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. GENERAL COMMENTS
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.
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
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
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. SPECIFIC ISSUES
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.
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 plansfor 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.
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
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 welcomedit
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
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). 
166 Localism must not miss the bigger picture on planning
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
YouGov survey for CIH http://www.cih.org/news/index.php Back
Responsible choices for a fairer future: CSR submission and evidence
document, NHF/CIH/NFA http://www.cih.org/policy/CSR_July2010.pdf