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

Written evidence from the Retirement Housing Group of the Home Builders Federation (ARSS 70)


RSS policies were beginning to recognise the importance of providing housing suitable for older people. This recognition must be carried forward into National Planning Guidance;

A planning hiatus has arisen following the revocation of RSSs and CLG must clarify the role of local authorities until the new framework is put in place;

under the proposed new planning system housing targets must not be the only criterion for granting planning permission. Criteria-based approvals should supplement the policy numbers;

Local Enterprise Partnerships should support National Planning Guidance which recognises the housing needs of an ageing population and they should encourage local planning authorities to include suitable policies to provide such housing in their development plans;

it is difficult to evaluate the effect of the New Homes Bonus until 20 October when the outcome of the Spending Review is known but it must be structured in such a way that local communities see that it brings them direct benefits, unlike S.106 Agreements, which clearly did not address that problem or overcome local opposition; and

in the light of the rapid growth in the number of older people as a proportion of the population consideration should be given to extending the proposed 125% incentive for social housing to specialist housing for older people to ensure an adequate supply of housing in the longer-term.


The widespread recognition at national policy level of the need to plan for an ageing and growing population (evidenced by PPS 3; "Lifetime Homes; Lifetime Neighbourhoods" and the Housing our Ageing Population: Panel for Innovation (HAPPI) Report)(1) was gradually being reflected in many regional spatial strategies, which were starting to acknowledge demographic trends and support the provision of suitable accommodation for an ageing population. Local planning authorities were required to take such regional policies into account when drawing up Core Strategies/Local Development Frameworks and no doubt they would have done so in due course. However as many have yet to be adopted it is difficult to assess how far that has been, or will be, taken into account at local level in future.

This is a significant issue for local plan-making. Demographic modelling shows that many areas have high and growing numbers of older people. For example, in May the ONS published the 2008-based Sub-national Population Projections estimates(2) showing that 16% of the English population was over 65 in 2008, rising sharply to 2033, with some local authorities registering over 40% by then (West Somerset, Berwick on Tweed, South Shropshire and West Dorset, Rother and North Norfolk).

We therefore hope that the National Planning Framework that government is to put before Parliament will not ignore the beneficial policy developments in RSSs, such as the recognition of the need to plan for housing for older people, and that this is included in the national guidance to which local planning authorities should have regard.

Following the revocation of RSSs, we hope that local authorities will recognise existing national guidance and the extensive work carried out regionally and sub-regionally when they revise current plans or draw up new ones. However the hiatus caused by the revocation of RSSs and the confusion created by the abolition of the regional tier is a concern, with Government issuing no clear interim guidance for local planning authorities on how to proceed during the transitional period. Many local authorities have suspended the plan process or asked to withdraw plans so they can consider the implications of the potential changes to the system, and take these into account in preparing the consultation documents. For example, Hart DC said it wanted to avoid any decisions being taken that were later proved to be unsound or unnecessary.

There could be a hiatus of at least four years if some local authorities suspend local plans until a) the new planning system completes its Parliamentary process and comes into effect and b) replacement plans are drawn up and adopted.

Because of the current policy confusion neither local authorities nor retirement housing developers are clear how to proceed. If this situation persists for any length of time there will be a significant hiatus in the development pipeline.

We therefore urge that that, as well as relying on the New Homes Bonus, Ministers issue fuller guidance under the new system to ensure local authorities know how to calculate housing numbers, even if they are totally responsible for the actual number, and that the criterion for determining planning applications will not be based simply on numbers but will also include the absence of harm to the plan to enable acceptable windfall sites to be developed.


CLG and BIS propose that Local Enterprise Partnerships, which should include groups of upper tier authorities, take over responsibility for planning and housing, local transport and infrastructure from RDAs and provide strategic leadership at sub-regional level.

On 14 July Housing Minister Grant Shapps said: "We are scrapping regional planning... removing the regional tier of Government...Regional Spatial Strategies and top-down housing targets. Instead, through Local Enterprise Partnerships, we are placing responsibility for economic development with the people who really understand the challenges and opportunities their area faces."

So how large a role will LEPs have on housing and planning matters? Will they be adequately funded to play an effective part at sub-regional level? Will they undertake research and issue information and guidance to local planning authorities?

We believe that their role should include the identification of the housing and social care needs of ageing populations in their sub-regions and the provision of an appropriate framework for policy implementation at local level.

Planning magazine commented on 3 September "...a clear blueprint for what LEPs should be doing, how they will do it and how their performance can be judged is noticeable by its absence...Without thinking through these basic ideas, ministers risk being forced to intervene further down the line. Without a proper remit, there will be no proper results."

Government has said that more information about the new sub-regional LEP structure will be available after the Spending Review in October. We hope this includes details of their relationship with local planning authorities and whether this will ensure that there is appropriate cooperation between local planning authorities on matters formerly covered by regional spatial strategies.

We would urge Government to devise such a blueprint, together with a framework to evaluate performance, before the Spending Review and any public announcement on LEPs, and we look forward to learning more about their role, funding and relationship with local planning authorities in the expectation that it will support positive policy making in this area.


We are also invited to comment on 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.

It is difficult to judge the likely effectiveness of the Bonus because there has been little additional detail provided since Conservative Policy Green Papers Nos. 9 and 10 were published in 2009.

Policy Green Paper No. 10 said: "...we will match the additional council tax raised by each council for each new house built for each of the six years after that house is built" and "We will therefore consult on how to build on and augment our council tax incentive scheme in order to increase the incentive for councils to deliver affordable houses." Recently CLG Minister Bob Neill commented (8 September) that the new homes bonus scheme would include funding at 125% for social or other affordable housing. It could reasonably be argued that a similar, enhanced, incentive for local authorities who supported specialised housing schemes for older people should also be given serious consideration, bearing in mind the need to provide for our rapidly ageing population. If the building of more such properties were encouraged by local planning authorities, older people could remain independent for longer, with a better quality of life, thereby relieving the burden on NHS, welfare and social services and freeing up family-sized homes for families.

It is very important that any incentive scheme is seen by local communities to be bringing them directly-related benefits arising from new development in their area. If there has been concern in the past that S.106 Agreements have failed to deliver this then the Bonus must identify and resolve the problem if, as the Government intends, it is to overcome opposition and win supporters for development.

We would welcome further information on how the New Homes Bonus will work and how this will related to the Government's revised proposals for a Community Infrastructure Levy which they say, together, will "send a very clear signal that local authorities that choose to go for growth...will receive substantial extra funding for doing so."(3)

We would be pleased to supply more information to answer further questions if the Committee would find this helpful.


(1)  The Government-commissioned HAPPI (Housing our Ageing Population: Panel for Innovation) to produce a Report which was published in December 2009, recommending that "Central Government prioritises the building of new homes for our ageing population as a key component of its housing, health and care policies".

(2)  Subnational Population Projections (SNPP) for England Statistical Bulletin—2008-based www.statistics.gov.uk/statbase/Product.asp?vlnk=997

(3)  Housing Minister Grant Shapps' letter of 9 August to local authority leaders formally announcing the New Homes Bonus.

September 2010

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