Abolition of Regional Spatial Strategies: a planning vacuum? - Communities and Local Government Committee Contents


Written evidence from Jim Parke (ARSS 05)

EXECUTIVE SUMMARY

This evidence is based on a wide range of strategic planning experience. Part of that experience was gained at a number of Examinations in Public (EIP) of Structure Plans and Regional Spatial Strategies. The issues relating to house-building targets were common to almost all of the EIPs. The evidence also draws on relevant strategic planning practice in Scotland and Europe. The following conclusions are reached:

(i)  Planning Authority Co-operation

  • The scale of the administrative regions did not reflect the nature of the housing markets within them.
  • The abolition of the regional spatial strategies need not jeopardise the effective consideration of housing matters provided cooperation is required across complete housing market areas.
  • If LEPs are to be given strategic planning powers, particularly for housing, their areas should encompass complete housing market area.

(ii)  Demand Methodology

  • It is important that whatever system is adopted to replace regional spatial strategies incorporates a requirement to facilitate an open debate on estimates of housing requirements.
  • Experience at EIPs suggests that a requirement should be imposed on the system replacing RSS to openly benchmark the housing market assessment against the most up-to-date ONS projections.

(iii)  Top-Down and Imposed Targets

  • It is important that the replacement system is required to establish an open decision making process.
  • Major stakeholders and the public should have an opportunity to challenge any assumptions and findings.
  • Any residual issues should be subject to a public independent inquiry.

(iv)  Incentives

  • The incentive approach should work within the findings of the replacement housing strategy system.

(v)  Other Matters

  • There is no reason why a Local Economic Partnership could not deal satisfactorily with the wide range of planning issues formerly covered by regional spatial strategies.

(vi)  Green Belt Protection

  • It is important that whatever approach replaces regional spatial strategies should not be predicated on the protection of the Green Belt.

(vii)  Data Handling

  • There is international recognition of the need for strategic planning mechanisms to gather the data, carry out research and prepare strategic plans for city regions.
  • In England sub-regional technical capacity should be established to take responsibility for inheriting and updating the data and research collated by the now abolished Regional local Authority Leaders' Boards.
  • In the London area consideration should be given to a body covering the wider London region.

BRIEF INTRODUCTION

0.1  This evidence is based on a range of strategic planning experience including work with Strathclyde Regional Council at a directorate level from its inception in 1974 until its demise in 1996. This work involved a wide range of planning issues from the urban renewal of the Greater Glasgow conurbation to the challenges facing the rural areas of Ayrshire and Argyll. It included the preparation and regular review of the Strathclyde Structure Plan.

0.2  Since the demise of the Regional Council in 1996, experience has been gained of European and international strategic planning with Metrex, a Network of European Metropolitan Planning Authorities.

0.3  Knowledge of the RSS system has been gained as a member of the panel of EIP Panel Chairs. In that capacity the experience included chairing the Warwickshire Structure Plan EIP in April 1999, the East Midlands RPG Public Examination in June 2000, the Kingston upon Hull and East Riding Joint Structure Plan EIP in January 2004, the Wiltshire and Swindon Structure Plan Alterations EIP in July 2004, the North East Regional Spatial Strategy Examination in Public in March-April 2006, the South West Regional Spatial Strategy Examination in Public in April-July 2007 and most recently the East of England Regional Spatial Strategy Lakeside Basin Single Issue Review Examination in Public in August 2009.

COMMENTARY

Planning Authority Co-operation

1.1  The scale of the administrative regions in England rendered co-operation across the constituent authorities unlikely, as there were few issues that required such co-operation. The issues that did link them could also be considered as national issues eg major transport linkages, ports and airports.

1.2  In the North East most of the planning issues focussed on the two city regions of Tyne and Wear and Teeside. By the time of the EIP in 2006 the Teeside local authorities had established joint working arrangements to deal with planning issues such as housing provision. The evidence submitted supported the view that the Teeside area could be regarded as a strategic housing market area as it contained both the origins and the destinations of the great majority of households which move home. It was therefore an appropriate area across which co-operation on strategic housing distribution could take place. In contrast there was no such co-operation to draw together housing issues around the Tyne and Wear conurbation. The urban authorities at the core of the conurbation were concerned about the scale of housing land being made available in the adjoining commuter areas of the counties of Durham and Northumberland. The absence of a co-operative mechanism allowed the emergence of unsustainable patterns of development, which became the focus of debate at the Examination in Public.

1.3  Many of the other administrative regions contain distinct sub-regions, which are relatively self-contained. Yorkshire and the Humber covers the four sub-regions of N. Yorkshire, Hull and the East Riding, South Yorkshire and West Yorkshire, within which housing matters are largely self-contained. In the North West region there is some interaction between the conurbation housing markets, but they are largely self-contained. The local authorities in Cumbria have indicated that it should be regarded as a separate housing market area. In some cases policies and proposals in draft RSSs were introduced which contradicted the principle that a strategic housing market area should be treated as a self-contained entity. The draft RSS for the North West allowed the land supply in one sub-region to be restricted because of the availability of land in another sub-region in the South West the demand in the more rural housing sub-regions was reallocated to more urban areas.

1.4  The South West Regional Assembly, during the preparation of the draft Regional Spatial Strategy 2005, gave consideration to the question of housing market areas, as prompted by PPS3. It was the only regional authority to implement this approach and it elected to identify housing market areas in terms of complete local authority areas. The Assembly concluded that the South West region is made up of 13 housing market areas (HMA) very few participants at the EIP disputed the usefulness of the areas in the consideration of the strategic housing issues. As the HMAs could be regarded as largely self-contained in terms of commuting and local migration patterns, they provided the Panel the means of dealing with the trend based limitations of the DCLG projections at district level. They also offered a useful means of considering how past trends can be modified to reflect sustainability principles.

1.5  In some of the main urban areas of the South West administrative region the local government boundaries made planning particularly difficult. In the Cheltenham area the areas of Tewkesbury Council and Cotswold Council resisted development areas around Cheltenham. At Swindon the most natural development opportunity fell within North Wiltshire District, which resisted development. Some of the more appropriate development areas around the Bournemouth/Poole conurbation lay within surrounding local authority areas. The housing market area approach allows such anomalies to be tackled if the local authorities are required to cooperate.

1.6  At the time of the EIP in 2007 the local authorities within some of the identified housing market areas were already co-operating in the preparation of strategic housing market assessments. The local authorities around Bristol, the West of England Partnership, were already involved in such work although all of the HMA authorities were not participating. In Dorset the County Council and the constituent authorities had also commenced work on assessments for the two HMAs within the county. The initial focus for these assessments was on the need for affordable housing. None of the assessments had progressed to the stage where a full assessment of the total housing requirement and the distributional implications had been assessed. It is this stage, which puts the greatest strain on joint working.

1.7  In dealing with the use of housing market areas the Panel Report[1] drew attention to the potential of adopting a tiered approach to housing market areas as suggested by the Housing Market Assessment Manual. The Manual suggested that some authorities might want to undertake an assessment at sub-regional level and then undertake further analysis at a level greater than a single authority.

1.8  The Panel considered that this more sophisticated approach would be particularly relevant to the more complex city regions such as Bristol, Exeter, Plymouth and Bournemouth/Poole. It was considered that the approach would provide a better appreciation of the balance between local and strategic demand.

1.9  The attention of the Committee is drawn to a working example of co-operation on strategic housing matters by 8 local authorities around Glasgow in Scotland. The Scottish Government has decided to require the local authorities around the major cities of Glasgow, Edinburgh, Dundee and Aberdeen to co-operate in the establishment of a strategic planning capacity to deal with a wide range of planning issues, particularly the provision of an adequate supply of land for housing[2]. In the case of Glasgow the co-operating authorities have adopted a tiered approach to the consideration of housing issues across the conurbation. This type of assessment has allowed the authorities to ensure an adequate supply to meet local housing demand and to take a sustainable approach to the location of allocations to meet the wider market demand. From time to time this approach has provided a sound justification for the release of land from the Green Belt despite a substantial supply of brownfield land.

1.10  The Government has proposed the establishment of Local Enterprise Partnerships (LEP) between local authorities and business to take over the role of the Regional Development Agencies. These Partnerships are to cover functional economic areas instead of the wider administrative regions and it has been suggested that they could be given strategic planning powers as well. As functional economic areas could be expected fit well with strategic housing market areas, the Partnerships could provide a reasonable mechanism for co-operation on the housing matters previously dealt with by Regional Assemblies. However the effectiveness of the LEPs in housing matters will depend on the extent to which the LEP areas reflect strategic housing market areas. The West of England Partnership, which is reported to be applying for approval as a LEP, does not include all of the local authorities in the identified housing market area. Furthermore the Association of Greater Manchester Authorities, which is also reported to be applying for LEP status, does not include the important suburban parts of the strategic housing market area. In a similar way the LEP for West Yorkshire would have to include those parts of N Yorkshire, which act as part of the West Yorkshire housing market area. Without the inclusion of such areas, strategic planning for housing will be impaired.

1.11  CONCLUSIONS

The scale of the administrative regions did not reflect the nature of the housing markets within them.

The abolition of the regional spatial strategies need not jeopardise the effective consideration of housing matters provided cooperation is required across complete housing market areas.

If LEPs are to be given strategic planning powers, particularly for housing, their areas should encompass complete housing market area.

Demand Methodology

2.1  Whether it is at the regional level or the strategic housing market level, there is a general acceptance that the assessment of future housing requirements should be based on assumptions about natural increase, migration flows and household formation rates. This approach is required to provide a sound evidence base for planning policies and proposals. It was the approach adopted by county structure plans and then by regional spatial strategies. The benchmark for this type of assessment is the Office of National Statistics (ONS) trend—based projections of population and households for each local authority area. These projections incorporate assumptions on migration trends within the UK and from international sources. They provided a foundation for most of the RSS assessments, despite the fact that they applied relatively short-term trends to generate long-term projections. Evidence for the South West EIP indicated that officers had advised the South West Regional Assembly that the ONS assumptions could not be challenged technically.

2.2  In 2006 the Government established the National Housing and Planning Advisory Unit (NHPAU) in order to provide the planning process with a better appreciation of the scale of housing requirements. The NHPAU produced a new series of projections of future housing requirements, which took the ONS projections a stage further by including allowances for matters such as the backlog of unmet need. As a result the NHPAU requirements implied a higher level of housing provision than the levels suggested by the ONS projections.

2.3  The ONS projections and the NHPAU requirements indicated a need for significantly higher levels of housing provision in the English regions than that proposed in the draft RSSs, particularly in southern England. Many local authorities in the southern regions rejected such findings and adopted a "policy-based" approach, which provided a significant input to the preparation of the respective regional spatial strategies. These "policy-based" assessments of housing requirements were derived from the housing capacity deemed consistent with the existing local plan policies. Several commentators have since pointed out that the same authorities subsequently identified further capacity.

2.4  CONCLUSIONS

It is important that whatever system is adopted to replace regional spatial strategies incorporates a requirement to facilitate an open debate on estimates of housing requirements.

Experience at EIPs suggests that a requirement should be imposed on the system replacing RSS to openly benchmark the housing market assessment against the most up-to-date ONS projections.

Top-Down and Imposed Targets?

3.1  On the assumption that the replacement system for the housing assessment in a RSS is wider than a local plan, it is likely that each cooperating local authority will be given a "target" as part of the wider distribution. In the case of the Glasgow housing market, the cooperating authorities have established a decision making structure in order to decide on matters such as the distribution of housing development.

3.2  In many ways the Glasgow approach is similar to that adopted for the housing component of County Structure Plans and the Regional Spatial Strategies. A draft assessment is made of the housing requirement and distribution, which is put out to consultation. This consultation allows a wide range of stakeholders, including the house-building industry, to challenge any of the assumptions and findings. In England the EIP process allowed major issues to be debated in a structured manner. The housing issues inevitably featured in the EIP debates. The EIP panels were obliged to set out an argued case for any change. It is difficult to describe this process as anything other than open to change.

3.3  The Government response to Panel Reports was to go beyond the recommendations and it generated massive reaction. In the face of legal action the Proposed Changes were never approved. It would have been better to have accepted the Panel Reports and required an early review to take into consideration evidence of higher levels of housing need. It was only at this stage that the process could have been described as top-down and imposed. In many ways Government anxiety over the level of house building led it into actions, which debased the RSS system.

3.4  CONCLUSIONS

  • It is important that the replacement system is required to establish an open decision making process.
  • Major stakeholders and the public should have an opportunity to challenge any assumptions and findings.
  • Any residual issues should be subject to a public independent inquiry.

Incentives

4.1  While one of the functions of strategic planning is to ensure an adequate long-term supply of housing, there is also an obligation to ensure that the distribution of housing reflects the principles of sustainable development. It is also important that the distribution of housing reflects the climate change imperative to reduce the level of CO2 emissions by reducing the length of travel and encouraging the use of public transport. A distribution based on the suggested incentive scheme is unlikely to achieve these wider objectives. Experience at EIPs demonstrates that some of the rural authorities on the edge of the housing market areas would be prepared to promote development in unsustainable locations, which could only generate longer distance commuting by car.

4.2  An incentive scheme, which merely encouraged all authorities to maximise the level of development, could therefore be regarded as potentially conflicting with wider national policy. It is important that the incentive scheme should work within the replacement system.

4.3  CONCLUSION

The incentive approach should work within the findings of the replacement housing strategy system.

Other Matters

5.1  The regional spatial strategies covered a wide range of matters, but not all of them required regional scale policies. In many cases the framework of a functional economic area/housing market area would provide the necessary geographical framework. Should the LEP framework be implemented the new organisations could be charged with dealing with a wide range of the matters previously dealt with through regional spatial strategies. The following points set out an appreciation of the requirements for a range of matters:

Employment issues tend to nest within travel to work areas, which largely coincide with functional economic areas and housing market areas. The Bristol issues were largely separate from the adjoining Swindon, Gloucester/Cheltenham and Taunton HMAs.

Retailing issues in the South West also coincided with the housing market areas. Although the catchment areas of centres such as Bristol and Plymouth extended beyond their housing market areas, most of the retail planning issues were contained within the housing market area eg should the Cribbs Causeway centre be expanded to reflect the proposed suburban growth.

The Waste Planning Authorities in the South West were the county councils and the Unitary Authorities around Bristol. Although the work of these authorities was co-ordinated by a regional committee most of the issues related to the main urban areas. There seems to be no reason why a LEP type body covering a functional economic area/housing market area should not be able to provide a strategic framework for this matter.

The Minerals Planning Authorities were also the counties and the unitaries, but the policy framework for minerals required a wider geographical context than a functional economic area/housing market area. The future planning for this matter might well require a wider cooperative framework.

Flooding is mainly a river basin issue. In many cases river basins fell within the regional boundaries, but there were notable examples, such as the Severn where a number of regions were involved. There is no reason however why a LEP should not deal with many of the flooding issues in its area if it were charged with the responsibility for strategic planning. Such a responsibility would require it to take flooding risk into account in identifying areas for development.

Renewable energy issues range from the location of wind farms to the insulation standards for housing. While some wind farm issues might require cooperation across LEP boundaries, the majority of issues could be dealt with within a functional economic area.

Natural Environment issues are largely dependent on the geographical distribution of the feature involved. Many of the RSS policies on the natural environment were derived form national policy designations such as National Parks and Areas of Outstanding Natural Beauty. There is no reason why a LEP body should not deal satisfactorily with such issues with a normal requirement for cooperation across boundaries when natural features require it.

5.2  The attention of the Committee is drawn once again to the cooperation of local authorities in the Glasgow area. The body is known as the Glasgow and the Clyde Valley Strategic Development Planning Authority.[3] The geographical area concerned could be described as a functional economic area and it is also regarded as a strategic housing area. In the terms of the proposals put forward by the Government this area would fulfil the suggested requirements for a LEP area. The Strategic Development Planning Authority provides a working demonstration that a wide range of planning matters can be dealt with effectively at the sub-regional level.

5.3.  CONCLUSION

There is no reason why a Local Economic Partnership could not deal satisfactorily with the wide range of planning issues formerly covered by regional spatial strategies.

Green Belt Protection

6.1  Part of the political justification for the abolition of regional spatial strategies was the removal of requirements to release land from the Green Belt. Even in areas such as the North East around the Tyne and Wear conurbation it was not possible to rule out the need for additional greenfield land despite the availability of a significant supply of brownfield land. In the case of the Housing market around Bristol, the Panel was convinced that, even after taking an optimistic assessment of urban capacity, there was a strategic requirement for Greenfield release. Given national policies on sustainability and climate change the Panel concluded that the releases should be located so as to minimise longer distance commuting. As a result the Panel supported the RSS proposals for releases at the edge of the built-up area on the inner urban edge of the Green Belt.

6.2  While the Green Belt debate has been clouded by the controversial Proposed Changes brought forward by the Government, the Committee should note that a number of independent EIP Panels supported releases from the Green Belt in order to ensure an adequate supply of housing.

6.3  CONCLUSION

It is important that whatever approach replaces regional spatial strategies should not be predicated on the protection of the Green Belt.

Data Handling

7.1  The Glasgow and the Clyde Valley Structure Plan Team inherited the background work for the Strathclyde Region Structure Plan and have maintained and developed it.

7.2  On this basis the bodies established to take responsibility for the preparation of strategic guidance on behalf of local authorities in England should be required to provide the technical capacity to allow the effective inheriting and updating of the data and research collated by the now abolished Regional Local Authority Leaders' Boards. In addition to Scottish practice the Committee should also consider the establishment of city region authorities in Germany. The Federal Government has encouraged the establishment of city region organisations to deal among other things with strategic planning.[4] The nature of the organisations varies from formal city region authorities, such as the Verband Region Stuttgart,[5] to looser cooperative arrangements.

7.3  This type of sub-regional cooperation could apply to many parts of England, but the nature of the South East region suggests that a wider cooperative structure might be necessary to accommodate the particular arrangements in the London area. Until recently the GLA and the two adjoining regions cooperated through the Inter-regional Forum, which was an advisory mechanism to consider common issues. In a previous era the SERPLAN mechanism was adopted to reflect the wider interactions around London. It covered parts of the East of England administrative region. The Paris region is the best equivalent in Europe and strategic planning for that complete region is the responsibility of the Ile de France Region.[6]

7.4  CONCLUSIONS

There is international recognition of the need for strategic planning mechanisms to gather the data, carry out research and prepare strategic plans for city regions.

In England sub-regional technical capacity should be established to take responsibility for inheriting and updating the data and research collated by the now abolished Regional local Authority Leaders' Boards.

In the London area consideration should be given to a body covering the wider London region.

August 2010



1   http://www.southwesteip.co.uk/home/ Back

2   http://www.scotland.gov.uk/Resource/Doc/212607/0084258.pdf

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3   www.gdpa.gov.uk/

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4   http://www.bmvbs.de/Anlage/original_1034851/Concepts-and-Strategies-of-Spatial-Development-in-Germany.pdf Back

5   http://www.region-stuttgart.org/vrs/main.jsp?navid=65 Back

6   http://www.iau-idf.fr/?home Back


 
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Prepared 31 March 2011