Memorandum from Hampshire County Council
EXECUTIVE SUMMARY
- The County Council believes there is a void between
high-level national policy making and local planning delivery.
Filling that "strategic planning" void is necessary
to address important issues related to the provision of infrastructure
and delivery of services which must be dealt with across arbitrary
district council boundaries for reasons of effectiveness and efficiency.
- Our submission to this Select Committee logically
follows on from our bid, in 2009 under the Sustainable Communities
Act 2007, to take strategic planning powers away from the
Regional Planning Body and give them to county councils. Both
recognise that county councils, working collaboratively with their
district partners and other stakeholders, can successfully fill
the void between national and local plan making. We would urge
the Committee to include a recommendation of this sort in its
report to Parliament.
- Following the abolition of regional strategies,
some district councils in Hampshire seem likely to plan for a
lower rate of house building. However, the new housebuilding figures
reflect important local factors which were not adequately considered
in the flawed and distant Regional Strategy preparation process,
yet they still provide for more than just local housing need.
This is localism and democracy in action and should be commended.
- In two-tier areas, responsibility for the delivery
of many local services are split between upper and lower tier
authorities. It is essential, therefore, that the statutory duty
to cooperate applies not only between lower tier planning authorities
but also with their county councils. This is essential in order
to "join-up" local planning with the planning of transport,
mineral extraction, waste disposal, education and social care
provision, and flood management—all of which are county
council statutory responsibilities.
- The Government's intention for district planning
authorities to have a "duty to cooperate" is welcome,
but it needs to also require cooperation with county councils
in two tier areas. Indeed, county councils could coordinate the
cooperation between authorities within their county.
- The County Council has major reservations about
Local Enterprise Partnerships (LEPs) being directly given any
planning functions. It would be undemocratic for public policy
to be determined by a private sector-led body. Decisions on which
planning policies to adopt should rest with local government who
need to take account of other considerations (environmental constraints,
public opinion etc.) in reaching planning decisions operating
via a democratically accountable process.
- Clarification from the Government is required
on the proposed housing incentives package. Based on the limited
information currently available, the County Council is concerned
that the proposed incentives package will not address the very
real funding issues for infrastructure and therefore will do little
to assuage fears of over-stretched local resources or to persuade
local communities to accept new development. The County Council
is concerned that the incentives may be paid only to lower tier
authorities: in two-tier areas, it is county councils who provide
most public services including the new education, social care,
transport and waste disposal facilities needed to support new
housing development. The Select Committee is urged to recommend
that Government set out details of the scheme as soon as possible,
including the production of a full Regulatory Impact Assessment
and Cost Benefit Analysis in order for the impacts of any potential
incentives package to be thoroughly assessed and debated.
- County Councils have a statutory duty to undertake
surveys of their areas. This duty provides a formal basis for
their research and data analysis activity. They employ specialists
such as demographers and economic analysts which individual district
planning authorities could not be justify employing, while surveys/data
analysis for a whole county can be more cost effective than if
undertaken by district authorities individually. It is unclear
whether this statutory duty will remain in legislation following
the passage of the Localism Bill. Without it, this valuable County
Council research activity could be lost. The Select Committee
is urged to recommend to Parliament that a similar provision be
incorporated in the forthcoming Localism Bill.
INTRODUCTION
1. Hampshire County Council believes there is
a need for a level of strategic planning between the national
and local level. As the County Council stated in its bid in 2009
under the Sustainable Communities Act 2007—which
sought to devolve planning powers from the regional level—this
should preferably be at county level. Please see a summary of
the key elements of the County Council's bid at Appendix 1.[38]
2. Hampshire County Council played a major role
in the preparation of the Regional Strategy for the South East
(the "South East Plan"), including the drafting, in
conjunction with the other upper tier authorities, of the two
sub-regional strategies which covered the more urbanised parts
of the county. The County Council, as minerals and waste planning
authority, was very influential in shaping the minerals and waste
policies in the South East Plan. The County Council also undertakes
demographic and economic forecasting, and monitors development
activity and land supply. Based on this knowledge and experience
and the work undertaken to prepare our Sustainable Communities
Act bid the County Council believes it can provide authoritative
evidence to the Committee.
3. The County Council wishes primarily to comment
on those aspects of the Committee's inquiry relating to future
arrangements for strategic planning, including minerals and waste,
but in order to help the Committee, this submission also includes
some evidence on the implications of regional strategy abolition
and the Government's plan for incentives. The County Council would
welcome any opportunity to elaborate through oral evidence to
the Committee.
ABOUT HAMPSHIRE
4. Hampshire is very large and diverse. With
a population of almost 1.3 million, it is England's third most
populous county. It is estimated to account for around 20% of
the South East Region's economy and population. Major urban areas
of Aldershot / Farnborough, Basingstoke and South Hampshire, contrast
with substantial rural areas including large parts of two National
Parks. The county includes two Growth Points and an Ecotown, while
two airports, two seaports and four universities add to the development
pressure in the county.
The implications of the abolition of regional
house building targets for levels of housing development
5. The implication in Hampshire of the revocation
of regional strategies seems to be a move to authorities planning
for a lower level of house building than that proposed by the
final version of the South East Plan. The emerging intentions
of the local planning authorities within Hampshire sum to around
5,600 new homes per annum over future years, compared to the 6,700
per annum target in the final version of the South East Plan.
The former is close to the 6,100 per annum proposed in the draft
Plan before the former Government's Ministers hiked the figures.
6. It therefore seems that future house building
in Hampshire could be only around 16% lower than the South East
Plan's target: not as dramatic a fall as some commentators are
predicting. Moreover, this lower provision would still provide
for all the household increase arising from demographic change
of Hampshire's existing population plus an element of in-migration.
The County Council's forecast[39]
is that demographic change (people living longer, more one-person
households etc.) will generate 85,000 additional households 2006-26.
This would be more than satisfied by the 112,000 new homes now
being planned for by borough/district councils.
7. The emerging picture in Hampshire shows that
local authorities do recognise the need for new housing development
and not only that required to meet indigenously generated needs.
Local authorities also recognise the acute need for affordable
housing. However, the new figures more fully reflect important
local constraints and infrastructure and environmental capacity
issues which were not, in the view of local communities, properly
acknowledged in the final South East Plan housing targets.
8. Hampshire County Council is not opposed to
development provided it is of the right type and scale, and is
supported by the infrastructure and services necessary to make
it sustainable. The scale of house building must take account
of housing needs generated by demographic change and economic
growth but must also take proper account of the capacity of infrastructure
to support development, environmental/sustainability considerations,
and the views of local residents. In short, the right balance
must be struck between these various considerations.
9. The County Council argues that decisions on
the appropriate balance are best made within local areas involving
local people and communities rather than at regional level, hence
our proposals under the Sustainable Communities Act 2007.
This means that such decisions are made by directly elected politicians
who have local knowledge and democratic legitimacy. Local politicians
also have the advantage of access to the advice of professionals
with intimate knowledge of local survey data and evidence, and
the ability to factor in wider "strategic" issues such
as the impacts on infrastructure and services (education, social
services, transportation, waste disposal, countryside recreation,
emergency services etc.) Local people and stakeholders relate
more readily to their county and locality, rather than artificial
regions, and feel more able to influence planning decisions and
issues associated with the need for new development.
The likely effectiveness of the Government's plan
to incentivise local communities to accept new housing development
and the nature and level of incentives which will need to be put
in place to ensure an adequate long term supply of housing
10. Details are still awaited of the size and
nature of the financial incentives. Media reports have suggested
that the Government might match council tax revenue from new housing
for a period of six years. This would mean a payment of around
£6,000-£9,000 per new home permitted. If this is the
case, Hampshire County Council's initial view is that this level
of funding would be insufficient to provide the infrastructure
and services necessary to support new development Consequently,
it is unlikely to assuage local fears about increased pressure
on stretched local services and infrastructure and will provide
little incentive to local communities to accept new development;
particularly if it is simply funding redirected from other sources.
One commentator has described this as "robbing Peterborough
to pay Poole".
11. In considering the likely effectiveness of
any future incentives scheme, the Select Committee is strongly
urged to recommend that the Government should make the full details
of the incentives scheme known, along with guidance on how it
will operate in practice as a matter of urgency. The County Council
would also like to see Government commit to undertake a full Regulatory
Impact Assessment and Cost Benefit Analysis of the proposed incentives
so that Parliament may have an informed debate about the merits
of the scheme. Without these detailed analyses it will simply
not be possible to properly consider the likely effects of any
proposed incentives scheme.
12. Hampshire County Council would be very concerned
if the funding for any proposed incentives (which seem likely
to be paid to lower tier borough/district councils) were to be
found from reducing existing grants to councils. If the latter
involved reductions in a broad range of grants to upper tier authorities,
this would effectively transfer resources from upper to lower
tier authorities; yet it is the upper tier authorities which provide
the vast majority of services to local communities. This would
undermine the ability of the County Council to provide highly
valued services to local communities. Furthermore, a stretch on
upper tier authority resources would mean being even less
able to provide the new services and infrastructure needed to
support new house building such as schools, social care, roads
and public transport, and waste disposal facilities etc. The County
Council urges the Select Committee to recommend that in two tier
areas, any financial incentive should be split between lower and
upper tier councils in accordance with the scale of the development
and infrastructure impacts.
The arrangement 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, etc)
13. To date, political and media attention has
focused on the inequities of top-down house building targets.
However, this ignores the fact that there is a far greater range
of topics to be dealt with in the successor arrangements to regional
spatial strategies. In two-tier areas, responsibility for the
topics listed in the Committee's question are split between upper
and lower tier authorities. Thus there is a need not just for
cooperation between lower tier planning authorities, but also
with their county councils. This is essential in order to "join-up"
local planning with the planning of transport, mineral extraction,
waste disposal, education and social care provision, and flood
management—all of which are county council statutory responsibilities.
14. To achieve the necessary "joined-up"
planning in two tier areas, the local (including county) authorities
should be required to prepare a broad shared vision for their
area which would draw on, and in turn inform, the preparation
of individual authorities' own documents. It would set out the
economic growth aspirations for the area, the key environmental
constraints and opportunities (eg flooding risk), the broad pattern
of development (areas for growth versus restraint but not specific
house building targets) and associated major infrastructure requirements
including broad locations for minerals development and strategic
waste facilities.
15. The vision document should not be seen as
an end in itself but rather the catalyst for a process of ongoing
dialogue and analysis about how the area should develop and change.
As well as being of value to the authority's own spatial and service
planning, it would be valuable to other agencies such as utility
providers, emergency services, Highways Agency etc who need to
dovetail the planning of their new infrastructure with the planning
of new development, and who operate at a geographic scale which
is much larger than an individual local planning authority.
16. It would be a form of informal strategic
planning that is not prescriptive nor imposed from above. Rather,
it would be prepared collaboratively between authorities and tiers
of authorities. It would seek to reflect the points made above
and identify and acknowledge cross-boundary and strategic issues
with local impacts. The key point the County Council wishes to
make with this submission is that, while it is a good thing that
regional strategic and regional house building targets have been
abolished, there remains a need for some form of collaboration
or "planning" to address strategically important issues
to operate on a greater-than-district basis. County Councils are
in the ideal position to take on this role and we would urge the
Committee to include a recommendation of this sort in its report
to Parliament.
The adequacy of proposals already put forward
by the Government, including a proposed duty to cooperate and
the suggestion that Local Enterprise Partnerships may fulfil a
planning function
17. The Government's stated intention to include
a "duty to cooperate", in tandem with changes to the
planning system, as part of its forthcoming Localism Bill is welcome.
18. The County Council's view is that a duty
to cooperate will not facilitate strategic planning unless given
support by national policy. Such policy would cover options on
inter authority arrangements and what issues need to be addressed.
In the preceding section, we outlined our proposals for how a
duty to cooperate should be complemented by a coordinating role
for county councils in two tier areas.
19. As far as minerals and waste planning is
concerned, where problems of supply and demand have to be seen
against a wide geographic canvas, the Aggregate Working Parties
(AWPs) and Waste Technical Advisory Bodies (TABs) in the past
provided a useful function. These bodies that comprised representatives
of planning authorities, Government and industry ensured relevant
information was collected, databases maintained and planning authorities
had relevant strategic advice. It is important that decision making
at the local level is informed by the strategic picture. The County
Council considers that these arrangements should be endorsed by
Government who should ensure they are appropriately funded.
20. The County Council has reservations about
Local Enterprise Partnerships (LEPs) being directly given any
planning functions, at least until there is greater clarity on
the way LEPs are to be developed and will operate in practise.
Whilst greater business involvement in shaping the development
strategies for an area is to be welcomed, there are questions
about the how LEPs would be able to ensure robust governance arrangements
that inspired community confidence in an area of statutory rights
and responsibilities such as planning; there could be serious
issues of democratic accountability dependent on the detailed
arrangements for the planning role in a LEP. As a minimum, LEPs
could usefully identify the planning approach which they feel
is needed to maximise economic growth and could champion those
during the formulation of planning documents. However, the decisions
on which planning policies to adopt should rest with elected local
councillors who need to take account of other considerations (environmental
constraints, public opinion etc.) in reaching planning decisions.
It could be seen as undemocratic for public policy and key planning
decisions to be determined by a private sector-led body.
21. Moreover, giving a planning function to LEPs
could, depending on the scale and nature of the LEPs, negate the
Government's objective, in abolishing the regional tier, of returning
decision-making to local communities. Having said that, the fact
that the Government is even considering the idea that LEPs might
perform some planning role is a welcome recognition by Ministers
that some form of strategic planning is needed.
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
22. The key issue here is ensuring that there
is a consistent and comparable approach to future research and
data collection on matters which cross local government boundaries.
This is relevant not just to issues which transcend boundaries,
but in terms of the economies of scale and thus cost savings which
arise from a co-ordinated, joint approach to the collection and
analysis of data.
23 County councils could play a major role in
information collection, research and analysis within two tier
areas. Hampshire County Council, for example, collates and analyses
data on population, the economy, development activity, and land
supply, and produces population and economic forecasts. This information
is relied upon by Hampshire district councils to prepare and monitor
LDF policies, as well as being used by the County Council itself.
The same services are provided to two adjoining unitary councils
under a Service Level Agreement. This makes best use of scarce
specialist resources, such as economists and demographers which
individual local planning authorities could not justify employing
on their own account, and also minimises costs through economies
of scale.
24. With the same cost-saving objectives in mind,
the County Council also leads one-off research projects for all,
or groups of, authorities within Hampshire. Recent examples include
ground-breaking county-wide research into the future housing needs
of a growing elderly population and a research into future employment
land requirements in north Hampshire. These examples show the
use of the County Council's in-house expertise and involvement
of specialist consultants who are managed by the County Council
on behalf of all participating authorities.
25. Sections 13 and 14 of the Planning and Compulsory
Purchase Act 2004 and the associated Town and Country Planning
(Local Development) (England) Regulations 2004 place a duty on
County Councils to undertake surveys of their areas, which provide
a statutory basis for the County Council's research and data analysis
described above. It is unclear whether this section will remain
in legislation following the passage of the Localism Bill. Without
this section this valuable County Council research activity could
be lost. The Select Committee is urged to recommend to Parliament
that a similar provision be incorporated in the forthcoming Localism
Bill.
APPENDIX 1
EXTRACTS FROM HAMPSHIRE COUNTY COUNCIL'S
SUSTAINABLE COMMUNITIES ACT BID FOR THE RETURN OF STRATEGIC PLANNING
POWERS
PROPOSAL
The proposal is to devolve the responsibility for
Regional Strategy preparation from the regional level to county
level, enabling closer links between planning and delivery of
services such as transport, education and health, and enhancing
local democratic accountability.
It should be noted that the scope of the proposal
excludes Local Development Framework and Multi-Area Agreement
processes, instead focusing only on the recovery of powers currently
held at the regional level and not suggesting any transfer of
powers to or from district councils or sub-regional partnerships.
The proposal is that responsibility for preparing
the Regional Strategy should be transferred to county level as
follows:
Each county area should prepare a strategy for its
area:
- These should be combined into a region-wide document
and assessed by South East England Development Agency and the
Leaders Board, who should resolve any inconsistencies with the
county areas concerned;
- To ensure consistency, the region would set the
timetable for preparation of all the county strategies and their
scope in the context of the existing strategy (South East Plan),
national policy etc;
- The Examination in Public (EiP) Panel should
play a role in testing the combined region-wide document, building
on their ongoing role in the Regional Strategy preparation process;
- Each county strategy should be prepared by the
County Council jointly with any unitary council(s) and any National
Park Authority in the county area, in consultation with the non-unitary
district councils and other stakeholders;
- Members would give strategic direction to the
process, with the final document signed off by the County Council
following discussion with other principal local authorities;
- Each county strategy should be a holistic, integrated
strategy including the identification of the infrastructure required
for delivery of development. This would enable infrastructure
items to be listed in the Regional Strategy Implementation Plan,
which would thus provide a framework for local authorities to
implement them through the devolved funding arrangements put forward
later in this proposal. That, in turn, would require locational
specificity for any major development areas proposed.
Variants on the above could include:
- The region to prescribe parameters for the content
of each county strategy, for example, house-building range to
be tested and broad development principles.
- The timely preparation of the county strategy
could be a target in the Local Area Agreement (LAA), which would
build in local authority commitment to it at a high level and
give reassurance to Government over timely delivery.
There is scope to further develop the proposal. For
example, "integrated county strategies" could subsume
the County Council's Sustainable Community Strategy, Local Transport
Plan and the duty to prepare an economic assessment.
THE CASE
FOR CHANGE
The case for county-level rather than regional strategies
is that:
- They would be drafted by individuals who are
closer to reality on the ground and have intimate knowledge of
the findings of surveys and research undertaken at this level;
- They would be steered by directly-elected politicians
who have local knowledge;
- They would be integrated with county-level community
strategies;
- The remoteness of the current preparation process
means that local bodies do not feel much "ownership"
of the plan, with potential impact on their willingness to deliver
it;
- The South East Plan is set at too generic a level
to enable meaningful integration of Local Development Frameworks,
for example on transport or biodiversity. Failure to resolve issues
at the strategic level, or test and debate them locally, means
the Plan cannot confidently be said to be sustainable;
- The gap between the region and the district authorities
is simply too big for planning to be sustainable on the ground.
For example, the important links between housing, transport and
infrastructure can only sensibly be made at the county level;
- County and unitary councils deliver most of the
public infrastructure and services needed by new development—transportation,
education, social services, libraries, major countryside recreation
facilities—while police, fire, health authorities are similarly
county-based;
- Key stakeholders, eg economic partnerships, wildlife
trusts, countryside protection bodies, are organised on a county
basis;
- County/unitary-level plans would mirror the geographic
units (county and unitary councils) for the new economic assessment
duty;
- South East county councils have demonstrated
their ability to undertake such a task expeditiously and to a
high standard. During 2004-05, they led the preparation of sub-regional
strategies which were incorporated essentially unchanged into
the draft South East Plan; while in only six months (including
a period of public consultation) they provided South East England
Regional Assembly (SEERA) with a house building target for each
borough/district.
September 2010
38 The "case for change" set out in the bid
remains directly relevant in the context of this inquiry and the
"proposal" could be readily modified to still provide
a form of strategic planning in the new localism era. Back
39
Hampshire County Council's demographic forecasts are widely respected
and much used by other organisations for service planning and
decision making. The forecast mentioned here was presented in
evidence to the South East Plan Examination-in-Public and was
not challenged. Back
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