Written evidence from the British Property
Federation (BPF) (ARSS 90)
INTRODUCTION
1. This submission by the British Property
Federation has been prepared in response to the CLG Select Committee's
request for evidence on the revocation and abolition of regional
spatial strategies. We understand that the inquiry will have a
particular focus on the abolition of regional house building targets;
the likely effectiveness of incentives for local communities to
accept housing development and the nature and level of the incentives
needed to ensure long-term supply of housing. Evidence will also
be sought on arrangements to be put in place to ensure appropriate
cooperation between local planning authorities on matters formerly
covered by regional spatial strategies; the adequacy of proposals
already put forwards by Government; and how the data and research
collated by the Regional Local Authority Leader Boards should
be made available to the local authorities.
2. The British Property Federation (BPF)
is the voice of property in the UK, representing companies owning,
managing and investing in property. This includes a broad range
of businesses— commercial property owners, financial institutions
and pension funds, corporate landlords, local private landlords—as
well as all those professions that support the industry.
SUMMARY
We have no problem with the revocation of regional
spatial strategies. However, there is a need for a degree of strategic
planning in some areas above that of local authorities.
It is imperative that the transition to a new system
does not lead to a hiatus in development at a time in which there
is a need both to meet a major housing shortage and stimulate
business growth.
The duty to co-operate must be clearly defined in
order to assist local authorities to work together collaboratively.
However, we do not believe that such a duty will be sufficient
in itself to achieve the degree of strategic planning required.
In view of the need to have a proper degree of strategic
planning, we believe that there should be some requirement on
authorities to demonstrate that they have put workable procedures
in place.
We agree, in principle, that LEPs could take on some
sort of strategic planning role but we see a lot of potential
problems in their doing so
Few local authorities can possess the full range
of skills that they may need across areas such a regeneration
and planning. There will be a much greater need in future for
local authorities to share skills and even on occasions merge
departments. LEPs could in theory be a vehicle for achieving this.
We welcome the proposals to introduce incentives
to encourage local authorities to promote growth. We believe that
a gradual move towards even greater relocalisation of rate income
would provide a much stronger motivation for local authorities
to back new development that generates economic activity and creates
new jobs
TRANSITIONAL ISSUES
We fully accept that the Government has a clear mandate
to scrap Regional Strategies (RS). However, it is important that
the reforms are carried out with the minimum of disruption both
to local authorities and to the private sector. The revocation
of RS sparked fears that:
Local authorities would pull the plug on housing
schemes in their areas which they had never wanted but had felt
compelled to accept to meet their housing targets.
There is evidence that this has been happening.
However the Government has stressed its commitment to increasing
the overall level of housing supply and that it intends to offset
the revocation of RS and associated housing targets by giving
local authorities new incentives to approve new development. We
look further below at how effective these incentives are likely
to be but it is clearly desirable that they are put place as soon
as possible.
Local authorities would respond to the revocation
of RS and other uncertainties around planning by delaying or rejecting
applications for large scale schemes of commercial and mixed use
schemes as well as residential schemes.
The anecdotal evidence that we are getting
about this is inconclusive. There is a need to establish more
clearly what is happening on the ground. We are seeking evidence
from our members about this.
Those aspects of RS that were genuinely useful,
including a lot of the supporting data, could be lost, leaving
local authorities or successor strategic bodies to reinvent the
wheel at additional and unnecessary expense.
Both we and others have flagged up this
issue and we hope that, as the regional structures are dissolved
and regional staff are made redundant, proper procedures will
be put in place to safeguard valuable material. This is an important
issue for the select committee to explore.
THE RELEVANCE
OF STRATEGIC
PLANNING
Strategic planning can bring clear benefits. There
will always be some elements of planning (such as minerals, waste
and strategic infrastructure) that will require some form of co-operation
between neighbouring local authorities. If properly organised
and implemented, strategic planning can offer a more joined-up
approach to help deliver more efficient services and infrastructure
as well as deal with environmental issues that do not respect
local authority boundaries such as flooding. In the current climate,
in which the private sector often lacks the confidence to invest,
collaborative working between local authorities can also help
provide the certainty needed to ensure investment. Such working
can make best use of resources and specialist skills in plan-making.
Accordingly, we welcome the Government's recognition
that co-ordination of some strategic issues at a higher level
than that of individual local planning authorities is necessary.
The key then is to work out how that strategic planning can be
organised in a way that is compatible with the Government's overarching
commitment to localism.
GOVERNMENT PROPOSALS
FOR STRATEGIC
PLANNING
From what we can glean, the Government seems to be
suggesting that the degree of strategic planning needed can be
delivered though the imposition of a duty on local authorities
to co-operate with each other and possibly through some more structured
co-ordination, maybe via Local Enterprise Partnerships (LEPs).
DUTY TO
CO -OPERATE
We welcome the proposed duty on local authorities
to co-operate with their neighbours. This will be a helpful starting
point for any new framework for strategic planning. However, such
a duty to co-operate is not easily defined or understood, and
so will need further elaboration to avoid confusion and to ensure
that each local authority plays their part. If the duty is to
take effect as it should, enabling authorities to work together
effectively to produce cross boundary agreements and facilitating
collaborative working, this should be clearly defined in the forthcoming
legislation. The emphasis should be on continual planned engagement
rather than sporadic communication to ensure that the most effective
collaborative systems and methods of working can be put in place.
Cross-Border Structures
Whilst we agree that imposing a duty on local authorities
to co-operate with each other would be helpful, it would need
to be coupled with some clear structure within which that co-operation
can take place. The Government is keen that any new strategic
planning structures should, in the spirit of localism, reflect
the wishes of relevant authorities. We have no difficulty with
that but, in view of the need to have a proper degree of strategic
planning; we believe that there should be some requirement on
authorities to demonstrate that they have put workable procedures
in place.
The Government has suggested that Local Enterprise
partnerships could have a role to play in this context. We agree
in principle that LEPs could take on some sort of strategic planning
role. However, also see a number of stumbling blocks:
A strategic planning role would be more practical
if, as originally intended; LEPs genuinely reflect natural economic
areas. However, the likelihood that there will be over 50 LEPs
does not fill us with confidence that such bodies will operate
at an appropriately strategic level.
The function and structure of LEPs have been defined
in only the broadest terms at present and so it is unclear how
such a planning function would fit with other LEP functions.
There is also uncertainty over the amount of funding
likely to be available to LEPs. The £1 billion Regional Growth
Fund (spread over two years) is unlikely to stretch very far given
the many different claims upon it. It is likely, therefore, that
strategic planning could only be delivered via LEPs if local authorities
were prepared to contribute their own staff and resources to the
process. This might be difficult in light of the cuts that are
certain to fall on local authorities.
SHARING AND
POOLING OF
SKILLS
It is not feasible for all local authorities to possess
in-house the full array of specialist skills that they may from
time to time require. This is particularly the case in regeneration
and planning. When a comparatively small authority takes on a
major regeneration project, it generally needs to access outside
expertise. LEPs could be a vehicle for fostering the greater sharing
of skills (in areas such as land assembly, decentralised energy,
regeneration and conservation) that is needed between local authorities.
It might be that LEPs could also play a role where local authorities
decide to go even further in improving service delivery by merging
some of their activities which those of neighbouring authorities
(for instance, Westminster and Hammersmith and Fulham are looking
to merge educational services, whilst Cambridgeshire and Northamptonshire
are looking to merge back-office services). There is no reason
why the potential for doing this in an area such as planning should
not be examined too.
HOUSING/COMMERCIAL
DEVELOPMENT
Whilst the government has scrapped housing targets,
they have stressed that this is not a signal for local authorities
to sit on their hands. They are looking to local authorities to
respond positively to the country's housing need and are committed
to incentivising local authorities to meet that need. They are
equally committed to incentivising business growth.
EFFECTIVENESS OF
PROPOSED INCENTIVES
We applaud the Government's commitment to incentivise
local authorities to take a more positive approach to development
proposals. It proposes to do this for housing under the New Homes
Bonus scheme by matching the council tax raised on each new house
for six years. It is also proposing to use rating incentives to
encourage business expansion via a Business Increase Bonus.
With house building is at its lowest since the 1920s,
there is a danger that the hiatus in construction will continue
as planners and local authorities readjust from the previous "top-down"
system to the new "bottom-up" approach. It is imperative
therefore, that full and complete proposals are published as soon
as possible to expedite more housing, job creation and regeneration.
We note that the money to pay the bonuses to authorities
will come from the overall grant that authorities receive and
that those authorities who fail to authorise development will,
therefore, not only lose out on the bonus but would actually see
their income fall. In the light of this, our view is that this
approach could be more successful than some people think in motivating
authorities to approve new development.
We believe, however, that the Government should be
even bolder. Breaking the link between local authorities and rating
income has led to a position where local authorities gain little
from actively seeking or fostering beneficial development. A gradual
move towards even greater relocalisation of rate income would
provide a much stronger motivation for local authorities to back
new development that generates growth and creates new jobs. It
would show, perhaps more than anything else, just how seriously
the Government is taking its localism agenda.
PRESUMPTION IN
FAVOUR OF
SUSTAINABLE DEVELOPMENT
We welcome the Government's commitment to introducing
a presumption in favour of sustainable development. This too could
act as a counterbalance to the abandonment of housing targets.
It will, however, need careful drafting. The danger is that such
a presumption could be hedged with such a lot of caveats and exemptions
as to be totally meaningless.
September 2010
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