Written evidence from the Planning and
Development Association (PDA) (ARSS 137)|
Revocation of Regional Spatial Strategies
The effects of revoking RSSs are of more immediate
concern than abolishing regional targets;
longer-term, planned numbers will probably be reduced
in many places; guidance is needed on how to produce policies
with housing numbers that are not maxima and which allow them
to be exceeded if proposed development does no "harm";
the sudden revocation of RSSs left a planning vacuum,
which is deterring developers from submitting planning applications
in many places; and
the new planning system will not be operational for
up to four years, so interim guidance is needed to prevent a lengthy
hiatus in planning for housebuilding.
Community incentives to accept new housing
the impact of the New Homes Bonus will be difficult
to judge until the scale of grant reduction is known; and
if houses cannot be built profitably the Bonus will
not be achieved by local authorities, so it is equally important
that Ministers address development viability as well as incentivising
Co-operation between local authorities and Local
currently LEPs seem to be driven by the need to agree
local authority groupings rather than their boundaries being determined
by their purpose and goals;
LEPs should be statutory consultees on cross-border
matters, particularly infrastructure; and
there should not be too many LEPs and they should
be sufficiently strategic in scale.
Implications of the abolition of regional housebuilding
targets for levels of housing developments
The policy vacuum left by the revocation of RSSs
is having more impact on developers currently than the longer-term
effects of the abolition of regional and other targets. The need
for substantial numbers of additional houses is widely accepted
across the political spectrum as a result of discussions about
housing numbers at RSS level and the work done by bodies such
as the NHPAU over the last decade. However it will remain difficult
to persuade people in the locations where it is most needed of
Housebuilding levels are determined by the effects
of the credit crunch, economic uncertainty and mortgage shortages
at present, not by the existence or otherwise of regional targets.
Nevertheless targets are important and their absence
can, as has been the case in the past, restrict housebuilding
output to below market demand levels. Without top-down targets,
excessively low figures should not be allowed to be substituted
at local level, without proper evidence and sanction.
New national planning guidance approved by Parliament
should determine how far local authorities will be free to reduce
numbers; the evidence needed to justify numbers and whether these
are to be the only test for local plan policy and for determining
planning applications, or whether other more flexible, criteria-based
policies will be encouraged (eg whether a particular planning
application involves sustainable development and it does no harm
to the objectives of the plan).
It seems inevitable, because that is the wish of
many local authorities, that the policy targets in many high demand
areas will be reduced. However it will depend on the nature of
planning guidance issued whether those numbers are ceilings that
cannot be exceeded or just one amongst other measures against
which planning applications are judged and hence housebuilding
The revocation of RSSs
The revocation of RSSs was not a surprise because
it was clearly indicated in the Conservative Party's policy documents
of 2009 and was confirmed in the Coalition Agreement. However
of great concern has been the inadequate attention that has been
paid to the need for transitional guidance following that revocation.
The sudden withdrawal of draft and adopted plans
by some local authorities has created a planning vacuum in those
areas and left applicants without a planning framework or any
plan backing against which to make planning applications. This
will both disrupt the pipeline of land that is always required
to maintain development and could also prevent smaller sites that
could come forward from doing so.
Our members' experiences suggest that local authorities
have responded in a number of ways:
the suspension of existing approved or emerging Core
Strategies and other development plan documents;
suspension of work on plan documents in order to
change policy - generally assumed to mean a reduction in housing
suspension of policy development pending further
guidance from Ministers; and
continued support for Core Strategies based on RSS
often, but not exclusively, in areas in the Midlands and North
that are seeking regeneration.
It had been expected that Ministers would provide
advice to secure a smooth transition to the new system, including
instructions on the process and evidence base required to change
existing plans. This is vital because it provides confidence that
the system will continue to support the development of much needed
homes as well as the economic and employment benefits of housebuilding.
An essential element in any such guidance is the
status of five and ten to fifteen year land supply and how this
should be calculated on up-to-date data. Moreover, the evidence
base to which new plans refer must be kept up to date and, following
the abolition of NHPAU, local authorities will need a consistent
source of data to produce equitable results between authorities.
Ministers do not appear to have considered this or to regard it
Without adequate transitional guidance developers
currently lack confidence to make planning applications and this
is likely to continue for as long as there is no enforceable timetable
to end it.
Furthermore, if local authorities continue to suspend
plan-making until the new system comes into effect (probably in
April 2012) the transition could last for at least four years
because replacement plans will take at least another two years
to produce. Planning must not be left in suspension for such a
To allow the system to function and to provide a
framework for making planning applications, Government must provide
local authorities with an indication of the time within which
they must make changes to their development plan (preferably short);
remove doubts about work that may be redundant because of changes
in legislation (the Decentralisation and Localism Bill); set out
the evidence base required for any reduction in housing numbers
in local plans and set out other tests of soundness and sanctions
if the work on development plans continues to be suspended.
The Government has undoubtedly created problems for
itself in respect of such guidance because it may conflict with
the "localism" agenda and the freedom it wishes to grant
to local authorities.
But a lengthy planning hiatus also conflicts with
the Government's aim of delivering high levels of housebuilding.
However much Ministers may dislike the existing system, it cannot
be summarily halted without publishing effective and workable
arrangements that both local authorities and applicants understand.
The effectiveness of the Government's incentives
plan and its nature and level if an adequate long-term supply
of housing is to be secured
Since the New Homes Bonus is intended to change the
attitude of local authorities and communities to development it
is the essential accompaniment to revocation. It is vital that
full details are published as soon as possible, because too little
information is available to allow judgements to be made about
its likely effectiveness.
We understand that the Bonus can be accrued by local
authorities in the next financial year so they are being encouraged
to grant planning permissions now to benefit from completions
The system is understood to be financially neutral,
funded from a reduction in grant funding to local authorities,
with this acting as an incentive to build homes in order to secure
the Bonus. We do not yet know the scale of grant reduction that
local authorities will suffer to allow us to judge whether six
years of additional community charge receipts will be sufficient
to overcome objections in the most NIMBY areas.
To fully incentivise them, Government must make it
clear to local authorities that the Bonus is part of a package
of arrangements, including Section 106 and the Community Infrastructure
Levy, which will be attached to the development of new homes.
However, given that new house prices are still 20%
below their 2007 peak the amount local authorities can take should
not be so great as to further damage development viability. This
issue must be central to any new policy and local authorities
must be assisted and required to understand it.
It is not just local authorities that require incentivising.
Developers need to see a reduction in the heavy and expensive
burden of regulation which is now a major obstacle to development.
Unless housebuilding levels can be increased, simply incentivising
local authorities will be deeply unpopular with councillors and
local communities because the anticipated revenues will not be
received. As much attention must be given to the problems of development
viability as to the New Homes Bonus, because otherwise it merely
reduces local authority grants.
Co-operation between local planning authorities
on matters formerly covered by regional spatial strategies and
the suggestion that Local Enterprise Partnerships may fulfil a
Very little will be known about Local Enterprise
Partnerships until after the Spending Review on 20 October. They
are supposed to provide strategic leadership and set out economic
priorities, creating the right environment for growth by tackling
issues such as planning and housing, local transport and infrastructure
but it is not clear how they will fulfil the planning function
envisaged by BIS and CLG, if all such powers reside at local level.
BIS/CLG also said that Partnerships should include
groups of upper tier authorities and could match regional boundaries
if they chose to do so but the 56 bids submitted are all much
smaller and a number reflect county boundaries.
If they are to fulfil an effective sub-regional planning
function and work together on matters formerly covered by Regional
Spatial Strategies they must not be so fragmented that they cannot
offer adequate strategic direction; it is difficult to imagine
that such small groups can be genuinely business-led and focused
on sustainable economic growth.
There have been 56 bids submitted, far too many to
deliver strategic leadership at sub-regional level. When assessing
the bids Government must seriously consider whether they do cover
meaningful economic areas and have genuine critical massmany
business leaders fear they will turn out to be no more than council-dominated
talking shops with no sense of strategic priorities and little
economic impact. A further significant factor is whether there
will be sufficient funding for them to carry out any meaningful
duties and, again, this will not be known until after the Spending
Review in October.
LEPs should have a key role in advising on cross-boundary
problems, particularly infrastructure and large scale development,
and should be a statutory consultee on development plans and major
planning applications, which have cross-boundary impacts.