In July 2022, CIOB’s policy and public affairs team submitted written evidence to the Levelling Up, Housing & Communities Committee call for evidence on the draft Levelling Up and Regeneration Bill.
Back in February 2022, the Government published the Levelling-up White Paper, setting out a framework of action to reduce geographical disparities and raise socio-economic outcomes across the UK through investment in the built, social, and economic environment. The proposed programme of action primarily revolved around the setting of twelve ‘missions’, including empowering local decision makers; securing paths to homeownership; improving the connectivity of communities; and increasing the number of people completing high-quality skills training, amongst others. Collectively, these convey the Government’s ambition to ‘improve productivity, boost economic growth, encourage innovation, create good jobs, and enhance educational attainment’.
Following the Queen’s Speech in May 2022, the UK Government unveiled the ‘Levelling Up and Regeneration Bill’, and provided further details of how the Government would level up the nation in practice.
As the Bill embarked on its legislative journey, the policy and public affairs team published a blog, analysing the 'Rhetoric vs Reality' of the Conservative Party’s flagship policy.
After publishing the blog, the team began compiling evidence to submit to the Committee with the responsibility of scrutinising the Bill. Overall, our evidence sets out recommendations, of what CIOB believes the Bill should strive to achieve – from placing the quality of new homes as a primary objective of reforming the planning system; to introducing a Built Environment GCSE in England. Alongside this, we recommended that Government:
- Link in with existing legislation such as the Building Safety Act 2022 to create a cohesive suite of policy for the built environment.
- Review the existing land value calculations with a view of fostering a more inclusive planning system for SME housebuilders.
- Utilise the Government’s housing accelerator, Homes England, to provide SMEs with opportunities to develop small parcels of land as part of larger strategic developments to learn best practice and protect market involvement.
- Address the falling rate of SME housing development by implementing quotas for SME built sites as part of the local plan process.
- Provide greater clarity on the Infrastructure Levy prior to the release of secondary legislation.
- Consult with built environment stakeholders, to understand whether the Infrastructure Levy process would be best implemented as a phased payment or upfront payment system to provide local authorities with the funding for crucial local infrastructure early in the development process.
- Develop immediate strategies to recruit, retain, and progress workers within the construction industry to practically deliver levelling up.
To assist in digesting the information we have broken down our evidence into its key headings on the right hand side of this page.
CIOB response key areas
In our written evidence, we highlighted how the built environment has a significant role to play in achieving the twelve levelling up missions, from providing direct employment, investment, and revenue to local and national economies, to delivering housing, transport, and fundamental infrastructure. Overall, CIOB is supportive of the twelve missions, and the opportunities they present for the built, social, and economic environment. We believe that better buildings and infrastructure will contribute to improved productivity across the country, not just through their primary function or by increasing economic output, but also by making communities happier, safer, and healthier.
We are also broadly supportive of the need for Government to report back on the progress of each mission through a report issued to the House every twelve-months. However, we believe checks and balances are required to ensure a fair and impartial assessment of progress. We believe that the Government should therefore commission an independent body to scrutinise their progress against each levelling up mission. Alongside this, we would like to see a commitment from Government to publish in-depth reports on how each levelling up mission will be resourced to ensure transparency is maintained.
One of the key barriers to levelling up from a CIOB perspective has been the historical underlying issues that continue to limit construction’s potential, particularly in terms of the significant gulf between the labour and skills which currently exists. This concern is reinforced by the latest CITB Construction Skills Network report, which suggests that, if projected growth output is to be achieved, “over a quarter of a million extra construction workers may be needed by 2026”.
Ultimately, we believe that the levelling up agenda has the potential to address skills gaps in the construction industry. In our response we have recommended that the Government work with the industry to develop unique, sustainable, employment skills and opportunities that reflect local priorities; as well as ensure construction projects provide opportunities that create social value and support local economic growth.
To avoid levelling up becoming another policy that falls by the wayside Government must assess how the construction sector can strategically continue with its current resources, whist simultaneously planning for the future. We urge Government to develop immediate strategies to recruit, retain, and progress workers within the industry.
Throughout our written evidence, we actively advocate for small and medium-sized enterprises (SMEs) to play a significant role in meeting the UK’s housing demand, as part of the proposed planning reforms. In recent decades, we have witnessed SMEs be priced-out of the development market, primarily due to a lack of access to finance, and uncertainty over the outcome of planning applications. We have therefore proposed that the Government give due consideration in protecting SMEs to ensure competitiveness, as we believe that diversification of the housing delivery market is crucial to maintaining a consistent stream of new home completions.
These include through assessing the current system for calculating land value to ensure that costs for developments are evenly distributed throughout the whole planning and construction process, including quotas of housing allocations in local plans for local SMEs to ensure they can continue to play a role in the housing market and to utilise the Government’s housing accelerator in their role as master developer to allocate land parcels for SME developers as an opportunity to work alongside larger developers with greater resource pools to learn from best practice.
Alongside our proposals for SMEs to be actively included in the planning system, and housing delivery market, CIOB have called for greater community involvement in planning applications. Currently, community consultations predominantly operate as tick box exercise for developers to progress planning applications. As part of the proposed planning consultation reforms, we have therefore recommended that developers, as a minimum, inform the community of any development plans within an agreed geographical area with the relevant local authority. This should involve consistent communication throughout the planning process where local communities have an opportunity to view any draft development plans and provide comment.
A key part of the planning reforms included in the Bill are the proposed changes to the existing Section 106 (S106) and Community Infrastructure Levy (CIL) process. The new process, known as the Infrastructure Levy (IL), will require similar financial contributions from housing developers as part of the planning permission process.
Overall, CIOB supports the need for a financial contribution to fund associated infrastructure necessary to create stronger communities. However, we have some concerns relating to the trigger points in which a financial commitment is provided to local authorities, i.e., at completion of the last home. We have welcomed the suggestions of both Siobhan Baillie MP and the Royal Town Planning Institute (RTPI) who have suggested that the new system would be more effective if infrastructure requirements were required at the start or phased throughout the process of the development being built out or that local authorities be given the power to borrow against future development contributions respectively. Both of these alternatives would allow local authorities to plan further ahead for the provision of social housing and infrastructure.
CIOB has also encouraged the Government to explicitly align its levelling up agenda with wider-policy objectives, such as net zero. The Bill, in its current state, appears to be a missed opportunity to explicitly align the Government’s flagship policies on levelling up and net zero. It is precisely because of this; we have recommended that the Bill be used as a driver for addressing sustainable development and to align planning reforms with our legally binding climate targets.
We highlighted the need to empower local leaders to drive growth, shape their communities, develop business clusters and deliver socially valuable projects. Overall, CIOB believes that greater devolution will improve local and combined authorities’ ability to understand local needs and make decisions on future infrastructure, from housing to transport; renew efforts to encourage private investment; and continue to bear down on the drivers that halt progress and prevent innovation.
Conclusion
As a professional body, CIOB recognises that the construction industry has a significant role to play in achieving levelling up and is well-placed to advise on immediate and long-term strategies for future regeneration, improving the quality of housing and building the necessary knowledge and skills to match the levelling up ambition.
Construction officially accounts for approximately 6% of economic output of the UK and provides employment for 2.3 million people. It is recognised as a vital cog within the economy, but it is far more than just an economic driver. The built environment continues to influence and shape how we live, work, and play at community levels. Therefore, the Government must not underestimate the importance of listening to the industry on how best to deliver levelling up at a practical level.
Should you have any views on the Levelling up and Regeneration Bill, or would like further information, please contact [email protected]. CIOB’s policy & public affairs team will also be attending both Labour Party and Conservative Party Conference in September and October 2022 where we will be hosting events on the levelling up agenda alongside RIBA, RICS and RTPI.
Once our submission has been approved by the Committee, we will make it available on the following webpage.
