Written evidence from Devon County Council
(ARSS 79)
SUMMARY
In the absence of regional housing targets it will
be important to demonstrate how the cumulative levels of provision
made by LDFs address wider housing need and demand at the sub
regional level as individual LDF areas do not relate in any way
to Housing Market Areas or economic functional areas.
Government needs to re-assess national forecasts
to ensure their robustness and regain ownership of them at a strategic
level. This national framework needs to be the starting point
from which more local (sub regional or LEP area) assessments are
be undertaken in order to underpin LDF preparation.
The concept of incentivisation is welcomed in principle.
The concept does however need to be accompanied by clear rules
about apportionment as there are distributional issues, particularly
in two tier local authority areas.
It is essential that LDFs are not prepared solely
on the basis of the individual planning authority's area, but
rather in the context on the surrounding areas, utilising a shared
evidence base. Government should therefore ensure that there is
a focused but robust sub-regional approach underpinning LDF preparation,
based on a consensus established through a clearly defined "duty-to
cooperate" between local and strategic planning authorities
in order to address major cross-boundary strategic investment
and planning choices which need to be made.
A "duty to co-operate" would help to promote
consensus but the scope and nature of such a duty needs to be
clearly set out and the specific responsibilities of co-operating
authorities defined. Local Enterprise Partnerships do offer a
potential mechanism through which a strategic context can be established
for LDF preparation, but this role should be formally identified,
if and when such partnerships are endorsed by Government, as a
key element of the "duty to cooperate".
It would be helpful for upper tier authorities to
be given a duty to monitor cross boundary strategic issues and
maintain the evidence base necessary to inform a shared and agreed
sub regional evidence base for LDF preparation. This could be
secured through the LEP mechanism or cross boundary cooperation
of upper tier authorities.
It would be helpful for Government to ensure there
is a clearly defined duty-to-cooperate between upper tier authorities
to achieve sub regional minerals aggregates apportionment and
waste facility provision.
Question 1—The implications of the abolition
of regional house building targets for levels of housing development;
Historically, the publication of population and housing
forecasts at national and regional level by central Government
has provided a broad framework within which overall housing supply
could be assessed against housing need. More recently, however,
the targets included within emerging regional strategies have
been driven more by policy aims and aspiration than technical
evidence. Regional targets have therefore become less robust,
and have been based on short term trends that cannot be use as
a foundation for long term planning.
It is critical that housing provision within LDFs
takes account of patterns of population change, migration pressures
and assessments of housing need and demand. In the absence of
regional housing targets it will be important to demonstrate how
the cumulative levels of provision made in LDFs address wider
housing need and demand. These assessments can be undertaken
at a sub regional scale, but individual LDF areas do not relate
in any way to Housing Market Areas, or indeed economic functional
areas. In areas such as Devon, the pressure and need for new housing
is not derived from within each locality but primarily from migration
and movement between Districts.
In the absence of regional targets a purely "bottom
up" approach will therefore tend to focus on development
constraints and fail to provide a sound basis for assessing need
and demand. The essential relationship between housing supply
and demand would be lost.
Current evidence suggests that while some LPAs are
retaining their previous regional targets, a number are looking
at significant reductions. As a result, even assuming every LA
meets their own targets the overall level of provision is bound
to be below the original regional target.
In reality, however, the former regional targets
were not fully deliverable and not related either to the capacity
of the development industry or the availability of essential infrastructure
investment. In areas such as the SW, the removal of the regional
targets may not therefore necessarily reduce actual housing development
rates in the medium term.
In the longer term context, two key issues need to
be addressed. Firstly Government needs to reassess the national
forecasts, ensure their robustness and regain ownership of them
at a strategic level. Secondly, this national framework needs
to be the starting point from which more local (sub regional or
LEP area) assessments are be undertaken in order to underpin LDF
preparation. This will ensure that the planning system secures
a level of housing provision that is deliverable and can be seen
to meet the immediate and longer term needs of the wider community.
Question 2—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
The concept of incentivisation is welcomed in principle.
Development brought forward should however be done so within the
context of adopted Local Development Frameworks which have been
tested for sustainability.
The concept does however need to be accompanied by
clear rules about apportionment as there are distributional issues,
particularly in two tier local authority areas. Whilst it will
be District Councils preparing and adopting LDFs, the County Councils
will bear the major cost of upgrading key infrastructure particularly
for transport and education provision. This also needs to take
account of the impact of development across local authority boundaries
where development is close to the boundary with another authority
and may have significant impact in terms of issues such as transport
and education on the adjoining authority.
Question 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, &c)
It is essential that LDFs are not prepared solely
on the basis of the individual planning authority's area, but
rather in the context on the surrounding areas, and utilising
a shared evidence base. This is especially the case where there
are major cross-boundary strategic investment and planning choices
to be made (eg on strategic housing and employment growth, transport
and communications investment, education and green infrastructure,
renewable energy and the management of the natural environment).
Individual LDF authorities need to be able to make informed decisions
about these strategic choices, or understand the cumulative effects
of their decisions. This does not require an additional level
of plan making—but consensus must be formally agreed, and
tested through the LDF examination process.
Government should therefore ensure that there is
a focused but robust sub-regional approach underpinning LDF preparation,
based on a consensus established through a clearly defined "duty-to
cooperate" between local and strategic planning authorities.
A broadly defined duty to cooperate would not be
sufficient to ensure the effective use of resources or secure
efficient and joined up decision making.
The duty to cooperate must ensure that advice is
both sought and acted upon if it is to be effective. Without the
direct involvement of upper tier authorities there is a real danger
that LDF authorities, while willing to "cooperate",
will not be able to reach agreement on major policy choices.
County Councils and Unitary authorities already have
the knowledge, expertise and experience to inform LDF preparation
at the sub regional level. In order to address major infrastructure
choices and strategic delivery issues, it must be recognised that
upper tier authorities have extensive experience in assessing
strategic housing needs and economic growth, mineral and waste
planning and, critically, infrastructure planning across LDF authority
boundaries. County Councils already take a strategic view in relation
to minerals and waste Local Development Frameworks, Local Transport
Plans and economic assessment and strategy.
Experience in Devon's "Growth Points" has
shown the significant benefits of formal co-operative strategic
planning by groups of local authorities and other partners as
a pre-requisite for delivering sustainable economic and housing
growth. County Councils continue to have a lead role in infrastructure
planning in relation to their own service provision, and in relation
to the responsibilities of other agencies and authorities, and
the phasing and delivery of this infrastructure is critical to
the delivery of development proposed in Local Development Frameworks.
Mineral and Waste Development are matters which are
already determined by upper-tier authorities.
Minerals Planning: In
planning for minerals supply there is a strategic balance to be
made to ensure that supplies in one part of the country are secured
to meet economic needs in another part. The abolition of RSSs
creates a risk that, in those regions such as the South West where
the sub-regional aggregates apportionment is not yet formally
resolved, the apportionment may stall. Failure to complete the
sub-regional apportionment could cause uncertainty and delay to
mineral planning authorities in preparing their development plan
documents and to the minerals industry wishing to seek planning
permission for new resources.
The existing Regional Aggregate Working Parties (RAWPs)
are technical advisory bodies and determination of the apportionment
is outside of their terms of reference and they are not publicly
accountable. Government should ensure there is a consensus established
through a clearly defined "duty-to cooperate" between
upper tier authorities to achieve this.
Waste Planning: There
are similar issues with Waste development. Waste development is
determined by higher-tier authorities, but even at this strategic
level, it is still necessary to work with other Counties/ Joint
Waste Partnerships.
Since the 1990s Waste Technical Advisory Bodies (TABs),have
provided planning authorities with information and data the need
for waste facilities. This strategic overview of provision has
to be maintained.
Question 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
A "duty to co-operate" would help to promote
consensus but the scope and nature of such a duty needs to be
clearly set out and the specific responsibilities of co-operating
authorities defined. Co-operation across local authority boundaries
could help inform the evidence base and the context for progressing
Local Development Frameworks within sub regions. Given the critical
importance of strategic infrastructure delivery, to support the
delivery of major housing and other development, upper tier authorities
must however be required to play a direct role in supporting coordinated
LDF preparation.
Local Enterprise Partnerships (LEP) do offer a potential
mechanism through which a strategic context can be established
for LDF preparation, but this role should be formally identified,
if and when such partnerships are endorsed by Government, as a
key element of the "duty to cooperate".
A Local Enterprise Partnership submission has been
made covering the areas of Devon County Council and the unitary
councils of Plymouth City Council and Torbay Council. Through
LEPs the strategic authorities and their partners would be able
to provide a clear link between the strategic remit of Local Enterprise
Partnerships and the delivery of economic development through
Local Development Frameworks.
Question 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 of further research on matters crossing local authority
boundaries
For the South West Region the data and extensive
studies which were used in preparation of the draft Regional Spatial
Strategy, and supporting it at public examination, have been archived
and will remain accessible by local authorities, other agencies,
academic institutions and the wider public. While it will remain
an interesting "snapshot" and resource base, the data
is now becoming out of date.
The future of the South West Observatory appears
uncertain, and in the current economic context it is unlikely
to be easy to assemble funding to maintain such discretionary
activity.
Upper tier authorities will need to conduct a certain
amount of data collection and analysis to support their local
economic assessments, and plan for their ongoing responsibilities
in relation to functions such as transport, waste management,
education, social care and perhaps health care. However, this
may fall short of the needs of the planning system.
It would be helpful, therefore, for upper tier authorities
to be given a duty to monitor cross boundary strategic issues
and maintain the evidence base necessary to inform a shared and
agreed sub regional evidence base for LDF preparation. This could
be secured through the LEP mechanism or cross boundary cooperation
of upper tier authorities.
September 2010
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