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
Back
3
www.gdpa.gov.uk/
Back
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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