Written evidence from Ashfield District
Council[107]
(ARSS 67)
SUMMARY OF
KEY POINTS
Local people and district councillors considered
they had little or no influence on the housing numbers and housing
requirements which they felt were imposed on them by the Regional
Spatial Strategy. This was reflected during the consultation period
for the Core Strategy Preferred Option published earlier this
year. There was very strong opposition to the larger urban extensions
proposed from existing communities. The urban extensions were
deemed necessary in order to meet the housing targets that had
been provided by the RSS.
The Council is supportive of the RSS being replaced
by a more localised system but simply abolishing the RSS has resulted
in a number of issues for the Council. These include: a local
policy gap, how to determine the long-term housing requirement,
an infrastructure policy gap and issues over what now constitutes
a five year housing supply.
The Council considers there is a requirement for
some strategic planning. One of the principle benefits from the
policies within the East Midlands Regional Plan (1)
has been that it has initiated the working together of local planning
authorities. Planning at a more strategic level is necessary to
set out priorities for investment and to tackle issues which go
beyond neighbourhood and district boundaries—ensuring sustainable
and demand led growth.
Cross boundary working is likely to continue but
a duty to co-operate does not mean that it will result in aligned
plans.
If a bottom up approach to housing is to be adopted
through localism, it has to be accepted that it may not achieve
the housing figures identified by the research undertaken by the
National Housing and Planning Advice Unit.
The revocation of the RSS has left a gap at a local
level in terms of longer-term housing requirements.
From the Council's experience, large scale development
is usually controversial and it is unlikely that any reasonable
level of incentives can persuade people to accept housing development
when the reality is that it will change the local landscape which
they value. Under the new proposals, Local Authorities may be
put in an invidious position of trying to balance the much needed
revenue from incentives against the concerns of local communities.
There are difficulties in getting local people involved
in matters of strategic planning. From the responses received
to the Council's consultations it was clear that, despite all
the consultation undertaken by the Council, local people were
unaware of the housing requirements for the District or simply
ignored it on the grounds it was unlikely to directly impact upon
them.
The current system of LDF is too complicated and
takes too long and it needs to be simplified. Change is required
but this can be achieved through changes to regulations and simpler
policy guidance to make the system more effective and easier to
understand for Members, Officers and the community.
One of the key aspects raised by local people in
relation to housing proposals was the inadequacy of the local
infrastructure to take more housing developments. New housing
needs to be accompanied by the appropriate infrastructure, particularly
if local people are going to support further development. Clarity
on this link is vital in order to overcome opposition and make
development truly sustainable.
1. ASHFIELD DISTRICT
COUNCIL
1.1 Ashfield District is located on the
western side of Nottinghamshire. The Council serves an estimated
population of 116,450 (mid-2008 ONS). The majority of this population
together with associated housing, jobs and services are concentrated
within the three main towns of Sutton in Ashfield, Hucknall and
Kirkby in Ashfield together with three large villages in the substantial
rural area mainly to the west of the M1 motorway.
1.2 As a local planning authority, the Council
is under a statutory obligation to prepare local development documents
under Part 2 of the Planning and Compulsory Purchase Act 2004
and is required to control development under Part III of the Town
& Country Planning Act 1990.
2. RESPONSE
Regional Spatial Strategies (RSS)
2.1 There is little doubt that the RSS was remote
from local people. The Council's experience in undertaking consultations
on the Core Strategy was that the majority of people in the district
were unaware of the East Midlands Regional Plan (the RSS)(1)
and its implications. Local authorities also became less relevant
in planning terms as the housing numbers and their distribution
were determined at a regional level. The Council's Core Strategy(2)
was substantially shaped by the East Midlands Regional Plan which
not only identified the specific housing numbers but also their
broad location. Policies within the RSS required new houses to
be located in and around the urban areas of Mansfield-Ashfield
and Hucknall (emanating from a policy of urban concentration).
From the responses on the Core Strategy consultation and the comments
of District Councillors, it is clear that both local people and
Members considered they had little or no influence on the housing
numbers and housing requirements were imposed on them by the RSS.
2.2 The Council would give broad support to the
RSS being replaced by a more localised system which allows for
meaningful consultation and for decisions to be made at a local
level. However, simply abolishing the RSS has resulted in a number
of issues for the Council which include:
A local policy gap - Section 54A of the Town and
Country Planning Act 1990 requires that applications for planning
permission should be determined in accordance with the development
plan unless material considerations indicate otherwise. The development
plan consisted of two elements:
(a) The East Midlands Regional Plan (RSS).
(b) The Local Plan or where adopted the Local
Development Framework.
In accordance with Government guidance, a number
of policies in the Ashfield Local Plan Review 2002 were not saved
on the basis that they were repeated in the Joint Structure Plan,
which in turn was replaced with policies with the RSS. The abolition
of the RSS has resulted in not just the housing numbers being
removed but also all the other policies within the Plan. Effectively
part of the development plan no longer exists. Consequently, the
Council is reliant on the saved policies in the Ashfield Local
Plan Review,(3) which expires in 2011 and national
planning policy statements/guidance. This includes for example
flooding, where the Council no longer has any local flooding policies.
Issues around the determination of long-term housing
requirements. How are these to be determined and who provides
the technical expertise for population/household projections?
An infrastructure policy gap—It has left a
policy gap in relation to making major investment decisions in
infrastructure.
Uncertainty on the five year housing supply—Planning
Policy Statement 3 (PPS 3)(4) identifies that the Council
should have a five year housing supply and there is a presumption
in favour of granting permission where there is less than a five
year housing supply (PPS 3 paragraph 71). The letter from the
Chief Planner at the Department for Communities and Local Government
dated 6 July 2010(5) stresses that authorities should
have a five year land supply of deliverable sites. What the letter
fails to do is identify what the five year housing supply is to
be based now the housing figures in the RSS have been revoked?
This has created uncertainty and confusion for local planning
authorities, agents, house builders and the local community. It
also increases the likelihood of appeals against planning determinations
until such time as there is some clarity on this issue.
Localism
2.3 Planning has always reflected the need to
incorporate and balance international, national, regional, sub-regional
and local issues. However, in recent years there has been an increasing
prescriptive approach from national planning statements and regional
planning. For example, Planning Policy Statement 4(6)
emphasis economic issues over social or environmental aspects.
It also states in paragraph 3 that "It is only necessary
for the development plan to reformulate development management
policies in this PPS 4 if there are specific
factors justifying variation of these policies. "It is felt
that "Place shaping" needs to be undertaken at a local
level rather than being prescribed at national and regional levels.
Therefore, the Council is supportive of a local approach to planning
where planning reflects the aspirations of local communities.
2.4 Nevertheless, the Council also recognises
that there are distinct dangers if there is a total absence of
any level of strategic planning. One of the principle benefits
from the policies within the East Midlands Regional Plan is the
working together of local planning authorities. This has been
seen both in developing an evidence base and in an aligned Core
Strategy for the Greater Nottingham area. However, since the Coalition's
announcements on the revocation of the RSS, the aligned Core Strategy
across Greater Nottingham has been put on hold. Planning at a
more strategic level is necessary to set out priorities for investment
and to tackle issues which go beyond neighbourhood and district
boundaries. This can include issues such as the local economy,
transport, flooding, water resources and the protection and enhancement
of the environment. Therefore, localism has to be seen in the
context of where it is necessary to plan for some issues at a
larger scale, recognising that meeting the needs of the wider
community may have an impact on a more localised neighbourhood.
This is recognised in the governments LEP proposals so there appears
to be a policy discord in this respect.
2.5 To date local council's in Nottinghamshire
have worked together and this is likely to continue into the future
as there as costs saving through providing a shared evidence base.
However, without a duty to co-operate there is a danger that the
benefits of cross boundary working may be lost in the localism
agenda. Nevertheless, a duty to co-operate does not mean that
it is necessary to produced aligned plans. If there is a significant
need for housing development in Greater Nottingham, this may require
substantial areas of green belt land around Nottingham to be released
and for neighbouring authorities in Greater Nottingham to work
together. Without some form of policy obligation, as was set out
in the EMRP, it is much more questionable whether there will be
an aligned Core Strategy for Greater Nottingham, for understandably,
local councillors are concerned with their immediate area.
2.6 The taking forward of a localism agenda is
likely to require a number of actions including:
(a) The Council in terms of both Councillors
and Officers in engaging with the local community in quickly producing
a long term plan for the place shaping of the District.
(b) Planning, and Housing Officers to provide
an up to date evidence base of local housing needs.
(c) Councillors to accept that there is a requirement
for them to be properly trained on planning and development to
support localism.
(d) For Councils, developers and local communities
to work together particularly on master plans and area action
plans.
Future Housing Requirements
2.7 The revocation of the RSS has left a gap
in terms of housing requirements. The "Open Source Planning"
Green Paper suggests that regional targets and regional plans
should be replaced with local targets based on assessments of
housing need. However, with the revocation of the RSS no interim
arrangements have been put in place and no guidance has been provided
in relation to undertaking a "local" study of housing
requirements. Under these circumstances, the Council has determined
to put the housing requirements on hold until they are clarified
by central government. This has resulted in a further delay to
producing a Local Development Framework which relates to much
more than just housing issues.
2.8 Local housing assessments are necessary but
it is important that there is some degree of uniformity across
councils in the techniques and methodology applied to identifying
local housing needs. However, in our opinion it has to be accepted
that if a bottom up approach to housing is to be adopted through
localism, it is unlikely to achieve the level of housing building
that research undertaken by the National Housing and Planning
Advice Unit(7) has identified.
2.9 A more localised approach is likely to increase
community buy in and may bring forward community-led development
on a small scale. However, will this be the case if a significant
housing requirement is identified? From the Council's experience,
large scale development is usually controversial. Proposals for
large housing sites generate opposition from people who already
have homes in the immediate vicinity of the proposals and are
looking to protect the local environment in which they live from
change. It is unlikely that any reasonable level of incentives
will persuade people to accept the housing development required
when the reality is that it will change the local landscape they
value. What is often not heard from in our consultations is the
silent element of the community for whom affordable housing is
required or who are priced out of the housing market by the relationship
between local incomes and house prices. Affordability remains
a key element of delivering sustainable and targetted housing
growth to support socio-economic change.
2.10 There is a need for a local evidence base
of housing requirements together with infrastructure requirements
which provides a base for formulating the LDF. The question that
arises is how to take forward planning decisions reflecting the
evidence base which may be opposed by local people in a specific
neighbourhood?
2.11 Localism will put far more responsibility
on local councillors and proper support and training is required.
In these circumstances, local councils need to make difficult
choices in the context of being fully informed by an evidence
base and the interests of local people. Further, local councillors
need to be able to participate in local decisions and engage with
the community at both pre and post application stages. This means
that issues relating to probity need to be considered and clearly
set out as part of any future guidance.
2.12 In essence, the housing
requirement comes back to the traditional planning dilemma of
balancing economic, social and environmental issues against the
need for a democratic process that enables communities to influence
how their local area develops.
Community engagement
2.13 There are difficulties in getting local
people involved in planning. The Council took a number of steps
to increase awareness in the District of the housing requirements
(11,200 dwellings for the period 2006 to 2026). This included:
a leaflet being distributed to every household in the District
to highlight the issues surrounding the LDF and, in particular,
the need for 11,200 houses in the District. Extensive additional
consultation was also undertaken. Nevertheless, it was not until
strategic sites were allocated in the Core Strategy Preferred
Options document that local people became significantly involved
in the consultation, opposing the proposed sites close to their
homes.
2.14 Currently, community empowerment in Ashfield
has focused on tackling key local objectives, eg community safety,
environmental improvement and front-line service delivery. However,
spatial planning, is vital to place shaping and people need to
be engaged so that they feel they have a real stake in changes
to where they live and work. In this context, the current system
relating to the LDF is too complicated and confusing for local
people and needs to be simplified and reformed as opposed to being
abolished per se. Local communities and organisations have contributed
towards the Council's Core Strategy and this work needs to be
carried forward. Reform is required but this can be achieved through
simpler changes to regulations and policy guidance to make the
system more effective, streamlined and easier to understand.
Infrastructure
2.15 A key aspect for any housing development
is the associated infrastructure. From the consultations undertaken
by the Council one of the key aspects raised by local people was
the inadequacy of the local infrastructure to take more housing
developments. Whether this was true or not, clearly new housing
needs to be accompanied by the appropriate infrastructure, particularly
if local people are going to support further development. This
has a number of implications:
(a) The infrastructure delivery plan needs to
be retained if changes are made to the LDF.
(b) There is a need for some strategic planning
across district boundaries at a sub regional level across district
boundaries.
(c) How are improvements to the infrastructure
to be financed given that:
low values in districts such as Ashfield limit opportunities
for securing developer contributions to infrastructure, and
the public expenditure cuts will result in limited
opportunities to undertake regeneration schemes?
(d) Limited public investment in such areas as
transport infrastructure programmes will impact on the local communities'
perception in relation to new housing and infrastructure requirements.
(e) How will the proposed Local Enterprise Partnerships
act as conduits for infrastructure investment into the district?
(f) How does the government's proposal for new
schools fit into the localism agenda and infrastructure planning?
It is stressed that it is important that the duty
to co-operate does not simply relate to councils but on public
bodies and on the utility companies such as Severn Trent Water
if spatial planning is to be taken forward.
REFERENCES
(1) East Midlands Regional Plan 2009. Department
of Communities and Local Government.
www.gos.gov.uk/497296/docs/229865/East_Midlands_Regional_Plan2.pdf
(2) The Core Strategy The Preferred Option. March
2010. Ashfield District Council.
www.ashfield-dc.gov.uk/ccm/cms-service/stream/asset/?asset_id=10873001&
(3) Ashfield Local Plan Review. November 2002.
Ashfield District Council
www.ashfield-dc.gov.uk/ccm/cms-service/stream/asset/?asset_id=5071143&
(4) Planning Policy Statement 3: Housing. June
2010. Department of Communities and Local Government.
www.communities.gov.uk/documents/planningandbuilding/pdf/planningpolicystatement3.pdf
(5) Letter to Chief Planning Officers: Revocation
of Regional Strategies. 6 July 2010. Chief Planner, Department
for Communities and Local Government.
www.communities.gov.uk/documents/planningandbuilding/pdf/1631904.pdf
(6) Planning Policy Statement4: Planning for
Sustainable Economic Development. December 2009. Department of
Communities and Local Government.
www.communities.gov.uk/documents/planningandbuilding/pdf/planningpolicystatement4.pdf
(7) More homes for more people: advice to Ministers
on housing levels to be considered in regional plans. July 2009.
National Housing and Planning Advice Unit.
www.communities.gov.uk/documents/507390/pdf/1299593.pdf
September 2010
107 It should be noted that the response has been provided
by Officers from Ashfield District Council and has not been formally
endorsed by Members of the Council. To this end the comments provided
are from a professional and not a political standpoint. Back
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