Written evidence from Fenland District
Council, Huntingdonshire District Council, and Cambridgeshire
County Council (ARSS 98)
1. INTRODUCTION
AND SUMMARY
1.1 This response has been prepared by the Strategic
Directors for Planning for the following Cambridgeshire authorities
in consultation with Lead Members:
Fenland District Council.
Huntingdonshire District Council.
Cambridgeshire County Council.
1.2 In summary it is considered that:
The abolition of regionally imposed housing targets
and the creation of a more locally-based planning system are welcomed
in principle.
The implications of the abolition of regional house
building targets will be different for different areas, but will
have less impact where there is an existing strategy in place
that already receives wide support. However, the abolition has
given rise to some uncertainty which the Cambridgeshire authorities
have dealt with through a joint statement.
Any incentives for new communities to accept development
need to be delivered in an open and transparent way and need to
be part of a wider package of measures if they are to have the
desired effect.
Upper tier authorities should have their statutory
strategic planning role reinstated.
Any proposed "duty to cooperate" on infrastructure
provision is welcomed. However, infrastructure provision cannot
be considered in isolation from the planning strategy it is intended
to facilitate.
Data from the now-abolished Leaders' Boards should
be made available on-line and preferably held at a single place.
This information will need to be updated, but it is likely that
this will be on a different geographical basis.
2. THE IMPLICATIONS
OF THE
ABOLITION OF
REGIONAL HOUSE
BUILDING TARGETS
FOR LEVELS
OF HOUSING
DEVELOPMENT
2.1 The abolition
of regional house building targets and the creation of a more
locally-based planning system are welcomed. Local authorities,
working with local communities, are best placed to determine appropriate
levels of growth for their areas and should, through working in
partnership, plan strategically for their wider sub-regions.
2.2 The implications
of the abolition of regional house building targets will be different
for different areas depending on a range of factors, including
the stage local authorities had reached in preparing their Local
Development Frameworks, whether the Regional Strategy was under
review and whether there was general agreement on the housing
targets it contained.
2.3 While the abolition of Regional Strategies
may have led to delays in some areas of the country, in areas
where partnership working has led to the development of a joint
strategy, the loss of regional housing targets will have less
impact. In Cambridgeshire the authorities have a history of joint
working to address strategic planning issues. This resulted in
the Cambridgeshire and Peterborough Structure Plan (2003) which
in turn informed the Regional Spatial Strategy, The East of England
Plan (May 2008). The authorities continued this work in responding
to the review of the RSS, and the authorities' comments were reflected
in the policies and growth levels subsequently set out in the
draft revision to the East of England Plan in March 2010. The
Cambridgeshire strategy has already met with considerable success,
and while more remains to be done, it is likely that any review
of the strategy can be undertaken through further joint work within
a supportive legislative framework. In the meantime the uncertainty
surrounding the current position has been dealt with locally by
the Cambridgeshire authorities agreeing a joint statement of adherence
to current policy which had in any event been locally derived.
2.4 It is considered
that the abolition of Regional Strategies provides an opportunity
for local authorities to plan strategically through cooperation
and partnership working. To provide additional clarity it is recommended
that the anticipated National Planning Framework and the forthcoming
Localism Bill support this approach and promote the strategic
planning of new development and infrastructure and planning for
minerals and waste (see response under Section 4).
3. THE LIKELY
EFFECTIVENESS OF
INCENTIVES TO
LOCAL COMMUNITIES
TO ACCEPT
NEW HOUSING
DEVELOPMENT
2.1 There needs to be recognition that the identification,
allocation and development of new housing sites is a complex process
influenced by a range of factors, including:
The general economic climate.
The aspirations of landowners and developers.
The views of the local community and capacity to
influence the process.
The strategic vision for the area and local planning
process.
Existing infrastructure capacity and planned infrastructure
improvements.
3.2 These factors also influence each other:
the economic climate will affect developers' and landowners' aspirations
and appetite to develop and will also affect viability and the
infrastructure improvements that can be secured through development;
levels of infrastructure provision will affect local support for
a scheme; and community support will depend on an understanding
of the benefits new development can bring and previous experience
of the planning process.
3.3 Any proposals to improve the delivery of
housing need to address these complex and interlinked issues.
The Rt Hon Eric Pickles MP in his statement of 6 July stated that
"The new planning system will be clear, efficient and will
put greater power in the hands of local people, rather than regional
bodies." To foster economic recovery and ensure that employment
growth is matched by housing to support sustainable development
in the most appropriate locations, it is likely that some incentive
mechanism will be needed, but this should be part of a wider package
of measures that tackle the factors outlined above and addresses
all of the service and infrastructure impacts that development
gives rise to.
3.4 Any proposal for a system of incentives needs
to address the following issues:
Level of the incentive—There
is currently little information on which to judge proposals for
the New Homes Bonus, although it appears that there will be no
additional money beyond that previously allocated through the
Housing and Planning Delivery Grant. Any incentive will need to
be substantial if it is to influence what could, in some areas
of the country, be firmly established opposition to new development.
Timing and relationship to other funding—There
needs to be clarity between incentive arrangements and other development
funding mechanisms, particularly the Regional Growth Fund, Community
Infrastructure Levy and Section 106 Agreements or their replacements.
Authorities are also engaged in the Single Conversation with the
Homes and Communities Agency (HCA). The Cambridgeshire Local Investment
Plan (CLIP) for example has been prepared by Cambridgeshire Horizons
and the Housing Board, in partnership with Local Authorities and
other key stakeholders, in order to facilitate the Single Conversation
between the Cambridgeshire authorities and the HCA. Infrastructure
to support new development is a key concern for local people;
new housing needs to be supported by a full range of infrastructure,
including public transport, education and community services,
renewable energy and green infrastructure. While most of this
will be provided through the development itself, there will be
circumstances where further funding is needed. This infrastructure
needs to be delivered up-front; however the proposed New Homes
Bonus is likely to be received after the homes have been occupied
at a stage when it is too late to influence local views about
the suitability of a scheme.
Transparency of funding arrangements—Any
replacement funding system will need to be transparent, so that
it is not undermined by the perception that planning permission
is being 'bought' through the provision of incentives.
Certainty of funding arrangements—New
proposals need to engender long-term certainty so that local authorities
can plan for the future with the confidence that necessary improvements
can be secured. Clarity is needed so that local authorities can
make decisions on infrastructure funding and how to mitigate the
impacts of new development.
3.5 In Cambridgeshire, the local authorities
and Cambridgeshire Horizons have undertaken considerable community
engagement work to shape the County's growth strategy and ensure
a fully informed debate. The authorities also led on engaging
local people and businesses during the review of the former East
of England Plan to raise people's awareness of the regional planning
debate and make sure that the Cambridgeshire response was properly
informed by local views. In Cambridgeshire the delivery of infrastructure
is a more significant barrier to housing delivery than lack of
community support—the Integrated Development Plan identifies
an infrastructure gap of £6 billion (at 2007). If it is to
be effective, a local incentive must be part of a wider package
of measures, tackling all the barriers to housing delivery.
4. ARRANGEMENTS
WHICH SHOULD
BE PUT
IN PLACE
TO ENSURE
APPROPRIATE COOPERATION
BETWEEN LOCAL
PLANNING AUTHORITIES
ON MATTERS
FORMERLY COVERED
BY RSSS
4.1 It is considered that, despite the abolition
of Regional Strategies, there remains a need to think and plan
strategically. Strategic planning is necessary to join up local
needs and aspirations to wider issues that cross administrative
boundaries. Strategic planning fulfils a number of functions,
including:
Tackling the relationship between housing market
areas and economic issues, such as housing affordability, housing
mix and tenure, economic growth and labour supply.
Considering functional economic areas, including
opportunities to rebalance the economy and promote growing sectors
of the economy.
Linking land use and transport planning at a strategic
level.
Providing a framework for the delivery of strategic
infrastructure, including highways, public transport, renewable
energy, green infrastructure and flood and water management.
Assessing the cumulative impacts of development on
protected habitats, river catchments and other environmental assets.
Providing for the future needs of communities by
anticipating likely economic and demographic trends.
Providing a coherent sub-regional strategy to enable
infrastructure providers and utilities companies to plan their
investments.
Securing economies of scale through the joint commissioning
of work and sharing resources.
4.2 It is considered that the most appropriate
way to address these issues is through voluntary partnerships
of authorities coming together to plan strategically for sub-regions.
Planning at this scale should be driven by the need to deliver
sustainable development, linking employment and housing and identifying
priorities for future investment.
4.3 This partnership approach needs to be based
on local authorities' knowledge of local needs and aspirations,
their joint understanding of the wider issues facing their sub-regions
and their vision for its future development.
4.4 Legislation should make provision for sub-regional
strategies to be afforded development plan status, provided that:
This approach receives the endorsement of all the
authorities within the area.
It can be demonstrated that this is needed to tackle
issues of greater than local importance.
4.5 Whatever mechanisms are put in place they
need to recognise the key role of strategic authorities. Under
the previous system strategic authorities had a statutory role
in providing advice to Regional Assemblies on the development
of Regional Strategies, until this was removed under the Local
Democracy, Economic Development and Construction Act. Any future
system needs to recognise that strategic authorities play a vital
part in planning for and providing services - including social
services, transport and education - and bringing forward the infrastructure
needed for sustainable growth
4.6 There also need to be clear links to the
implementation of any sub-regional strategy and support for the
infrastructure requirements it gives rise to. It is unclear what
will be encompassed by the "Infrastructure Plans" referred
to in the Green Paper and to what extent they will encompass existing
processes (local planning authorities' Infrastructure Plans and
strategic authorities' Education, Libraries, Waste Management
and Local Transport Plans) or the work of Local Enterprise Partnerships.
A sub-regional approach would provide the opportunity to deliver
the priorities outlined both by the local community and the strategic
vision emerging from the Local Enterprise Partnership.
4.7 Regarding planning for minerals and waste,
although the revocation of Regional Strategies has provided an
element of uncertainty, the implications for Cambridgeshire and
Peterborough are considered to be manageable.
4.8 Cambridgeshire County Council and Peterborough
City Council have evaluated the implications of the revocation
of the East of England Plan on the emerging Minerals and Waste
Plan as part of their response to the Inspector who has begun
the examination of the Plan.[135]
From this evaluation the Councils have concluded that the provision
set out in the emerging Plan is consistent with work produced
by the East of England Regional Aggregates Working Party (RAWP)
and the Regional Waste Technical Advisory Body (RWTAB). This consistency
meets the advice set out by the Secretary of State in his revocation
letter, where he states:
"Councils should continue to plan for mineral
provision within the established framework of aggregate apportionment."
In relation to waste, "the work of the RWTABs
should inform the provisions of the Plan."
As such the Councils have concluded that the Plan
should progress on the basis of the existing level of minerals
and waste management provision regardless of the revocation of
the East of England Plan.
5. 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
5.1 There is little information on the proposed
"duty to cooperate" put forward in the Green Paper;
however, such a duty is welcomed if it encourages local authorities
and other agencies—including infrastructure providers—to
work together in planning for new infrastructure. However, the
infrastructure plan should not be developed in isolation from
the wider spatial vision for an area; both should emerge from
the joint planning approach outlined above. Infrastructure and
facilities are required to enable key public and statutory services
to be provided.
5.2 It is considered that the role of the Local
Enterprise Partnership should be to support the case for investment
in the physical and social capital needed for a successful economy
by identifying needs and contributing to overcoming the barriers
to growth.
6. HOW THE
DATA AND
RESEARCH COLLATED
BY THE
NOW-ABOLISHED
LOCAL AUTHORITY
LEADERS' BOARD
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
6.1 The existing evidence base developed for
the Regional Strategies should be made publicly accessible. It
would be helpful if the evidence was held by a single body as
a national dataset.
6.2 Without a regional impetus to the collection
and analysis of data, it is likely that the existing evidence
base will become out of date. However, local authorities will
wish to come together to share resources and commission new research.
There are therefore likely to be new collaborative geographies
that emerge following the demise of the regions, whether based
on Local Enterprise Partnership areas or smaller groups of local
authorities acting sub-regionally. There are clear benefits to
this approach in ensuring consistency of data and securing economies
of scale in commissioning work. The danger is that the existing
models developed for the regional planning process quickly become
out of date, and the construction of new models, based on different
geographies, involves high initial start-up costs.
September 2010
135 For a full copy of the response please see the
"Response to Inspector's Note 1" (reference CSCRIN1)
using the following link: http://www.cambridgeshire.gov.uk/environment/planning/mineralswasteframework/mineralswasteplan/dpdexaminationrestrategy/responsestoinspector.htm Back
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