometimes deliberately, before decisions are made, if indeed any decision is made.

3.  Revocation of the Right to Buy Legislation to ensure affordable homes remain affordable

We applaud the last Government in 2008 allowing receipts from the sale of social housing to build more—however this is far too little and too late. Whilst the principle behind Right to Buy may have been laudable, we have the situation now, where there is a crisis in affordability, and social housing being lost to the rental and private home market sector—with an impossibility for LPAs to replace and increasing pressure on land. In addition we have long had the problem in respect of social housing for life. In some cases this may be appropriate, in others it is clearly not. We consider it is flawed to espouse-that everyone has a right to own their own home—however a right to a decent habitable home is appropriate. We support social housing whether rented or part owned for those who can not afford private rented or owned homes, but these homes must remain available as such. We are of the view that Right to Buy should be revoked as unsustainable.

We are also of the view that there should be encouragement of the culture of rental market over the 1980s culture of ownership, to give populations greater freedom to move freely in response to changing personal and economic situations.

4.  Legislation on minimum standards and regulations of existing private and social rented accommodation accompanied by a "whistle blowing" mechanism for tenants

In the last 15 years the need for affordable homes has been accompanied by an increase in sub standard rental accommodation, where in many cases landlords/agents maximising their profit has led to the sort of housing conditions in some areas that are worse than Victorian times. In addition pressure on LPAs budgets and increasing use of housing associations has also led to a deterioration of social housing stock. We consider it reprehensible that Government after Government has failed to address the-deteriorating situation, and vulnerable tenants are not in a position to take action.

5.  Building standards code, and Sustainable Homes Code to be made mandatory and enforced—noting that only 30% new builds currently meet building regulations

The consequences of the lack of priority in planning for sustainable design, architecture and building regulation monitoring during construction during the boom years will leave a long tail as buildings do not stand the test of time. In too many cases housing developments and indeed commercial buildings have been erected quickly and cheaply en masse and a matter of 20 years often shows the poor construction and design. The perverse incentive of the profit motive, unless regulated and enforced, will continue this trend and long term planning for sustainability and climate change will be lost.

6.  Government incentives and disincentives and increased LPA powers in respect of the second/holiday home market

Desirable holiday and retirement locations have their particular problems. On one hand we have communities blighted and indeed disappearing due to the prices commanded by the second home market, and on the other by the economic benefits of tourism during what is often a short season, in addition to the cost disincentive of business outside tourism setting up in these areas. This is all compounded by increased health and social costs of the retirement market. We would consider that action needs to be taken to address this situation in particular in restrictions placed on community new builds.

7.  Stringent and enforced reviewable immigration controls, and transitional arrangements for all new EU countries is required to address the uncontrolled immigration legacy of the last decade or so in the short term. Robust longer term immigration policy in terms of work permits, length of stay, and other measures is required, to prevent the current problems recurring, balancing the needs of service and commercial industry, with the realities the economy and space

8.  Increased financial regulation and separation of the banking and investment industry

As this Government will know well, the main causes of the "credit crunch" were the short-term incentives in both lending and investment areas of banking which led to the sub prime market and its failure, and bundling of bad debt into global investment packages. We would wish to see much stronger regulation in respect of lending, and separation of the banking and investment arms of banks.

September 2010



 
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