Written evidence by Crest Nicholson (ARSS
43)
INQUIRY INTO
THE ABOLITION
OF REGIONAL
STRATEGIES & HOUSING
TARGETS
These representations are submitted on behalf of
Crest Nicholson Limited (CN). CN are a leading UK
house builder with a recognised track record of developing sustainable
mixed use housing schemes along with the regeneration of many
deprived areas. Of particular note is the award winning redevelopment
of Ingress Park in Kent and the regeneration of the Park Central
estate in Birmingham.
CN has direct experience of the effect of the Government's
policy on housebuilding and in particular the abolition of regional
strategies and housing targets and make these representations
in order to inform the Inquiry.
CN are willing to provide further details of the
evidence provided in this short submission and give oral evidence
at the Inquiry.
1. SUMMARY
The abolition of the regional strategies and housing
targets are already having a profound negative effect on the house
building industry. It is CN's view that this will continue and
will result in a reduction in the number of dwellings constructed
and further exacerbate the chronic shortage of good quality housing.
The lack of any transitional arrangements following
the abolition of the regional strategies and the regionally set
housing targets has created a policy vacuum.
The policy vacuum coupled with the lack of any detail
on the incentives that are to be offered to LPA's has resulted
in the cessation or delay of work on a large number of core strategies
particularly in relation to major strategic which have historically
provided the largest proportion of new housing numbers.
That policy vacuum has also resulted in the delay
in considering planning applications which will result in an increase
in the number of applications that will need to be determined
through the appeal system.
Any incentives and the Government's proposals for
planning obligation and any changes to the community infrastructure
levy or the introduction of local tariffs, need to be set out
clearly as soon as possible. These will need to be fair and reasonably
relate to the development in order to provide a proper incentive
to a LPA and local community to permit development.
The duty for LPA's to co-operate with each should
have a statutory basis and be enforceable. CN believes that there
is a need for cross LPA boundary considerations of housing need
and infrastructure requirements and suggest that consideration
should be given to using County Councils to encourage, facilitate
and police such arrangements based upon nationally set parameters.
The data that is already available through the Regional Local
Authorities Leaders Boards could form part of this along with
a requirement to keep that data up to date with independent testing
of its robustness.
2. THE IMPLICATIONS
OF THE
ABOLITION OF
REGIONAL HOUSE
BUILDING TARGETS
FOR LEVELS
OF HOUSING
DEVELOPMENT
2.1 The revocation of regional strategies and
the abolition of regional house building targets left a policy
vacuum which has had and will have a very significant effect on
the level of house building development across the country. This
is and will continue to be particularly acute in certain areas
such as some cities and larger towns which have constraints upon
the land available for development within their administrative
boundaries. We have set out below evidence from CN's own experience.
The Government's incentives to aid this are, subject to some caveats,
welcome and are also dealt with below.
2.2 Whilst we understand the reasoning behind
the Government's decision to abolish regional strategies and housing
targets, we believe that there is a real need to bring certainty
to its plans to provide incentives to LPA's to grant planning
permission for housing and mixed use development to in order to
avoid further long term problems in the provision of new good
quality housing.
2.3 An immediate effect of the letter of 27 May
2010 to all LPA's and the Planning Inspectorate from the Secretary
of State for Communities and Local Government (The Right Honourable
Eric Pickles MP) and the subsequent revocation of the regional
strategies was the cessation of work on and the proposed cancellation
of some core strategies (for example Aylesbury Vale are seeking
consent from the Secretary of State to withdraw its core strategy
from the examination process). We believe that 58 LPA's have stopped
work on or have delayed their core strategies with only three
LPA's responding positively (continuing with their core strategy
process).
2.4 As far as CN's schemes are concerned many
of these have been effected with the following a relatively small
representative example.
2.4.1 The DERA Site (Runnymede)—A brownfield
site within the Green Belt "allocated" in the revoked
South East Plan for 2,500 dwellings. A planning application is
yet to be submitted but this site was being promoted by CN through
the Runneymede Core Strategy process. The LPA are now looking
to review its core strategy housing allocation as a result of
the revocation of the South East Plan with a view to proposing
a lower housing target and retaining the green belt. The effect
is to delay consideration of the proposals pending this review.
No timetable has been provided for the resumption of work on the
Core Strategy.
2.4.2 Church Farm (800 dwellings) and Fern Hill
Heath (200 dwellings) (Worcester, Wychavon and Malvern Hills)—a
planning application was being prepared and the sites were being
promoted through the planning process. CN have undertaken detailed
public consultation. The applications have been delayed as a result
of potential changes to the housing targets. Despite the identified
need for further housing development in Worcester the city is
constrained by its administrative boundary. That housing need
can only be met by developing in the adjoining districts of Wychavon
and Malvern Hills, however to support that growth infrastructure
investment will also be needed in Worcester as well as within
those LPA's boundaries. All three LPA's are waiting to see the
details of the incentives that are to be offered by the Government
before committing to such schemes.
2.4.3 North Whitley (3,000 dwellings—jointly
CN, Taylor Wimpey and Bovis) (Winchester)—The Winchester
Core Strategy is delayed as a result of the revocation of the
South East Plan. This is subject to challenge by way of judicial
review by CALA Homes which is to be heard on 22 October 2010.
The proposed housing development on the CN site is supported by
the LPA and will help in meeting the identified housing and infrastructure
needs in the area. However the review of the Core Strategy has
delayed any progress by one year.
2.4.4 Oakgrove (up to 1,300 dwellings) (Milton
Keynes)—The planning application was due to be heard by
Milton Keynes on 15 July 2010 but has been deferred indefinitely.
2.4.5 Mid Sussex (100 dwellings) (Mid Sussex)—Following
public consultation an application has been lodged with the LPA
. However the LPA have ceased work on their Core strategy as a
result of the revocation of the RSSs. A timetable has not been
given for any review.
2.4.6 Hicks Gate (1,500 dwellings and employment)(Bristol
City and Bath and North East Somerset)—BANES have stopped
all work on their Core Strategy and are consulting on alternative
housing strategies as a result of the Governments policy and the
revocation of the regional strategies. This is a cross boundary
site that will be held up despite Bristol City Councils need for
housing.
As a corollary to the Hicks Gate example, at
the Examination in Public of Bristol City's Core Strategy on 7
September 2010, the LPA proposed a reduction in the number of
dwellings to be provided for the plan period lan from 30,000 to
26,400 dwellings. The reason given was that Government policy
allowed the LPA to set its own housing figure.
The Inspector at the Examination in Public
raised a question over the weight that should be given to the
proposed reduces housing figure given that the Council's own evidence
points to a higher figure. This raises an important point of principle—is
planning policy to be evidence based or not? If Bristol City maintains
it's position the Vision and objectives in the core strategy will
need to explicitly state that the City does not intend to meet
it's need. This will send a clear sign to potential investors
in one of the Country's major cities.
2.5 The above provides a small example of the
delay and uncertainly that is now faced by the housing industry.
The policy vacuum that exists will mean that many sites are likely
to be decided through the appeal system rather than locally which
in turn will result in increased delay and cost both to the development
industry and the LPA's. Such costs will effect the viability of
schemes and the ability for them to contribute financially towards
the local community in addition to the provision of much needed
quality new housing.
2.6 Whilst CN recognise that there is not any
proposal to return to regional strategies and regionally imposed
housing targets, those polices did set a framework against which
local policies had to be formulated and provided an opportunity
to examine housing requirements over a housing market area rather
than the artificial boundaries of a LPA's administrative area.
3. THE LIKELY
EFFECTIVENESS OF
THE PROPOSED
INCENTIVES
3.1 As the details of the proposed incentives
are yet to be published the submissions below can only be based
upon the information available to date and is necessarily general.
Two new incentives have been proposed, the New Homes Bonus and
a bonus to be paid for permitting commercial development. In addition
mention should be made of the current extant system of mitigating
the effects of a development through planning obligations and
the proposals for either an amended community infrastructure levy
(CIL) or local tariff.
3.2 The overriding issue is a requirement for
certainty. This will allow LPA's and the local communities to
see and consider the benefits that allowing such proposals will
bring through the provision of new and enhanced infrastructure
in addition to the provision of new housing. The present proposals
lack this certainty which along with the policy vacuum mentioned
above is (as referred to in the above examples) exacerbates the
already dire need for new housing provision.
3.3 New Homes Bonus and commercial development
bonus—certainly as far as the New Homes Bonus is concerned
(we have not seen any detail on the commercial equivalent), is
stated to be fiscally neutral.
3.4 Overall CN can see that providing a financial
incentive to LPA's to permit new housing or housing led mixed
use development may be effective in increasing the numbers of
new dwellings that are given planning permission. It will however
be important to ensure that planning decisions are made upon planning
grounds and not the prospective receipt of such incentive payments.
The later having the potential to damage public confidence in
the planning system when poor decisions are made on that basis.
Equally it will be important to ensure that there is a recognised
benefit from the payment and use of the incentive sums.
3.5 In particular CN believe that the following
main points should be considered fully in formulating an effective
incentive system:
(i) How will the bonus or incentive be calculated,
will that be at a national or local level or based upon the local
council tax levels?
CN have concerns as to how the level of funds
to be paid could provide sufficient incentive to an LPA that has
an identifiable need for new hosing within its boundaries but
is reluctant to permit such development. The funds paid should
be used in a manner that relates to the proposed development.
Equally where much of the effects of a proposed development are
felt in adjoining administrative areas but the development is
predominantly within one area, the resulting funds should be paid
to LPA subject to the greater impact rather than the one with
the greater number of dwellings within its boundaries (see the
examples given above).
(ii) How will the funds be split between a District
and County?
Whilst it may the District that permits the
development, it is the County that is often required to provide
much of the infrastructure for example schools, libraries and
highways.
(iii) Should a LPA be allowed the New Home Bonus
if the proposal was approved on appeal?
It is CN's considered view that many LPAs will
prefer to allow proposals to be determined by the Inspectorate
rather than make decisions that do not enjoy complete local support.
By either not determining proposals or refusing otherwise sound
schemes the LPAs are introducing a significant cost to all parties.
It seems inequitable that they then benefit further from the New
Homes Bonus in these circumstances.
3.6 CIL/Local Tariff—whether this
is revision of the CIL provisions or a new tariff based system,
it will be important that funds received can be shown to be mitigating
any potential harm a development may cause along with providing
recognisable benefits flowing form the development. Linked with
incentives mentioned in paragraphs above these could (particularly
if they are ring fenced towards direct mitigation and benefits
flowing from the development) help in showing the real benefits
of allowing housing development in an area.
3.7 CN's concern is that such payments should
not be in conjunction with any planning obligations, taxation
and building regulation requirements which make development unviable
or incapable of implementation and should be a material consideration
in granting planning permission.
3.8 A major issue with all of these incentives
is the speed and clarity that the details emerge. At present LPA's
cannot judge the likely benefits that those developments will
provide above the provision of new housing. Uncertainty results
in delay.
3.6 The Government need to ensure that any incentives
are properly enforceable and allow for cross boundary issues to
be addressed including the provision of funds to a County Council.
4. COOPERATION
BETWEEN LOCAL
PLANNING AUTHORITIES
4.1 It is important that and cross border issues
(whether that is the requirement for new housing, or the effect
of new housing are quickly, properly and clearly considered.
4.2 Where there are major housing and infrastructure
requirements there is a need for sub regional and at times regional
co-operation. It is sometimes not possible to consider the housing
need of one LPA area in isolation from adjoining areas (again
see the examples above). In addition the effects of major housing,
mixed use or commercial proposals will need to be considered at
a level that is above a single LPA's remit. The abolition of the
regional strategies which dealt with such issues has, as stated
above left a policy vacuum that will need to be filled.
4.3 County Council's could use their role to
assist or act as facilitators in producing such sub-regional policy.
5. REGIONAL LOCAL
AUTHORITIES LEADERS'
BOARDS DATA
AND RESEARCH
5.1 This should be made widely and publicly available.
5.2 LPA's should be required to prepare and keep
up to date housing need supply data that should also be made widely
and freely available. These should (where they are shown to be
robust and up to date) be a material consideration in any planning
decision and be subject to independent examination to test their
robustness based upon objective nationally set parameters.
5.3 There should be penalties if there is a failure
to provide that up to date data, maybe linked to the incentives
mentioned above or any residue planning delivery grant.
September 2010
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