Abolition of Regional Spatial Strategies: a planning vacuum? - Communities and Local Government Committee Contents

Written evidence from Persimmon Homes Special Projects Western (PHSPW) (ARSS 112)


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.


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.


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.


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.


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.


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?


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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