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

Written evidence from Redcliffe Homes (ARSS 156)


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 Government.

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 house—but 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 .

Recommendation—That 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.

September 2010

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Prepared 31 March 2011