Written evidence from the Association
of Directors of Environment, Economy, Planning and Transport (ADEPT)
The Association of Directors of Environment, Economy,
Planning and Transport (ADEPT) represent local authority Strategic
Directors who manage some of the most pressing issues facing the
UK today. ADEPT membership is drawn from County, Unitary and Metropolitan
authorities from all four corners of the United Kingdom. The expertise
of ADEPT members and their vision is fundamental in the handling
of issues that affect all our lives. Operating at the strategic
tier of local government they are responsible for delivering public
services that relate to the physical environment and the economy.
SUMMARY
- Revocation of Regional Spatial Strategies has
wider implications than simply removing targets for new homes.
- New arrangements need to be put in place to enable
local authorities and the house building/development industry
to move forward with confidence.
- Strategic planning recognises the need to address
issues that cross boundaries. It should form part of a reformed
planning system.
- A robust Sub-regional partnership approach, taking
Local Enterprise Partnerships as a starting point for planning
at the strategic level, is supported.
- New homes and other development requires infrastructure
to deliver sustainable communities. Further debate is needed to
ensure the infrastructure required for sustainable communities
is funded.
- New Homes Bonus—concerns about take-up
by councils/communities and the ability of the tool to influence
new homes completions.
- Community engagement, however effective, is unlikely
to bring consensus. Strong local leadership is needed to make
the difficult decisions.
- Suitable arrangements can be made for updating
data and research.
1. Implications of the abolition of regional
house building targets for levels of housing development
1.1 It is important to note at the outset that
the revocation of, and the eventual abolition, of Regional Spatial
Strategies will have implications for a wide range of issues not
just house building targets. Regional Spatial Strategies also
set regional priorities for where new development should go, economic
growth, transport and other infrastructure and the natural environment.
There is a continued need to plan for these issues in a co-ordinated
way at a level that is wider than local.
1.2 The revocation of Regional Spatial Strategies
has brought a number of immediate implications in terms of uncertainty
for local authorities, the development industry and local communities.
These include: withdrawal of Local Development Framework documents
by councils, uncertainty about appropriate policies on which to
base decisions on planning applications, and disruption of ongoing
work on infrastructure planning, due to a lack of clarity on the
development levels for which infrastructure is required..
1.3 It will take time for local authorities to
establish a robust position from which to go forward. Currently,
this process is being hindered by a drip feed of new policy changes
for planning and other areas, proposals for new responsibilities
and working arrangements and public sector funding cuts. Clarity
on these issues is needed to enable local authorities and their
partners as well as investors to move forward with confidence.
1.4 Progress on national planning issues and
solutions to the strategic planning vacuum will be key in helping
local authorities to deliver positive outcomes for communities.
These are considered in turn, as follows.
1.5 Work needs to be completed as soon as possible
on the National Planning Framework and National Infrastructure
Plan. These will help guide local areas on national priorities.
National guidance should include the government's position on
meeting the nation's housing needs and aspirations.
1.6 There must be recognition of the strong case
for carrying out strategic planning at a level between national
and local levels. ADEPT strongly supports the case for strategic
planning and is a signatory to the letter to the Communities and
Local Government Secretary, Rt Hon Eric Pickles MP on "Larger
than local planning".
1.7 Strategic planning is needed because local
needs cannot be addressed in isolation. Many issues cut across
local authority boundaries or have a national or international
context. These matters include:
- Ensuring that housing provision is based on a
sound understanding of housing markets and their interrelationships
with economic and social factors (demographic change, overall
supply, mix, type and tenure of housing, economic growth levels
and labour supply).
- Making provision for economic growth based on
an understanding of functional economic geography (skills levels,
employment land supply, promotion of key sectors, etc).
- Meeting Gypsy and Traveller needs.
- Ensuring the sustainable, efficient and effective
movement of people and goods through integrated transport strategies.
- Providing other strategic infrastructure (eg
flood management, water supply and disposal, health, education).
- Taking account of the cumulative impacts of development,
such as those upon sensitive environmental assets or the transport
network (trip generation, commuting patterns, etc).
- Moving towards a low carbon future, which will
rely in part upon an integrated approach to matters such as renewable
energy opportunities, climate change adaptation, and reducing
the need to travel.
- Understanding future needs of communities (i.e.
dealing with the need to plan responsibly for future residents,
including the children of existing communities and possible migration
patterns, in the face of political tensions arising from existing
residents who are fearful of new development pressures).
2. Likely effectiveness of the Government's
plan to incentivise local communities to accept new housing development,
and the nature and level of the incentives which will need to
be put in place to ensure an adequate long-term supply of housing
2.1 The delivery of new homes is a key issue.
New and affordable homes must be built in the right places to
support economic growth, population change and address existing
unmet housing needs— particularly for affordable housing.
New homes and economic growth must be supported by appropriate
infrastructure. Local councils have a key role in enabling this
to happen.
2.2 The low levels of house building over the
last two years reflect the economic situation. The rate of house
building is strongly linked to the state of the economy and less
in the hands of local communities or councils. However, planning
for housing is necessary to provide greater certainty for developers
in terms of the supply of housing land in the longer term. Local
councils can enable new housing development by developing local
policy and granting planning permission but have little power
in terms of when the development is built.
2.3 Three key issues are relevant to the Government's
incentives proposals for new homes:
- Determining what is an adequate supply of new
homes.
- Gaining the support of local communities for
the building of new homes.
- Infrastructure to support housing development.
2.4 Robust assessments of local housing need
and the opportunities to meet that need will be required to inform
discussions on how much housing there should be and where it should
go. These assessments will need to take account of demographic,
economic and housing market factors, as well as supply-side issues,
taking account of the effect of environmental considerations.
With regard to the latter, there must be consistency of approach
with the emerging Government policy on the natural environment,
as promised in a forthcoming White Paper. It is recommended that
best practice guidance on making local assessments for housing
is prepared.
2.5 New ways need to be found to improve democratic
involvement and community engagement at all levels of government
in terms of how and where new housing should go. Community engagement
is important but it costs time and money, so a balance needs to
be found to avoid excessive delay. A key issue is that those who
tend to get involved are those who are least likely to benefit
directly from new development and most likely to oppose change.
The challenge lies in finding ways to engage those who are least
likely to get involved but are more likely to benefit such as
younger people and disadvantaged groups. At the same time, it
must be recognised that community engagement, however effective,
is unlikely to bring consensus. Strong local leadership is needed.
Difficult decisions will still have to be made by democratically
elected members in the light of the evidence and differing community
views.
2.6 Along with developing greenfield land, infrastructure
to support new development, particularly new homes is a key concern
of existing local communities in terms of accepting new development.
To build sustainable communities new housing must be supported
by transport, social, community and green infrastructure. This
should be funded as far as possible by development and user charges,
but it must be recognised that there are limits to this source
of funding. Whilst alternative infrastructure models are sought,
there is great concern about the continuing lack of investment
in infrastructure particularly at the strategic level. Further
debate is needed about this issue.
2.7 In terms of the government proposals, at
this stage the information on the New Homes Bonus scheme gives
little detail on which to gauge its potential effectiveness. It
is understood that the level of funding will not exceed that previously
provided through the Housing and Planning Delivery Grant.
- 2.8 The incentive scheme (proposed in the
green paper) of council tax match funding for house building may
not be sufficient to encourage local residents and councillors
to endorse housing growth. The following are issues to consider
for the New Homes Bonus:
- The Bonus will need to be significant to incentivise
local communities to see a benefit from new housing but this will
have to be balanced against overall cost. Given that we do not
have the full picture in terms of the spending review, developer
contributions arrangements etc, it is difficult to determine the
level of incentive that will encourage local communities to take
it up.
- The Bonus needs to be set up in a way that is
open and transparent so it does not appear that planning permission
is being bought. Linkages to community benefits must be realistic—for
example, robust assessments should be made and published of development
levels needed to retain schools, shops and other community facilities.
- The Bonus will need to be long-term to build
trust and certainty for local councils, local communities and
the development industry.
- There may need to be restrictions in terms of
the amount of Bonus given to each local authority. This could
be linked to growth rates above a threshold level.
- The Bonus is billed to ensure that communities
who go for growth will reap the benefits. It is questionable that
the potential option open to councils to cut council tax levels
will bring wider community benefits for the long term.
- A direct link, such as a link to Council Tax,
between the granting of planning permission for new homes and
the Bonus appears to make sense. However, there is no guarantee
that these homes will be built. There is a balance to be made
in terms of recognising what local authorities can enable and
getting new homes built.
- In two tier areas, arrangements will need to
be in place for both tiers of local government to benefit from
the Bonus.
- A clearer picture of the arrangements for the
Bonus, successor Community Infrastructure Levy and section 106
agreements is urgently needed to enable local authorities to make
informed decisions about infrastructure funding and to mitigate
impacts of new development.
3. Arrangements which should be put in place
to ensure appropriate cooperation between local planning authorities
on matters formerly covered by regional spatial strategies (eg
waste, minerals, flooding, the natural environment, renewable
energy, &c)
3.1 As explained earlier, strategic planning
at larger than local level is necessary to prevent a haphazard
approach between new housing, economic priorities and supporting
infrastructure. County and unitary councils should lead working
on strategic spatial plans working through robust sub-regional
partnerships.
3.2 Minerals and waste planning are currently
undertaken by county and unitary authorities. In many areas a
partnership approach to preparing joint local development frameworks
takes place. Over many years, planning authorities have worked
together through Regional Aggregates Working Parties to determine
the scale of mineral aggregates. This arrangement is set to continue.
Similar arrangements exist for waste planning.
4. 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
4.1 The "duty to co-operate", proposed
in the green paper, was proposed as a way to encourage councils
and other service providers to work together in terms of infrastructure
planning. Whilst partnership working at the sub-regional level
is supported it is necessary to develop robust partnerships arrangements.
Voluntary agreements may be relevant for some aspects but not
all. Sub-regional partnerships need strong legitimacy and the
necessary freedoms, flexibilities and resources. Local authorities
taking a leading role will provide the necessary democratic accountability.
There should not be a plethora of local partnerships.
4.2 ADEPT supports the creation of Local Enterprise
Partnerships—joint local authority-business bodies brought
forward to promote economic development. These should normally
operate at the sub-regional scale.
4.3 The government recognises that to create
the right environment for business growth in their areas, LEPs
will want to tackle issues such as planning and housing, local
transport and infrastructure priorities, employment and enterprise
and the transition to the low carbon economy. LEPs have the potential
to provide leadership for these and other cross boundary issues
that would benefit from a strategic approach. However, their primary
role is an economic one. Further clarity is needed as to whether
LEPs are to take on a wider remit and how the wider issues will
be balanced against the economic role. Clarity will also be needed
with regard to democratic accountability, with the balance of
power in LEPs residing in the private sector, but delivery of
many of the potential outcomes being the responsibility of the
public sector and, in particular, local authorities.
4.4 LEPs offer an opportunity to address the
strategic planning gap, although much will depend on the scale
and geographies of the final set of LEPs. If they are large sub-regional
entities, then the danger is that strategic planning at this scale
will attract the same criticism as attached to RSSs. However,
smaller-scale entities would be able to marry wider strategic
considerations with local aspirations, and come to more acceptable
solutions.
5. How the data and research collated by the
now-abolished Regional Local Authority Leaders' Boards 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
5.1 The existing data and research collated by
the abolished Leader's Boards can be made available by placing
in convenient and secure place on the internet and other relevant
archives. For example, South West Councils Leaders' Board/South
West Councils have made arrangements with the British Library/National
Web Archive to preserve the evidence base behind the draft RSS
for the South West to ensures that the pages and their content
are preserved for future use.
5.2 At the sub-regional level, data collection
and further research concerning cross boundary issues can be co-ordinated
by the relevant sub-regional partnership, which may be the LEP,
or a sub-regional partnership of upper tier authorities, building
on their existing capability and capacity. This data and research
will provide a common and consistent evidence base for the preparation
of development plans, as well as informing any future strategic
planning activity. Also, the data should be collected in a way
that can be useful at the local level but can be aggregated for
use at larger levels.
September 2010
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