Housing and Planning Bill

Written evidence submitted by the Association of Directors of Environment, Economy, Planning and Transport (ADEPT) (HPB 24)


1. This submission focusses on the elements of the Housing and Planning Bill which, without amendments, ADEPT consider as being potentially harmful to regeneration and economic prosperity: Starter Homes. ADEPT welcomes the aim of providing a supply of affordable homes in England, however, it is our view that without amendments the Bill will fail to meet this aspiration, and indeed actually have a negative impact on regeneration overall for two key reasons. First is the simple point that the current proposal will not guarantee affordability in the long term but rather act as a short term fix. Second is the issue that terms such as ‘underused’ and ‘no longer viable’ could serve to undermine the supply of industrial land and therefore job creation. It is ADEPT’s view that there is a real need to consider further the language used in the context of land envisaged as being suitable for Starter Homes in order to address this risk.

Introduction to ADEPT

2. This document contains the response of the Association of Directors of Environment, Economy, Planning and Transport (ADEPT) to the Housing and Planning Bill Committee call for written evidence. ADEPT is an umbrella organisation representing local authority county, unitary and metropolitan Directors responsible for 'Place based' services. Our remits include economic development, transport and communications, planning and housing, and the environment. ADEPT’s Policy Prospectus has been provided as Annex 1. [1]

3. In the current and future landscape of reduced funding, ADEPT want a serious devolution of thinking, planning, spending and decision making to a local level; allowing communities more responsibility for basic service delivery and commissioning, and enabling more effective use of local resources and assets.

The Affordability Issue

4. If as suggested Starter Homes can be resold or let at open market value five years after the initial sale, affordability cannot be maintained and purchasers can reap a windfall in the future. There is obviously a risk therefore that this would push up the values of Starter Homes after this initial time period.

5. In ADEPT’s view the Bill needs to be amended to state that the restrictions on re-sales and letting at open market value of Starter Homes are in perpetuity. This will help to achieve the aim of a long term supply of affordable homes rather than a temporary quick fix which the current Bill would provide.

The Suitability of Sites Issue

6. The Ministerial Statement of March 2015 and the Housing and Planning Bill Impact Assessment (p.32) refer to suitable sites for Starter Homes which have not previously been identified for housing as being likely to be those which are under-used or no longer viable for commercial or industrial purposes.   Any landowner could make the argument sites are under-used or no longer viable. Indeed it is even possible for land owners to make their sites under-used.  Typically housing values are higher than industrial values and it is likely that this could squeeze out industrial investment and perhaps even active industry. Often, industrial sites in places like the Black Country and other urban, industrial areas of the country are unviable in conventional senses and often take time to come forward along with public sector intervention. Therefore the use of terms such as "under-used and no longer viable" are potentially damaging in this context and the Government needs to fully understand the consequences of the language used in the Bill but also in supporting statements and documents.

7. To take Walsall as an example, there is currently 114.9ha of vacant industrial land (as opposed to premises) in Walsall. Using the Homes and Communities Agency employment / gross internal floorspace ratios at the historic take up rate of roughly an 80:20 division between B1/B2 and other types of industrial land such as logistics (which yields much lower employment yields), the total estimated net internal floorspace in the vacant land supply translates as 73,600 sqm of B8 and 294,400 of B1/B2/other. If this land was lost to Starter Homes that would equate to the potential job opportunity loss of 920 B8 jobs and 8,000 B1/B2/other sui generis type jobs.

8. This is obviously a worst case scenario of lost job opportunities but combined with recent changes to permitted development rights there is a real risk that the Starter Homes proposal will undermine the urban regeneration strategy. Some reduced industrial investment undoubtedly will continue, but given the amount of Walsall’s land that is in industrial use, the likelihood is that much of it will be either turned over to housing or kept as a speculative windfall asset with a housing rather than industrial value attached. This would severely curtail inward investment and not allow existing companies to grow.  As more sites are vacated over time there would be a barrier to them being used as industrial churn, leading to a speedier, and eventually terminal, decline in manufacturing employment, as landowners speculate on housing.    

9. It needs to be recognised that in order to meet the housing trajectory it’s essential to provide jobs as well. Industrial sites are already under pressure from house builders and there is a need to empower Councils to manage the regeneration of industrial sites, including the possibility of conversion to housing sites, that are no longer needed for industrial uses and not to reduce their control even further.


10. It is ADEPT’s view that a new section is needed in the Bill to address the issue of suitable sites for the provision of starter homes in order to reduce any potential adverse impact. The Bill should state that the provision of starter homes will be suitable on land/sites/premises that are no longer deliverable for commercial or industrial uses and that a supporting evidence statement will be required. It is not considered appropriate to have the description around the type of land envisaged for starter homes to sit outside of the Bill as it is so fundamental to the impact of this proposal overall. This amendment is considered necessary to protect not only active industry but also the supply of land for industrial development. A requirement could be included within the monitoring section for Councils to ensure they have sufficient and appropriate evidence to determine if land is needed to meet industrial requirements.

November 2015

[1] Not published.

Prepared 10th November 2015