June 2008


The Pitt Review was published by Sir Michael Pitt on Wednesday, 25th June, 2008. See here for the Cabinet Office Pitt Report Webpage where you can find the full report and a press release (bottom of page) which contains some key quotes from the full report. This report is relevant in determining the approach taken by planners when considering house building in areas at risk from flooding.

Unfortunately (although I haven’t yet read the report in detail) I gather from a debate in the House of Commons that some MPs are not happy with the report, see some questions posed by Martin Horwood (Cheltenham MP) and Laurence Roberson (Tewkesbury MP) to Hilary Benn (Secretary of State, Department for Environment, Food and Rural Affairs)here and here. It is also worth reading the rest of the debate.

However. The goverment Planning Portal Site says Pitt urges tougher development control in high flood-risk areas. Here’s some quotes:

The report voiced strong backing for current planning policy set out in Planning Policy Statement 25, which says there should be a presumption against building in high flood-risk areas, taking into account all sources of flood risk.

mmm. I see it doesn’t say you shouldn’t build in high flood-risk areas, and

Where it is necessary to construct buildings in high-risk areas to meet wider aims of sustainable development, PPS25 requires developers to fund necessary flood defence and mitigation works.

and

Pitt’s report has argued that the automatic right to connect surface water drainage of new developments to the sewerage system should be removed.

so may be in does help discourage building in this area, perhaps due to increased cost, but the reality will depend on the enforcement of the recommendations in the report.

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The Gloucestershire branch of Campaign to Protect Rural England (CPRE) have published a response to the draft Regional Spatial Strategy for the South West Examination in Public (EiP) Panels Report. The panels recommendations will feed into changes made to the draft RSS due for public consultation. The full response is here. It make the following important points :-

  • Urban extensions should only be considered when all major brownfield sites have been exhausted (The draft RSS proposes parallel development on greenfield and brownfield sites).
  • The CPRE believe that housing targets rely in too high estimates of economic growth and population increases and to low estimates of housing occupancy. Plus the fact that many of the assumptions are unreliable particularly given the predictions are for 20 years in the future. The Panel recommends a 40% increase in housing over the draft RSS!
  • The Panel is very complacent in flooding believing that the areas considered are not at risk from flooding and more detailed assessment should be left to Local Development Frameworks (LDFs).

Also see the CPRE – Gloucestershire Branch Website.

It is expected that the Secretary of State’s modifications to the Regional Spatial Strategy (RSS) will be released in July (likely to occur shortly before Parliamentary recess). Once published, the modifications will be subject to 12 weeks public consultation. It is likely that the consultation will not be delayed to take account of the peak summer holiday period therefore Parish Councils may find it useful to programme in appropriate time in their September agendas to consider the implications arising from the RSS modifications.

Some recent discussion with MP Martin Horwood (Cheltenham) and Caroline Flint (Housing Minister) primarily about whether the housing targets a likely to be reduced given the dramatic downturn in the housing sector. No much give from the Caroline Flint but even the Governments adviser on this says the housing targets should be reduced.

Oral Evidence Taken before the Environmental Audit Committee on Tuesday 3 June 2008

Members present:

Mr Tim Yeo, in the Chair
Colin Challen
Martin Horwood
Mr Graham Stuart
Jo Swinson

NB: Any public use of, or reference to, the contents should make clear that neither witnesses nor Members have had the opportunity to correct the record. The transcript is not yet an approved formal record of these proceedings.

FIRST EXCERPT…

Q163 Martin Horwood: I am impressed to discover the Department’s policy is not to tell people what to do. That is news to me. One of the things you are going to do is build the two million new houses by 2016 and a further one million by 2020. Obviously those targets were created at a time of rising house prices, with all the challenges of affordability that we talked about. Given that house prices now seem to be falling and we are apparently in an economic downturn, are those targets still right? Do they need to be revised downwards?

Caroline Flint: I think they are still right. Obviously we are, as people know and I have said it on numerous occasions, dealing with a challenging time; we are seeing changes in the market but I think the underlying need for a supply of more houses has not gone away. Part of my job and our department’s job, working across government with colleagues but also with the House Builders’ Federation and others, whilst recognising the downturn at the moment, is to see if we can make sure for the medium and long term how the market can pick up. That is why we continue to work to identify surplus land across government departments and why I think now we have something like 63 per cent of local authorities that have identified their five-year land supply going forward and again how we are working on our £8 billion social housing programme over the next three years through the Housing Corporation and through private developers to meet needs there.

Q164 Martin Horwood: This is based on Kate Barker’s analysis?

Caroline Flint: Yes, it is because I do not think fundamentally there has been any change. There is a slowdown in the market but that does not necessarily mean that the supply of houses and the target for those have substantially changed.

Q165 Martin Horwood: Can I quote you what Kate Barker told this committee in 2004 when she was questioned on this point? She said: ” …there are points in the review where I stress very clearly that you might start out with an intention to build X in an area and two years down the line what has happened in the market has suggested to you that X was too big and you should cut the target, and that would be absolutely reflected in this report.” She actually talked about, “One would hope that the reaction of the house builders …. [in a market downturn] is such that they would not build the houses”. Do you agree with her that that should be the response in a downturn?

Caroline Flint: I think the key point in terms of what you have quoted is her saying “in an area”. Clearly, all the time we are working with local authorities through regional and spatial strategies and other things, such as the growth areas, to identify the housing supply that is needed. We have a national target that is underpinned by negotiation on a regional and local basis. I think it is far too early to suggest that our national target, which I think is the point of your first question, should be changed, but of course we have to be mindful of what happens out there. It probably is the case that, in terms of the present climate, this year the number of houses built will be potentially lower than last year, given that last year was a record high.

Q166 Martin Horwood: That does not seem to be what she told us. You said that the key phrase in the quote I gave you was “in an area”, but she went on to say: “I am sometimes talked about as though I always talk about the need to increase building. The report absolutely does not do that.” Her point was that it was not about an absolute number; it was about increasing market responsiveness, so that in a downturn you should decrease those numbers.

Caroline Flint: I think it is far too early and premature to suggest that we should revise our target, which is 2016 and 2020. That being said, we are mindful of the market and recognise that some of our projections may have to be looked at based on how many houses might be built this year, which is likely to be lower than last year. Then again, it is about how the market picks up when those market conditions change. That is why I think it is too early to suggest that our target for three million homes in 2020 and two million by 2016 should be moved away from at this point.

Q167 Martin Horwood: The private house builders certainly are still complaining about increased costs and I guess they would say regulatory buildings [should read:burdens] too are making life difficult in this downturn. Do you not think that there is a risk that they will go for the quick wins in development terms, which might be the most environmentally costly, and not for the more difficult but more environmentally friendly options?

Caroline Flint: Firstly, the building industry is working with us as part of a ten-year strategy towards zero carbon new build homes by 2016. I think that work has been a good example of how government can engage with industry and over a really pretty long lead-in time but with a challenging target at the end of it really to make some changes to the way in which our building industry addresses these issues of energy efficiency. We have had the report recently from the UK-Green Building Council on the zero definition. We are consulting this summer on how zero carbon might be applied to commercial buildings. I have witnessed and seen myself some of the prototypes that have already been developed by some volume builders like Barratt in terms of zero carbon homes. I think having a clear sense of direction, a ten-year lead-in time, is one of the ways we can work very productively with the industry but that also gives us time to look at how the costs might be brought down. I do believe that the costs, whilst high at the moment – and that is something on which clearly we are working with the industry – if the expectation is that all houses will meet these demands, then I think that has an impact on lowering the costs over time. I think we have the right balance here between target and delivery towards that target.

Q168 Martin Horwood: I think other colleagues will question you a bit more about the standards.

Caroline Flint: That is about standards, is it not, zero carbon homes?

Q169 Martin Horwood: What I am trying to question you about is the impact of those targets. You say it is too early to say that the current downturn in house prices is one for which you should adjust the targets. Let us say it continues and that in due course you do have to adjust that target downwards, as Barker has suggested, what happens to the land that has already been designated for development? Some of it is sensitive greenfield sites and some of it more difficult urban regeneration, more difficult small developments around rural communities and things like this. Surely for developers, once the easier wins, the greenfield big developments, have been released for development, it will be impossible to pull them back from that and they will naturally as business people go for the more profitable sites and urban and small rural community regeneration will end up coming second?

Caroline Flint: Again, this is where local authorities have a crucial role to play in developing their local development frameworks.

Q170 Martin Horwood: If you will forgive me, that is based on the current targets. What I am saying is: if those targets in a downturn have to be or ought to be cut back as Barker suggested, in practice how does a local authority cut them back? How do they reclaim land?

Caroline Flint: Speculating on whether we will reduce our targets or not when I have indicated it is too early to give you a position on that – and actually the overall housing supply and demand is still there, regardless or not of the downturn – I do not think would add anything to the debate. What I can say is that we work with the building industry, and I think it is absolutely right that this is where Government does set a direction that shows leadership, about the types of homes that we feel should be the standard for the future. In doing so, we work with the industry because we do recognise at the end of the day they are the ones that will be putting up these buildings and they have costs; they are private firms and so forth. The other part of the question in terms of costs is that we are working with the industry at the moment to look at some of the issues around cumulative costs that are put on them as a result of different things that Government, not just my department but other departments, are asking of them. Again, I think that is a demonstration of a common-sense approach to having ambition but at the same time setting a realistic and common-sense framework to deliver on the target.

Q171 Martin Horwood: I am sorry to press this point but can I bring you back to the targets again? Kate Barker very clearly told us that in a downturn the targets should be reduced. That is the implication of what she said very clearly. Accepting that you think it is too early at the moment, are you saying that you will never look at reducing those targets and that she is wrong or are you accepting what she told us that in a downturn X might prove to be too big and therefore you should build less?

Caroline Flint: What I am saying is that the targets we have set are challenging but the long-term demands are not going to change. Whilst any government has to look at what is happening in the market and how it affects it, and our trajectories for housing growth is one of those areas, the long-term demands for housing still exist and will continue to exist in the future.

Q172 Martin Horwood: So when she says, “What has happened in the market has suggested to you that X was too big and you should cut the target”, you think she was wrong?

Caroline Flint: What I am saying, as I said earlier, is that I think it is too early to say that we should cut the targets.

Q173 Martin Horwood: I know that. I am sorry to press you, Minister. We have accepted that you think it is too early now. We are looking at the theoretical possibility that if the circumstances that Kate Barker described as a market downturn persist and that X proves to be, in her words, too big, then you should cut the target. Do you accept that she was right to say that, accepting that you think it is too early at the moment to make that judgment? Do you accept that that is possible, even in theory?

Caroline Flint: I would rather have a conversation wider than Kate Barker or a discussion around the demands that are made, which she identified in her report. Whilst we might have a situation in terms of our delivery that the number of houses that is projected to be built in any one year might be reduced because of market intervention, that does not necessarily mean in terms of the long term that we would move away from our target. The other point that I think is crucial to this is that as and when the market picks up, and the market will, have we got the necessary foundations in place to make sure that house building can move on quickly and as is needed in those communities? That is why some of the fundamentals like identifying land now is very important to all of that.

Q174 Martin Horwood: I am sure Kate Barker would agree with you about market responsiveness and that was part of her theme as well, but it sounds as though you are saying that those targets would stand regardless of the market. Is that right?

Caroline Flint: No, I think I said that at the moment I do not think there is a justification at this point for changing any target.

Q175 Martin Horwood: Not at this point; we accept that.

Caroline Flint: But I have just said in terms of the market now, and I can only talk about the market now. I think it would be unwise to theorise about where the market might be next year or the year after that.

Q176 Martin Horwood: Your adviser did: Kate Barker talked about the scenario in which a market downturn meant that the targets were too big and should be cut. Why will you not just answer the question about whether in theory you would accept that and say that if the scenario turns out to be a market downturn —

Caroline Flint: I think I have said – I am sure the transcript of the meeting will bear this out – that based on the present situation, I do not think there is a necessity for targets to be cut.

Q177 Martin Horwood: Can you imagine any scenario in which the target would be cut?

Caroline Flint: I do not think it would be useful for me to answer that question.

SECOND EXCERPT:

Q199 Martin Horwood: On the green belt, may I declare a constituency interest because the precise scenario I am going to describe to you applies to my constituency. We have an urban district council which is almost entirely ringed by green belt.

Caroline Flint: Where is it?

Q200 Martin Horwood: Cheltenham. It is AUNB [should read: AONB, for Area of Outstanding Natural Beauty] on one side but green belt on three sides. It has been handed down in the regional spatial statutory housing targets which project about 6,000 houses inevitably going into the green belt. Local councils of all colours have been committed to protecting that green belt but they are being asked to meet the housing target. How do they do it?

[There was a really long pause before she answered. M]

Caroline Flint: You will have to forgive me; I will have to be careful about what I say about anything that is in terms of the Regional Spatial Strategy and individual housing targets for legal reasons. What I will say is that we have protected the green belt and the procedures that underpin its protection are not something that we plan to change at all. In fact, in England the green belt has actually increased by 64,000 acres since 1997. The proportion of land in England counted as urban is something around 8.5 per cent of it, certainly under 10 per cent, well below 13 per cent of land in England that is currently green belt. Our view and our guidance underpinning this is that we should be looking to develop on brownfield. I think we increased from 56 per cent to nearly 75 per cent brownfield use since 1997; a quarter of new homes built on brownfield has risen by those figures. In some cases clearly green land as opposed to green belt has been utilised as well. My general advice to any local authority is to make sure that it has looked to all planning guidance that is provided, that it has looked at what available land outside the green belt is there for it to use. In those circumstances, that will be part of the negotiations for any house supplier or house delivery on the ground. As I say, there are cases sometimes where green belt I understand is infringed on in some way but often as part of negotiation. That is then offset by creating green belt elsewhere or it is on a marginal point in terms of the development. But, overall, green belt has increased and brownfield sites have increased.

[discussion about amount of new Green Belt omitted here. M]

Q203 Martin Horwood: To bring you back to the original question, if the Regional Spatial Strategy specifically says that 8,000 or 10,000 per year [shouldn’t read ‘per year’] of an area is the maximum capacity, all the potential exploited, therefore a larger number has to go into the green belt, how does any local council that wants to commit to protecting the green belt square that circle?

Caroline Flint: As I say, I think it is only in exceptional circumstances that green belt boundaries can be amended through the development plan process and only after there has been robust public consultation, an independent examination and the independent examination of the draft proposal. It is important therefore if a local authority has any view on the development in its area that it looks at making those cases and that is part of the discussion that takes place in the negotiation. I cannot really say any more than that.

Q204 Martin Horwood: You said it was exceptional but CPRE has told us that there are 37 current or projected reviews of green belt boundaries. Is that right?

Caroline Flint: They may have situations where development plans come forward in which they want to impact on green belt. That does not necessarily mean that they are going to be allowed to go forward. The whole point is that these are subject to very robust investigations and examination. That sounds logical to me. We cannot stop a situation where someone might put a plan forward but by putting the plan forward that might infringe on the green belt it does not mean it is necessarily going to go ahead at the end of the day. That is why there are the various planning policy statements and other guidance available to underpin the importance of the green belt and for that therefore to be used by local authorities and others in their negotiation about whether a development should or should not go ahead.

Q205 Chairman: So in very broad terms what would be the ratio of proposals to amend the green belt which are rejected?

Caroline Flint: I will have to come back to you on that.

Chairman: Thank you very much for coming this morning. I am sure what you have said will be useful to us in writing our report.

CPRE Figures

Government Target is 240,000 homes per year = 3m by 2020.
Regional Spatial Strategies provide for 203,000 pa.
Current rate 180,000 pa, highest for 15 year. Equals 21 sq mile.
Affordable home 10% of this.
There are 670,000 more homes than households in Britain, not all in good repair (however treasury figures say only 300,000 empty for over 6 months).
255,000 families have second homes.
Housing density 2001 was 20-25 per hectare. 2006 was 40. CPRE recommend 50.
Percent homes on previously developed land or conversion =74%
Previously developed land available for housing = 62,700 hectares
Of this 27,600 ha suitable for housing = over 1m homes at 40 per ha.
Developers hold plots for 341,000 homes.

The Barker Report

Many of these figures come from the Barker report of 2005. Her report is based on the ODPM statistic which shows 190,000 more households forming per year to 2021. Reasons given: Longer life expectancy, different family basis (marital breakup etc), no mention made of immigration.

Have not yet found how ODPM figures derived. CPRE do not say. Cant find basis on any annual growth figure.

The head of the Gloucestershire branch of the CPRE (Campaign to Protect Rural England) urges the goverment to use brownfield rather than greenfield land for new houses and argues that the amount of housing needed should be much lower. Heres the full article from the May 20th Gloucestershire Echo:

Here follows a debate in the House of Commons between Laurence Robertson (Tewkesbury MP), Martin Horwood (Cheltenham MP) and Ian Wright (Hartlepool MP, Parliamentary Under-Secretary, Department for Communities and Local Government) on the implications of building in the area to the NW of Cheltenham which is proposed in the South West Regional Spatial Strategy. Some good points are raised on flooding, whether houses might not be built in places that really need them, the consultation in the changes to the RSS and how the quasi-judicial nature of the RSS blocks the normal democratic processes.

Hansard 7 May 2008 : Column 816
South West Regional Spatial Strategy
Motion made, and Question proposed, That this House do now adjourn. —[Mr. Watts.]
8.58 pm

Mr. Laurence Robertson (Tewkesbury) (Con): I am pleased to have secured this debate. I am very grateful to the Minister for staying behind to reply, particularly as we did not know what time it would be when we got to this stage.
The subject of this debate—the implications for Tewkesbury of the south west regional spatial strategy—is especially important. Not only do we have green belt, green fields and beautiful areas in my constituency that we wish to protect, but, as the world knows, we have a problem with flooding. I say “as the world knows” because it is true. On recent trips to three countries in the far east and four countries in the Caribbean, my constituency of Tewkesbury was known about for the wrong reason—the terrible floods of July 2007. It is worth remembering that as a result of those floods, three people lost their lives and thousands had their homes and businesses flooded. Hundreds of thousands lost mains water supplies—some for up to three weeks—and power supplies were affected. The effects of the July 2007 floods remain with us. Even now, almost 10 months on, approximately 385 households in my constituency are still displaced from their homes, and some are probably still months from returning to them. Business in certain parts of my constituency remains depressed.
I have held two Adjournment debates on flooding and on each occasion—and on many other occasions—I have said the following. People in my constituency accept that living at the confluence of two rivers means that the area will flood every so often. Fields in the area flood a number of times each year. Although we all accept that the rainfall of 20 July 2007 was exceptional, we believe that certain factors made the flooding worse than it needed to be. One factor was the poor maintenance of the culverts, sewers, drains, ditches and waterways, but the other factor was that too many houses have been built in flood risk areas. People accept that the area will flood, but the one overriding message that people give to me, which they want me to pass on to the Minister, is that we should not be making the situation any worse than it needs to be. We should mitigate, rather than escalate, the problem. Imagine, then, the disappointment and anger at the contents of the regional spatial strategy, which proposes the building of thousands of houses in my constituency, in areas that have to be classed as at risk of flooding.
Before I go any further, let me state what should be the obvious. This is not just a matter of whether the new houses flood. Houses built in the wrong place take up field space that would otherwise have soaked up water, thereby preventing that water from resting on those fields. Water will be sent into other areas, causing terrible flooding. In other words, the run-off of water from one development causes other developments to flood. That fact should be obvious, but certain people just focus on whether the new houses flood. That is missing the point, either deliberately or otherwise. Those people also state that houses built in those areas should be flood-resilient. Again, that is missing the point, because the presence of these houses causes
other houses to flood. It is my submission, therefore, that to build thousands of houses in or around my constituency would be madness. What further evidence, other than three deaths, people still being out of their homes and business still being flat 10 months on, do those taking the decisions need to persuade them to build houses elsewhere?
In the RSS, the required number of houses for the whole housing market area is about 56,400, with 23 per cent. of these—a total of 13,100—proposed for the Tewkesbury district. If we want to talk about constituency boundaries, 27.7 per cent.—15,600 houses—would be within my constituency, much of which is a flood risk area. If we analyse those figures, we see that the RSS proposes the building of many houses at Longford and Innsworth, close to the Walham power station, which, as everyone knows, almost went under during the 2007 floods. If the water had risen much higher at that power station, hundreds of thousands of people would have lost their mains power supply, and that was almost the case. If that area is not at risk of flooding, what is? How can it make sense to propose to build houses in such an area?
Houses also flooded in Bishop’s Cleeve, but the RSS proposes the building of thousands of houses close to that village. Uckington floods, and flood alleviation schemes are being built to contain the River Chelt in that area. Yet again, thousands of houses are being proposed for that area, and 2,900 houses are proposed for the rest of the Tewkesbury district. From conversations that I have held with planners, it appears that those houses might have to be built close to Tewkesbury town, which was badly affected only last year, and remains so. No one can forget the television images of the town surrounded by water.
The evidence of the problems of excessive building is already there for all to see. For example, in Bredon road in Tewkesbury, houses in the process of being built flooded, and houses that were built in Noverton lane worsened the flooding in the village of Prestbury, where in June—never mind July—houses flooded for the first time in people’s 40-year memories. They flooded again in July of course, and the streets became like rivers. Who can say that those extra houses did not worsen matters?
The Government often say that they have strengthened the case against building in flood risk areas through planning policy statement 25. However, a glance at that document, which was published in December 2006—months before the terrible floods in 2007—shows that the guidance on building outside flood risk areas is qualified by “wider sustainability objectives”. The “exceptional test” allows building in flood risk areas.
So what is the principle that underpins PPS25? Is it avoiding inappropriate development in flood risk areas or ensuring that housing targets are met? In other words, the exceptional test undermines the principle of the whole document and disregards the dangers and major disruptions experienced by people who live in flood risk areas.
As Sir Michael Pitt says in his interim report:
“Some respondents felt that the introduction of this test could be interpreted as a get-out clause for local authorities”—

or, in this case, the RSS. Crucially, he continues:

A decision to permit development should not be taken lightly by the planning authority, not least because a prospective purchaser will generally assume that the granting of planning permission signals that the local authority does not perceive there to be a problem with flood risk”.


That is a good point. Who will buy those houses if they are perceived to be likely to flood, and if there are problems with insuring them? Earlier today, the Association of British Insurers told me:
“We want to ensure that wherever possible new homes are not built in high flood risk areas. If they are, then insurers cannot guarantee to offer cover.”


Planning policy statement 25 calls for flood risk assessments to be made at all levels of the planning process. However, what flood risk assessments were made during the compilation of the RSS, a document that was largely drawn up before the floods of July 2007? Does not that in itself make it incumbent on the Secretary of State to require the authors to go back to the drawing board on their housing proposals?
What constitutes a flood risk area? If the definition is based on annual likelihood of flooding, how can that be assessed if we accept that climate change is taking place? In other words, a place with a one in a 100 chance of flooding in the past can no longer be assumed to be in that category if the climate is changing as the Government tell us it is.
We are, of course, supposed to be protected from inappropriate development by the Environment Agency. However, an appeal to build 600 houses near Longford in my constituency, close to Walham sub-station, is currently being considered by the Secretary of State. I have submitted photographs of at least part of that site when flooded, yet the Environment Agency did not even submit an objection to the application. Even worse, the Environment Agency said that the area did not have a monitoring station on the site, but it does. That station indicated flooding, so I hope that the Secretary of State will take that error into account when assessing the appeal.
I suggest that the fact that the Environment Agency has not objected to the proposed building at Longford is evidence that, as currently constituted, it is simply not up to the job and its role should be reviewed. How can the Environment Agency, when it has seen the effects of the flooding in my area, fail to object to the proposals to build thousands more houses there? It defies belief. Of course, some might describe my objection to those houses as an example of nimbyism—but if it is, so be it. I am paid to represent the people of my constituency, and I do not believe it to be in their best interests to have those houses.
Let us consider the situation somewhat more widely. Village post offices are closing, including a further six in my constituency, pubs are closing at the rate of an estimated 27 a week, and village shops are struggling. So why not top up the housing stock in villages throughout the country? Many villages are calling for such development, partly so that their own people can continue to live in the villages where they were born.
Why is the concentration on principal urban areas? Why are so many houses needed in the first place? What is the science used to calculate the need for such housing stock? It cannot be that the divorce rate and the life expectancy figures are still accelerating to such a degree. However, I accept that the net immigration figures are a worry, with a total of 1.62 million more people coming to this country than leaving it over the past 10 years, which puts pressure on housing. That perhaps needs tackling as a separate problem. The method of calculation, immigration, the dispersal of houses and the planning process are all underlying issues that the Government should tackle, rather than allowing unelected regional bureaucrats to make crude calculations about the number of houses that we are supposed to need in each constituency.
The Government have made two promises that are relevant to this debate. One, which they made before being elected to office, was to end the predict-and-provide approach to housing. That has not happened; in fact that approach has been entrenched, and on a regional basis, which is why we are in the current predicament. The second promise, made after last week’s election results, was that the Prime Minister would listen to people’s concerns.
The Prime Minister paid a welcome visit to my constituency during the flooding. I now call on him, the Secretary of State and the Minister to listen to what the people of Tewkesbury are saying: that building extra housing to the level proposed by the RSS would make the risk of flooding in the area significantly worse, with the risk to life, property, business and possessions being greatly heightened.
When he visited Tewkesbury, the Prime Minister saw for himself the water, the bowsers, the problems at Walham and the Mythe, and the enormous efforts that people were making to help each other. I know that he would not want us to go through that again. So through his Secretary of State and the Minister who is here tonight, the Prime Minister needs to reject the proposals in the RSS to which I have referred, in order to reduce that likelihood. To refuse to do so will be to fail to respond to the situation in which we found ourselves last year, and will also represent a failure to listen. As only the changes that the Minister makes to the RSS will be open to further public consultation, this is our last chance to affect the outcome of what, to us, is a crucial process.

The Parliamentary Under-Secretary of State for Communities and Local Government (Mr. Iain Wright): I congratulate the hon. Member for Tewkesbury (Mr. Robertson) on securing this debate. I am aware that he raised similar issues during a debate on the south west regional spatial strategy in January, to which my right hon. Friend the Chief Secretary to the Treasury responded, when she was Minister for Housing. The hon. Gentleman has this evening reiterated how important the regional spatial strategy for the south-west is to him and his constituents, and I commend him on that.
However, I am sure that the hon. Gentleman will be aware that I shall have to disappoint him tonight. Like my right hon. Friend in January, I am unable to respond to many of his concerns. The RSS process is a quasi-judicial one involving plans and planning decisions, and I do not wish in any way to prejudice the impartiality of my right hon. Friend the Secretary of State in coming to a decision. I apologise to the hon. Gentleman for that, but I hope that he will accept it.

It would be helpful to start by giving some background to the regional spatial strategy. A regional spatial strategy is a requirement of the Planning and Compulsory Purchase Act 2004. That piece of legislation, and the role of the RSS in particular, helped to strengthen the role and importance of regional planning. A regional spatial strategy’s purpose is to set out a broad development strategy for a 20-year period. I acknowledge that the process undertaken in the preparation of a regional spatial strategy is often described as, at best, laborious. However, the regional spatial strategy is a vital document. The length of the process rightly reflects the need for extensive dialogue in its preparation.
A regional spatial strategy is a key component in achieving more sustainable development and provides a spatial context for local development frameworks and other strategies and spending frameworks. Regional spatial strategies include issues such as how much housing is needed, the general location where it should be built, the priorities for new infrastructure and economic development, the strategy for protecting countryside and biodiversity and the policy for reducing carbon emissions and safeguarding natural resources—for example, water and minerals.
It might also assist the hon. Member for Tewkesbury if I mentioned something about the history of the regional spatial strategy in his area of the south-west. As he will be aware, responsibility for the initial drafting of the regional spatial strategy rested with the regional assembly, which submitted its draft to the Government on 24 April 2006. A 12-week public consultation gave the opportunity to put comments to an independent panel, which was appointed by the Secretary of State for Communities and Local Government to test the soundness of the draft regional spatial strategy. Following that, an examination in public was held between April and July 2007 to discuss and test the draft regional spatial strategy before the panel. The length of the examination in the public stage reflected the level of interest in the draft RSS, with the panel reviewing comments from almost 2,000 different parties. I understand that 191 organisations and individuals took part in public hearings held in Exeter. The panel’s report was submitted to the Government on 10 December 2007 and was published for information on 10 January 2008. It contains recommendations to the Secretary of State on all aspects of the draft regional spatial strategy.
I have now set out the background to the draft RSS, but I reiterate what I said in my opening remarks—that I hope that the hon. Gentleman will understand that on account of the quasi-judicial nature of the process, I am very much constrained in what I am able to say at this stage about the detailed proposals contained within the RSS. I must point out that in taking quasi-judicial decisions under the Planning Acts, there is clear guidance for Ministers, which is based on advice from the Law Officers and First Treasury Counsel. A copy of the guidance can be found on the website of the Department for Communities and Local Government and is entitled “Guidance on propriety issues in handling planning casework in Communities and Local Government”. If it would assist the hon. Gentleman, I can certainly provide him with a copy of it. That guidance outlines that Ministers should not enter into discussions with interested parties on the changes that might be made to a draft regional spatial strategy while consideration is being given to the panel’s report.
Martin Horwood (Cheltenham) (LD): Will the Minister give way?
Mr. Wright: I certainly will, even though the hon. Gentleman was not in his place at the start of the debate.
Martin Horwood: I am very grateful; I was listening to the debate from another location. The Minister says that the examination in public took account of many hundreds of submissions. However, in an area called Leckhampton, which straddles the boundary between the constituency of the hon. Member for Tewkesbury (Mr. Robertson) and my own, potentially up to 1,300 extra homes have been approved for building on land that is waterlogged as we speak. That development, which will increase flooding in parts of both my and the hon. Gentleman’s constituency downhill, has been approved despite hundreds of objections from local people. In effect, those unelected inspectors have made this decision with no democratic accountability. If the Minister will not answer questions on this strategy, where are we to ask them and how are we to challenge this decision making?
Mr. Wright: The hon. Gentleman has made his case, but I am not that tempted to respond to it. As I have tried to explain, the whole process regarding the regional spatial strategy is a quasi-judicial one and I do not want to be tempted to make any comment that would prejudice in any way the Secretary of State’s ability to come to an impartial view about the figures and the detail contained within the RSS. I hope that the hon. Gentleman understands that point.
As I said earlier, the panel’s report was submitted to the Government on 10 December and was published for information the following month. I am sure that the hon. Member for Tewkesbury would like me to explain, following the publication of the report for information, what the next step is. The Secretary of State is now considering the panel’s report, along with all the representations previously submitted, and aims to publish her proposed changes as soon as possible. I must stress that at this stage no conclusions have been reached on any of the panel’s recommendations. There will then be a 12-week period of public consultation when the proposed changes are published. That will be the opportunity for those interested in the content of the regional spatial strategy to make their comments known. Following consideration of comments and views arising from that consultation, the Secretary of State expects to publish the final regional spatial strategy before the end of 2008.
Mr. Laurence Robertson: Am I right in thinking that only the changes the Secretary of State proposes will go out to public consultation—in other words, the whole lot does not go out again, but only the changes?
Mr. Wright: Yes, that is my understanding: the proposed changes will be put out for the 12-week consultation.
The hon. Gentleman raised important points on flooding in his area. Again, I will not be drawn into talking about specific details, or about specific housing developments
and planning permissions on floodplains. I should, however, point out that the Government believe that effective flood defences are a vital component of new infrastructure, and that they will be an integral part of development. Also, it is for councils to take key decisions on individual developments, but we have put in place the toughest planning rules ever through planning policy statement 25. For the first time, all councils must now consult the Environment Agency on their housing plans, to ensure that all new homes are safe from flooding and properly sustainable for the future. Those new rules have been praised by Sir Michael Pitt and the Environment, Food and Rural Affairs Committee’s report on flooding, and they have been backed by the Association of British Insurers. I am pleased that we have put in place the toughest planning rules ever with regard to development on flood risk areas.
Martin Horwood: The Minister might be interested to know that not all the environmental organisations accept that the new planning guidance is sufficient, partly because it is only site-specific, so it does not take into account the overall landscape. If a site is entirely inundated with water, it does not really matter where the drainage goes. If the overall landscape has been allowed to develop in such a way that there is too much urbanisation, increasing run-off or increasing surface-water flooding, the local site-specific consultation will not be sufficient. Does the Minister not see the problem with that?
Mr. Wright: To some extent, the hon. Gentleman is making the argument for a regional spatial strategy. These matters sometimes transcend local boundaries, so it is important that we have a regional overview. Essentially, however, it is up to local authorities to carry out developments in a plan-led process, in order to make sure that the whole environment is considered when deciding where development should take place. I am sure that—not for the first time—I will have disappointed the hon. Member for Tewkesbury that I have been unable to enter into a debate on the content of the south west regional spatial strategy. However, I am sure he will continue to represent his constituents’ views energetically when the proposed changes are published shortly. He has done that tonight, and he did it in the debate in January.
Mr. Laurence Robertson: I am not satisfied with planning policy statement 25 as it is inadequate in that it compromises itself. My main point, however, is this: although I understand that the Minister is in a difficult position with regard to the process, all I am asking him to do is consider the serious points I have made about the difficulties the RSS will cause us in Tewkesbury. Will he have a serious discussion with the Secretary of State about the points I have made? That is all I expect of him tonight.
Mr. Wright: As I said, I will not do anything that will compromise the ability of the Secretary of State to be able to come to an impartial decision, based on the report that is put on their desk, with regard to the RSS. The hon. Gentleman has made his case on behalf of his constituents most eloquently tonight, as he has in previous debates, and I would expect nothing less from him.
Question put and agreed to.
Adjourned accordingly at twenty-four minutes past Nine o’clock.