Written evidence from Persimmon Homes
Special Projects Western (PHSPW) (ARSS 112)
SUMMARY
RSS has been abolished, with no clear system to replace
it, or other transitional arrangements put in place, creating
a Policy vacuum and a climate of delay and uncertainty where housing
proposals are being deleted, without sound evidence, and plans
and strategies being delayed. This is preventing the Company bringing
forward proposals and planning applications which would contribute
to meeting the acknowledged housing shortfall.
The proposed system of incentives is unclear, the
level of incentives are unlikely to be sufficient and will not
encourage a long term supply of housing to come forward.
Local Authorities should also co-operate on strategic
housing issues.
If Local Enterprise Partnerships are to have an overall
planning role, it should be clearly set out.
There is a need for an independent body to provide
data for Local Authorities.
INTRODUCTION
This statement is submitted on behalf of Persimmon
Homes Special Projects Western (PHSPW). Persimmon Homes is one
of the Country's leading house builders. PHSPW is responsible
for promoting and delivering large scale strategic housing and
mixed-use sites in the south west and Oxfordshire, through involvement
in all levels of the forward planning system and submission of
planning applications.
ISSUE 1—THE
IMPLICATIONS OF
THE ABOLITION
OF REGIONAL
HOUSE BUILDING
TARGETS FOR
LEVELS OF
HOUSING DEVELOPMENT
PHSPW accept that the Coalition Government are committed
to a fundamental change in planning for housing, based on the
principles of Localism. Over the years there have been a series
of changes to the planning system and the house building industry
has always adapted to make any changes work. In the past clear
changes have been announced and transitional arrangements put
in place to deal with the change from one system to another.
Our first concern, therefore, is that this already
established process has not been followed. Firstly, a Ministerial
Statement was made announcing the intention to abolish Regional
Spatial Strategy. Secondly, there was no indication of what would
replace it (other than an idea that financial incentives would
have a role to play). Thirdly, there were no transitional arrangements
put in place to move from one system to the other (which of course
was difficult, given the new system remains unknown), but instead
the Ministerial Announcement abolishing RSS would apply immediately.
Abolishing one framework, without setting out its
replacement, creates uncertainty in an already weak market and
the establishment of a damaging Policy vacuum, which has had two
consequences for Local Authorities. On the one hand, Authorities
have stopped work completely on progressing their Local Development
Frameworks whilst they wait for further announcements on the forward
planning system. On the other hand, Authorities have reacted to
the announcements by continuing their Local Development Frameworks,
but removing housing allocations from plans, on the basis that
the RSS allocations which required them have been abolished, but
with no consideration of any evidence of whether or not those
allocations were still required. The HBF have estimated that potentially
over 100,000 homes have been deleted in this way.
A particular example of this arbitrary deletion of
housing, of which we are aware, occurs in the west of England
where the four Authorities have deleted over 35,000 houses from
the original RSS allocations (North Somerset 9,000, South Gloucestershire
8,600, Bath and North East Somerset 9,000 and Bristol City 8,500).
All four Authorities are continuing with Core Strategy Documents,
on the basis of these lower arbitrary figures. These figures will
be justified by new evidence of population and housing need, which
will clearly justify the targets, rather than identifying the
actual new requirements.
In relation to houses lost, we accept the Government
will argue if those houses are needed and supported locally they
will still come forward. Our point is that in the current Policy
vacuum, there is no clear indicator of when and how these houses
can be brought back at a time of the lowest house building rates
since the 1920's and acknowledged housing needs. So from our point
of view, in trying to adopt a positive response to making Localism
work, the impact of simply abolishing RSS and doing little else
has created a climate of delay and uncertainty. This affects us
principally in two ways. Firstly, proposals we have been promoting
over many years through the RSS process and subsequently through
Core Strategies are stalled where Local Authorities have either
postponed, or withdrawn Core Strategies. Secondly, proposals already
identified in Core Strategies where we were preparing planning
applications in parallel with the Core Strategy, have no Policy
justification where the Core Strategy has been abandoned. The
issue is, do we continue to prepare and submit that planning application
at considerable risk, or do we wait for an unknown period of time
for the planning system to be resolved?
Wiltshire Council provides an example of the delays
we are experiencing in an area where we have a large number of
interests. Wiltshire is a new Unitary Authority and was preparing
two Core Strategies. The first for South Wiltshire was brought
forward in advance of an overall Core Strategy for the new Authority
in recognition of the severe housing needs in Salisbury. Its Examination
was held in March and April 2010 and the Inspector had prepared
his report in July. However, following a Consultation by the Inspector
on the implications of the Coalition Government's changes, the
Council asked the Inspector to hold the Examination in abeyance
until November 2010, in order to reconsider its position and review
its housing and employment figures. In other words, right at the
end of the process the Council has decided to reconsider the fundamental
reason for pressing ahead with the strategy in the first place,
that of a shortage of housing in Salisbury. This uncertainty has
forced us to delay the submission of a planning application.
The Council were also preparing a second Core Strategy
for the rest of its area. Following Consultation in October 2009,
the Council was due to carry out additional Consultation this
summer. This has been abandoned and again the housing and employment
figures will be reconsidered, but here there is no definite timetable
for doing this and the Council have an indicative time frame for
consulting on a revised strategy in "spring" 2011. This
affects strategic sites we were promoting in Chippenham, Warminster,
Melksham and Trowbridge and a number of smaller sites.
From all the above, we conclude that the Government's
actions are resulting in delays and uncertainty in the forward
planning system.
The Committee posed the question regarding the abolition
of house building targets for levels of housing development. We
have a slightly different view of the housing figures set out
in RSS, in that they should not be viewed as absolute targets,
but figures to monitor housing provision against. Any one figure
is never a target to be achieved, because as new evidence becomes
available, the RSS will have been reviewed and the figure would
change. What was continuous was the monitoring process behind
it, to assess levels of provision against it. The concern now
is that the consistency and continuity of the housing monitoring
figure has now been removed with nothing to replace it. Its importance
for monitoring purposes was that it took into account trends over
a wider area. Even if Regional Housing Targets are abolished,
they cannot be replaced with a purely Local Target for say a District
Council area, because District Council areas rarely correspond
to housing market areas. We note there is still a requirement
in PPS3 to calculate five year housing supply and the needs to
be tested against something more than a self-fulfilling Local
Target.
The other issue that needs to be considered here
is Localism versus Nimbyism. The fear of the house building industry
is that in too many cases Nimbyism will take over from Localism.
There will then be disproportionate effects across and between
communities, where some accept new development and others reject
it. The danger of this is that the resulting pattern of new housing
development will not reflect actual housing needs. We have seen
nothing in the Localism Agenda which considers how housing needs
can be reflected. The other problem is that the Localism approach
is very much a here and now approach and does not allow for a
longer term view, which the RSS process provided. Considering
housing needs over a longer period was not just a technical exercise,
but considered real issues. For example, new housing development
is usually unpopular with those already in housing in a community,
from which the Nimby voice arises. But what about the voice of
those in housing need, or more importantly in the context of long
term projections, who will be in housing need, like those aged
between 10 and 15 now, who will require housing in the next 20
years and who were taken into account in the RSS process. In our
view the needs of that group are likely to be increasingly hidden.
ISSUE 2—EFFECTIVENESS
AND NATURE
AND LEVEL
OF INCENTIVES
PHSPW have four points to make in relation to incentives.
Firstly, our concern is that again the lack of details
and clarity of how the system of incentives would work, which
adds to the Policy gap described above and makes detailed comments
impossible. The fact is the new system of incentives should have
been introduced as the old system was abolished, with suitable
transitional arrangements.
Secondly, in many respects, views on the effectiveness
of the incentives are better addressed by the Local Authorities.
Therefore, in order to comment on whether incentives are likely
to be successful, we can again use the example in the west of
England. It is a fact that the four Authorities involved have
already reduced the RSS figure by some 35,000 houses. Using a
very simplistic example and assuming an average of £1,250
Council Tax per dwelling, those 35,000 dwellings would have attracted
£43.75 million per year for those Authorities, which over
six years would have amounted to £262.5 million. If those
Authorities are willing to give up that amount of money at the
stroke of a pen at this stage in the process, we doubt whether
the current level of incentives will be sufficient, but it does
also call into question whether any realistic level of incentives
would cause those Authorities to change.
Thirdly, we do not think that incentives will work
on their own. The planning system has always been notoriously
slow. The need to balance potential negativity from local communities
concerned primarily with the negative impact of new housing in
their community, with the potential income that the new housing
will generate, is only likely to slow down the process even more.
Therefore, we think any scheme of incentives also has to be backed
up by an imperative to prepare strategies, or plans, in a reasonable
time frame. In fact, the availability of incentives provides the
ideal opportunity to introduce a clear timetable for the preparation
of a Local Plan (or whatever the document is to be called), which
if it was not met, could be allied to a reduction in the level
of incentives the Authorities subsequently received. National
guidance could set out an indicative time frame for preparing
plans, but the specific timetable for each plan should be agreed
locally, the mechanism for which already exists in the form of
the local development scheme. The advantage will be that if it
is linked to the receipt of incentives, the local development
scheme would have real meaning and should ensure plans are produced
on time, rather than against an LDS timetable that can too easily
slip and be reviewed.
Fourthly, we question whether the system of incentives
does indeed encourage a long term supply of housing, or for Authorities
to take a long term view. The incentive for any one house merely
applies for a six year period, although for a large site, with
delivery phased over a longer period, cash flow would be spread
out. However, this does not encourage long term thinking and it
may be that if the level of incentives are not increased, then
the time for which they can be claimed should be increased from
six years.
ISSUE 3—LOCAL
AUTHORITY CO
-OPERATION ON
WASTE, MINERALS,
FLOODING, NATURAL
ENVIRONMENT AND
RENEWABLE ENERGY
In its involvement with the preparation of Regional
Spatial Strategies, PHSPW have always taken a wider view than
simply looking at the housing and employment issues. Policies
relating to waste, flooding, the natural environment and renewable
energy are linked to and can have a dramatic impact on individual
development sites, both in terms of physical provision and viability.
It is also important that Policies on issues like roads, physical
infrastructure, waste disposal and renewable energy are looked
at on more than a purely local basis. The planning system has
always sought to avoid repetition and therefore Policies which
were contained in the now abolished Regional Spatial Strategies
on these topics now no longer exist, creating another Policy vacuum.
The question is, therefore, how can they now be accommodated?
Even if groups of Local Authorities co-operate on producing Policies
over a wider area, what will be the vehicle for dealing with these
Policies? In addition to setting out a requirement for Authorities
to co-operate, there is also a need to set out guidance on how
these Policies will be dealt with. Mere co-operation does not
provide Policy guidance, or action, and again the example of the
west of England shows that even where Authorities work together,
this does not necessarily result in successful implementation
of Policies, in the Bristol case provision of transport proposals
between South Gloucestershire and Bristol.
If a duty for co-operation amongst Local Authorities
is included in the Localism Bill, it is absolutely vital that
this includes a duty to co-operate in the preparation of housing
figures over a wider than single District area, as well as the
other topics identified by the Committee.
ISSUE 4—ROLE
OF LOCAL
ENTERPRISE PARTNERSHIPS
Local Enterprise Partnerships provide an obvious
vehicle for Authorities to deliver the fruits of their co-operation
and in particular to deliver a planning function related to the
provision of overall housing and employment needs. However, our
fear is that in the absence of specific guidance at a National
level, it would be left to emerge at the Local (LEP) level and
bearing in mind how long it has taken in the past for proposals
to emerge from similar bodies, there could be a further Policy
vacuum whilst appropriate arrangements emerge, also different
arrangements for different areas will lead to inconsistency and
conflict. In our view, if LEP's are to be given a co-ordinating
planning role, this needs to be made clear from the outset and
guidance set out on how LEP's should perform this role. We have
submitted more detailed comments on this to the Business Innovation
and Skills Committee Inquiry into LEP's.
It is not just in the provision of overall housing
figures where co-operation between Local Authorities, or the role
of another group like the LEP is required to resolve housing and
planning issues. Another example concerns city region overspill
and again the west of England provides an example of this. Bristol
cannot meet all its housing needs within its administrative boundary,
which is why the RSS in the first instance proposed the urban
extensions, which have fallen with the abolition of the RSS and
the reaction of the west of England Authorities in deleting the
urban extensions. This issue occurs around all the major cities
in the UK and many other towns. If housing needs cannot be met
in the administrative area of the main settlement and the adjoining
Authorities are unwilling to accept what they consider to be overspill
from the main settlement, how will this issue be resolved? Can
Authorities be expected to resolve the issues voluntarily, or
through LEP's, where they will have considerable influence?
ISSUE 5—DATA
AND RESEARCH
It is important planning decisions, particularly
those relating to provision of employment and housing, are based
on recognised data backed up by credited research. In our view,
the NHPAU provided such a service, which again has been set aside.
We therefore consider re-instatement of the NHPAU, or the establishment
of another independent body to provide data and research for Local
Authorities to take on board, is an absolute requirement.
September 2010
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