Written submission by the Town and Country
Planning Association
1.0 ABOUT THE
TCPA
1.1 The Town and Country Planning Association
(TCPA) is an independent charity working to improve town and country
planning. Its cross-sectoral membership includes organisations
and individuals drawn from practitioners in local government,
private practice, housebuilders, academia and third sector organisations
and special interest groups. It puts social justice and the environment
at the heart of policy debate and champions fresh perspectives
on major issues of planning policy, housing, regeneration, the
environment and climate change. Our objectives are to:
— Secure
a decent, well designed home for everyone, in a human-scale environment
combining the best features of town and country.
— Empower
people and communities to influence decisions that affect them.
— Improve
the planning system in accordance with the principles of sustainable
development.
2.0 SUMMARY OF
TCPA EVIDENCE
— The
TCPA's response focuses on the Committee's first question: "How
effective is the Government's approach to regeneration likely
to be?"
— The
Government's approach to regeneration as set out in "Regeneration
to enable growth. What Government is doing in support of community-led
regeneration" covers four areas, which are:
— 1. reforming
and decentralising public services, including reform of the planning
system, with the introduction of Neighbourhood Plans, and changes
to Housing Benefit;
— 2. providing
powerful incentives that drive growth, such as the New Homes Bonus;
— 3. removing
barriers that hinder local ambitions; and
— 4. providing
targeted investment.
— The
removal of the regional tier of planning and housing policy, which
has been replaced by a new incentive scheme for housing (the New
Homes Bonus), is likely to have a significant impact on regeneration.
The Bonus rewards high-market-demand areas, but penalises renewal
areas with high levels of demolitions (the Bonus is awarded on
net additions). Therefore the benefits of the Bonus, and indeed
the costs, to communities and places will differ substantially
across England. This has the potential to exacerbate spatial inequalities
and favour high growth areas rather than direct and enable development
and investment in areas where renewal is needed.
— The
combined impact of key planning and housing reforms on regeneration,
not only the removal of regional planning and the New Homes Bonus,
but Housing Benefit reform and the "Affordable Rent Initiative",
may also have spatial implications. In particular sustaining urban
renewal and striving for socially and economically mixed communities
could be compromised if, for example, Housing Benefit policy leads
to much greater social housing need in those areas already subject
to significant deprivation and disadvantage.
— The
planning system - outside London, which retains its regional London
Plan with proposed new housing and regenerations for the Mayor,
and new mayoral development corporations - will have to deal the
growing hosing and regeneration challenges at a time when both
the framework and the resources have been significantly reduced.
— There
is a continuing need for the planning system to provide the long
term strategic framework to drive sustainable development and
regeneration.
3.0 TCPA RESPONSE
TO "HOW
EFFECTIVE IS
THE GOVERNMENT'S
APPROACH TO
REGENERATION LIKELY
TO BE?"
3.1 Regeneration is a term which denotes a wide-ranging
package of measures to reverse, improve or create the necessary
conditions for bettering the social, economic, environmental and
physical well-being of communities. The TCPA highlights the pre-conditions
for effective and sustainable regeneration in a definition offered
in Urban Regeneration. A Handbook: "comprehensive and integrated
vision and action which leads to the resolution of urban problems
and which seeks to bring about a lasting improvement in the economic,
physical, social and environmental condition of an area that has
been subject to change".[61]
The need for regeneration is not just confined to the urban areas
but also the former industrial and mining areas.
3.2 Previously, there was a comprehensive and
integrated vision with actions underpinning regeneration efforts,
including:
— A national
vision for housing and regeneration: the Sustainable Communities
Plan in 2003 and the Housing Green Paper in 2007 targeted areas
of low demand and aimed to deliver more homes and making homes
more affordable, such as central funding through the Housing Market
Renewal and New Deals for Communities programmes;
— Central
funding and co-ordinating support namely through the Housing Market
Renewal pathfinders since 2002 in the Midlands and northern regions,
coalfields regeneration programme, and through the work of bodies
such as the Homes and Communities Agency; and
— A planning
framework becoming established which provided all sectors with
a degree of certainty over issues such as identifying market and
social housing need, aspirations and delivery targets, and housing
land allocations through the statutory development plan.
3.3 The Coalition Government intends to implement
a radical reform of the planning and housing delivery system,
from the abolition of regional planning and a renewed emphasis
on localism to the streamlining of national planning guidance,
but without a green or white paper to allow proper analysis, consultation
and review. The Government also intends to replace strategic "top
down" planning with an incentives-based regime through the
New Homes Bonus, CIL and restricted use of Section 106 Planning
Obligations. All of this set against a backdrop of severe public
spending cuts, including on regeneration programmes such as the
Housing Market Renewal areas.
3.4 While welcoming some elements and aspirations
of the reforms, the TCPA believes that the collective and cumulative
impacts of these reforms have not been thought through. Going
back to the definition of regeneration set out in 3.1, the nature
of the problems to be tackled has not been adequately identified
in the first instance. The effect has already generated uncertainty
and speculation over the potential impact of this on planning,
housing (and in particular the delivery of housing need) and the
environment, as evident in stalled inner city schemes. And the
outcomes may undermine drivers of positive change or to contribute
to the processes of decline in many communities and places previously
earmarked and/ or needing regeneration, which the report of the
Urban Task Force in 1999 sought to address.
3.5 For example, the TCPA cites a recent report
by the Audit Commission in March 2011 reviewing progress in 2009-10
and the future of the Housing Market Renewal programme.[62]
It highlighted the difference that the HMR programme is making
and has provided the finances and the impetus for action to rebuild
housing markets, and that without a dedicated funding stream under
March 2011, a realistic future vision is needed for these areas
given the changed economic circumstances and the housing and economic
problems they continue to face.
3.6 The TCPA has analysed the details of the
planning reforms closely since intentions were published in the
Conservative Party policy paper Open Source Planning, and agrees
in the validity of some criticisms of the current planning system
through our representations to the Committee on its inquiries
into the Revocation of the RSSs and Localism, the Environmental
Audit Committee's inquiry into Sustainable Development in the
Localism Bill, and publications in 2010 on the future of planning[63]
(see Section 4 for full references). However the TCPA still fundamentally
believe in the important role of the spatial planning system.
It is needed as a long term strategic framework for sustainable
development, and in particular and including delivering sustainable
regeneration where a mechanism for positively managing change
is needed.
3.7 The TCPA would like to draw the Committee's
attention to forthcoming report by the TCPA, commissioned by the
Joseph Rowntree Foundation, which examines how the reform of the
planning system will impact on housing provision and social justice.
Through this analysis, it is clear to the TCPA and stakeholders
who attended the two roundtables that the benefits, and indeed
the costs, to communities and places will differ substantially
across England.
3.8 The TCPA concludes this submission by highlighting
key conclusions of this report.[64]
The final report is attached as supporting evidence to this submission
(see Attachment):
— the
long-terms patterns of spatial inequalities in England are likely
to be reinforced by a combination of the end of regional planning
and policy and an incentive scheme for housing which rewards high-market-demand
areas and penalises renewal areas with high levels of demolitions;
— there
will be shorter-term impacts on a significant number of low-income
households in terms of housing benefits and potential for spatial
disaggregation; and
— net
result in lack of uncertainty about the way we plan for and deliver
housing, particularly in areas in need of renewal.
4.0 TCPA REFERENCES
TCPA Policy Statement: Housing Market Renewal, April
2006.
TCPA Policy Statement: Urban Renaissance in England,
October 2003.
TCPA and JRF, March 2011, Policy analysis of housing
and planning reform, to be published on Tuesday 22 March 2011,
hard copy attached - Attachment.
TCPA submission to the Department for Communities
and Local Government on the New Homes Bonus, December 2010: www.tcpa.org.uk/data/files/resources/1006/TCPA-sumbmission-to-the-New-Homes-Bonus-consultation.pdf
TCPA submission to the Communities and Local Government
Committee inquiry into the abolition of regional spatial strategies,
September 2010: www.tcpa.org.uk/data/files/resources/936/20100915_CLG_Select_Committee_RSS_TCPA.pdf
TCPA submission to the Communities and Local Government
Select Committee on Localism, September 2010: www.tcpa.org.uk/data/files/resources/947/20100929_TCPA_FINAL_CLG_Committee_Localism.pdf
TCPA, June 2010, The future of planning report: distilling
the TCPA roundtable debates: http://www.tcpa.org.uk/data/files/tcpa_futureplanning_report.pdf
March 2011
61 Edited by Peter Roberts and Hugh Sykes, 2005, Urban
Regeneration. A Handbook, SAGE Publications, London, pp 17. Back
62
Audit Commission, March 2011, Housing Market Renewal. Housing,
programme review. Back
63
TCPA, June 2010, The future of planning report: distilling
the TCPA roundtable debates. Back
64
TCPA and JRF, March 2011, Policy analysis of housing and planning
reform, embargoed copy until Tuesday 22 March 2011. Back
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