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

Written evidence from Barton Willmore (ARSS 124)


1.1  This evidence is submitted by Barton Willmore LLP, the UK's largest planning consultancy. Within the planning profession there are a number of concerns with the abolition of RSSs:

1.  The drive to achieve the step change in housebuilding will be lost—housebuilding has the potential to be an important engine of economic recovery as well as meeting fundamental social needs;

2.  Urban extensions around our major cities and towns are the most likely casualties of the localism agenda—potentially having an adverse effect on economic growth and sustainable development solutions;

3.  No interim procedures were put in place when the announcement of the abolition of RSSs was made - leading to significant loss of momentum in bringing forward large strategic sites.

1.2  We therefore recommend the Government to:

1.  Do more than they have so far to emphasise the social and economic benefits to the Country of higher levels of housebuilding as a context for localism, and to include in their National Planning Guidance a desired level of housing for the Country as a whole;

2.  Clarify the detailed position on incentives and the level of housing delivery to be increased;

3.  Put in place effective arrangements for cooperation between adjoining local authorities;

4.  Ensure that plans continue to be evidence based—particularly with regard to the assessment of housing needs (identified by a robust and independently examined methodology); and

5.  Articulate, as a matter of urgency, a set of interim arrangements that will guide the planning process through the next three or four years, based on the continuation of Local Development Frameworks in order to avoid situations in which delays in the planning system result in a shortfall in housing land and the delivery of new homes.

2.0  The Implications of the Abolition of Regional House Building Targets for Levels of Housing Development

2.1  The problem that first began to be recognised in the middle of the last decade is that we were building far too few houses. The evidence is provided by demographic projections. These provide a picture of important social trends such as the effect on household formation of an ageing population, marital breakdown, more people living alone and more people moving into the country. They are not perfect tools but they are by far the best we have available to plan for housing, and they should not be discarded lightly.

2.2  Kate Barker, in her 2004 report on housing, first drew attention to the underprovision of housing, and the drag it was having on the economy because of the resulting rise in house prices. In 2006 the first Government Household Projections for England using 2001 Census data showed clearly that household formation was taking place faster than expected, at the rate of about a quarter of a million new households a year, indicating that this is the minimum level of new housebuilding that is required.

2.3  Housebuilding has not reached this sort of level for many decades. Even in the boom years of the middle of the last decade less than 200,000 houses were being built a year in England. This indicates clearly that a huge, sustained effort needed (and still needs) to be made to reach the levels of delivery required. It is our view that this needs to be led by Government, and local communities cannot be expected to respond to it without a central lead. The housebuilding industry needs to be re-energised, new forms of delivery need to be encouraged (and this is an area where we think the Government is making some positive moves) and the lessons of history suggest that a significant social housing programme also has to be a part of the strategy.

2.4  But, above all, sufficient land needs to be made available in development plans to accommodate these homes.

2.5  Regional Spatial Strategies showed what these higher levels of housebuilding might look like on the ground. In particular, they were able to look at city regions as a whole and plan for their needs across district boundaries. The resulting urban extensions, many of them in green belt, have been among the most unpopular features of RSSs. The concerns arising from the abolition of RSSs may therefore be summarised as:

1.  A significant reduction in housing numbers because schemes considered unpopular by vocal residents of the immediate neighbourhood will be abandoned (this is already happening) to the disadvantage of those in the wider community that will benefit from new housing;

2.  Those reductions impacting most significantly on areas of economic growth, because authorities are unwilling to meet the needs of neighbouring authorities, thus jeopardising economic growth; and

3.  By abandoning regional targets the Government has limited the ability to identify the extent to which individual planning decisions contribute to addressing a national problem of underprovision.

2.6  We believe that a National guideline figure should remain for housebuilding as an acknowledgement of the problem, and an easily understood signal to the public in local areas of the scale of the problem to be addressed. A national target is a far cry from prescribing a target for each individual local authority, which was one of the most unpopular features of the Regional Spatial Strategies. We do believe it is important to have a guideline figure for national output in the National Planning Guidance we have been promised. This will be a benchmark against which the Government's proposed incentives can be measured. Having Ministers simply saying that they aim to build more houses than Labour is hardly a substitute for this. Does it mean more houses than in the boom years of 2005-08 or the recession years of 2008-10? If it is the latter then the bar is being set much too low.

2.7  The "Big Society" needs to understand the big picture now that they are entrusted with decisions on the future of housing in their area and, cumulatively, for the Nation as a whole. Rarely do objectors recognise the need to build more affordable homes, and certainly not in their back yards.

2.8  The importance of this to the Nation cannot be underestimated. In social terms, there were 1.8 million families on waiting lists for affordable housing at April 2008. That's one household in eight. The lists began to grow more rapidly in 2002, when they stood at 1.1 million (this predates the introduction of open waiting lists in 2003), and have been growing at the same rate ever since (Local Authority Housing Statistics, England 2007-08, Chart 2 and Table 2) (Appendix A). The average age of a first time buyer, not getting financial help, is now 37 years. Housing is one of the greatest sources of unfairness in our society today. We have a population divided into "haves" —largely older households who bought their houses some years ago and have benefitted from the rise in house prices —and the "have nots"—largely younger households on lower incomes who cannot afford to buy a house at today's prices. This has to some extent always been the case but is becoming increasingly worse.

2.9  The housing shortage also has important implications for the economy. First, private sector housebuilding can be an important engine of economic recovery. This does not just extend to the construction industry itself but to all the suppliers who benefit from people moving to a new house. The Home Builders Federation estimates that each house built creates 1.5 jobs. Second, encouraging private housebuilders ties in completely with the Government's stated aim of rebalancing the economy in favour of the private sector. Third, it is important that there is a plentiful supply of houses in places where jobs are created—and this is one of the biggest worries about the messages that are coming out of the Government.

2.10  Our major cities are the driving engines of job creation. A Report by the Centre for Cities in June (Private Sector Cities: A New Geography of Opportunity) (Appendix B) showed that the largest numbers of private sector jobs created in the ten years from 1998 to 2008 (outside London which far outstrips any of the others) were in a number of large and medium sized cities - Bristol, Manchester, Leeds, Newcastle, Milton Keynes, Portsmouth, Brighton, Preston and Reading. Creation of private sector jobs is key to the Government's plans for economic recovery. But Private Sector Cities shows that in the recent past the picture is one of relatively limited population growth in economically buoyant areas. Restricting the physical expansion of buoyant cities restricts economic growth and job creation. It also limits people's mobility, making it more difficult for them to access jobs in high growth areas because housing costs are too high (p20). In the current recession we cannot afford to jeopardise growth in this way.

2.11  Evidence that we submitted to the South West Regional Spatial Strategy EIP illustrates the point (Appendix C). Economic forecasts for the Region indicated job growth of between 365,000 and 465,000 between 2006 and 2026. The level of housing growth proposed in the Draft Regional Spatial Strategy (which might relate to so called "Option 1" figures) would equate to an increase in workers of 149,000. Even allowing for reduced expectations of job growth due to the recession there is still a significant mismatch. The job growth forecasts allowed for significant improvements in productivity. With many authorities now reverting to Draft RSS levels of housing it can be seen how this could adversely affect job growth.

2.12  We think that this is what is in danger of happening, as the following examples show. Leeds was one of the first authorities to signal its intention not to adopt RSS housebuilding provision. It has resolved to revert to Draft RSS housing numbers of 2260 dwellings per year, compared with 4300 a year in the adopted RSS, a reduction of 40,800 houses over what would have been the lifetime of the RSS. Many of our large cities are constrained by administrative boundaries, such that the only areas for expansion are in neighbouring authorities. Bristol is a good example of this. Authorities around Bristol have all abandoned or reduced the size of urban extensions proposed in the RSS, amounting to the loss of 27,500 houses from the 87,000 planned in the RSS Proposed Changes. Cities such as Newcastle, Manchester, Liverpool, Leeds, Hull, Sheffield are all tightly constrained also.

2.13  The Government has also stated its desire to rebalance the economy geographically, but this has been tried before and failed. At best it will take some time to achieve. In the meantime recovery from the recession needs to take priority and concentrating on the areas with a proven track record in job creation should be pursued.

2.14  We would single out three things that we think need to happen.

2.15  First, the most pressing issue is for the Government to put in place some clear interim guidance. The failure to do so has created a huge amount of uncertainty, and consequently inactivity, among local planning authorities and the development industry. The importance of this becomes clear when the likely timetable for implementing the proposed new local plan system, trailed in Open Source Planning, is examined. The Government has announced its intention to introduce the Localism Bill in November 2010 and have it enacted in November 2011, presumably to become effective from April 2012. However, looking at the sheer scope of the Bill, this timetable will be challenging. It is usual for regulations to have to follow before a new system is introduced. Councils will then need to move across to the new system, and in the case of local development frameworks this was not a rapid process. For the next three or four years at least, interim arrangements will be needed. These interim arrangements will need to be based on the local development framework system.

2.16  Second, we believe that it is important that LDFs should continue to be evidence based. Housing requirements should be assessed on "the provision of good data by the local planning authority to the electors in the neighbourhoods" (Open Source Planning p8) the principles of which should be as in PPS3 paragraph 33 (appendix D). This includes having regard to the Government's latest published household projections and the needs of the regional economy, having regard to economic growth forecasts. If this is to have any meaning, there must be tough national guidance on the type of robust methodology required to identify a target and this must be independently examined. Like the Select Committee's role in calling ministers to account, the Planning Inspectorate should have a role to play in ensuring Local Authority decisions are based on a robust evidence base.

2.17  Third, plans need to be based on cooperation between authorities where issues of common concern arise. In some cases authorities may need to cooperate with more than one group of authorities. We will examine this in more detail below.


3.1  We are pleased that the Government has now confirmed its plan for incentives to local authorities in the form of the New Homes Bonus Scheme. This is a key part of the package they are proposing, which would otherwise have the appearance of a NIMBY's Charter. In principle, we welcome the Government's attempt to, in effect, change the politics of housing to try to garner support for development from local communities which is often lacking at the moment. However, the Minister's letter to Council Leaders of 9 August was worryingly short on detail. Three questions arise. First, is the incentive enough? Second, is it affordable? Third, will the Government actively support the benefits of housebuilding?

3.2  It is understood that the incentive scheme will be financed from existing local authority grants, which, themselves may be expected to fall significantly, though the money from the Housing and Planning Delivery Grant will be added to the pot. Thus, there will be a fairly strong incentive for local councils to build houses as it will be possibly the only way of generating additional revenue, which they will badly need. The Minster's letter of 9 August gives Councils the choice of using extra money to improve or maintain services or to avoid council tax rises. In practice, we believe that councils will tend to opt for spending on services, partly because they will be under heavy pressure to maintain spending and partly because the benefit to individual council tax payers may be quite small.

3.3  It is also understood that the money will only be paid to district or unitary authorities. This begs the question of how the precepting authorities will react to this—county councils where they exist, town and parish councils and police authorities. The county council precept is usually a very significant proportion of the Council tax bill. Increases in this could nullify any benefit to the district of council tax reductions.

3.4  Finally, there is the concern that, because there is a finite, and declining, amount of money available, the Government will end up giving with one hand and taking away with the other, thus nullifying the effect of the New Homes Bonus. The Chartered Institute of Housing has already warned that the Bonus scheme could cost over £1 billion by Year six and may need to be capped. The reality is that all authorities will build some houses, probably quite a lot of houses, the concern being that they will not build as many as are needed rather than that they will not build any at all. John Healy talks about "robbing Peterborough to pay Poole" but the reality may be that it will be "Poole that is robbed to pay Poole" because the residual left after top-slicing is so reduced. If this happens the effect of the New Homes Bonus may be significantly reduced.

3.5  We hope that the incentive scheme works, because localism will not deliver more homes without it, but we have misgivings about whether it will for the reasons set out above. More details are needed about how it will work before a full assessment of its effectiveness can be made.

3.6  We also think that, in parallel with the incentives scheme, Ministers need to sell the virtues of housebuilding more. We feel that mixed messages have emerged so far. The Minister for Housing has expressed himself in favour of more housebuilding on a number of occasions, and this is welcome, but he needs to say more about why it is a good thing. The Secretary of State's pronouncements, particularly about protection of green belt, do cause concern, as this is where sustainable urban extensions to many cities need to take place.


4.1  We have said above that cooperation is important. We welcome the Secretary of State's acknowledgement in a letter to the President of the RTPI that "'Larger than local' is important to us" (Appendix E). Open Source Planning indicates that legislation will include a duty to cooperate (p10). This applies to all adjoining authorities, but we expect that in practice groupings will emerge related to counties or city regions, many of whom cooperate already through partnership arrangements and local area agreements. Councils will also continue to pool resources to provide services jointly in a bid to save money.

4.2  In respect of the matters listed by the Committee in the first bullet point (waste, minerals, flooding, natural environment, renewable energy, etc) we believe that authorities can and do cooperate, and we have few concerns about their ability to do this.

4.3  We do have concerns about the effectiveness of any cooperation regarding housing and economic development, particularly in city region situations where the core city is constrained by administrative boundaries and its development needs need to be met in other districts. Here, we think that there will be resistance by the surrounding councils to urban extensions in their districts, and generally the core city authority will defer to these sentiments, particularly if they are under the same political control.

4.4  We can only see a role for Local Enterprise Partnerships in planning if the constituent councils want them to undertake it. This might be an expedient to save money, but may lead to clumsy operation if each constituent authority wants to approve key decisions individually. Another possibility is that groupings that could form if Place Based Budgeting is introduced could also carry out strategic planning functions.

4.5  Pooling resources seems to be the only way that joint intelligence will be procured. We see little need to pool information and intelligence at a regional level if there is no regional strategy. The need will be at the sub-regional level—the county and city region groupings we have referred to above. Local Enterprise Partnerships are well placed to undertake this work providing their budgets allow.


5.1  There are a lot of concerns about the way the new system will operate, which have been exacerbated by the failure of Ministers to announce transitional arrangements. We therefore welcome the Select Committee's interest in these matters and hope that these comments will assist the work of both the Committee and Government.

September 2010

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