Written evidence from Galliford Try (ARSS
39)
SUMMARY
Galliford Try understands the principles of the proposed
changes to the planning system. The company intends to work constructively
to help make it work as efficiently and effectively as possible.
However the company is concerned about the vacuum
created by the removal of the RSS.
The development plan process must retain primacy
and there needs to be some sort of means of ensuring that development
plan documents, whatever they are called, are produced and adopted
speedily and efficiently with real and appropriate penalties if
they are not.
There needs to be some sort of housing targets co-ordinated
above the local level.
Data collection and research should be done by an
independent body which should produce the evidence for the relevant
plan making and housing target authorities.
Local Authorities should be expected to provide for
the housing that the independent research shows is needed unless
they can demonstrate exceptional circumstances why they should
not.
Housing targets could be set at housing market area
level but this then needs to be translated into local area targets.
Incentives will only work if combined with targets
and they will not be enough on their own. Incentives will work
better if they bring a direct and visual benefit to the actual
communities affected by development. Incentive calculation via
the council tax formula may still work if spend is still visible
at a local level.
INTRODUCTION
Galliford Try (GT) is one of the leading national
house builders and construction companies building approximately
2,000 houses per year and employing 3,500 people. Turnover was
£1.4 billion last year. The company has plans to grow significantly
in the coming years and by doing so, employ more staff and increase
investment.
The company is particularly concerned about the implications
of the abolition of RSSs in relation to potential implications
for investment plans in the construction and property sectors.
This at a time when investment is very much needed to support
employment and increase economic growth.
As set out below, GT has concerns about the revocation
of RSSs without proper consideration being given to a replacement
system. However we recognise that localism and Big Society concepts
are policy commitments and we hope to work constructively to make
these concepts work as effectively as possible whilst delivering
the housing and growth that the country desperately needs.
ABOLITION OF
REGIONAL HOUSING
TARGETS
The effect of this abolition has already been seen.
Research shows that about 38,000 houses in the west of England
have been removed from the plan-making system since the revocation
of the RSS. The figure for the country as a whole will be much
higher. Clearly the prospect of promised incentives has not been
seen as being potentially attractive enough to retain house building
targets.
The other main consequence of RSS removal has been
significant delay to many Local Development Documents when this
process was already proving slow anyway. We consider that this
will further delay delivery of houses to meet needs that are well
documented through Housing Market Assessments, population and
household projections and local authority waiting lists.
Examples of where this is happening are at North
Devon, Mid Sussex, several Oxfordshire authorities and Aylesbury
Vale. These are being delayed whilst housing numbers are reviewed.
The latter is being withdrawn at a very late stage because of
the RSS revocation.
The development industry needs commitment to building
houses at locations where suitability and need has been demonstrated
without fear of significant investment becoming abortive. An example
of that lack of commitment is at Mole Valley where a decision
was taken in 2009 to release some sites for development because
supply was not meeting identified need. Since revocation of the
RSS that decision has been reversed. This "stop—start"
decision-making process is damaging to the economy and discourages
investment.
The construction and housing sectors are very important
to the national economy and extra care should be taken to encourage
investment and job creation.
The issues that come out of this are considered below:
PLAN MAKING
SYSTEM
It is important that the planning system continues
to be led by the development plan process rather than by speculative
applications and appeals. The problem has always been the speed
at which development plans are produced and adopted. The concern
is that without any incentive (following the removal of Planning
Delivery Grants), Local Authorities will under resource their
Planning Policy Departments in order to save money. There is a
danger that plan preparation will slow (or even cease) undermining
the whole established principle of a plan led system.
The industry has long argued for absolute requirements
for Development Plan Documents (whether they be Structure Plans,
Local Plans or LDFs) to be produced speedily and efficiently with
severe penalties if this does not happen. Local Development Schemes
have been produced as part of the LDF process. These were intended
to set a firm timetable to adoption for the Development Plan Documents
that were identified. However there are numerous examples where
those timetables have slipped, often severely, without any identified
repercussions or intervention. Some authorities are on their third
or fourth version of the LDS. This seems to have been accepted
by government without question.
This situation threatens to continue to undermine
the whole system. Currently there are no measures in place to
encourage or enforce progress in producing planning policy. If
not addressed, this problem is likely to get worse.
HOUSING TARGETS
AND COLLECTION
OF DATA
It is essential for the delivery of housing for there
to be some targets co-ordinated above the local level. This ought
to be based on the evidence which in most cases is in place through
work done for the RSS and LDFs.
The premise that evidence and research should be
done at distinct housing market area level is a sound one and
this is not constrained by local authority boundaries. This reinforces
the need for planning above the local level with targets being
set according to housing market area research. Our concern is
that targets set exclusively at a local level will not deliver
the need that has been identified by the research.
It may be that LEPs are appropriate bodies to administer
and deal with housing targets but too little is known of their
remit to come to a firm conclusion. An alternative could be county
and unitary authorities.
Whichever body is identified to identify housing
needs and targets, there will need to be consistency of approach
and clear guidance on how this should be done. There is a danger
that each of the housing target authorities will do things differently
which will cause confusion and disagreement. It might make co-operation
between authorities difficult and cause tensions between the private
sector delivery agents (eg developers) and the regulatory authorities.
Whoever is responsible for setting targets, data
collection and research should be done by an independent group
free of political interference. This group could update the data
according to housing market areas based on the evidence and report
the findings. It would then be for the housing target setting
bodies (whether that would be LEPs, counties or others) to use
that data to plan for the housing that is required. Local Authorities
can then work with local communities to deliver the needed housing
growth.
It is important that the evidence for new houses
is expressed clearly and made available widely. People have to
be aware of data in order to make an informed decision. This is
an essential part of localism as without information clearly showing
why new homes are needed, people often instinctively resist change.
This can all be consistent with localism principles
whilst effectively using research and delivering housing where
it is needed. Without some target co-ordination above the local
level, we are convinced that the chronic trend of under delivering
on identified housing numbers will only get worse regardless of
incentives.
INCENTIVES
Currently the prospect of substantial incentives
has not been sufficient to increase levels of house building being
planned through planning policy.
Our experience of public engagement shows that communities
rarely have a consensus on what they want to do. Each household
will have its own priorities based on its own circumstances. For
example, households with children will be concerned about education
whilst people without children might prefer to keep their locality
as it is even if that does threaten the quality or even existence
of the school. Some people might be willing to accept housing
development if it brings a community hall whilst others would
prefer to miss out on the community hall because they do not want
new houses. Our concern is that in many communities, there will
be a core of people who will resist change through this process
and it is these people who have the most time and resources to
enforce their views.
Our concern is that the council tax incentive seems
too indirect in most cases to benefit the actual communities that
are being asked to accept new housing.
The attraction of small reductions on council tax
(as a result of extra council tax receipts) or provision of extra
capital investment across a district will not be enough of an
incentive to encourage people affected by development to accept
it particularly in the affluent areas where the housing is most
badly needed. For example, residents of Clevedon should not necessarily
benefit from Weston-super-mare taking lots of development if they
are not materially affected by it.
This proposed approach seems designed to promote
large developments which generate a greater capital receipt. We
are concerned that this will discourage appropriate smaller developments
because they do not deliver the council tax incentives at a sufficient
scale to be much of a benefit to the local authority.
The incentive scheme might stand a better chance
of success if money goes directly towards paying for a particular
benefit or to a parish council so that people can actually see
a direct and visual link between the new houses and improvements
to their local area.
Our conclusion is that there may be some instances
where financial incentives can help but it needs to be more direct
and in itself this will not be enough to increase house building
where it is needed. This needs to be combined with effective housing
target setting.
OTHER CONSEQUENCES
OF RSS ABOLITION
Other problems have emerged since RSS abolition.
Local Authorities were told not to include policies that replicated
policies at a national or regional level in order to keep Local
Development Documents concise.
With the removal of the RSS, a whole level of policies
have been instantly removed meaning that policies that previously
formed part of the development plan have now gone and there is
a vacuum. This has created great uncertainty on major issues not
least environmental protection where important policies are no
longer applicable.
This all reinforces the need to prepare policy quickly
and effectively including planning for growth. Authorities should
not be permitted to pick and choose which policies to replace
at the expense of planning for housing which should be an essential
part of the plan making exercise. For example, some authorities
might choose to develop environmental protection policies in isolation
to housing, employment and other policies. This would be a disjointed
approach. There is precedent on this sort of process where some
authorities have proved to be unable to produce an adopted Core
Strategy for resource reasons but have been able to produce SPDs
to avoid independent examination of new policy. By doing this,
restrictive policies are introduced whilst planning for needed
growth is not developed.
CO -OPERATION
BETWEEN LOCAL
PLANNING AUTHORITIES
Major infrastructure projects are always going to
be controversial. It is unrealistic to look for volunteers amongst
local authorities for necessary strategic facilities that are
always going to be controversial (eg power stations, landfill
sites, incinerators) unless some sort of strategic assessments
and decision-making procedures are in place. Failure to consider
this at a broader level means that tensions will emerge between
local authorities and could become divisive.
An additional concern is where the most appropriate
sites for development may be large developments across local authority
boundaries (eg new settlements). There needs to be procedures
in place to ensure fair treatment for each local authority as
well as providing for the housing numbers that are needed. Co-operation
is needed between councils. There does need to be some form of
independent adjudication where each authority looks to abdicate
its responsibilities to another unwilling authority.
Decisions should be based on the independent evidence
that is produced and co-operation should be required on this basis.
CONCLUSION
Galliford Try acknowledges that a localism approach
is a policy commitment for the coalition government. Whatever
the system, it is essential that ways are found to ensure that
Local Authorities produce their development plans speedily and
efficiently and that they plan and deliver the housing growth
that is needed.
September 2010
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