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

Written evidence from Galliford Try (ARSS 39)


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.


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.


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:


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.


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.


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 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.


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.


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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