Written evidence from East Midlands Councils
SUMMARY OF
EVIDENCE
- East Midlands Councils is the consultative forum
for all 46 authorities in the Region. It provides support to Councils
to improve their services and is a strong voice for the East Midlands.
- There is no evidence to suggest that housing
delivery in the East Midlands is currently being restricted by
a lack of land with planning permission. As a result, the removal
of regional housing targets will have little short term impact.
However over the longer term the situation is less clear, particularly
if economic growth strengthens and market conditions improve.
- It is right that Government looks at changes
to local government finance that would support rather then penalise
population growth. However, there is currently insufficient evidence
to conclude that the fiscal measures proposed by Government will
on their own increase housing delivery to a level that meets the
nation's demographic and economic needs in a sustainable manner.
- The new system must avoid the protracted and
repetitive Examinations in Public that could result from a lack
of an agreed strategic context for some complex matters. In addition,
the Government remains responsible for the collective outcome
of local authority actions at a national level in a number of
key policy areas, particularly under European legislation.
- It appears unlikely that Local Enterprise Partnerships
(LEPs) will be given statutory planning powers as a result of
the Decentralisation & Localism Bill, or that the emerging
geography of LEPs will match that of existing joint planning arrangements
in the East Midlands. However, there could be a key role for LEPs
in co-ordinating strategic infrastructure and investment planning
and in the monitoring land use change.
- East Midlands Councils is undertaking a range
of measures to ensure evidence and other intellectual capital
developed through the regional planning process remains available
to local planning authorities, and to support local planning authorities
over the transitional period to the new system.
1. The implications of the abolition of regional
house building targets for levels of housing development.
1.1 Housing delivery in the East Midlands between
2001-02 and 2008-09 is set out below[32].
The figures show that completions rose to meet the Regional Plan
(RSS) target in the period up to the 'credit crunch', and then
fell away as the recession took hold.
1.2 As of 31
March 2009, there were outstanding planning permissions for 97,000
new dwellings in the East Midlands[33]—equivalent
to 4.5 years supply against the Regional Plan target. There is
therefore no evidence to suggest that housing delivery in the
East Midlands is currently constrained by a lack of land. Instead
it appears to be constrained by a lack of mortgage finance and
adverse market conditions caused by wider economic uncertainty.
The removal of regional housing targets will therefore have little
impact on housing delivery in the short term. However, this situation
could change rapidly once economic growth recovers. It is also
worth noting that the latest sets of official population and household
projections indicate a level of housing provision above the Regional
Plan target[34].
1.2 As a result, the Committee may wish to consider
what steps the Government might reasonably take if the collective
impact of housing targets developed by individual local planning
authorities fails to meet the nation's long term demographic and
economic needs in a sustainable manner.
2. 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.
2.1 At the time of writing, few details are known
about the Government's "New Homes Bonus" and consultation
on formal proposals is not expected until the autumn of 2010.
However, under the current revenue grant system, local authorities
with rapidly growing populations are effectively penalised twice.
Firstly, factors such as the council tax base and relative need
indicators appear to have a much greater impact on the funding
formula than population growth. Secondly, there is often a time
lag between the impact of real population increases on the ground,
and the additional population being recognized in the official
figures used in the funding formula.[35]
As a result, some councils are forever
"emptying the bins of people for free", and it is difficult
for existing residents to see any benefits to them of living in
a growing community.
2.2 It is therefore entirely appropriate for
the Government to examine how the relationship between council
tax and revenue grant operates, and to see if the system can be
used to support population growth, rather than to penalise it.
However, the Committee may wish to examine the evidence that fiscal
measures of this type would on there own be sufficient to increase
overall housing delivery, and whether the resulting distribution
of development would be likely to meet the nation's demographic
and economic needs in a sustainable manner.
2.3 In considering the details of the proposed
New Homes Bonus when published, the committee may also want to
consider:
- The scale of additional resources available (as
yet unknown) as compared to the total local authority 'Formula
Grant' for England (£29 billion for 2010-11)[36]
and the investment in local infrastructure and affordable housing
that the planning system delivers through Section 106 Agreements
(estimated at £4.9 billion in 2007-08).[37]
- The impact on those authorities where significant
growth would be inappropriate because of landscape designations
(such as National Parks and Areas of Outstanding Natural Beauty),
planning designations (such as greenbelt and green wedges) or
environmental constraints (such as flood risk).
- How completions of purpose built self contained
student accommodation should be treated, given that wholly student
households are currently exempt from Council Tax.
- The possibility that linking the grant of planning
permission directly to the receipt of additional Government funding
may undermine the probity of the planning system in the eyes of
local communities.
3. 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).
3.1 There are a large number of policy areas
where coordinated action between local authorities and other partners
is required to ensure international obligations (such as EU landfill
diversion and renewable energy targets) or national policy priorities
(such as biodiversity habitat and landscape recreation and management
targets) can be delivered, or to address complex issues that cross
local authority borders (such as coastal flood risk). In the past
regional groupings have provided the main mechanisms through which
this co-operation has been facilitated and managed, underpinned
by RSS policies. Regional bodies have also facilitated collective
activity on major strategic "cross border" issues such
as the enhancement of the Midland Main Line and proposals for
High Speed Rail.
3.2 In the absence of regional structures and
policies, it will be for local authorities themselves to ensure
this cooperation continues through successor arrangements, underpinned
by a statutory duty to co-operate. These arrangements will need
to be robust enough to provide a clear strategic context within
which local decision making can take place, and to avoid protracted
or repeated consideration of strategic issues at LDF Examinations
in Public (EiP).
3.3 For example, a steady and adequate supply
of minerals is essential to construction, industry and commerce.
However, minerals can only be worked where they occur, which can
be a considerable distance from where they are needed. Planning
for minerals therefore requires a strategic balance to be made
to ensure that supplies in one part of the country are secured
to meet needs in another. The Managed Aggregate Supply System
(MASS) operated through the RSS with the advice of Aggregate Working
Parties (AWPs) to this end. In the absence of the RSS consideration
needs to be given as to how mineral planning authorities will
have access to strategic advice for making local decisions that
have wider significance and to ensure that the expertise, data
capture, analysis and links with industry that have been developed
through AWPs is not lost.
3.4 It is also worth noting that the Government
will remain responsible for the collective national outcome of
local authority actions, particularly in relation to European
legislation.
3.5 As a result, the Committee may wish to consider
what mechanisms could be put in place to help resolve any outstanding
strategic policy conflicts prior to EiP, and how delivery of international
obligations and national policy objectives can be ensured.
4. 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 fulfill
a planning function.
4.1 Local authorities in the East Midlands have
considerable experience of joint working on planning issues on
a housing market area basis, underpinned by RSS policies. Statutory
joint planning arrangements have been established under current
legislation in West Northamptonshire (comprising Northampton,
Daventry and South Northamptonshire), North Northamptonshire (Corby,
Kettering, Wellingborough and East Northamptonshire), and Central
Lincolnshire (Lincoln, North Kesteven and West Lindsey). Informal
joint arrangements are operating around Nottingham, Derby and
Leicester, and in some of the more rural parts of Derbyshire and
coastal Lincolnshire. Such arrangements have the potential to
secure efficiencies and costs savings as well as more sustainable
planning outcomes.
4.2 The form and functions of Local Enterprise
Partnerships (LEPs) are open to considerable local discretion
and have yet to be fully determined. However, there are currently
no proposals from Government to grant LEPs statutory planning
powers and it seems unlikely that the emerging pattern of LEPs
in the East Midlands will match existing joint planning arrangements.
4.3 As a result, the main opportunity for LEPs
in relation to the operation of the planning system is likely
to be around strategic infrastructure and investment planning,
for example transport, and the monitoring land use change. This
would help to provide a strategic context for the work of individual
local planning authorities and could be underpinned by a statutory
duty to co-operate. Local authorities in the East Midlands have
developed considerable knowledge and expertise around investment
prioritisation from the former Regional Funding Allocations process.
There are opportunities for this to be deployed through sub-regional
LEPs and extended to other policy areas through place based budgeting
initiatives.
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 EMC has deposited an archive of material
covering the last 15 years of regional planning in the East Midlands
with Nottingham Trent University (NTU), and is producing a DVD
containing the NTU archive for each local authority in the region.
Arrangements are being made for evidence that is still relevant
to plan-making to remain publicly available via the internet.
The old Regional Assembly web-site as been archived in its entirety
with the British Library http://www.webarchive.org.uk/ukwa/target/49741949/)
and it is proposed to do the same with the Regional Strategy and
EMC web-sites in due course.
5.2 EMC is working with agencies and local authorities
to ensure that the Ptolemy Land Use Transport Integrated Model
(http://www.ptolemy-model.org/) and the Waste Treatment Capacity
Model remain available to local authorities. EMC is also working
with local authorities to ensure that the considerable public
investment in local and region-wide land use monitoring systems
made over the last five years is not lost and can be adapted to
serve new sub-regional geographies.
5.3 In addition, EMC is making use of "transitional
grant" from CLG to support local planning authorities in
the East Midlands by:
- facilitating a "Planning for Localism"
seminar for all local authorities in the East Midlands (to be
held on 1 October 2010) with speakers from CLG, PINS, Planning
Aid and the Home Builders Federation;
- working with the Improvement and Efficiency Partnership
to develop a "low cost" continuing professional development
(CPD) programme for local authority planners, and an elected Members
Network;
- making use of resources from DECC to provide
local planning authorities with a consistent core evidence base
on opportunities for renewable energy and heat mapping; and
- facilitating a technical monitoring seminar for
local authorities on the 4 November 2010.
September 2010
32 Figures from East Midlands RSS Annual Monitoring
Reports. Back
33
East Midlands RSS Annual Monitoring Report for 2008/9, Table 2.3. Back
34
The 2006 based Household Projections indicated a figure of 26,000
p.a. Forthcoming 2008 based Household Projections are likely to
be lower, but still above the Regional Plan target. Back
35
MKSM Inter-Regional Board 6 March 2008 IRB 11(5). Back
36
Written Statement by the Secretary of State, 10 June 2010. Back
37
Research commissioned by CLG from the University of Sheffield,
published July 2010. Back
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