Written evidence from Ropemaker Properties
Limited (ARSS 76)
SUMMARY
The need for new homes across England, particularly
in London, the south-east and east remains significant.
New homes, both market and affordable, are vital
elements of the social infrastructure required to support economic
growth and recovery.
The implications of the proposed abolition of Regional
Strategies will depend upon the measures put in place to plan
for and deliver future development.
Much greater detail is needed about those measures
in order to be able to consider the longer term implications.
The revocation of Regional Strategies has had an
immediate impact, with a number of authorities withdrawing or
reviewing plans and in some instances refusing planning applications.
This will have the effect of reducing the supply
of land for housing in the short term at least. It has also created
uncertainty amongst developers, particularly in relation to strategic
schemes.
In many quarters there is a concern that sufficient
land will not come forward for housing.
Local communities must be involved in the process
which leads to decisions being taken which will affect them, however,
in relation to planning for development, there are often wider
public interests to be weighed and taken into account.
In order for local communities to effectively engage
in a constructive debate there is a need to provide evidence and
information in an accessible format on matters such as affordability,
demographics and economics.
The evidence base prepared for Regional Strategies
remains relevant and material, often having been tested at examination
and found sound.
That evidence should be accorded significant weight
in preparing plans and in taking decisions on planning applications.
In bringing forward any reforms there is a need to
put in place effective mechanisms for spatial and strategic planning
across boundaries and for determining appropriate levels of housing
provision.
A duty of cooperation should be enshrined in primary
legislation.
This submission is made by Savills on behalf of Ropemaker
Properties Limited, the property nominee of the BP Pension Fund.
The planning system has a major impact on land and property values
and therefore is of significance to Ropemaker and the Pension
Fund.
1. Implications of abolition of regional house
building targets for levels of housing development
1.1 The need for new homes across England, particularly
in London, the south-east and east is significant. We welcome
Government statements that it will support people's aspirations
for housing. We consider that new homes, both market and affordable,
are vital elements of the social infrastructure required to support
economic growth and recovery in these areas and nationally. In
many communities people are forced out of the housing market by
the lack of availability or cost. Not only does this have significant
social implications, but it also has negative environmental effects
as people are forced to travel further, usually by car, compounding
climate change impacts. Delivering new homes in the right locations
has social, economic and environmental benefits.
1.2 The implications of the proposed abolition
will depend upon the measures put in place to plan for and deliver
future development. Much greater detail is needed about those
measures in order to be able to consider the longer term implications.
However, the revocation of Regional Strategies has had an immediate
impact, with a number of authorities withdrawing or reviewing
plans and in some instances refusing planning applications. This
will have the effect of reducing the supply of land for housing
in the short term at least. It has also created uncertainty amongst
developers, particularly in relation to strategic schemes. In
many quarters there is a concern that sufficient land will not
come forward for housing. In moving toward a more community focussed
approach, there are a number of factors which we consider will
need to be taken into account.
PUBLIC INTEREST
1.3 The planning system was established in 1947
to control the development and use of land in the public interest.
We agree that in any system, local communities must be involved
in the process which leads to decisions being taken which will
affect them. However, in relation to planning for development,
there are often wider public interests to be weighed and taken
into account in decision-making. It is right for Governments,
both local and national, to consider all the evidence and come
to "in principle" views on issues such as the level
of house building in the public interest. That public interest
might take a number of forms - social, economic or environmental.
Social disadvantage
1.4 The east of England contains a number of
former new towns, which are in need of investment and regeneration.
Local authorities in some of those areas have supported growth
in order to help transform and regenerate their urban communities.
In many instances this has required/requires expansion into neighbouring
rural areas, often across local authority boundaries. In a number
of cases the communities in those rural areas have opposed growth.
An important facet of the planning system is, in the public interest,
to consider and reconcile issues and if necessary take difficult
decisions. There is a risk that communities, whose housing and
employment needs are met, will resist development to the disadvantage
of those less well-off.
Supporting economic growth
1.5 In our view, housing, both market and affordable,
is critical infrastructure needed to support economic recovery
and regeneration. An adequate supply of new homes is required
to house the labour force. Failure to deliver sufficient new homes
will act to undermine economic growth and recovery. A key objective
of any reforms to the planning system must be to facilitate the
delivery of development required to support economic growth of
the country coming out of the recession and to sustain that growth
in the longer term.
Environmental implications
1.6 Failure to deliver sufficient homes in locations
of high demand and close to economic drivers is likely to have
significant environmental implications. People will be forced
to live further from the places where they work and will often
be forced to commute by car, generating greater carbon emissions
and contributing to climate change.
1.7 In bringing forward a more community-oriented
planning system, care will need to be exercised to ensure that
undue weight is not given to private interests over genuine public
interests, such as addressing social disadvantage, supporting
economic growth and tackling climate change.
Spatial & strategic planning
1.8 Planning for a community cannot be undertaken
in isolation from other places. There is a need for spatial and
strategic planning. For example, the influence of London is significant
and extends well beyond its administrative boundaries. Communities
in London's hinterland have an important role to play in supporting
the growth of London in the national economic interest. There
can also be significant benefits for those communities, not always
recognised, such as the income associated with jobs in London,
which is spent in local communities.
1.9 It is not just London which exerts influence
beyond its boundaries. In many places across the east and south-east
of England, small to medium sized market towns have grown to their
boundaries. Often these places are important economic centres,
serving sizeable rural hinterlands. Given the range of services
and employment opportunities they offer, such places have in the
past been identified by local authorities as the locations most
suitable to accommodate growth where the most effective use of
transport, social and other infrastructure can be made. However,
the future growth of such places cannot be planned for in isolation
from neighbouring towns and villages.
1.10 Strategic decisions are also required to
deliver the scale of new homes likely to be required. Society's
need for housing is a material planning consideration. There remains
a need for the planning system to indentify the need for new homes
and to plan for that growth. The planning system is key to reconciling
the desires of local communities with the needs of society.
1.11 In South Cambridgeshire, for example, there
are over 100 villages. If each village were to determine it should
deliver say 50 homes over a 15 year period, 5,000 homes might
be delivered. The Council's adopted Core Strategy currently proposes
to deliver 1,176 homes a year equating to 17,650 homes over a
15 year period.
1.12 In bringing forward any reforms there is
a need to put in place effective mechanisms for spatial and strategic
planning across boundaries and for determining appropriate levels
of housing provision.
CERTAINTY AND
CLARITY
1.13 The development industry, investors. Infrastructure
providers and communities all seek certainty and clarity from
the planning system. The revocation of the RS has created uncertainty
and a lack of clarity. Swift action is required to address this
to ensure development does not stagnate whilst primary legislation
is delivered.
DEFINITION OF
LOCAL COMMUNITIES
1.14 Local communities are diverse and varied.
Within an area there may be any number of local community interests.
There are residential communities, business communities, sporting
communities, urban communities, rural communities. All will have
different perspectives on issues. Often those interests will cross
local authority boundaries. Whilst we fully support the need to
engage with local communities in determining the future of their
areas, that must encompass the full ambit of local community interests
and there will remain a need for the planning system to reconcile
the views of those different interests.
2. The likely effectiveness of the Government's
plan to incentivise local communities to accept new housing development,
and the nature of the incentives which will need to be put in
place to ensure an adequate long term supply of housing
The incentives
2.1 Underlying the Government's proposed approach
is a belief that incentives will ensure a long term supply of
housing. Getting the incentives right will, therefore, be fundamental
to achieving Ministers' objective of meeting peoples' housing
aspirations. To date there has been limited information on what
these incentives might be and how they might operate.
2.2 The New Homes Bonus Scheme intends to directly
reward councils for new homes built. We agree that any such scheme
must relate to the actual delivery of new homes, rather than the
granting of permissions. The Minister for Housing and Local Government's
letter of 9 August 2010 announcing the New Homes Bonus Scheme
advises that consultation on the detail of its operation will
take place later this year. In the absence of this detail of its
operation, it is difficult to comment on the likely effectiveness
of the measures. Given the current spending climate, there is
a need for clarity as to the level of funding which will be made
available.
2.3 The Minister's letter of 9 August advised
that local authority finance does not adequately reflect the costs
of growth. We agree that local authority financing should reflect
the costs of growth. There are a number of issues which
need to be factored in. Firstly, local government financing has
operated on a basis of floors and ceilings to ensure variation
in funding does not vary excessively. Dependent upon the scale
of the incentives, there is potential for major winners and losers
to be created if funding regimes are to be amended to reflect
the costs of growth. Secondly, in the case of extensions to urban
areas, growth may occur across local authority boundaries. Whilst
development may occur in one authority, the actual impacts on
communities may be felt in an adjoining area. It is clear that
economic factors and development needs do not respect artificial
boundaries. Whatever system is put in place, there needs to be
far greater joint working and cooperation between local authorities
2.4 We have already noted that there has been
an impact on progress with development plans following revocation
of regional strategies. Given the current financial climate and
the Comprehensive Spending Review, there must be a question as
whether and to what extent the incentives will deliver additional
funding. Clarity on this matter is required urgently to encourage
local authorities and communities to start embracing and delivering
new development.
3. The arrangements which should be put in
place to ensure appropriate cooperation between local planning
authorities on matters formerly covered by regional spatial strategies
(eg waste, minerals, flooding, the natural environment, renewable
energy, etc)
3.1 Arrangements are required in order to ensure
appropriate cooperation between planning authorities. That is
not just in relation to the matters identified above, but also
in relation to economic growth targets, meeting housing needs
and infrastructure requirements.
3.2 A duty of cooperation would be welcomed.
Such a duty should be enshrined in primary legislation. Such a
duty should extend to setting policy and consideration of cross-boundary
issues, rather than simply being a duty to cooperate with other
authorities operating within the same local authority area.
3.3 Advances have been made in recent years with
local authorities cooperating in the preparation of the evidence
base for development plans. However, we consider there remains
scope for greater cooperation over matters such as infrastructure
studies, development options, retail studies, housing assessments.
Not only should this lead to better planning and a more consistent
evidence base, it should also result in cost savings.
4. The adequacy of proposals already put forward
by the Government, including a proposed duty to co-operate and
the suggestion that Local Enterprise Partnerships may fulfil a
planning function
Duty to cooperate
4.1 A duty of cooperation would be welcomed.
Such a duty should be enshrined in primary legislation. Such a
duty should extend to setting policy and consideration of cross-boundary
issues, rather than simply being a duty to cooperate with other
authorities operating within the same local authority area.
Local Economic Partnerships
4.2 We consider that Local Enterprise Partnerships
could and should have an important role in the planning and development
of areas. Businesses are vital elements of the local community
and its right that business interests should have a say in how
communities grow or develop. It will be important that LEPs are
seen as bodies which are involved in and can influence the development
of policy and decision-making or there is a risk that they will
fail to attract business leaders. The duty to cooperate should
include a duty to engage with the LEP in the preparation of development
plans.
5. How the data and research collated by the
now-abolished Regional Local Authority Leaders' Boards should
be made available to local authorities, and what arrangements
should be put in place to ensure effective updating of that research
and collection for further research on matters crossing local
authority boundaries
5.1 Whilst the policies of the RS no longer form
part of the development plan, the evidence base which was used
to prepare published RS has been tested through Examination in
Public. Such tested evidence is not without significant weight
and should not be discarded lightly. It is likely that in many
cases re-assessments of housing need will demonstrate that evidence
to be sound. Accordingly, the RS evidence based should be used
therefore not only to inform the preparation of development plans,
but also decisions on planning applications during the transitional
period unless and until there is evidence to the contrary.
5.2 In order for local communities to effectively
engage in a constructive debate about the future of their communities
there is need to provide evidence and information in an accessible
format on matters such as affordability, demographics and economics.
Without such information, debates over the futures of local communities
risk being uninformed and polarised. Information such as that
prepared by the Leaders' Boards may well have an important role
to play in educating and informing local communities so that they
can give informed views.
6. CONCLUSIONS
6.1 It is right that local communities play a
role in the debate over the future of places. It will be important
that in increasing the role of local communities in decision-making
that all voices can be heard and that debates are fully informed
by evidence presented in accessible formats.
6.2 Whilst incentives for accommodating new development
is welcomed, the planning system must look forward, identify issues
to be addressed, forecast development needs and make provision
for new development and supporting infrastructure. That requires
planning authorities to take a wider view in the interests of
society as well as taking into account the wishes of local communities.
6.3 At the heart of any system must remain the
principle that planning seeks to weigh and reconcile competing
interests and that decision-makers act in the wider public interest.
In modern society, where economies do not respect artificial boundaries
there is a need to ensure that mechanisms are put in place to
secure effective spatial and strategic planning across areas.
September 2010
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