Written evidence submitted by the northern parish councils of Rother District Council and Burwash: Save our Fields (the Joint group) [FPS 143] Introduction 1) The members of the Joint group are: a) Councillors from Brightling Parish Council, Burwash Parish Council, Etchingham Parish Council, Salehurst and Robertsbridge Parish Council, and Ticehurst Parish Council b) Our County councillor c) Two of the local Rother District councillors d) Members of Burwash: Save our Fields 2) Burwash: Save our Fields was set up in 2014. Details of the group can be found at www.burwashsaveourfields.org.uk/. Since 2014, the group has been involved in about 12 planning applications, issues and planning appeals and it has seen its arguments accepted in all of them. 3) The Joint group was set up this year to co-ordinate a response to government planning proposals. 4) Areas the Joint group can assist you with: a) Areas of Outstanding Natural Beauty (AONBs) 83% of Rother District Council is in an AONB. Over 90% of Rother District Council is in a protected area, the AONB, Sites of Special Scientific Interest (SSSI), RAMSAR sites etc., see para 28. b) Rural issues The parishes are rural parishes. Planning is primarily urban-centric. Rural issues in planning are some of the most intractable. c) Local perspective Parishes and local groups are able to assess how planning works for the public. They have an independent focus about their impact on villages which statistics rarely provide. Unlike some witnesses, our overriding consideration is the public interest. All but one of the parishes have recently been involved in drafting a Neighbourhood plan. d) Housing needs An examination of a local area can often show the problem of finding homes for the young and the elderly better than statistics. Housing problems are particularly acute in rural areas. Executive summary of this written evidence 5) The main points of this written evidence are: 1 a) The proposed formula for calculating the housing for local authorities is flawed and will not deliver what is claimed (Step 1 in Consultation document page 12). b) An adjusted formula will still produce the wrong figures. c) The proposed formula will reduce the new housing which young people can afford. d) There is inadequate protection for AONBs. They are a vital national asset which must be fully protected. e) There should be greater concentration on reducing land banking and stopping it from increasing in the future. f) The recent 2020 proposals do not adequately address the problems of housing and planning in rural areas. The problem with the proposed formula 6) The key questions about the proposed formula are: a) ‘Is 5% of existing housing stock in each local authority a suitable yardstick to estimate housing needs?’ (see Consultation document para 23), b) ‘Is Workshop-based median house price earnings ratio (the first affordability adjustment) a suitable adjustment?’ (see Consultation document para 29), c) ‘Is change in affordability over the last 10 years a suitable factor to include in the formula?’ (see Consultation document para 29). All other issues revolve around these three questions. Is 5% of existing housing stock in each local authority a suitable yardstick to estimate housing needs? 7) A local authority area may have a number of suitable sites or very few. Before the pandemic, a local authority area might have been experiencing high growth or contraction due to declining industry etc. A local authority may have a very large part of its area protected by being in an AONB etc. 5% of the existing housing stock will not reflect these factors. The 5% estimate will guarantee housing targets are wrong. The affordability tests 8) The second and third questions in para 6 can be taken together. The sub-text in the proposals is that by building more where people cannot afford houses, the price of housing will fall and people will be able to find somewhere to live. The research in the UK (Bank of England Staff Paper No. 720) and elsewhere shows that greatly increasing the supply of housing in a district will not lower house prices. Logic also supports the research. Suppose Esher and Richmond were identified as areas where people couldn’t afford homes. Further suppose all the fields in those areas were built on, in an attempt to solve the problem. Over the eight or so years, the new houses would be considered by those living within say 30 miles of the area and some living further afield and abroad. If only those in Richmond and Esher could buy the houses, the price of houses might fall, but as the area where potential purchases live would be so wide, there would be no drop in house prices. 2 9) Rother District has one of the lowest GDPs in the country because there is so little industry and commerce. The main employment is public sector work, health care, service industries and to a limited extent hospitality. Partly for these reasons Rother District has very low wage rates. East Sussex has no section of motorway. It has some of the worst roads in the country. However, Rother District has high house prices, partly due to its proximity to London and partly because of the number of people who retire here because of good communities, the sea, it is considered warmer than other parts of England and because its beautiful countryside. Most local people cannot afford ‘affordable homes’ and the young who grow up in the area have to move out to find somewhere to live. These problems will not be solved by the new formula. They would be solved if there was housing allocated for local people. Exception sites are welcome but the funding for them and the land for them is not there. So how should house targets be fixed? 10) There is no easy solution. However, the government proposal will not assist those trying to find a home. The Joint group puts forward the following solution. a) The government has decided 1 million homes for the five-year housing requirement. Perhaps 900,000 might be more realistic. b) There should be a decision whether there are going to be any new towns started in the five-year period and if so how many houses the new towns would produce in the five-year period. c) The number of housing units where planning permission has been granted but the developer or owner chooses not to build (land banking figures) should be ascertained. d) The two figures in b) and c) should be deducted from the 1 million/900,000 figure. e) That new figure should be divided by the total population of England and then multiplied by the total population of each local authority area to give each local authority a base target. f) The local authority would then be able to submit reasons why that figure should be increased or reduced. The government should provisionally state its agreement or opposition to the local authority figure. g) An Inspector should rule if there is a dispute. 11) Factors which the local authority and the Inspector could take into account should include: the estimated demand for new housing, the estimated available land for housing, its land banking figure, the area subject to protection, and such housing trends that look reliable and relevant. 12) While these figures are being assessed (hopefully in less than nine months), the old targets would remain in force. 13) This solution would ensure that the target reflects all relevant local conditions. How should the programme be accelerated? 3 14) In 1945, after the war, compulsory purchase of land was used to accelerate the house- building programme. One of the housing ministers was Harold Macmillan and he achieved totals of up to 350,000 homes a year. This was not achieved by requests or targets. The system had a number of advantages. It made land available relatively quickly. It produced houses that the local population wanted. The poor could be housed and the vulnerable protected. 15) If land were compulsorily purchased, the purchase price could be set by a new body, which could be a national authority or a number of local ones. This would drive away the speculators and add certainty. The authority, called here the Housing Authority (HA), would manage the scheme. A possible procedure would be as follows: a) The HA should, working with others, identify land suitable for housing. This would include land banking sites. b) The HA would apply for planning permission (if required). c) The community would have the same ability to support or oppose the planning applications. d) If planning permission were granted, the HA would buy the land at 10% more than it would be worth without planning permission. e) The HA would then finalise the proportion that would be sold at the market rent and the proportion for renting. Because of the difference between market rent and the purchase price, the non-market housing could be paid for. f) The houses for rent could be retained by the HA, given to the local authority or put into a housing association. 16) The issue is complex and the Joint group would be able to provide an assessment in another paper. The questions in the terms of reference A Is the current planning system working as it should do? 17) Yes. It needs adjustment, but not replacement. B What changes might need to be made? 18) The suggested changes are distributed in this document. C Are the Government’s proposals the right approach? 19) No. The government’s proposals would be a disaster for house building, communities and the environment.