Written evidence from Roger Tym & Partners (RTP)
OUREXPERTISE
1. This submission is being made by Roger
Tym & Partners (RTP) in response to the press notice posted
on www.parliament.uk on 28 July 2010. The document draws on the
expertise and experience of the firm as a whole and the two principal
authors, Bill Brisbane and Cristina Howick.
2. RTP is an independent consultancy founded
in 1973, which works in planning, regeneration and economic development.
In recent years we have been heavily involved in the development
of Local Development Frameworks, Regional Spatial Strategies and
spatial strategies for growth and regeneration areas. We also
understand how these plans work in practice, through our work
on development proposals, both for the private and public sectors.
3. Bill Brisbane is a planner, who was managing
partner of RTP from 1987 to 2008 and was heavily involved in work
on strategic and infrastructure planning. The many studies he
directed include the Milton Keynes and South Midlands Study,
which informed the MKSM Sub-Regional Strategy; The Cost
of Funding Growth in the South East, for the South East Counties;
Augmenting the Evidence Base for the Examination in Public
of the South East Plan, for ODPM and GOSE; Ashford's Growth
Area: Funding and Implementation. Bill also gave evidence
at the ODPM Parliamentary Select Committee Inquiry into Sustainable
Housing and Communities and was chair of the Large Sites and Infrastructure
Sub-group of the RPG 9 Advisory Panel to Lord Rooker. He is now
a consultant to RTP and a part-time director of Ashford's Future
Delivery Company.
4. Cristina Howick is an economist and currently
joint managing partner of RTP and has particular expertise in
planning for sustainable economic growth. She has produced
evidence base studies and policy advice on planning for the economy
for around 50 local authorities and regional and sub-regional
planning bodies, and pioneered the development of analytical methods
in this area. Cristina also produced regional guidance on planning
for the economy in four English regions and advised CLG on the
new Planning Policy Statement (PPS)4 and supporting guidance.
She has played a significant role in the national debate on planning
for economic development, through many contributions to conferences
and the specialist press.
WHAT WAS
WRONG WITH
RSSS?
5. Below, we will address in turn the questions
asked in the Committee's terms of reference. But first, to set
the context, we comment briefly on the planning system that was
in force until recently. What has gone wrong over the last 13
years to provoke such a strong backlash against regional planning
in? There are at least four important reasons:
(i) The democratic deficit
The Labour government originally intended that Regional
Assemblies be elected. But a referendum in the North East (generally
considered one of the most cohesive regions) rejected this principle,
so it was abandoned in favour of appointing Assembly members,
many of whom came from local government. Despite this veneer of
democratic representation, many people felt that the Assemblies
did not have full democratic authority.
(ii) Government control of regional spatial
strategies
Although Regional Spatial Strategies were drafted
by Regional Assemblies, they were ultimately controlled by central
government, through Government Offices for the regions and the
Secretary of State's powers to amend the draft RSS and EiP Panel
proposals. In the South West and East of England, the Secretary
of State intervened heavily, in effect dictating new housing targets,
above those proposed by the Assemblies. The figures were legally
challenged in both regions. It is in these same two regions that
the revocation of RSSs was followed by the greatest immediate
reduction in proposed housing numbers — around 60,000 and
20,000 dwellings respectively. RSS targets which did not reflect
the views of counties were rapidly dismantled.
(iii) Absence of strategic infrastructure
planning
The then government was slow to realise that local
opposition to new housing was motivated by lack of adequate infrastructure
to support that housing, such as roads, public transport and schools.
Latterly RSS gave more attention to the issue, but still there
was no certainty that the necessary funding would be forthcoming.
It was this uncertainty which led Essex and Hertfordshire County
Councils to seek a delay to the East of England EiP and then to
request that government provide a commitment to fund the regional
infrastructure supporting the "high" housing numbers.
It was not until the 2007 Sub-National Review that
the Treasury paid detailed attention to the specific infrastructure
needs and costs of different regions. Even then, no clear link
was established between RSSs and infrastructure investment. The
RSSs would have been more effective if they had been used as infrastructure
investment plans, to be translated into public funding commitments
in a reliable and transparent manner. France provides a model
for this approach, using "contracts" between central
and regional governments as the basis of infrastructure funding.
(iv) Absence of national spatial strategy
An attempt was made in the early 2000s to promote
a comprehensive strategy on the location of growth through the
Sustainable Communities Plan, prepared under the auspices of the
Deputy Prime Minister. But the Sustainable Communities Plan mainly
covered southern and eastern England, focusing on the key growth
areas identified in the earlier Regional Planning Guidance (RPG)9.
For national guidance, the planning system relied — and
still relies — on Planning Policy Statements, which contain
general principles rather than geographically specific proposals.
There was, and is, no national spatial guidance for England to
set out the broad location of future new housing, jobs and strategic
infrastructure investments such as roads, ports and power stations.
The development of such guidance could have been the opportunity
for an informed debate about the spatial distribution of long-term
growth and the infrastructure that will support that growth.
6. In summary, the widespread dissatisfaction
with regional planning in recent years does not demonstrate that
the concept is faulty. Rather, there were major flaws in the application
of the principle by previous governments. In particular, regional
planning lacked democratic accountability, it was subject to excessive
government interference, it had no broad national spatial strategy
to guide it, and it was not linked to infrastructure investment.
New arrangements for strategic planning, based on sub-regional
co-operation rather than regional planning bodies, could potentially
correct these flaws.
IMPLICATIONS OF
THE ABOLITION
OF REGIONAL
HOUSEBUILDING TARGETS
FOR THE
LEVEL OF
HOUSING DEVELOPMENT
7. The impact of abolishing targets, along
with the other questions addressed in this submission, have already
been much discussed in public. Below, we do not repeat earlier
arguments, even when we agree with them, but rather try to add
to the debate.
8. Leaving aside the New Homes Bonus for
the moment, the evidence from local authorities and housebuilders
strongly suggests that the total volume housebuilding —
or, more precisely, the total planned supply of housing land —
will be reduced by the abolition of the RSS targets. For example,
of a sample of 70 local authorities surveyed by Roger Tym &
Partners in July, just over half expected to review their housing
targets, and their comments left us in no doubt that most of these
revisions would be downwards. Press reports and our own experience,
as well as our survey, suggest that many authorities are now aiming
to fulfil "local need" only, and therefore reduced numbers
are especially likely in those authorities that under the old
regional targets were required to "import" demand from
other areas. A typical example is Ashford, one of the Sustainable
Communities Growth Areas, where in August the Council announced
that:
"Over 5,000 homes have already been built in
Ashford since 2001 as part of the area's housing targets, agreed
with the last Government administration, of 31,000 by 2031.
However, the new Government is giving councils more
control over these targets to give them the opportunity to get
the appropriate rate of growth and ensure that quality is not
sacrificed for speed.
Ashford Borough Council will be reviewing its Core
Strategy… and will be able to look at housing targets…
based solely on local requirements, as opposed to targets set
by central Government.
Paul Bartlett, Leader of Ashford Borough Council,
said: …'Whilst the revision of our Core Strategy and the
details within it is a council policy decision, I personally believe
that we can deliver quality homes of better design with lower
density by revising our targets downwards by around 10%-20%...This
means that we would still be looking at around 25,000 new homes
in the area by 2031 — a significant number by anyone's standards.'"
9. This approach is not surprising. A major objective
of the RSS targets was to shift housing demand across local authority
boundaries, from places that were constrained — whether
by land availability, environmental limits or infrastructure —
to places that had more capacity. These planned transfers were
of two kinds: urban extensions where towns and cities were to
spill over into adjoining districts, and Growth Areas, where demand
was being shifted over longer distances, away from the most congested
areas in southern England.
10. Such transfers, and more generally migration
across local authority boundaries, provide much of the rationale
for strategic planning. In a world where people never move house
between local authority areas, there would be a strong case for
extreme localism, in which the central government does nothing
to influence housing land supply. In this world of immobile households,
one might argue that local democracy will find the correct balance
between housing need and other priorities, such as open space
and freedom from congestion (it might still not produce enough
houses to meet social priorities and provide for the poor and
vulnerable, but that is another story).
11. But in real life very many people do move
house across administrative boundaries or would like to do so.
In this case, extreme localism will not produce the right answer,
because potential migrants into the local area do not have a voice
or a vote in the destination community. Under the old system,
regional planning provided a mechanism (whether effective or not)
to represent the interests of these potential migrants. The new
system aims to achieve the same objective through a "quasi-market",
where the central Government buys the consent of host communities
through the New Homes bonus. Below, we look at the likely success
of this approach.
EFFECTIVENESS OF
THE GOVERNMENT'S
PLAN TO
INCENTIVISE LOCAL
COMMUNITIES TO
ACCEPT NEW
HOUSING
12. In terms of the national total of housing
development, we cannot tell yet how far the proposed New Homes
Bonus will offset the impact of abolishing RSS targets. For a
reliable verdict, we have to wait for full details of the bonus
and for local authorities' response.
13. However, one thing is already clear: the
new incentives will do little to put new housing in the right
places — where the need is greatest and that need can be
met most efficiently. This is because the bonus, as currently
proposed, will be based solely on the value of houses, as reflected
in Council Tax bands.
14. We mentioned earlier that the bonus is in
effect a price — the price paid by the central government
to local communities in exchange for their consent for housing
development. But, unlike a real market price (say for tomatoes
or personal computers), the bonus will be depend neither on the
demand or need for the goods being bought or the cost of producing
those goods. It will not be higher in those local authority areas
where there is the highest need for extra housing land, for example
to extend a congested urban area. Nor will it be higher in areas
where development requires expensive infrastructure or spending
on clear dereliction or decontaminate land.
15. In practice, this is a serious problem, because
in our experience there are huge differences between places, both
in the level of housing need and the cost of infrastructure and
site reclamation required to meet that need. The New Homes Bonus
will of course be higher in places where houses are more expensive,
but these variations are likely to be modest, due to "capping";
and only weakly related to housing need and infrastructure costs.
By contrast, in the old system RSS targets analysed large amounts
of evidence and consulted widely, to try and match the location
of housing sites to need and costs.
16. In summary, the abolition of RSS targets
and the New Homes Bonus, taken together, seem likely to reduce
total housing development; but it is too early to be definite
about this. The bonus, considered on its own, should have a positive
impact on the total amount of development. But it is a blunt instrument,
which will do little or nothing to put new housing in the places
where it is most needed and can be provided most efficiently.
Nor can we think of an alternative pricing mechanism that would
be less blunt. The factors that should be taken into account are
too many and too complex.
ARRANGEMENTS THAT
SHOULD BE
PUT IN
PLACE TO
ENSURE APPROPRIATE
COOPERATION BETWEEN
LOCAL PLANNING
AUTHORITIES ON
MATTERS FORMERLY
COVERED BY
REGIONAL SPATIAL
STRATEGIES
17. Below, we restrict our comments to planning
for housing and economic land uses, which are our main areas of
expertise. We do not comment on other areas of planning, such
as waste, minerals or flooding.
18. The arguments demonstrating that we need
strategic planning, covering areas larger than local authorities,
are well-rehearsed and we do not repeat them here. Less obvious,
but still familiar, is the argument that planning should cover
"functional market areas". Very briefly, the argument
is that, if democracy is to work as it should, the spatial level
at which decisions are taken should reflect the geography that
is affected by these decisions. So the design of a local park,
for example, should perhaps be controlled by residents of the
immediate locality, because hardly anyone else will use it. At
the other extreme, decisions about national airports should be
taken by central government, because they affect the whole country.
19. Based on this principle, strategic land-use
planning for housing, jobs and services should be done at the
level of housing market areas, which contain the bulk of residential
moves, or labour market areas, which contain the bulk of journeys
to work. These two kinds of market area broadly coincide (because
both reflect the extent of an acceptable commuting trip) and they
are sub-regional in scale — larger than local authorities
but smaller than regions. Some functional market areas are city
regions; others are polycentric areas, not anchored by a single
dominant settlement.
20. So co-operation between local authorities
should be largely based on functional sub-regions (housing market
areas, labour market areas). All RSSs included such sub-regions
as important building blocks, and much time and effort was spent
in defining their boundaries. In our experience, much of this
time and effort was wasted, because the definitions can never
be perfect. No geographical area is entirely self-contained, so
regardless of how we draw boundaries there will be cross-boundary
impacts. Moreover we do not have the necessary knowledge to draw
boundaries so as to mimimise these cross-boundary impacts, so
the best we can do is try and keep them to a manageable level.
Therefore sub-regional boundaries should be drawn pragmatically.
For the sake of convenience, they should be groups of authorities
(ie the sub-regional boundary should not cut across local authority
areas) and the same sub-regions should be used throughout the
plan, for all land uses or areas of policy.
21. It is also important that sub-regional groups
of authorities be stable over long periods of time, so that they
can be planned for effectively. Under the 2004 planning
system, our experience suggests that stability was only achieved
when the RSS made it compulsory. Otherwise sub-regional groups
tended to form and dissolve often, depending on the changing views
of elected members, the vagaries of LDF timetables and the availability
of resources at different times. This suggests that planning sub-regions
should be set up for the whole of the plan period, perhaps 15
or 20 years (though they could of course be reconsidered as part
of plan reviews).
ADEQUACY OF
PROPOSALS ALREADY
PUT FORWARD
BY THE
GOVERNMENT, INCLUDING
THE SUGGESTION
THAT LOCAL
ENTERPRISE PARTNERSHIPS
MAY FULFIL
A PLANNING
FUNCTION
22. The above discussion suggests that, in principle,
it would be right for the LEPs to fulfil a planning function,
because they are roughly the right order of magnitude to cover
functional sub-regions.
23. However, if the LEPs are to work properly
as the basis for sub-regional planning, their definition should
consistently follow the principles we have outlined in the last
section. The 56 bids received so far from councils wishing to
create LEPs do not meet this condition. Many, such as Greater
Manchester or the West of England for example, seem to be very
good definitions of functional city regions. Others are far less
so. Some authorities, such as Kent, are part of more than one
proposed LEP.
24. It is not surprising that the LEP bids are
so uneven. Authorities had only a few short weeks to put together
bids, and were given no directions on how to define LEP areas.
On the contrary, ministerial pronouncements have stressed that
LEPs should be flexible, defined from the bottom up and potentially
for different purposes:
"In some areas, there might be a focus on skills.
In others, LEPs may help set priorities for planning and infrastructure
decisions…. These partnerships are built from the bottom
up and will have the flexibility to determine their own agenda,
rather than have it handed sown to them by Whitehall."[1]
25. This permissive approach to LEPs may be a
good basis for creative economic development, but it seems ill-suited
to statutory land-use planning. Therefore LEPs as currently proposed
are not satisfactory vehicles for planning that rises above local
authority boundaries.
September 2010
1 Vincent Cable, quoted on PublicPropertyUK.com, 7
Sep 2010. Back
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