Written evidence from Barton Willmore
(ARSS 124)
1.0 SUMMARY
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.
3.0 THE LIKELY
EFFECTIVENESS OF
INCENTIVES
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.
4.0 ARRANGEMENTS
TO ENSURE
COOPERATION BETWEEN
AUTHORITIES
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.
5.0 CONCLUSION
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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