Written evidence from Star Planning and
Development (ARSS 15)
SUMMARY
By reason of the current revocation and proposed
abolition of Regional Spatial Strategies:
There is a need for a framework at national and sub
area level for the provision of housing to at least provide a
metric for monitoring housing provision if only to assist with
the distribution of financial incentives and to potentially act
as a "stick" in default of a locally derived and robust
housing provision;
There is the inherent potential for conflicts between
local planning authorities wanting growth or financial purposes
versus the local community who may remain resistant to new development;
and
As a consequence of the abrupt policy vacuum caused,
there will inevitably be delay in the preparation of Local Development
Frameworks (or Local Plans).
HOUSING PROVISION
1. The proposed abolition of Regional Spatial
Strategies (RSS) is not a new idea and there has been a period
of at least 12 months for the current Government, when in opposition,
to devise robust alternative arrangements. However, such arrangements
were not devised and are still not in place other than the proposal
to encourage Councils to accept housing growth via financial incentives.
2. The Select Committee will receive more
detailed evidence on this matter but, based on Star Planning and
Development's experience, it is clear that local planning authorities
are revisiting previously accepted policies concerning housing
provision and this is resulting in delays to the preparation of
Local Development Framework/Local Plans (a minimum of six months
and perhaps up to 18 months) and refusing schemes which might
otherwise have been approved (whether on application or appeal).
3. As part of this submission, Annex 1 comprises
a letter is attached dated 8 October 2009 to Bob Neil MP covering
the concerns of Star Planning and Development following his presentation
to a RTPI sponsored event in Manchester during the Conservative
Party Conference. From a cursory inspection of the letter's contents
the reader will note that some of the issues now identified by
the Select Committee were highlighted to Mr Neil in October 2009
and an approach suggested which could potentially have avoided
the current malaise and uncertainty in the planning system caused
by the blunt approach of revoking RSSs. Further, the suggested
approach would ensure generally that the process of distributing
housing growth would be democratic and major decisions locally
based albeit with a "stick" to ensure that the wider
housing needs of the country are met through the planning system.
No response was forthcoming from Mr Neil.
4. An area of particular concern is that
there is an established link between house prices, housing supply,
economic growth and social well-being which was demonstrated by
Kate Barker's Review of Housing Supply. Without some form
of national context or framework for the provision of new dwellings,
how can there be a reasonable degree of certainty that the housing
needs of the country would be being met in a co-ordinated manner,
including the wider issue of infrastructure providers providing
the necessary capacity and services?
FINANCIAL INCENTIVES
5. The financial incentives being advocated
by the Government as the preferred approach to encourage additional
housing do have some merits if allied to disincentives for those
authorities failing to provide their "fair share" of
country's new dwelling requirement. However, there are two specific
concerns which arise:
(a) Will there need to be a benchmark against
which the housing provisions and financial incentives will be
tested? If this is the case, what will the benchmark be and how
will it be established?
A clear framework to allocate the available funds
needs to be established and, logically, there must be a "target"
housing provision, whether nationally, regionally or locally,
against which the payment of financial incentives can be measured.
The only other alternative is a metric based on the number of
new homes provided within each administrative area. Accordingly,
some of the rural areas, especially those in National Parks and
Areas of Outstanding Natural Beauty, would materially "loose
out" because of the very tight controls on new house building.
(b) The tension (or as the Government refer
to the matter an "honest debate) between an authority which
is perhaps seeking to maximise the financial benefits associated
with new housing versus the local community who may be against
any new development. The so called NIMBY to YIMBY argument raised
by Mr Neil last year.
Many local communities welcomed the revocation of
RSSs because they perceived the potential threat of new development
was removed (Star Planning and Development currently has such
experiences). However, given the financial incentives being suggested
by the Government, together with the potential for new development
to fund wider community benefits via a reformed Community Infrastructure
Levy, pursuing growth may well be attractive to a significant
number of authorities. Accordingly, the growth originally envisaged
in a particular location identified the in revoked RSSs would
potentially only be delayed. It should be noted that the RSS locations
were generally based on robust evidence bases and new studies
are unlikely to come to different conclusions. When it is again
suggested by an authority that growth should occur at a previously
identified RSS location there will be an undermining of the community's
perception of the Government's original "promise" about
abolishing the undemocratic planning system inherent in the RSS
process.
OTHER POLICIES
6. Star Planning and Development has sought
to clarify with the Department for Communities and Local Government
why the Regional Strategies (RSs) were revoked and the exchange
of e-mails is attached as Annex 2. Clearly, the Secretary of State's
decision was politically based and could be justified by reference
to Collation Agreement. However, other than this political dimension,
there appears to be no specific or sound technical reasons why
all or parts of the various RSs were withdrawn, including both
RSS and Regional Economic Strategy elements.
7. The revocation of, in particular, RSSs
has left a significant policy vacuum in terms of employment and
housing land provision and targets for mineral extraction which
might be considered to be the more contentious matters. However,
RSSs included important environmental and sustainability polices
and targets such as overarching affordable housing targets, the
basis for co-ordinating transport provision, a clear framework
for cross-boundary working between individual authorities and
general sustainability matters and green infrastructure provision.
There is now a policy vacuum associated with these important matters.
Little thought appears to have been given by the Secretary of
State to the provision in the Local Democracy Economic Development
and Construction Act 2009 which allows for "any parts"
of an RS to be revoked. A more selective approach could have been
adopted to retain the less politically contentious aspects of
RSS policies.
8. It may have been politically expedient
to revoke the contentious parts of the RSSs but it remains unclear
why they were revoked in full. Unless the vacuum for the less
contentious policies is expediently filled by the National Planning
Statement, all that will now happen is that Local Development
Frameworks/Local Plans will inevitably become significantly longer
and more detailed than originally envisaged. This level of detail
will add to the timescale to produce these documents. In this
regard, sight must not be lost that the preparation of any planning
policy document has to comply with wider requirements concerning
sustainability and environmental assessments, the preparation
of a sound evidence base and ensuring a democratic basis for drafting
policies. It is generally these matters which cause the delay
in the process rather than the actually writing of the policy
document itself.
CONCLUSION
9. As with any significant change to the
planning system, the revocation and future abolition of RSSs has
and will continue to result in Local Development Frameworks/Local
Plans being delayed with the need for the significant policy vacuum
to be filled at local level. The inevitable frustrations associated
with this delay will more than likely result in further tinkering
in about two years time to try and speed up the development plan
system. Further, the likely disappointment of the community in
the planning system because the abolition of the RSS will not
stop growth pressures combine with authorities wanting growth
to secure the Government's financial incentives has the potential
for significant conflicts to arise which may not be capable of
successful mediation.
September 2010
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