There is growing concern from grass-root members of the Planning Officers Society that the arbitrary application of growth point syndrome by Regional Assemblies and Regional Government Offices in emerging RSSs is blocking the non growth areas ability to promote adequate levels of sustainable growth to address local affordable housing targets. POS says this is a critical flaw in the draft PPS3 and needs to be re-examined.
The Planning Officers Society (POS), in its response to the Planning Policy Statement 3: Housing (PPS3) supports the proposals for five and fifteen year land release triggers and the sub regional and local authority breakdowns. However, it believes the Regional Spatial Strategies (RSS) are unlikely to be in a position to determine the circumstances under which land should be released throughout the country since the proposals are predicated on Housing Market Assessments (HMA) being applicable in all areas and in London and remote rural areas they are unlikely to reflect sub regional joint working structures.
The Society is of the view that decisions about triggering the release of 5-15 year land need to be taken at the local market area level and any RSS triggers of land release are likely to be based on broad criteria which would not adequately reflect community involvement, Housing Market Area Partnerships views, or a clear understanding of the balance of the appropriate area factors in the HMA. The Society believes the RSS will only be equipped to oversee the cooperative arrangements necessary in any sub regional area identified in the RSS, thus for those parts of a region which lie outside an identified sub-region the RSS will not be able to provide the necessary guidance. This appears to be confirmed by the proposed appendix D to PPS3 where, outside growth areas, the option for identified sub regional release mechanisms is presented.
Geoff Cross, for POS, says “We suggest the PPS is amended to make it clear the RSS should only determine the general area in which local planning authorities will be expected to work to determine any 5-15 year land release at the sub regional level and local authority levels.” The Society goes on to suggest the RSS could influence LPA activity through an indication that the prevailing situation, if not resolved, is forcing the Development Plan Document out of conformity with the RSS.