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

Written evidence from the Chartered Institute of Housing (ARSS 135)


1.1  CIH welcomes the opportunity to respond to the Select Committee's Inquiry. CIH is the professional body for people involved in housing and communities, with a diverse and growing membership of over 22,000 people both in the public and private sectors. CIH exists to maximise the contribution that housing professionals make to the wellbeing of communities.

1.2  Many of our members are involved in the delivery of new homes for social rent, low cost homeownership and specialist supported housing. We also have members involved in the strategic housing role in local authorities, and therefore the planning system and changes to it are areas of great importance for them and the communities they serve.


2.1  We strongly believe that robust strategic spatial planning above the local level is essential for strong and well-functioning places. We have made this point in a recent joint letter to the Rt Hon Eric Pickles.[166] There, we stressed the need for developing new forms of inclusive strategic planning and investment, ie any form of planning (statutory or otherwise) which enables communities to express a vision for the future of an area wider than their own. We believe that taking this forward is particular urgent (given the abolishment of the RSS) in order to limit any adverse impacts that this may have on investment whilst communities consider and implement alternative approaches.

2.2  In the light of forthcoming demographic challenges, ie population increases, new household formations and an ageing population, the need for more housing development and more affordable housing in particular, is now critical (currently there are a record 4.5 million on housing waiting lists and 2.6 million in overcrowded housing).

2.3  The transition to a new planning framework must be made quickly, efficiently and with minimum disruption to maintain ongoing development. Uncertainty and confusion will put delivery of much needed housing at risk.

2.4  The new planning system needs to be one that promotes growth and development, encourages a robust strategic approach and is clearly linked to economic growth.

2.5  It appears that the proposed incentive system in itself will not necessarily deliver the right housing in the right places; it needs to be coupled with well understood evidence and strategically planned responses.

2.6  The housing needs and aspirations of the most vulnerable and marginalised groups in communities must be safeguarded in the localist approach.


3.1  This section will now address the specific issues that the Select Committee has raised for consideration.

The implications of the abolition of regional house building targets for levels of housing development

3.2  Housing delivery in England has not kept pace with the growth in household formation, resulting in significant shortfalls in affordable accommodation; there are already a record 4.5 million people on housing waiting lists and 2.6 million in overcrowded housing. By 2011, it is predicted that there will be more than five million on waiting lists.[167] The need is clearly acute and it is vital that changes made to the planning framework are handled in such a way as to minimise uncertainty over where and what development is required and ensure minimum time is lost in ongoing delivery of much needed homes.

3.3  The abolition of the regional spatial strategies (RSS) and CLG's advice that local authorities may wish to review decisions has had a range of responses from local authorities. In some areas authorities have confirmed the numbers that were established in the RSS and development is progressing. In other areas however, decisions have already been reversed or put on hold, which in the short term means fewer homes being delivered. The long term impacts will not be known until the authorities revise or refresh their local development plans making clear the evidence and priorities they are setting for their locality. The resulting uncertainty is likely to hinder investment and, where developments are halted or advance more slowly due to that confusion, may experience a loss of funding made in principle, including investment by the Homes and Communities Agency. Such uncertainty could also hinder robust conversations between housing strategists and developers in relation to viability and planning gain, quality and housing mix on schemes.

3.4  In cases where local authorities are reviewing plans and decisions, it must be made clear on what evidence base they are implementing changes, and this must be done as soon as is practical, given the concerns about time scales for delivery. The evidence collated for RSS made clear and vital links between housing development and economic growth, demographic changes and environmental concerns; all of which should be considered in the evidence base being used. And more evidence on the benefits nationally and locally of house building needs to be clearly demonstrated in plans—for example, the modelling for our CSR submission that demonstrates that, for every £1 on spent on house building, £1.40 in gross output will be generated.[168]

3.5  The research gathered at the regional level enabled a greater methodological consistency across local areas, and the regional structures and process were well developed; it is likely that, in some areas, there will be a gap in the policy and evidence at the local level, where there was reliance on the shared evidence base. A presumption in favour of following the RSS evidence and numbers until local authorities have had time to review core strategies and refresh their evidence base, should be considered to prevent greater confusion and delay to much needed development. This would enable local authorities to develop a strong system of inclusion and conversation with all groups in local communities as well. The Decentralisation and Localism Bill should include directions for assessing needs that will support both consistency and robust plans that local authorities can ensure maximise planning benefit for local communities.

3.6  The need to involve communities in robust consultation processes to set new core strategies and planning frameworks is a critical issue. However, more clarity is needed about what 'local' means in planning decisions, and how potential disagreements in and between communities will be resolved and reconciled in the process. In particular this needs to be considered in relation to the economic and social advantages which development can bring, but which is likely to cover a more dispersed area than the small locality (and community) in which the development actually takes place. This consideration also applies in respect of the type of housing that may be needed in a local area. CIH has many members involved in providing housing for very marginalised and vulnerable groups and there is real concern that these may loose housing opportunities in a new planning framework. In particular, concerns were strongly expressed about the difficulty for the identification and development of sites for gypsies and travellers, and doubts about the ability of the incentive system to address this. Now that targets and the regional architecture, including government offices have gone, it makes strong local leadership even more important in order to build the right homes in the right places, taking into account the needs of marginalised groups and local communities.

The likely effectiveness of the Government's plan to incentivise local communities to accept new housing development, and the nature and level of the incentives which will need to be put in place to ensure an adequate long term supply of housing

3.8  Incentives that can encourage communities to support develop are welcome, and it is appropriate that communities should receive benefits from new developments in their area. However, there are still many questions around the proposed New Homes Bonus, and need for greater clarity before a realistic assessment of its potential impact can be made.

3.9  CIH understands that the New Homes Bonus will be funded from existing finances rather than additional monies, ie where it is a benefit to one locality, it will be a loss to another local authority where there is less opportunity to build (either in terms of availability of land or agreement with communities). Whilst this may also indirectly incentivise local areas to work together to develop a strategic approach - which is to be welcomed—it may take some time before local communities averse to building feel the impact of those decisions. The risk is that this may happen in areas where affordable housing is most greatly needed. Areas where the necessary development would be small in number, such as in villages, will not necessarily see the amount of benefit received from the incentive as enough to compensate for development.

3.10  There will need to be some clear guidelines for the use of the New Homes Bonus; in particular it should be clear how it might work alongside, rather than replacing, current housing planning gain tools such as section 106 agreements. The incentive, by itself, will not necessarily deliver the right type of housing in the right places (size, tenure or specialist provision), without a robust strategic approach by local authorities. The strategic approach needs also to be developed across local boundaries to maximise the connections to economic growth and job opportunities. Other mechanisms to support development should also be included, such as a review of the meaning of "best consideration" that will encourage public sector bodies to prioritise use of land for affordable housing before other purposes.

3.11  In terms of the nature and level of the incentive, we understand that building affordable housing will bring an increased level of incentive of 125% of match funding, but what the term "affordable" encompasses could usefully be further refined. As with planning gain currently, the inclination may be to agree to local cost home ownership as acceptable affordable housing, where the real need may actually be for social rented housing or specialist accommodation. Again, this is a particular concern for those CIH members working with more marginalised groups.

3.12  The problem of how extensive the incentive scheme can be in the climate of public sector cuts is also a critical issue; it could be hugely damaging to the aims of localism if new homes are agreed but the timing of development means that money for the incentives has run out by the time they are completed; consideration should be given to providing at least part if not all of the incentive on planning consent. Quality and design should be recognised as significant element that can also encourage acceptance of development along with robust environmental standards, and some reflection of long term sustainable measures (for example Lifetime Homes standards) could also usefully be reflected in the incentives. The incentive scheme as currently modelled is very expensive and raises questions as to its viability. Furthermore, given that local authorities have lost considerable amounts of money they would previously have got through s106 due to the economic downturn, development incentive money is simply a replacement rather than an additional resource.

3.13  It also has to be recognised that even the most generous incentive scheme can only achieve so much. For instance, a recent survey[169] commissioned by CIH has revealed that a small but active minority of generally older home owners is opposed to new housing being built in their area. The results showed that 15% of respondents agreed that they were opposed to new homes being built in their area and this rose to 20% for retired people and 22% for those who owned their home outright. This implies to things, firstly local authorities will have to become better at engaging with communities around the social and economic benefits of new housing (including presenting robust data of local housing need) and secondly there needs to be a better understanding of the "right" level of incentives that will make people accept new housing as well as anything else that would help make communities more comfortable about it. It is important that any consultation exercise is as inclusive as possible and gives equal voice to all section of the community and not only to those who are already engaged if NIMBYism is to be avoided.

The arrangements which should be put in place to ensure appropriate cooperation between local planning authorities on matters formerly covered by regional spatial strategies, and

The adequacy of the proposals already put forward by the Government, including a proposed "duty to cooperate" and the suggestion that Local Enterprise Partnerships may fulfil a planning function

3.14  The government has proposed a "duty to cooperate" to ensure that local authorities work together on matters formerly covered by the RSS. These areas (including transport for travel to work issues) could usefully be explicitly set out in the Decentralisation and Localism Bill and in the proposed National Planning Framework. Without that there is a risk that a parochial approach will lead to loss of housing opportunities and shared solutions, particularly for some marginalised groups where the numbers for scheme development work at a sub regional rather than local level.

3.15  Some sub regional groups under the previous structures made significant progress in developing the data and evidence and strategies that reflected local priorities and characteristics, and the new framework should provide incentives and encouragement for these partnerships to continue.

3.16  Local Enterprise Partnerships may be another route for planning delivery, in particular as this may encourage stronger links between economic and housing development. If this is the case, it will need to be clear how the planning powers they have work through their democratically accountable local planning authority partners. It is likely however, that the current economic situation will mean, rightly, that their capacity is concentrated on encouraging economic growth.

How data and research collected by the now abolished Regional Local Authority Leaders' Boards should be made available to authorities, and what arrangements should be put in place to ensure effective updating of that research and collection of further research on matters crossing local authority boundaries?

3.17  The evidence base that supported previous RSS was developed and held by a range of partner bodies, such as Regional Development Agencies and Regional Observatories as well as the Regional Local Authority Leaders Boards. There was a consistent methodological approach and robustness in linkages made to economic development which would remain a useful model for local authorities. However, increasingly this was based on a housing market area rather than local authority boundary, which would make any comparison and analysis going forward more difficult, unless authorities are encouraged and incentivised to take shared strategic approaches on key elements forward (as paragraph 3.15). It will be important to make the wealth of research and evidence available for future use and easily accessible; potentially the Homes and Communities Agency, in partnership with a lead local planning authority, or with regional observatories, might be the well placed body to support and work with local authorities in ongoing research and evidence gathering.

3.18  Needs assessments in future must also take account of the impacts from the wide reforms being taken forward by the government. Modelling has suggested that the Housing Benefit reforms will mean people moving from some high value private rented sector areas, to cheaper areas, and a consequent increase in demand for social housing. Local authorities may also need to take shared strategic approaches to how they use the private sector in meeting their homelessness duties in the future. This reinforces the need to ensure the new planning framework supports a robust strategic approach across housing and planning by local authorities. (CIH in its CSR submission has made the case for ongoing investment in this vital strategic function). [170]

September 2010

166   Localism must not miss the bigger picture on planning http://www.rtpi.org.uk/item/3937/23/5/3 Back

167   For more evidence see; Responsible choices for a fairer future: CSR submission and evidence document, NHF/CIH/NFA http://www.cih.org/policy/CSR_July2010.pdf  Back

168   IbidBack

169   YouGov survey for CIH http://www.cih.org/news/index.php Back

170   Responsible choices for a fairer future: CSR submission and evidence document, NHF/CIH/NFA http://www.cih.org/policy/CSR_July2010.pdf  Back

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