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

Written evidence from Cavendish Keymar (ARSS 47)



The Communities and Local Government Committee has launched an Inquiry into the abolition of Regional Spatial Strategies. Submissions are invited to address:

The implications for regional house-building targets.

The likely effect on this of government's financial incentives to local planning authorities for housing delivery.

The arrangements that should be put in place to ensure appropriate cooperation between local planning authorities.

The adequacy of proposals already put forward by government including a proposed duty to cooperate.

At present, the detail of financial incentives is sketchy and there seem to be no government proposals requiring local planning authorities to cooperate. Accordingly, this submission focuses on the implications for house building and housing delivery.


House building—how popular?

  I (Edward Keymer) attended a recent residents' meeting to consider the possibility of strategic housing growth on the edge of Stevenage. Not surprisingly, the meeting was convened in a rural village hall and was attended by 47 members of the public; 44 of them were over 50 years old and at least 25% of those present were no longer economically active. Only three young people attended; one couple left after 20 minutes, the remaining person (in his 20s) stayed because his parents were present.

The purpose of this observation is to stress that decisions on housing provision are rarely taken by those who are likely to be occupying them and, too often, housing growth is seen not as a facility for housing the next generation, but as a threat likely to be populated by aliens!

This fear of the unknown and obsession with the status quo is reason enough why the provision of housing within Great Britain should be decided at a level above and beyond local District Councils. Indeed, until the introduction of the 2004 Planning and Compulsory Purchase Act, housing numbers were decided by County Councils, who were able to take a more objective view.

It is my professional opinion, after more than 25 years of promoting strategic private sector housing development, that if housing numbers are left to local planning authorities, the South-East will face a critical shortage of housing. This, in turn, will de-house the workforce, causing employers to desert London and the South-East to locations where labour can be hired at affordable rates.

This is not a convenient relocation of jobs from Southampton to Solihull, but quite possibly from Southampton to Slovenia.

Labour must be provided where it is needed and to meet this requirement so, too, must housing be made available at prices people can afford.

House building—how much?

The figures put forward in the approved East of England Plan and in the proposed roll forward to 2031 are not based on fiction, but on hard fact. Attached at Appendix I with this submission are extracts from the Strategic Housing Market Assessment Report (SHMAR) for the London Commuter Belt (East) 2008. This document is attached for three reasons:

1.  It sets out the science behind the requirement for house building.

2.  It demonstrates on page four that, in terms of cost, the main areas of cheaper housing within the North London commuter belt are Harlow and Stevenage—both new towns. This is shown on the plan by dark green colouring suggesting that house prices are 75% to 90% of the average, whereas areas marked red are as much as 200% of the average price. The thrust of this submission relates to Stevenage which is where my expertise is focused and where there is a proven need for substantial strategic housing releases over the next 10 years.

3.  Figure 5 of the SHMAR demonstrates that, in Stevenage, only 10% to 15% of people commute to London. As such, it is a more sustainable location to expand rather than, for instance, Harlow which, although it offers good value in terms of house prices, lacks the substantial employment base of Stevenage, benefitting as it does from British Aerospace, Glaxo and a host of other major employers.

The case of Stevenage could apply equally in terms of strategic housing growth to any number of substantial settlements around London—be it Basingstoke, Reading or Guildford—especially when the main settlements lack sufficient space within their administrative boundaries to determine their own rate of expansion.


I repeat that the reason for making the growth case for Stevenage should be viewed in the generality, in that matters which apply to Stevenage can apply equally to other towns. Stevenage has few claims to fame, apart from E M Forster and Lewis Hamilton, but its growth requirements are mirrored throughout the South East.

However, Stevenage's special qualities are:

Cheap house prices—Hertford is up to 70% more (see Appendix II).

Strong employment base.

Substantial social and physical infrastructure, in particular schools and a major hospital.

Location on north-south routes of communication.

Proximity of airports at Luton and Stansted.


Over the last 25 to 30 years, Stevenage has grown steadily at about 800 houses per annum—see Appendix III. In recent years, growth proposed for this key strategic centre, under the East of England Plan, or Regional Spatial Strategy, was to be located west (now approved) and north of Stevenage—within the North Herts administrative area. This was and is because Stevenage has virtually no land for growth within its administrative boundaries.

These new neighbourhoods were being planned jointly by Stevenage and North Herts Planning Authorities, under the Stevenage North-herts Action Plan (SNAP).

DateDevelopment Number of houses
1990sChells Manor3,000 (East Herts)
2000 onwardsGreat Ashby 2,500 (North Herts)

This sustained private sector growth followed on from Stevenage's previous designation as a "new town". The increased amount of private sector housing has increased importance of Stevenage as a key employment regional centre over the past decade(s). It has also changed the economic profile of the population and encouraged higher calibre employers.


Growth envisaged by Stevenage over the next 20 years and, indeed, embraced under the auspices of the Regional Plan and its review was predicted according to the plan attached as Appendix IV.

LocationDate Houses
NES 3/SNAP 52011 ?1,000 (North Herts)
North Stevenage2013 ? 1,000 (North Herts)
NES 42013 ?5,000 (North Herts)
NES 5 new RSS not SNAPPost 2020 5,000 (East Herts)

In contrast to piecemeal housing estates, the SNAP proposals—see Appendix V—envisaged the provision of complete communities, provided with schools, shops, employment and open space, all holistically planned within each neighbourhood. Prior to the abolition of Regional Plans, development consortia were in place, ready to submit planning applications on these growth areas in order to deliver new complete communities from 2013.


As stated previously, prior to the abolition of the East of England Plan, Stevenage Borough Council and North Herts District Council were working jointly on SNAP in order to plan and deliver the longer term growth of Stevenage, related to its role as a key centre.

Following the Secretary of State's letter of 27 May 2010, North Herts District Council resolved on 15 June to place all work on SNAP into abeyance.

The Council stated:

"Whilst the North Hertfordshire Cabinet resolution refers to all work on SNAP ceasing until there is further clarity, it is extremely unlikely that SNAP will be resumed in its current form once that clarity is found."

The Council went on to state:

"It is highly unlikely that (NHDC) will reach the same conclusions reached by the East of England Plan."

We are now informed that North Herts plan to go back to Stage I to re-consult on the principles of growth in the district.

In the meantime:

1.  Further strategic housing provision at Stevenage has stopped which will inevitably lead to housing shortages and rising prices.

2.  The provision of a Northern Relief Road (NRR) is scrapped, so it will no longer offer relief to existing housing areas north of the town.

3.  The provision of new primary schools and financial contributions to secondary schools will now cease.

4.  Planned improvements to the Stevenage foul drainage system, already much needed, have stopped.

5.  The much-needed population growth of Stevenage will not now happen, leading to no increased "spend" in the dilapidated town centre, so much in need of regeneration.

6.  Stevenage will offer no safety-valve for housing demand in the locality, which will exert pressure for less sustainable forms of development


Finally, the Terms of Reference include a brief to comment on the arrangements in place for the effective cooperation between local planning authorities and the adequacy of government proposals regarding a duty of local planning authorities to cooperate.

These two questions are identical but attract the same answer. There do not appear to be any arrangements in place that require local planning authorities to cooperate. Indeed, very little seems to have been put in place by Government, only a spree of abolition, which has horrified the House Builders Federation and prompted Carla Homes, among others, to seek a judicial review of the government's actions.

Other sources have calculated that in the order of 26% of the national economy is dependent upon a buoyant housing market; this high figure stems not only from direct employment in the construction industry but in DIY purchases, purchases of carpets and soft furnishings, removals, conveyancing but, most importantly, the whole supply chain of the building industry.

In spite of this vital importance to the national economy, Planning Resource reports that housing supply decreased for the second month in a row, falling by 2.2% in August according to latest market research by Hometrack.

In addition, Government has announced the cancellation of Housing and Planning Delivery Grants (HPDG) which will further curtail planning authorities' ability to kick-start the private housing sector.

We are told that the purpose of the new legislation (although there has been no legislation) was to promote more rapid housing delivery because the Local Development Framework introduced under the Planning and Compulsory Purchase Act 2004 was not working.

On the contrary, it was working and "if it ain't broke, it does not need fixing".

Yet now the joint SNAP plan at Stevenage has been scrapped, and over 7,000 much-needed houses will not be built in this vibrant town.

September 2010

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Prepared 31 March 2011