Written evidence
from Building and Social Housing Foundation (BSHF) (ARSS 71)
EXECUTIVE SUMMARY
The Building and Social
Housing Foundation (BSHF) is an independent housing research charity
which is committed to ensuring access to decent and affordable
housing for all.
BSHF has undertaken research into the likely impact
of the abolition of Regional Spatial Strategies (RSS) on regions
in the Midlands and the North of England. The following recommendations
are based on the findings of this research (summarised in this
submission) and on previous work by BSHF on "the future of
housing".
BSHF welcomes the government's acknowledgement of
the broad need for additional housing supply but recommends that
it should be clarified into a commitment to act to deliver sufficient
housing supply to meet need.
BSHF recommends that the government should urgently
act to reduce the current uncertainty by requiring local authorities
to publicly register their housebuilding targets or timetable
for revision. Proposed changes to the planning system should include
a mechanism for local authorities to publish both their housebuilding
targets and actual completions.
BSHF recommends that the RSS housing target be made
the explicit default target in every area that has not formally
adopted an alternative figure. This would not prevent local authorities
from setting their own targets, but would minimise the potential
for harmful policy voids as there would be a default target in
place until and unless an alternative was set at the local level.
BSHF recommends that the government ensures that
adequate technical and methodological support is provided to local
authorities to ensure that their assessment of housing need is
robust.
BSHF recommends that the government clarifies how
it will monitor the impact of policy changes at a local and national
level to ensure that they are having the desired impact. Sufficient
data and analysis should be made freely available to local authorities
and the public to ensure accountability and transparency.
BSHF recommends that the government should clarify
how local authorities determine "local need" for Gypsy
and Traveller accommodation with specific reference to when Gypsy
and Traveller Accommodation Assessments should be updated.
BSHF recommends that the government should require
each local authority to publish their targets for Gypsy and Traveller
accommodation and actual completions on an annual basis. As above,
this information should be collated centrally and published by
CLG, to improve transparency and aid monitoring. This will help
to ensure that the costs of undersupply are minimised.
The
Building and Social Housing Foundation (BSHF) is an independent
housing research charity which is committed to ensuring access
to decent and affordable housing for all. BSHF holds Special Consultative
Status with the United Nations Economic and Social Council. In
June 2009 BSHF organised a Consultation at St George's House,
Windsor Castle. It was chaired by Lord Richard Best and brought
together practitioners and academics from a wide range of housing-related
backgrounds to examine "The Future of Housing". This
submission is based on the findings of that Consultation[108]
and on original research conducted by BSHF.[109]
More detailed information can be found on the BSHF website (www.bshf.org)
or on request from the organisation.
1. Recognition of the continued importance
of long term undersupply of housing
1.1 In their announcement of the abolition of
Regional Spatial Strategies the coalition government highlighted
that housebuilding had dropped to its lowest levels since 1924
despite government targets to build three million homes by 2020.[110]
1.2 Since the announcement of the RSS revocation
organisations such as the Royal Town Planning Institute, National
Housing Federation and Planning Officers Society have expressed
concerns about the proposed changes. The overwhelming concern
pivots around the economic and social effects of a more restricted
housing supply. It is clear that many feel that the removal of
the regional layer of the planning system would significantly
reduce the supply of new build houses and therefore limit the
overall increase in housing stock of the England.
1.3 In this context it is important to recognise
the urgent need for greater supply of housing. Kate Barker's review
of housing supply in 2004 highlighted the main economic problems
surrounding an undersupply of housing within a UK context.[111]
It explained that an undersupply of housing can:
Constrain economic growth.
Create a greater risk of macroeconomic instability.
Worsen affordability.
The social repercussions caused by an under supply
in housing are also significant and include:[112]
Affordability issues for first time buyers.
Limited accessibility to both the market and social
sectors.
Greater housing pressure, as future housing requirements
increase.
1.4 The coalition government has acknowledged
that there is a need for additional housing. On the day that the
RSSs were abolished, the Secretary of State, Eric Pickles, said
in a speech to the Local Government Association that "the
country has a housing shortage. But it's time to concentrate on
building homes, rather than dreaming up numbers."[113]
He expressed similar sentiments in parliament, stating:
"Imposed central targets will be replaced with
powerful incentives so that people see the benefits of building.
The coalition agreement makes a clear commitment to providing
local authorities with real incentives to build new homes …
Because we are committed to housing growth, introducing these
incentives will be a priority…"[114]
1.5 BSHF welcomes the government's acknowledgement
of the broad need for additional housing supply but recommends
that it should be clarified into a commitment to act to deliver
sufficient housing supply to meet need.
2. Investigation into the impact of RSS abolition
on housebuilding targets
2.1 BSHF has been undertaking an urgent review
to assess the likely impact of RSS abolition on housebuilding
targets in the regions of the midlands and the north of England.
(Research had previously been announced, commissioned by the National
Housing Federation and conducted by Tetlow King covering the southern
regions. Consequently BSHF has not sought to duplicate that work.)
2.2 A questionnaire was sent to all planning
departments across these regions. The questionnaire was used to
gain information on the effects of new government policy on the
assessment of housing need and subsequent housing targets in each
local authority. Each local authority was asked to provide the
following information:
Will the Local Planning Authority be changing its
housing targets since the RSS revocation, or will it be staying
with its RSS targets?
If the targets will be changing, which figures will
the Local Planning Authority be adopting instead? For example,
the Chief Planner has stated the possibility of using Option 1
figures (the figures originally submitted to the original Regional
Spatial Strategy examination).
Therefore, what are the Local Planning Authority's
future housing targets?
Are you also reviewing the RSS figures for provision
of Gypsy and Traveller pitches (and if so, how and when will you
be reviewing it)?
2.3 The first wave of research was conducted
in the East Midlands, with the questionnaire subsequently sent
to the local planning authorities in the West Midlands, Yorkshire
and the Humber, North East and North West. Consequently we have
the fullest results so far from the East Midlands.
2.4 The questionnaire was sent to all 40 local
planning authorities in the East Midlands. In the East Midlands
the response rate to the survey was 85% of local authorities (34
authorities). Of those that responded, the indications were:
38% of local authorities are keeping the RSS targets
for housebuilding.
32% of local authorities are undecided.
21% of local authorities are intending to adopt a
new target.
9% of local authorities are using the RSS while they
decide a new figure.
No local authorities have yet decided to adopt the
Option 1 figures.
2.5 For the remaining regions surveyed (West
Midlands, Yorkshire and the Humber, North East and North West)
the questionnaire was again sent to all local planning authorities,
a total of 107. As these questionnaires were sent in a second
wave the response rate at the time of writing is lower than for
the East Midlands. These results should be viewed as interim findings
and BSHF will publish the full findings in due course. The response
rate to date has been 56%. Of those that responded, the indications
were:
48% of local authorities are keeping the RSS targets
for housebuilding.
30% of local authorities are undecided.
13% of local authorities are intending to adopt a
new target.
5% of local authorities are using the RSS while they
decide a new figure.
3% of local authorities are using Option 1 figures.[115]
2.6 Of those local authorities undecided or intending
to adopt a new target, only nine gave an indication of the likely
direction of any change. Of these, seven indicated a reduced target;
two other local authorities indicated that need for housing was
higher than RSS targets and that any new target would be likely
to involve an increase. Of those local authorities indicating
that their targets would change, one provided an indication of
the scale of that change, a reduction in the range of 11-24%
1. 3. Confusion
and the need for clarity
3.1 One of the major findings of the research
was the level of confusion that exists at a local level. Some
local authorities responding to the research were struggling to
understand the nature and scope of their new responsibilities.
This is despite the vital importance of avoiding undersupply of
housing.
3.2 BSHF recommends that the government should
urgently act to reduce the current uncertainty by requiring local
authorities to publicly register their housebuilding targets or
timetable for revision. Proposed changes to the planning system
should include a mechanism for local authorities to publish both
their housebuilding targets and actual completions.
3.3 Local authority housebuilding targets should
be collated by Communities and Local Government (CLG) and published
on their website. This could be done on a periodic basis, through
a mechanism similar to the Housing Strategy Statistical Appendix
(HSSA) spreadsheet published annually, or through a mechanism
similar to the Live Table spreadsheets that CLG makes available
on other housing issues.
3.4 Proposals from the Conservative Party prior
to the election stated that during the interim period between
the abolition of regional government and the introduction of a
new planning system, local authorities would revert back to their
Option 1 figures. They stated that:
"Local planning authorities have already projected
the number of houses they (as opposed to the regional authorities)
believed would be necessary by 2026 for local needs—the
so-called Option 1 numbers".[116]
3.5 Of the local authorities that have responded
to the survey, only three stated that they intended to use their
Option 1 figures; in two of those cases the Option 1 figure was
the same as that in the RSS, so the authorities could equally
have responded that they were keeping their RSS figures.
3.6 There are indications that the definition
of "Option 1" figures is either not sufficiently clearly
defined, or that the definition is not universally understood
in a consistent fashion. One professional involved in the former
regional planning process told us:
"My understanding is that Option 1 housing figures
are those which LAs [local authorities] approved for inclusion
in the draft RSS. … However, one could argue that option
1 figures generated by LAs are in fact those which came out of
technical work done by the LAs themselves which were then modified
through discussion with the then [Regional] Assembly. In some
cases the figures agreed by LAs and presented to the Assembly
were higher than those which eventually appeared in the draft
RSS, which in the end represented politics and consensus."
3.7 Some other local authorities stated that
they did not have an Option 1 figure.
3.8 Given the inconsistent understanding of the
term "Option 1", and the fact that some local authorities
do not believe that they have such figures, it is concerning that
they have been proposed as an implicit default target. An alternative
default would be the RSS figure, which is present in every local
authority area.
3.9 BSHF recommends that the RSS housing target
be made the explicit default target in every area that has not
formally adopted an alternative figure. This would not prevent
local authorities from setting their own targets, but would minimise
the potential for harmful policy voids as there would be a default
target in place until and unless an alternative was set at the
local level.
2. 4. Providing
support to local authorities
4.1 Local authorities responding to the research
expressed concern about their ability to accurately assess housing
need in their area. One local authority stated that as it was
a small authority it "did not have the capacity to produce
anything of similar robustness [to the RSS]". Local authorities
have previously received support in this process from several
sources at both a regional and national level.
4.2 Regional bodies such as Government Offices
and Regional Assemblies provided support to local authorities
in the assessment of local housing need. This took the form of
technical guidance and scrutiny for local assessments of housing
need. Further support to local authorities was provided by organisations
such as the National Housing and Planning Advice Unit (NHPAU).
The NHPAU provided free, independent information on housing provision
and affordability. The NHPAU has been closed and much of the regional
support has now finished. The withdrawal of this support is a
major concern to some local authorities who fear that they do
not have the financial or technical resources available 'in-house'
to make a robust assessment of local housing need.
4.3 BSHF recommends that the government ensures
that adequate technical and methodological support is provided
to local authorities to ensure that their assessment of housing
need is robust.
3. 5. National
assessment of policy impacts
5.1 The loss of technical support and knowledge
at both regional and national level will also have an impact on
wider assessment of housing need.
5.2 Another important practice, carried out by
the Regional Leaders Boards, was the collection of local authority
data. Through the RSS a comprehensive database of strategic targets
was built up, this allowed greater efficiency in analysing and
researching different impacts of both regional and national trends.
With the removal of the statutory functions from the Regional
Leaders Boards, there is a risk that the compilation of data will
be lost. There has been no announcement of a replacement for this
function. It is important that central government, local authorities
and the wider housing sector have access to good quality data
on housebuilding targets and affordability.
5.3 The closure of the NHPAU in June 2010 led
to the loss of impartial, evidence-based, expert advice and research
about the impact of planned housing provision on affordability,
and wider housing supply issues in England. This removed valuable
research and expertise in a time of major policy change. There
is an urgent need to monitor the proposed changes to ensure that
they are having the intended impact on housing supply and affordability.
The closure of research hubs such as the NHPAU also diminishes
the transparency of both local and national government through
reducing research on the impact of policy changes.
5.4 BSHF recommends that the government clarifies
how it will monitor the impact of policy changes at a local and
national level to ensure that they are having the desired impact.
Sufficient data and analysis should be made freely available to
local authorities and the public to ensure accountability and
transparency.
6. Provision of accommodation for Gypsies
and Travellers
6.1 There is a major shortage of accommodation
for Gypsies and Travellers that has built up over decades. Evidence
suggests that this undersupply leads to local authorities incurring
significant expenditure for every pitch that is under-supplied
in their area[117],
not to mention the social impacts felt both by travelling communities
and the wider population.
6.2 Local authorities in the East Midlands have
also responded to BSHF about their intentions in relation to the
provision of accommodation for Gypsies and Travellers. These results
indicate that:
71% of local authorities that responded were planning
to keep the RSS targets for provision of accommodation for Gypsies
and Travellers.
29% of local authorities that responded were planning
to review the RSS targets for provision of accommodation for Gypsies
and Travellers.
6.3 The proportion of local authorities who intend
to keep the RSS targets for Gypsy and Traveller accommodation
is much higher than those intending to keep the RSS targets for
housebuilding (71%-45% respectively). Comments from local authorities
suggest that they chose to keep the Gypsy and Traveller targets
because they were derived from the Gypsy and Traveller Accommodation
Assessments. They considered these to be a robust estimation of
need and, therefore, were happy to retain these targets. Several
local authorities who are reviewing their targets cited problems
with the Gypsy and Traveller Accommodation Assessments as their
reason for doing so. Other local authorities highlighted the need
to review their Gypsy and Traveller Accommodation Assessments
from 2012 onwards.
6.4 BSHF recommends that the government should
clarify how local authorities determine "local need"
for Gypsy and Traveller accommodation with specific reference
to when Gypsy and Traveller Accommodation Assessments should be
updated.
6.5 BSHF recommends that the government should
require each local authority to publish their targets for Gypsy
and Traveller accommodation and actual completions on an annual
basis. This will help to promote transparency and ensure that
the costs of undersupply are minimised. As above, this information
should be collated centrally and published by CLG, to improve
transparency and aid monitoring.
September 2010
108 Diacon, D, Pattison, B and Vine, J (2009) The Future
of Housing: Rethinking housing for the twenty-first century, http://www.bshf.org/scripting/getpublication.cfm?thePubID=4FF3F1F7-15C5-F4C0-99959BAD3ED44A50 Back
109
The full findings of the research will be published in due course
and can be made available to the Select Committee on request. Back
110
Communities and Local Government (2010) Eric Pickles puts stop
to flawed Regional Strategies today, http://www.communities.gov.uk/news/newsroom/1632278 Back
111
Barker, K (2004) Delivering Stability: Securing our future housing
needs, http://www.barkerreview.org.uk/ Back
112
NHPAU. (2009). Housing requirements and the impact of recent economic
and demographic change.
http://www.communities.gov.uk/documents/507390/pdf/1221553.pdf
Back
113
Pickles, E (2010). Speech to Local Government Association Conference
2010. http://www.communities.gov.uk/speeches/newsroom/lgaconference2010 Back
114
Pickles, E (2010) Written Ministerial Statements, 6 July 2010.
http://www.publications.parliament.uk/pa/cm201011/cmhansrd/cm100706/wmstext/100706m0001.htm#10070623000003 Back
115
Figures do not sum to 100% due to rounding. Back
116
The Conservative Party, n.d. http://www.conservatives.com/~/media/Files/Green%apers/planning-green-paper.ashx
Back
117
Vine, J and Pattison, B (2009) Providing Accommodation for Gypsies
and Travellers in Leicestershire: A Financial Analysis, http://www.bshf.org/published-information/publication.cfm?lang=00&thePubID=E84E09F7-15C5-F4C0-99D6F89557BC0263 Back
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