Written evidence from Redcliffe Homes
The decision to abolish the Regional Spatial Strategies
(RSS) without any transitional arrangements and then to republish
PPS3 with references still to RSS was poorly thought through and
nothing more than a knee jerk reaction from the new Coalition
Planning needs certainty but the current lack of
adopted policy to guide development is leading to confusion by
Local Authorities and consequently causing delay in getting consent
for housing development.
Without guidance and proper decision making from
Local Authorities, developers are having little choice but to
take sites to appeal.
The Planning Inspectorate will be unable to cope
with the increase in Planning Appeals. The time to receive an
appeal date has already increased to six months in some instances.
A number of Local Authorities will find that their
enthusiasm to reject housing targets set by RSS returns to haunt
them when their Local Plans are rejected and house builders obtain
unacceptable planning permissions by default in areas where locals
do not want it.
Overall levels of housing development are and will
continue to decrease in this policy void. Furthermore, the Government's
localism agenda will do nothing to help the situation as it will
be difficult to ever incentivise communities into wanting housing
development in their back yard. The current proposals of six years
equivalent Council Tax financial incentive equates to circa £10,000
per housebut Local Authorities already receive an average
of £9,500 in S106 payments (excluding affordable housing
provision)we do not believe this on its own will be sufficient
to overcome the natural inclination to oppose local development
LPA's be required to formulate their LDF's using the locally derived
RSS Option 1 housing supply figures, with a further obligation
for the overall allocation numbers to be fully debated through
the LDF process and the Independent Planning Inspectors review
of numbers accepted without challenge.
Implications of the abolition of regional house
building targets for levels of housing development
Almost four months have passed since the abolition
of the Regional Spatial Strategies (RSS), and we are still experiencing
local authorities in states of uncertainty and chaos given the
lack of guidance from government. This has led to confusion and
misguidance given to developers which is undoubtedly having a
huge negative impact on delivering housing land.
Unlike local authorities in the south east which
were further forward in their LDFs due to an adopted RSS, many
Local authorities in the south west were only on the road to producing
Submission Core Strategies. Once the decision to abolish RSS's
was announced, most of the progress towards these documents was
put on hold until further clarification from DCLG ministers. Without
the RSS to guide and shape their policies, local authority decision
making and consequently, housing development has ground to a halt.
It is Redcliffes experience that most Local authorities
in the south west are using the abolition of RSS to re-examine
their housing figures downwards even though many of them agreed
to these figures by putting them forward to the draft RSS. Whilst
we are finding a lot of support from Local Authority Planners
within Strategic Policy departments not to abandon the hard work
that has gone into formulating and submitting these housing figures,
their committees are taking an entirely different view. We are
being told by many local authorities that Councillors are all
too are keen to review and reject housing targets that they previously
agreed to in order to please their constituents and ensure re-election
at next May's local elections. Housing development is never seen
as popular and if there is an opportunity to reduce or remove
it then Councillors will take it. This may well fit in well with
the Government's localism agenda, but unfortunately this approach
will inevitably lead to reduced rates of housing development.
According to the Chartered Institute of Housing,
the population in the south west is set to increase by 24% by
2031. Given the current state of housing supply in many south
west Local Authorities, with only a handful having a five year
land supply, the region is set for a serious shortfall of housing
that is already at its lowest building rate since the 1920s.
The question of how housing targets are set has presented
itself with problems throughout the years and throughout different
Governments who have blown hot and cold on regional planning.
Its abolition is of course nothing new. In the early 1990s lots
of authorities relied on increasingly dated plans to make planning
decisions, and as a consequence appeal rates increased. In 1998,
John Prescott announced the abolition of a "top-down"
approach to planning, moving away from "predict and provide"
to allowing locals a greater say in the amount of housing required
in their area. However this proved unsuccessful as local planning
authorities were reluctant to set their housing targets too high
and so we saw the return of the top-down approach in 2004 with
the Planning and Compulsory Act 2004 which gave the Secretary
of State the last say in housing figures. This is crucial if housing
demand is to be met.
Clearly however past lessons have not been learnt
and the implications this time around are proving no different.
Without proper guidance and adopted policy, we are experiencing
Local Authorities that are unsure on what planning decisions to
make and so appear more than happy that the decision is being
taken out of their hands and made by the Planning Inspectorate.
Unfortunately, what they don't seem to understand is that planning
by appeal will only lead to housing development in locations where
many locals will not want it. Councillors must be educated to
tell their constituents that development should not be seen as
something to tolerate and object to, but something which they
can have a say in and influence to benefit their community and
provide the infrastructure and facilities that they need.
The Coalition government plans to incentivise local
authorities by allowing them to keep the council tax raised from
new properties. The more houses they allow, the more money they
will have to pay for increased services. In principle this is
all well and good and may be attractive to local authorities but
it is doubtful whether it will make any difference to the local
communities themselves. It is our view and experience in dealing
with the public that local communities already expect their council
tax to go towards facilities such as new schools, sports provision
etc. Furthermore if there are new houses proposed the expectation
is all too often that us as developers will fund these things.
It is therefore unlikely that that anything will change and that
this approach alone will incentivise local communities to bring
housing land forward.
Indeed, a number of Local Authorities will surely
find that their enthusiasm to reject housing targets set by RSS
returns to haunt them when their Local Plans are rejected and
housebuilders obtain unacceptable planning permissions by default.
According to the "Open Source Planning Green
Paper", each Local Authority will now be required to assess
housing need in their own area. No mention is made of how they
might resource this assessment, bearing in mind they've never
had to do it before and they are already under pressure to reduce
costs. Guidance and finance will be required at a national level
to assist these councils if they are to conduct robust projections
of housing need that are unchallengeable. Overall, it is difficult
to see how any of this will bring forward housing delivery.
In summary, it could be said that the real problem
is not necessarily the removal of the RSS, but the complete lack
of any strategic-level alternative and the short-sighted view
that the major issues of housing shortage and infrastructure delivery
can be delivered through a system, which seemingly seeks only
to pander to those 'locals' who are able to shout the loudest.
Decisions on planning applications must be judged on their own
merit, not on the basis of political whims. Such weakness in the
planning system will fail to deliver the housing required and
will further threaten economic recovery.