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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