Written evidence from The Campaign to
Protect Rural England South East (CPRE SE) (ARSS 42)|
CPRE has a long record of close involvement in housing
and planning issues.
CPRE welcomed the removal of regional housing targets
because they were top down, but we are sure some form of strategic
planning will be needed to fill the void left by the abolition
of the overall strategies.
The RSS involved extensive consultation and planning
work in the region especially on directions for sustainable development.
This work should remain accessible for the next, more local work
on strategic planning.
The RSS set the framework within which current local
plans (LDFs) are prepared, and has created the current "action
mandate" through core strategies and other local development
documents (LDDs). There is therefore a large gap following the
revocation of the RSS. The strategic issues remain, now looking
for locally focussed policies and solutions.
Housing development targets are being reset locally;
some, but not all, are lower. Local authorities will continue
to manage land supply and approve planning applications: they
do not deliver the housing.
Local Enterprise Partnerships may have to take on
some strategic planning of housing, infrastructure and transport,
to fill the gap left by the removal of regional plans, but only
if they are given a wider remit than solely promoting economic
Provision of affordable housingstill a back
log, is key in the South East.
More cooperation between authorities will be essential,
and will need to be based on mutual benefit.
Data from the regional strategy work including ideas,
plans and data should be made available to the new LEP teams,
through the South East Councils secretariat, which is based at
Hampshire County Council.
1. This submission is made by the Campaign
to Protect Rural England group in the South East of England (CPRE
South East). It complements the submission made by CPRE nationally.
CPRE has a long record of involvement in housing and planning
issues, and especially working at a strategic level. This submission
was prepared after discussions with CPRE county branches in the
2. CPRE is pleased that the regional housing
targets have been revoked by the incoming government. We were
always opposed to housing targets because they imposed on local
councils who have no way of regulating the housing market except
by means of land use allocations. Despite its ill founded structure
the RSS process in the South East did a lot of good work to understand
sustainable development in a pressured region where the environment
and development are often in conflict. Many local authorities
and interested parties were involved and there was a sound consultation
process. Nevertheless the whole process was widely disliked, because
of the constant pressure for higher housing numbers, disregard
for local knowledge and valued land uses including greenbelts.
The parallel diversionary initiatives of Growth Points and Eco-town
housing targets added to the disrepute of the RSS process. It
is very important that the good evidence base work and understanding
is not completely lost as the people involved move on and the
current radical restructuring takes place. As a new definition
of strategic planning beings to emerge with the Local Enterprise
Partnerships (LEPs), many of the same questions: on housing, the
environment, transport and minerals, waste and water will be asked.
3. The Planning and Compulsory Purchase
Act 2004 brought in a statutory system of regional
spatial strategies. These presented a vision for what the region
will look like in 15 years' time. Regional planning became more
important for the future of local communities, effective infrastructure
and countryside protection than previously. This is because:
The Regional Spatial Strategy influenced what happens
locally, because the Local Development Frameworks have to conform
It was part of the local authority's development
plan that has to be taken into account when deciding planning
applications and making other planning decisions.
The majority of the planning body's members were
councillors from the local authorities in the region, so they
had regard to both region-wide and local issues.
It set out how its policies would be delivered: the
focus was on deliverability and on implementation; on getting
It had to help make things happen that were included
in other strategies on issues such as tourism and energy.
Other strategies had to pay attention to what the
regional spatial strategy said, for example on sustainability
and climate change; the aim was for the various strategies to
complement each other.
It was not intended to repeat or counteract guidance
contained in national statements.
It was the only layer of planning between national
policy and local development frameworks. It took over sub-regional
planning and replaced the structure plans that county councils
had produced since the Town and Country Planning Act 1968.
Their removal creates a very large gap in the planning
4. It is also relevant to note that regional
strategies were developed over a lengthy period of time. This
allowed much buy-in by local authorities and stakeholders, and
the ability of all participants to influence outcomes was significant.
The South East Plan was given two periods of formal consultation,
and this was regarded as an important element of democratic involvement
at these stages. The public and local organisations had become
familiar with the consultation process, and with the level of
options available. This process of buy-in went some way to countering
the fundamental flaws of an excessively top down, target driven
system. It may also account for the fact that some very good groundwork
was done to understand the sustainability agenda of a complex
region containing huge differences in economic and social and
The implications of the abolition of regional
house building targets for levels of housing development
5. There is a widespread view that removing
targets will simply allow councils to avoid significant levels
of development in their areas. However not all local councils
want less. Many councils - perhaps as much as 50 per cent in the
South Eastwant to maintain the present momentum as part
of economic growth and regeneration strategies. The uncertain
economic situation makes establishing reliable figures for house
building very difficult in the short term. But the base data of
house building ambitions in each local authority combined with
five-year housing land availability land may give some idea soon
of how the new locally generated figures relate to the previous
6. In the absence of a regional level strategic
plan it will become necessary for there to be some similar strategic
level integrated approach with declared strategic aims for a sustainable
approach to development covering economic assumptions; employment
and housing ambitions and vision for the community or Local Economic
Partnership area being planned. In the context of the South East,
and applying experience learned under the previous system, the
aims should generally be for reasonable levels of housing taking
account of infrastructure provision; making better use of land;
and a step change in affordable housing; together with making
better use of existing stock; and working within the constraints
of the local environment.
7. The work on housing targets at regional
level, wrestled with complex problems of household composition,
age structure, and housing types. In the absence of a continuation
of regional housing strategy, these factors will continue to be
important but at local level, and plans will need to be based
on locally relevant national data and local knowledge. The back
log of affordable housing provision and the under provision recently
of family houses will be issues that go forward to the new locally
based strategic planning.
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
8. The present incentive suggestion from
the Coalition Government announced by the Housing Minister, Grant
Shapps on 9 August is to pay local authorities a New Homes Bonus
equivalent to the council tax of the new property over six years.
It is said to be payable on approval of planning permission, and
the money not ring fenced. While the money will no doubt be welcome
to local authorities, it will be a minor element of local authority
budgets and no more than a small proportion of the money needed
to fund essential strategic planning work in a local authority
to ensure houses are built in the right places and in the right
numbers to match provision of infrastructure, comply with environmental
constraints including flood assessments and local transport plans.
9. The need for a five-year housing land
supply is still in place and is well exceeded in many areas. This
makes the need for incentives per se redundant. The councils involved
need simply (and are required to) grant the applications that
comply with their development plans. Housing land supply is a
key factor in determining where houses are provided. There are
wide variations in housing land supply distribution, from constrained
areas like Surrey having only five years and the Isle of Wight
15 years. In 2008, there was enough land in the region for 235,000
dwellings, which is 8.5 years supply, on past targets.
10. There are already incentives for affordable
housing in the South East. These come mainly from the traditional
funding streams of the Homes and Communities Agency, via social
landlords, and have resulted in some 8,000 such houses being built
annually in the region. Other provision has come from local agreements
with large scale developers. Given the very significant demand
for affordable housing in the South East it will be important
that incentives regimes do not remove or replace funding for affordable
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 and renewable
11. Co-ordination of policies and strategies
is essential. Councils already have to work jointly with adjacent
authorities, but this will not necessarily address wider issues
on a geographical or practical basis to address the gaps arising
from the revocation of regional strategy and organisation. Many
local authority planning officers will have experience of life
before RSS: in the South East, prior to the spatial strategies,
there were regional planning conferences. Notably SERPLAN started
in 1962 was a wholly-owned entity of the local government sector.
This body was able to provide guidance for local councils on a
wide range of subjects and policy areas, including energy, the
rural economy, minerals and waste. The process of arriving at
figures and policies was participatory, and included expert working
groups reviewing policies and developing strategic positions.
Similar arrangements pertained in other regions, and these were
essentially voluntary with a degree of outside interested party
12. In public sector work today there is a need
for greater transparency, and wider consultation and involvement
of communities. The agenda has also moved on as sustainability
has become central and climate change adaptation and mitigation
are always a consideration. Pressure on water supply and waste
water provision in the South East and the requirements of the
Habitats and Strategic Environmental Assessment Directives set
a very different context from that under SERPLAN. Residents and
communities now have strong opinions on and affiliation to green
space and provision of safe cycling and walking and more recycling
of waste, and better air quality and less noise and congestion.
These and other changes argue for a different approach going forward,
which will be necessarily quite complex even if locally based,
and with cooperation. If the SERPLAN model were to be considered,
as an approach to strategic level planning, it would therefore
need to be evolved.
13. A duty to co-operate will be difficult, if
councils are not minded to do this, or share common aims. Many
local authorities are competitive with their neighbours, for employment,
resources, and may have long standing contested relations. A good
example of this is the desire of Oxford city to expand its borders,
and the view of surround authorities that it should remain closely
contained. If a formal duty to cooperate is combined with mutual
financial or other benefit of doing so, it will have greater potential.
Cooperation based on a wider jointly agreed strategic objective
is more likely to be achieved if there is a level of strategic
planning shared across local authorities.
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
14. Local Enterprise Partnerships will have to
work on the tasks fulfilled by previous strategies, and fill some
of the policy gaps left by the loss of RSS. As models of local
cooperation and determination to succeed, they may have a defined
geography, as exemplified by some of the proposals submitted.
They may use or cross regional administrative boundaries as the
Milton Keynes and South Midlands area has done for some years.
It will obviously be difficult to decide which LEP bids should
be approved in the absence of a national planning framework, but
in this situation the geographical pattern and spatial planning
intentions of approved LEPs may be a key factor for the national
framework preparations. It the present time, and looking at the
range of LEP bids, it is unclear how the strategic planning functions
could be fulfilled.
15. The new approach would have to encapsulate
both the challenges and the dilemmas of the region. On the one
hand, some consider that economic growth and concomitant development
has been a necessary condition for prosperity and social and environmental
action in the South East. On the other, it is increasingly apparent
that the price of that growth, in terms of resource consumption
and other net impacts, including noise, congestion, air quality
and loss of tranquillity is very high and needs to be addressed
to avoid destroying the physical, social and environmental assets
that have account for the success of the South East. In recent
years the use the Sustainability Appraisal has proved to be a
useful tool for working through these dilemmas.
16. LEPs would need a core statement of policy
or vision, and this would need to take into consideration other
influences outside of their boundaries. The South East has long
been conscious of its global and European position. It is also
aware of its relationship to other English regions. There has
been an evolving relationship with London, as a capital region.
There is a need to have a sustainable development context set
by Government policies and local frameworks. There are continued
imbalances between the east and west of the region, and a strong
urban influence from previous regional statements. All this requires
working at a level between national and local. The need for efficiency
in the use of natural resources is overriding. There is also a
need to identify investment priorities for health, education and
affordable housing. LEPs will be looking to supplement their own
visions with an understanding of outside influences and opportunities,
at whatever geographical level they are operating.
17. LEPs in the South East will emphasise economic
opportunity and enterprise aspects, but should also celebrate
its varied and attractive countryside. They can only fulfil a
planning function if promoting a more sustainable pattern of development,
a more bio-diverse environment, as well as reducing levels of
natural resource consumption. The scale of development they propose
will be scrutinised carefully, as will the timely delivery of
infrastructure on which any development is dependent. It might
be possible to give LEPs a spatial planning function if this were
carried out in an integrated way, respecting the principles of
sustainable development. This would also avoid the proliferation
of structures at this strategic level.
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
18. As stated in the Introduction, a great deal
of work, including data collection and research has been done
to understand the characteristics of the South East and considerthrough
implementation plans as well as strategy and policy, how to evolve
the region in the direction of more sustainable development including
behaviour change. It is important that this work is not lost,
and that it remains useable and accessible. It will also assist
monitoring and evaluation purposes in the longer term. In the
South East, much of the data collected over recent years has been
deposited with a new group: South East England Councils SEEC.
SEEC is based at Hampshire County Council, and will provide a
limited updating facility, based on local authority returns and
manage access to previous strategy work and topic papers.
19. The removal of RSSs, although widely anticipated,
has happened more quickly and suddenly than expected and there
are concerns that the vacuum that has followed their revocation
undermined established good principles of plan-led development.
The current period of "creative destruction" to remove
the top down target driven system, needs to be followed soon by
a new sub national or supra local system that enables spatial
strategic planning to be rebuilt.
20. The new LEPs will have a lot of choice about
what to include in their strategies. Public involvement is essential
throughout this process. Local people should be asked to consider
what is important to them about their areas or sub-regions, particularly
if the remit includes planning. This should include wildlife and
landscape, and cultural heritage in the planning options. The
new bodies should deal with the issues people care about, as well
as ensuring a healthy economy.
21. The LEPs must strive for openness in their
planning and monitoring, whatever their mandate. They must meet
in public, with papers freely available in advance to the press
and public. The results should not be judged on the basis of rightness
or wrongness, but on the overall soundness. Implementation plans
will essential, and the Government should be committed to continued
partnership delivery. We are pleased to note that the voluntary
and community sector will be encouraged to come forward and take
part in strategy development and monitoring. All future stages
of LEP development should include involvement by all sectors.
LEP plans should include details about investment needs to facilitate
proposals, monitoring and local delivery vehicles, where appropriate.