Written evidence from Robert Hitchins
Limited (ARSS 26)
SUMMARY
The abolition of the Regional Spatial Strategies
and with them regional house building targets without the putting
into place of any clear transitional arrangements is unfortunate
and will inevitably reduce the levels of housing development,
in contrast to the Government's stated objective of increasing
house building levels. This is as a result of:
delays as local planning authorities adjust to the
"localism" agenda;
reduced locally set housing targets;
disruption to projects/planning applications already
in the planning pipeline; and
lack of cross border coordination.
Local communities will not accept new development
on the basis of some form of financial incentive. Virtually all
larger scale housing developments already bring about substantial
benefits to the receiving community, which does little if anything
to reduce levels of objection. Indeed objectors often accuse local
planning authorities of giving undue weight to such benefits.
It is not difficult to see objectors viewing any proposed governmental
incentivisation scheme in exactly the same way.
There is an urgent need to reinstate a strategic
level of planning to ensure that cross boundary issues, including
the collection and dissemination of research are fully addressed.
Local Enterprise Partnerships may, depending on the responsibilities
given to them, be a means of achieving this.
1. BACKGROUND
1.1 The Robert Hitchins Group was founded in
1958. It has its headquarters on the outskirts of Cheltenham.
The company is one of the most active developers in the Gloucestershire
area and has constructed around 15,000 houses and 1,700,000 ft2
of commercial property and manages around
2,000,000 ft2 of
commercial property. Although no longer a house builder the company
does bring significant quantities of serviced consented housing
land to the market which the Company has promoted through the
development plan and development control systems and thus provides
a vital component in the land supply chain and the house building
industry.
2. THE IMPLICATIONS
OF THE
ABOLITION OF
REGIONAL HOUSE
BUILDING TARGETS
FOR LEVELS
OF HOUSING
DEVELOPMENT
2.1 The abolition of regional house building
targets will inevitably reduce the levels of housing development.
This is as a result of:
delays as local planning authorities adjust to the
"localism" agenda;
reduced locally set housing targets;
disruption to projects/planning applications already
in the planning pipeline; and
lack of cross border coordination.
Delays as local planning authorities adjust to
the "localism" agenda
2.2 Within our area of operation there are already
a number of examples of delays to Local Development Frameworks
brought about as a direct result of the abolition of Regional
Spatial Strategy.
Gloucester, Cheltenham, Tewkesbury—Joint Core
Strategy:
"In May and July, the new Government announced major changes
to the planning system which give more power to communities. The
South West Regional Spatial Strategy—which set targets for
housing and jobs—was scrapped and councils must now establish
their own needs locally. The Government also committed to protecting
the natural environment and promoting renewable energy for example.
These are important changes so the JCS team is monitoring all
further Government announcements while reviewing its own work
and timetables."
http://www.gct-jcs.org/Home.aspx
South Worcestershire Joint Core Strategy:
"Before the Government announcement it was proposed that
the SWJCS could be presented to the three South Worcestershire
Councils for approval n the autumn this year with submission to
the Secretary of State in January 011. This is now unrealistic
as we will require additional time to consider how he SWJCS should
be revised."
Letter to Parish and Town Councils and for publication on
websites 15 June 2010
http://www.worcester.gov.uk/fileadmin/assets/pdf/Environment/planning/ldf/others/swjcs_update.pdf
Wiltshire Joint Core Strategy:
"In the light of the CLG letter and in anticipation of
the "Localism Bill", Wiltshire Council intends to continue
to develop the evidence base and the work commenced during the
"Wiltshire 2026" consultation. However, it is important
to recognise that in this period of policy upheaval, the process
of building a sound Wiltshire Core Strategy is likely to take
longer than originally perceived."
http://www.wiltshire.gov.uk/environmentandplanning/planninganddevelopment/planningpolicy/wiltshirecorestrategy.htm
South Wiltshire Core Strategy:
"Wiltshire Council will review housing figures across
the county following the Government's decision to abolish binding,
planning strategies.
As a result of the abolition of Regional Spatial Strategies (RSS),
the council's South Wiltshire Core Strategy proceedings will be
suspended.
The core strategy outlined the spatial vision, key objectives
and overall principles for development in the former Salisbury
District Council area.
Full Council agreed to submit the South Wiltshire Core Strategy
to the Secretary of State in November last year and it was subject
to formal Examination in Public (EIP) for six weeks during the
spring.
However, before the inspector issued his final report, the Communities
and Local Government (CLG) Secretary Eric Pickles revoked the
RSS which was key to the development of the council's South Wiltshire
Core Strategy.
Wiltshire Council and the inspector agreed that proceedings should
now be suspended while the council carries out a full review of
housing and employment needs in South Wiltshire."
http://www.wiltshire.gov.uk/latestnews.htm?aid=106041
Reduced locally set housing targets
2.3 As indeed there is already an example of
a reduced locally set housing target:
Cotswold District Council:
"In the light of the Government's intention to abolish
Regional Spatial Strategies (RSS) and the subsequent CLG letter
(a material consideration) to return decision making powers on
housing and planning to local councils, decisions on housing supply
rests with the LPAs (Letter from the Rt. Hon Eric Pickles MP to
Chief Planning Officers, 27 May 2010).
As the RSS for the South West will no longer form the basis for
calculating housing supply, the District Council has decided that
the RSS (July 2008) requirement of 345 dwellings pa will be replaced
by 300 dwellings pa. The latter requirement was proposed in the
Draft RSS (June 2006) following extensive joint work by the local
authorities. This is broadly in line with the average build rate
1991-2010 (291pa), and the Structure Plan Third Alteration proposal
(280pa), which, although ultimately not adopted, was tested at
EiP."
http://www.cotswold.gov.uk/nqcontent.cfm?a_id=12488
Disruption to projects already in the planning
pipeline
2.4 We have direct experience of an application
for outline planning permission for 175 homes on a site the officers
considered "is generally suitable for housing and the
proposed development would enable an inherently sustainable development
to take place" being refused. The reasoning including:
"In returning decision making powers on housing
and planning to local councils it is highly likely that any new
supply targets will be significantly lower than those set out
in the West Midlands Regional Spatial Strategy Preferred Options"
http://www.e-wychavon.org.uk/modern.gov/mgConvert2PDF.aspx?ID=3135&T=1
2.5 This is just one example of a Local Authority
acting to disrupt projects. What however, is going to be significantly
more damaging to the future housing supply is the fact that the
abolition of the RSS combined with the absence of any transitional
arrangements has led companies such as ours to halt investment
in projects that are in the pipeline because the road ahead is
totally uncertain. This is already a risky business and we can
not justify continuing to invest large sums in projects that rely
for their success on a planning system that does not yet exist
and for which there is little or no guidance as to its future
shape save for various "on the hoof" Ministerial statements.
2.6 This "parking" of projects in this
manner is widespread, these projects have lost momentum and a
few months delay now will lead to years of delay in the future;
this is our experience and the experience of other companies engaged
with the planning system and it will lead to very significant
"black-holes" in the land supply and housing supply
chains for many years to come. It has to be understood that most
housing projects take years of planning to come to fruition, to
obtain a planning permission and to finally provide homes and
this loss in momentum now occurring will be severely damaging
to the progress and delivery of these projects.
Cross border co-ordination
2.7 The Gloucestershire County Council's latest
household projections for Gloucester City indicate that household
growth in the City will greatly outstrip its capacity to accommodate
its growth within its boundaries. The administrative area of Gloucester
City is tightly hemmed in by the Districts of Stroud and Tewkesbury
to the extent that the majority of growth in the City is now taking
place or was (before the abolition of the RSS) planned to take
place outside of its administrative boundaries. In the absence
of the strategic tier of planning there are no effective mechanisms
to secure the cross boundary solution required in such situations.
In short it is difficult to see why one district would locally
decide to accommodate another's needs. This point is picked up
again in section 5 below.
3. 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.
3.1 It is naïve to assume that any local
community will accept new development on the basis of some form
of financial incentive particularly one that is likely to be severely
constrained by what the Country can afford.
3.2 It should be remembered that virtually all
larger scale housing developments already bring about substantial
benefits to the receiving community, for example new and improved
schools, new job opportunities, enhanced and new social, recreational
and community facilities and affordable housing. This however
does little if anything to reduce levels of objection and indeed
objectors often accuse local planning authorities of giving undue
weight to such benefits. It is not difficult to see objectors
viewing any proposed governmental incentivisation scheme in exactly
the same way.
3.3 Our direct and long experience in this field
and in particular with consultation with the local community is
that local people, in the majority of cases, object to the principle
of the development itself and no amount of collaborative working
with them in redesigning/altering the scheme to mitigate their
professed concerns will remove the in principle objection. The
payment to the Local Authority of an incentive to grant the planning
permission therefore, will not be translated into local community
acceptance, but the converse, namely a greater resistance because
the local community will regard the receiving of the incentive
as the Local Authority "selling out" the community's
wishes.
3.4 Moreover, incentives for the receiving community
are proposed to be paid to the local authorities (county/district
councils) and phased over the period of the development, and as
such any direct tangible benefit to the local community is likely
to be significantly diluted.
4. The Committee understands that the Government
intends to announce further details of its plans for incentives
"shortly", and would welcome comments on the adequacy
and appropriateness of those incentives when the details are available.
4.1 The much trailed six times council tax, even
if the country can afford that rate, would hardly amount to a
significant sum insofar as a local authority is concerned. It
is of course significantly less than is often already made available
to local authorities through S106 for improved and new infrastructure
(including social and community infrastructure) which has absolutely
no influence on those who are opposed to development.
5. The arrangements which should be put in place
to ensure appropriate cooperation between local planning authorities
on matters formerly covered by regional spatial strategies (eg,
waste, minerals, flooding, the natural environment, renewable
energy, &c.);
5.1 There is an urgent need to reinstate a strategic
level of planning on these matters and in doing so it would seem
eminently sensible, given the sort of problems highlighted in
paragraph 2.7 above, that the same strategic approach be taken
in respect of housing and employment land. It should also be borne
in mind that planning cannot be separated into discreet topic
areas and housing and employment are inextricably linked to the
topics listed in 5 above. In short a "joined up" approach
is essential.
6. the adequacy of proposals already put forward
by the Government, including a proposed duty to co-operate and
the suggestion that Local Enterprise Partnerships may fulfil a
planning function; and
6.1 There has always been a duty for local authorities
to deliver and perform and evidence of abject failure to do so.
It is therefore difficult to see that this in itself would ensure
co-operation.
6.2 Local Enterprise Partnerships (LEPs) could
be part of the solution depending on the nature of the planning
function they might fulfil. If the LEPs are to have a planning
function it must be sufficient to address cross boundary issues
whatever the planning topic and provide a bridge between national
policy statements and localism where needed.
7. How the data and research collated by the
now-abolished Regional Local Authority Leaders' Boards should
be made available to local 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.
7.1 The internet would seem the obvious means
by which such information should be disseminated. It should however
be available to all and not just the local authorities.
7.2 In terms of collecting/updating research
on matters that cross local authority boundaries this again could
be a responsibility of the LEPs.
September 2010
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