Written evidence from the Campaign to
Protect Rural England
EXECUTIVE SUMMARY
1. The Campaign to Protect Rural England (CPRE)
welcomed the abolition of top-down housing targets and the Government's
commitment to empowering local communities through greater involvement
in the planning system. We believe there is a need for some form
of strategic planning, however, in order to tackle cross boundary
issues, including protecting the Green Belt and promoting urban
regeneration, and to co-ordinate transport, development, service
delivery, landscape management and conservation of the natural,
historic and cultural environment.
2. In making recommendations to the Government
following the revocation of regional plans we propose that the
Committee consider the following key points:
- If incentives are to be used to encourage housing
delivery they should not be a blunt instrument that focuses solely
on how many new homes are granted planning permission. An incentives
scheme needs to reward the development of high quality new homes
that are in line with the local development plan. It should also
be acknowledged that not all development that receives planning
permission gets built and so incentives should only be payable
once homes have been built and are occupied.
- Bringing empty homes back into use is vital,
especially in deprived areas, and often more environmentally sustainable
than building new homes. This should be encouraged by the incentives
scheme.
- We believe there is a need for some form of strategic
planning, which sits between the national and local level and
sets a framework for, but does not dictate targets to, local authorities.
This will help ensure that neighbouring plans set out a coherent
vision for future development, including transport infrastructure,
and environmental protection and enhancement.
- Further clarity is needed on how the proposed
duty to cooperate will work in practice. CPRE is concerned that
it will not be sufficiently strong to resolve areas of conflict
if there is no ability to enforce outcomes.
- Current proposals suggest that Local Enterprise
Partnerships will be focused on delivering economic growth. We
do not believe, therefore, that they will be suitable mechanisms
to undertake a planning function. While economic development may
be an important goal for strategic planning, environmental and
social factors should be given equal weight to ensure that the
approach is sustainable, and delivers a better quality of life
for communities.
INTRODUCTION
3. CPRE welcomes the opportunity to submit evidence
to the Communities and Local Government Committee on the abolition
of Regional Spatial Strategies (RSSs). As a leading environmental
charity, we have worked to promote and protect the beauty, tranquillity
and diversity of rural England by encouraging the sustainable
use of land and other natural resources since our formation in
1926. In the recent past an important part of our work has been
undertaken at the regional level, in particular by helping to
shape regional plans.
4. We welcomed the revocation of the top-down
housing targets and support the Government's aspiration to empower
local people to play a more active and influential role in shaping
the futures of the areas in which they live and work. We still
believe, however, that some form of strategic planning is necessary
in order to ensure spatially coherent development, which protects
and enhances communities and the environment.
DETAILED COMMENTS
The implications of the abolition of regional
house building targets for levels of housing development
5. CPRE accepts the need to provide sufficient
housing, and particularly affordable housing in rural areas. Based
on our involvement with the development and implementation of
regional plans, however, we believe there was an over-emphasis
on housing numbers in RSSs. This was illustrated back in early
January 2008 when the then Parliamentary Under Secretary of State
for Communities and Local Government wrote to the West Midlands
Regional Assembly, on the day the draft RSS Phase 2 Revision was
published for consultation, stating that the Government did not
feel the housing numbers in the draft were sufficiently high.
The Government asked the Government Office for the West Midlands,
therefore, to commission research to look at options for delivering
higher housing numbers. The over-emphasis on housing numbers within
regional plans resulted in them becoming less and less deliverable.
At the same time, the high housing targets, which were translated
into local targets, led to more greenfield land being allocated
for housing unnecessarily. When these sites were 'cherry-picked'
by developers, regeneration of previously developed land was often
undermined.
6. We believe it is too soon to fully understand
the implications of the abolition of housing targets on levels
of housing development. Anecdotal evidence from CPRE's county
branches suggests that while some local authorities have decided
to review their housing targets, with a view to reducing them,
others, such as Stevenage Borough Council, continue to push for
high levels of growth in their Core Strategy. Whether the targets
in local plans are met is of course unknown, but it is likely
that low levels of housing development are attributable mainly
to the prevailing economic climate, rather than changes to regional
planning.
7. CPRE is concerned about the implications of
the loss of a strategic approach to planning for housing. While
we did not support the imposition of housing targets on local
authorities, we do believe there is a need for a framework which
helps ensure authorities take account of both their own housing
needs and that in neighbouring authorities. This is particularly
problematic in areas such as the South West, where brownfield
land and regeneration opportunities are distributed unevenly between
local authorities. Following the revocation of RSSs there is a
need to consider how local authorities can address such cross-boundary
issues.
The 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
8. CPRE believes that the Government's housing
strategy should recognise that the origins of the current crisis
of housing affordability and supply are too complex to be attributed
solely to the claimed failure of the planning system to maintain
a sufficient supply of land for housing. The Conservative Green
Paper Strong Foundations pointed out that the present crisis
of housing affordability and supply is due in significant part
to the sustained availability of cheap credit, which fuelled the
1998-2007 housing boom.
9. Ultimately the Government must consider how
it can help to establish a more stable housing model that is resilient
under a wide range of economic and geographic circumstances. This
includes recognising the role that developers play in determining
actual levels of house building, as well as local authorities.
The role of developers is evidenced by analysis of data contained
in the seven largest house builders' (by volume completed) 2009
interim and annual reports. This shows that between them they
owned and had at least outline planning permission for housing
development on 271,947 plots in 2008-09. In spite of this Communities
and Local Government statistics show that in the same period construction
began on only 80,360 homes.[26]
We recommend, therefore, that the new incentives scheme is designed
to ensure that these are only paid if properties are built and
occupied within a set period of time following completion.
10. The proposed new incentives scheme should
also reward quality of outcomes, rather than the quantity of outputs.
CPRE believes that housing should not be seen in isolation, but
in the context of broader objectives. Incentives should not be
encouraging the development of more housing estates—whether
executive or social housing estates. To avoid this, financial
incentives should reward planning authorities for delivery of
their local development plan. This should hopefully ensure the
delivery of development that fosters sustainable neighbourhoods
and safeguards scarce resources, such as land, energy and water.
In some communities it is a lack of jobs and services or a poor
quality public realm rather than housing that is the main issue.
We believe, therefore, that the Government needs to consider how
incentives can reward provision of jobs and services, stewardship
of the public realm, environment and natural resources, as well
as housing.
11. It is also critical that incentives do not
only reward the development of new market housing. Communities
that take action to bring empty properties back into use should
also be rewarded through the incentives scheme. Incentivising
simply the quantity of houses delivered will do little to help
local authorities whose main problem is the quality of existing
homes. This is often the case in the most deprived communities.
12. Without a focus on outcomes, there is a risk
that incentives could damage the countryside and communities,
by promoting spatially incoherent development. Especially given
current financial circumstances, local authorities may be tempted
to approve proposals that otherwise would be unacceptable to guarantee
receipt of extra funds. If incentives are not linked to encouraging
development that is set out in the local plan the scheme could
undermine the effectiveness of community-led neighbourhood plans.
13. The abolition of the regional tier means
that responsibility now falls to local authorities to establish
a robust evidence base on which to base its own targets for house
building. CPRE encourages the Government to consider offering
incentives only where the existence of sound evidence of local
housing need can be demonstrated. In particular, we believe further
guidance is needed to ensure that Strategic Housing Market Assessments
(SHMAs) provide a more accurate and responsible account of housing
need. Especially crucial is the way in which SHMAs use statistics
such as population projections. In 2009 a CPRE study, Housing
the Future, examined how the direct equation of population
projections with housing demand, as tends to be the current practice,
can lead to wholly inaccurate targets for new housing development.
CPRE recommends that the Government works with local authorities
to develop a more sophisticated approach to determining housing
targets.
14. Incentives could play a part in the implementation
of a housing model which delivers sustainable planning and housing
outcomes. CPRE is urging the Government to consider carefully
how incentives can fulfil this wider role, rather than being a
blunt instrument to deliver housing numbers alone.
The 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)
16. Following the revocation of regional plans
CPRE believes there is a need for some form of strategic planning
to deal with a wide range of environmental cross boundary issues,
including the promotion of Green Belt protection and urban regeneration,
and to co-ordinate development, transport issues, service delivery,
landscape management and conservation of the natural, historic
and cultural environment. Although we recognise the Government
does not want to be prescriptive to local authorities, there is
a need for some form of spatial planning, which is undertaken
at a level between local authority and national level.
17. Strategic planning can also play an important
role in dealing with and mediating conflict between local authorities.
If the regional supply of minerals, for example, has traditionally
been mined in one county (as is the case in Staffordshire), there
needs to be a mechanism whereby other local authorities are required
to consider their provision if this is not the most sustainable
option. Without coordination, there is likely to be a continuation
of the status quo, based on the lobbying of existing minerals
interests and a defensive position from adjoining authorities,
even if it is not the most sustainable option.
18. In our recently published briefing, The
Bigger Picture: the case for strategic planning, we set out
a number of criteria that we believe will need to be addressed.
These include the requirement that future strategic planning should:
- Set out a flexible framework for local plans—Strategic
planning should not impose targets on the local level, but rather
provide a vehicle for local authorities to discuss, and reach
agreement on, issues that have impacts across boundaries.
- Achieve a balanced focus—While economic
development will be an important goal for strategic planning,
environmental and social factors should be given equal weight
so that the approach is sustainable, and delivers a better quality
of life for communities.
- Be transparent and accessible to the public—The
transparency of structures, so that local people understand what
bodies are doing and how they can feed in, will be essential.
Equally, those involved in strategic planning must place significant
emphasis on enabling local people to participate fully in planning
processes.
- Be inclusive so that local expertise is fed into
the process—Locally elected members should take the lead
in strategic planning to ensure that it is democratic, but this
should not prevent them from recognising the importance of, and
need for, expert advice and direct engagement on environmental,
social and economic issues.
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
19. A duty to co-operate could help ensure local
authorities work with their neighbouring authorities. It is currently
unclear, however, how such a duty will work in practice. For example,
we do not think it would be sufficient for local authorities to
simply have to consult neighbours on draft local plans. Where
local authorities have common goals and outlooks co-operation
may add benefit but it will not resolve areas of conflict where
there is no clear basis for discussion or an ability to enforce
outcomes.
20. It is also not clear how the proposed duty
would help tackle a situation where the aspirations for development
of neighbouring local authorities could undermine each other.
This could be a problem, for example, where a rural authority
abuts an urban authority and the former includes proposals for
housing and employment land development on greenfield land in
its area. Such plans could undermine plans for urban regeneration
in the urban authority.
21. We recognise that the Government has suggested
that Local Enterprise Partnerships (LEPs) could have a planning
function. Strategic planning must consider economic, social and
environmental issues in an integrated way. So, if LEPs are to
play a significant role in enabling cross-boundary discussions,
it is essential that their remit is widened beyond the current
proposal that they should be mechanisms for delivering economic
growth. If LEPs are to undertake strategic planning successfully
they will need clear, detailed objectives that are guided by principles
of sustainable development, including protecting, and where possible,
improving, the environment and social cohesion.
22. The need for a wider remit can be illustrated
by recent changes in strategic planning for transport. In some
regions there has been a move away from legacy schemes that increase
road capacity, towards public transport schemes and wider packages
that seek to reduce the need to travel, particularly by car. The
need to reduce carbon emissions from transport had a major influence,
for example the research carried out for the Yorkshire and Humber
RDA on the measures needed to create a low carbon and sustainable
transport system showed that a fundamental change in priorities
was needed.
23. There are dangers not just that the skills
being developed in relation to planning for sustainable transport
systems will not only be lost but also the LEPs will take time
to get up to speed with the new agenda. Moves to develop local
carbon budgets, such as CLG's Local Carbon Framework pilots, would
be complicated by transferring some powers to LEPs, particularly
where LEP boundaries differ from those for Local Transport Plans.
24. The ability of the RSS process to objectively
address tensions between local authorities has been limited, especially
given that some local authorities are clearly much more economically
powerful than others. The RSS approach did, however, allow proper
scrutiny and comparison, including via the Examination in Public
process, which involved adjoining local authorities as well as
other interested parties. We are concerned that the current proposals
for LEPs are not sufficiently transparent to ensure they gain
public confidence and the lack of any independent scrutiny could
mean that the concerns raised by adjoining authorities will not
be given sufficient weight.
25. To ensure LEPs are able adequately to address
social and environmental issues within their areas, and to ensure
they are seen as legitimate, relevant voluntary sector groups
should be able to play an active role in their operations. We
were disappointed that the Government originally proposed that
LEP boards should be made up of local authority and local business
leaders. This did not seem consistent with the thinking behind
the "Big Society". We welcome, therefore, the recent
confirmation from the Minister for Decentralisation that voluntary
organisations and social enterprises can play a key part in the
new Partnerships.
26. We note that some proposals being put forward
to Government are for LEPs which cover a fairly small geographical
area, such as a county. Consequently, further consideration should
be given to what additional co-operation and coordination is needed
across neighbouring LEPs to ensure there is an adequate strategic
overview. As is emerging in some areas, such as the North West,
one possibility could be through the retention of small regional
bodies. If such bodies are to be retained they will need to have
clear remits and broad support from local authorities and relevant
stakeholders.
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
27. The data and research collated by Leaders'
Boards, and Regional Assemblies before them, has traditionally
been held on their websites. These should be archived and kept
available for the foreseeable future, not just to local authorities
but also to other parties. It is likely that Panels and Inspectors,
whether testing the soundness of Core Strategies or deciding whether
to give approval to development, will use the evidence base for
some time to come and it needs to be available to everyone involved.
This was the case, for example, at the recent Black Country Core
Strategy where parties were specifically asked to say what would
need to be transferred from the RSS to the Core Strategy to make
it sound.
28. It is unlikely, however, that this existing
data will remain valid over time, although the length of its validity
will vary between regions, topics and issues. There will be a
need for on-going cross-boundary assessment of issues such as
the availability of previously developed land (not least because
of the recent change of definition to exclude gardens) and such
work will need to be organised at least sub-regionally. The priorities
for any new monitoring will depend on who commissions it and this
relates to our concerns about the breadth of the role of LEPs
when they decide what new technical work is progressed and how.
September 2010
26 CLG Housing Live Table 208, as accessed on 10 August
2010. Back
|
