Written evidence from the Joseph Rowntree
Foundation (ARSS 32)|
The Joseph Rowntree Foundation (JRF) is delighted
to submit the following response to the CLG Committee's Inquiry
into the abolition of regional spatial strategies. This response
was drafted on behalf of JRF by Gemma Burgess, Sarah Monk and
Christine Whitehead, CCHPR, University of Cambridge and Alison
Bailey, Consultant Planner.
This consultation input draws on insights from recent
work for the Joseph Rowntree Foundation on locally incentivised
from the body of research conducted by the Cambridge Centre for
Housing and Planning Research over many years
and on the expertise of a former senior planner with the South
East regional planning body.
The context to this issue is one of continued housing
supply shortages and a top down approach to setting targets for
new housebuilding. Difficult decisions have to be made about where
new housing should be located in order to meet housing need which
were mediated by regional bodies and set out in the Regional Spatial
Strategies (RSS). The RSS abolition does not remove these problems
and new ways are required to address them.
The removal of unrealistic regional housebuilding
targets is probably necessary but a strategic approach is still
necessary to encourage housing investment and to link housing
development with other factors such as infrastructure provision
over the long term and across local authority boundaries.
There are concerns that housing targets determined
by individual local authorities will not add up to meet the needs
of the country and will not provide the "right" type
of housing in the "right" place as the spatial distribution
of housing is crucial.
Many factors, other than targets, impact upon levels
of housing development. In particular, the nature of local resistance
to new housing must be better understood. Incentives will not
work if existing local communities cannot see the benefits of
A system without national and regional targets requires
not just a combination of local targets and incentives, but also
a system of penalties to ensure that local authorities do not
opt out of their responsibilities.
Even with the incentives scheme, it has to be questioned
whether additional tax benefits will be adequate to ensure sufficient
affordable housing is built where it is most needed.
The current plans to ensure cooperation between local
authorities are vague. Some could lack the capacity, resources
and skills to tackle all of these responsibilities. Spontaneous
collaborations between local authorities are likely to need resourcing.
There is a risk that skills and expertise will be
lost if new arrangements are not quickly established. New forums
for knowledge sharing must be developed.
A solid evidence base is even more important under
localism, particularly since the Communities and Local Government
(CLG) letter on RSS revocation indicates that the RSS evidence
base remains a material consideration. Existing web sites should
be retained and updated, at least for the foreseeable future.
CLG must seek to ensure a more orderly transitionthe guidance
published so far is insufficient.
A central website could be developed collating all
relevant data, research and guidance. An innovative use of online
technology would enable local authorities to share resources and
work together effectively.
(a) Implications of the abolition of regional
house building targets for levels of housing development
Regional targets were seen as part of a top down
approach to determining and allocating housing requirements. The
regional layer provided important elements of the evidence base
for housing requirements, linked them to other requirements eg
transport and infrastructure, allocated housing targets between
different local authorities in a region and monitored what was
achieved. Whilst there were problems with this system, many of
these tasks still need to be carried out.
A solid evidence base is still required and a strategic
approach has to be taken to link housing development with other
factors such as infrastructure provision over the long term and
across local authority boundaries. It would be wrong to characterise
RSS housing targets as purely top down; there was considerable
"bottom-up" input to the process and (at least in the
South East) extensive public consultation. They were based on
a broad range of evidence covering demography, affordability,
climate change, bio-diversity and landscape, flood risk, water
resources and water quality, transport, the relationship with
other regions etc, as well as the critical relationship between
housing and the economy. Many of these issues inherently cross
New arrangements must deal with the relationship
between housing and other policy drivers/constraints. Decisions
about housing provision cannot and should not be made in isolation
from decisions about infrastructure including transport, waste,
energy, social infrastructure such as doctors and schools and
decisions made by adjacent areas. It is crucial that new arrangements
allow for a way of looking at housing in this wider context.
The consequence of abolishing RSS on the development
of Local Development Frameworks (LDFs) is also crucial. Despite
the advice set out in the letter from CLG
that local authorities should continue work on their LDFs, it
appears that work is slowing/being halted in some areas. This
is perhaps inevitable with no transitional arrangements and uncertainty
about how incentives will work. CLG must seek to ensure a more
orderly transitionthe guidance published so far is insufficient.
Adopted and emerging LDF policies were often reliant
on RSS policies. This was exactly how the Development Plan system
was designed to operate: LDF policies "nested" within
the RSS and were encouraged not to repeat sound and robust strategic
policies. Taking the South East Plan as an example, it was underpinned
by an evidence base more comprehensive than that ever assembled
for previous regional strategies. The policies in the Plan were
tested and found to be robust by a Government appointed panel
of independent inspectors; as part of that process they were subject
to a rigorous Sustainability Appraisal and Habitats Regulation
This applies to housing provision but also more widely.
For example, LDFs in the South East relied heavily on RSS targets
for carbon reduction and renewable energy and national Planning
Policy Statements (PPSs) refer to RSSs. As a result, there are
now question marks against many LDF policiesnot just those
dealing with housing targets.
The RSS also provided a framework for decisions about
infrastructure provision. In the South East's case the RSS included
a policy requiring the phasing of development to be closely related
to the provision of infrastructure, in recognition that the scale
and pace of housing delivery is inextricably linked to the timely
delivery of infrastructure. Without this framework, infrastructure
provision may be less effective and failure to provide infrastructure
acts as a barrier to sustainable housing provision.
There are concerns that without some form of top-down
framework housing targets determined by individual local authorities
will not add up to the provision of sufficient housing to meet
demand and in particular will not take account of the needs of
migrants into the area (many authorities assume zero net migration).
There is uncertainty as to whether the new system will provide
sufficient housing of the "right" type in the "right"
place. Yet, the spatial distribution of housing output is crucial.
Allowing local authorities to determine their own
targets may reduce resistance and conflict in the planning process,
leading to more cooperation and therefore swifter development.
However, local authorities may set lower targets and permit less
housing development where there is local political pressure to
do so, but this is often in areas with the worst affordability
Many factors, other than targets, impact upon levels
of housing development. Research indicates that there are many
other factors that shape construction levels that must be addressed,
unrelated to housing targets. These include the availability and
cost of credit to housebuilders and the buoyancy of the housing
market which in turn depends on incomes and the mortgage market.
Not enough is understood about why local communities
are so resistant to new housing development. The well-housed have
a strong voice in responding to planned new housing developments
because already existing communities are coherent, but the community
who would live in new housing does not yet exist, is disparate
and cannot easily come together to have a voice. New ways must
be found to engage people in the planning process so that those
who cannot afford their first home, who are living in inadequate
or over-crowded housing or remain on housing waiting lists, have
a voice in the granting of permission to new development.
(b) 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
What is critical about an incentives system is both
that enough new homes are built overall and that they are the
right types of property in the right places. This requires a sound
evidence base and incentives of sufficient scale to encourage
housing development in the most high-pressured areas.
Details on the proposed incentive scheme are currently
scant. There is no hard evidence about the likely response to
financial incentives in different local political and economic
environments. It is difficult to know whether the proposed level
of incentives will be sufficient to encourage local authorities
to permit enough new housing to meet need, particularly in political
contexts where there is a strong anti-development lobby.
A combination of local targets and incentives must
be complemented by a system of penalties to ensure that some local
authorities do not opt out of their responsibilities. There is
a need for both sticks and carrots, and the "sticks"
will need to be big enough and the "carrots" visible
enough, not just to convince local authorities but also local
Incentives will not work if existing local communities
cannot see and feel the benefits of new development. Local authorities
will have to show that the extra funding will be used to meet
local priorities that could not otherwise be met and that it is
of sufficient scale to offset costs to the community. There are
also unanswered questions as to whether the incentives system
will add to the overall pot of funding available and whether incentives
will be sufficient in particular to provide gypsy and traveller
Section 106 (S106) has been a tried and tested way
of making a new development acceptable and negating its externalities
to the local community. It seems counter-productive to suggest
replacing a system that is so closely tied to individual local
developments with a tariff system that is not tied to specific
developments in the same way. It would be better to develop local
authority skills in securing contributions and developing a mixed
system of tariffs and S106 where appropriate that can be used
successfully by all local authorities. In a context of localism,
local authorities should promote their use of S106 to demonstrate
to their communities what a new housing development will contribute
to the area. S106 has been responsible for community benefits
such as open space, education, highways, public transport and
as well as over 60% of all new affordable housing.
A simple and effective way to facilitate higher housebuilding
levels would be a presumption in favour of development alongside
an incentives system. Such a presumption needs to be based on
clear and tested local policies to ensure that development is
In the current circumstances a major government housing
initiative as part of restructuring the economy could be a means
of supporting change. This is particularly important because the
housing market is in uncharted waters, with continuing uncertainty
about the economy, the availability of development finance and
public investment. The scale and nature of recent changes in the
housing market could fundamentally alter the way that the house-building
sector operates, what it delivers and where. Indeed, in an environment
where the viability of many proposals has been severely compromised
there is a danger that local authorities may accept new proposals
put forward by developers because they are the only ones on offer.
The proposed incentives scheme needs to provide a means of safeguarding
against this without becoming an argument used by the anti-development
It is very unlikely that an incentives system alone
will be enough to support all housing development required, in
particular, there will need to be continued additional investment
in affordable housing. But the affordable housing sector could
be more innovative both in how funds are raised and in the low
cost home ownership (LCHO) products that are available. As part
of the restructuring, simpler and better targeted LCHO products
should be developed as the current products are too complex and
(c) Arrangements which should be put in place
to ensure appropriate cooperation between local planning authorities
on matters formerly covered by RSS
There are many policy areas where co-ordinated policy
action between local authorities (inter and/or intra-regionally)
and others is required (strategic transport, habitats regulations,
waste, water, minerals). The RSS and associated delivery mechanisms
were the main means by which this was achieved.
The RSS enabled local authorities to consult across
areas and it set out what each district was expected to achieve.
It also provided information for the development industry. The
RSS shared the "burden" of new development targets between
local authorities. There will still need to be negotiation between
different local authorities. Without the RSS we risk losing strategic
decisions across boundaries and strategic monitoring. We also
risk losing research at a strategic level, important in determining
what is required to ensure competitiveness and a decent home for
The loss of regional bodies means a reduction in
the number of professionals with skills in analysis and monitoring.
In many areas it is already too late: the skills and expertise
were lost when the regional teams were abolished. Some local authorities
lack the capacity, resources and skills to tackle all of these
responsibilities and will need to rely on consultants.
While these activities could be picked up by central
government and/or by county councils and unitary authorities,
the most appropriate possibility would appear to be spontaneous
collaborations between local authorities. Voluntary local authority
co-operation on planning issues has a long historyat least
in certain parts of the countrythat pre-dates statutory
regional plans by many decades. But it is not clear whether there
would be sufficient impetus to continue this. A key issue is that
local authorities are having to make massive cuts. In this climate
it is difficult to see non-statutory work like this getting priority
and collaboration would require resources of the kind that regional
bodies once provided. Perhaps one solution would be creative thinking
around developing new forums for knowledge sharing.
(d) Adequacy of proposals already put forward
by the Government, including a proposed duty to co-operate and
the suggestion that Local Enterprise Partnerships (LEPs) may fulfil
a planning function
The proposed duty to co-operate is as yet undefined
and will require a formal structure if it is to be realised. LEPs
would be joint council-business bodies to promote economic development
but the planning skills that existed at regional level were specialised
and it is not clear how they would fit into this council-business
Whilst the form and functions of LEPs are yet to
be determined, our understanding is that Government does not currently
envisage that LEPs will have a statutory planning function. However,
LEPs could have a non-statutory planning role, similar to the
now-abolished Leaders Boards that were set up to replace regional
assemblies; opinion seemed to be that they were beginning to operate
There is a real risk that without unless already
existing skills can be brought in quickly, the new LEPs's role
of dealing with planning would be a time consuming and expensive
learning curve. If LEPs are going to have a planning function
then existing expertise and skills need harnessing as soon as
possible so they are not lost.
(e) 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
It is crucial that the evidence base that has been
built up is not lost, particularly since the CLG letter on RSS
revocation indicates that the RSS evidence base remains a material
For any plans and targets to have local legitimacy,
they must be based on clear and transparent evidence. But it is
not clear how new evidence and research will be conducted or funded,
particularly across local authority boundaries.
The RSS evidence bases have (at least in some cases)
been transferred to the successor bodies. However, there is a
need to ensure that the evidence that has been deposited is actually
made available, that existing web sites are retained and updated,
at least for the foreseeable future.
We would suggest the creation of a central website
where all relevant data, research and guidance is collated and
hosted. This would prevent individual local authorities from 'reinventing
the wheel' when they identify knowledge gaps. An innovative use
of online technology could be used to determine shared research
agendas and evidence gaps, to enable local authorities to see
where they have similar needs and provide opportunities to share
resources and work together. It would thus offer a chance to create
Given that RSS no longer exist except in London,
the main challenges can be summarised as:
1. Strategic decision making across local authority
2. Mediation between conflicting demands and
3. Ensuring that national housing needs are addressed.
4. Monitoring and research at strategic level.
These jobs still have to be done but in a dynamic
and forward looking manner. One way forward is to provide national
support for spontaneous and organised collaboration between local
areas and ensure a robust evidence base is maintained.
16 http://www.jrf.org.uk/publications/planning-system-more-housing. Back
Steve Quartermain to Local Planning Authority Chief Planning Officers,
6 July 2010. Back
Crook et al, 2010, The Incidence, Value and Delivery
of Planning Obligations in England in 2007-08, CLG, London. Back
Monk and Whitehead, 2010, Making Housing More Affordable: The
Role of Intermediate Tenures, Wiley Blackwell, Oxford. Back