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

Written evidence from Steve Tremlett (ARSS 06)

This submission is an edited extract from my recent MA Urban & Regional Planning dissertation titled "The Institutional Structures of Waste Planning." Part of the dissertation considered the effectiveness of regional planning under the Labour Government and the impact of the Coalition's abolition of Regional Planning Bodies and RPBs on the planning for waste management facilities. Key findings were as follows:

There is a need for a strategic level to effectively plan for waste management. Abolition of RSSs has created a large policy vacuum.

The elevation of RSSs as part of the development plan had a positive effect in increasing the speed of delivery of waste facilities

The focus on localism and local decision making may be problematic when applied to such an inherently controversial form of development as waste management. Political pressures are likely to restrict the delivery of new waste infrastructure.

Abolition of RSSs has removed the strategic targets and level of policy which could be used locally and by industry to demonstrate the need for new facilities

Waste streams have become increasingly specialised in order to maximise the recycling and recovery of materials, and an increasing number of facilities are consequently only required at a regional level. Planning for these facilities is most effectively carried out at regional level.

European countries which achieve high diversion from landfill have a strong emphasis on an influential regional tier that provides clear and unambiguous forward capacity planning.


All those questioned for the research agreed there is a need for a strategic level to effectively plan for waste management. It generates administrative economies of scale, and allows for a better understanding of the wider picture of waste management amongst the counties, rather than just what is occurring within their borders (interview with former CLG officer). It also provides a context for each Waste Planning Authority (WPA) to work in, and a better understanding of the interrelationships between WPAs' areas, and indeed adjacent regions (interview with regional planner).

The elevation of RSSs as part of the development plan had a positive effect in increasing the speed of delivery of waste facilities (Bell, in "Waste Planning", August 2010). The RSS also enabled local members to see the broader picture and the need for certain policies even where these policies may have been unpalatable locally. Without the regional tier, unpopular but necessary policies may become harder for local authorities to accept (interview with regional planner). This is a key comment given that one of the reasons given for the removal of the RSSs is that they contain unpopular policies.

Waste streams have become increasingly specialised in order to maximise the recycling and recovery of materials, and an increasing number of facilities are consequently only required at a regional level, for example waste paper and glass reprocessing (interview with Strategic Waste Policy officer). Indeed, even some types of facility that previously attracted a sufficiently large quantity of waste to enable their provision at a County level, for example landfill, are now moving towards regional or sub-regional facilities. This is because the declining amounts of waste being sent to landfill combined with the economies of scale required to make a site viable mean that they will serve larger and larger areas, in effect becoming regionally significant facilities (interview with County Council Waste Planning Policy Manager). The waste management company Biffa (2010) state that their business model is already based on the regional scale for reprocessing and recovery facilities, and believe that will be the case for landfill provision in the future, especially given the increasing impact of policy drivers such as landfill tax. If facilities are serving a regional area, it makes sense to plan for them at the same spatial scale.

SLR Consulting (2005) examined the institutional architecture in nine other European countries which currently vary significantly in how sustainably they manage their waste. They concluded that countries with success in achieving more sustainable waste management regimes generally have a clear, consistent policy statements from central government that provide certainty through the planning system. Partnership working between national, regional and local government is promoted with a strong emphasis on an influential regional tier that provides clear and unambiguous forward capacity planning. This is contrasted in the report with the situation in the UK which is characterised by a lack of direction and leadership from central Government, with a reliance on market based policy tools such as LATS.

Regional planning of future capacity needs can also facilitate cooperation at the lower tier towards sharing the burden of new infrastructure, and the study recommended giving a clear mandate for Regional Planning Authorities in the UK, noting that a further benefit of this is to distance local politicians from unpopular decisions (SLR Consulting, 2005:64).

The Coalition Government is criticised for the speed of removal of the regional tier, with Chalmers (contribution to forum at www.pas.gov.uk, 8.6.10) arguing that "removing it asap without recognising how it forms a critical part of the whole planning process is at best naïve", and suggesting that the new Government may be too focussed on housing numbers. It was also suggested that the previous structure of waste planning "has been hampered by the broader political hostility to regional planning in many areas, perhaps driven principally by dislike of the regional housing allocations" (interview with former CLG officer).

The abolition of RSSs before any alternative systems have been implemented is also criticised, with an anonymous forum contributor stating that "the real problem here is… the complete lack of any strategic level alternative." (contribution to forum at www.pas.gov.uk, 8.6.10). The "Open Source Planning" Green Paper (Conservative Party, 2009) which does not make any reference to waste planning which increases suspicion that it has been broadly overlooked.


There was a broad consensus that RTABs have played a beneficial role in facilitating effective waste planning, however a number of issues were identified which restricted their effectiveness.

It has been difficult to create a truly technocratic group with a politically neutral environment has failed as political influences have come to the fore when controversial issues have been discussed. It was argued that any collection of local authorities will inevitably be political to some extent.

The original concept of collaborative governance has not been successfully achieved with little interest from industry for ongoing engagement and consequently local authority officers dominating groupings. For example, the effectiveness of the South East RTAB (SERTAB) has been restricted by the dominance of local authority planning officers in the group. The government's intention in creating RTABs was for a broad range of stakeholders to be represented, however in the South East representatives from the waste industry have tended only to get involved when it suits them. It was questioned whether industry is able to lead a planning process rather than respond to it, hence the limited involvement (interview with County Council Planning Policy Manager).

The process of agreeing on a way forward for difficult strategic decisions was problematic as officers are at times wary of offering views that "may not be well received back at the ranch". The principal of what is trying to be achieved is understood but difficulties can arise when detailed discussions occur. The example was given of the apportionment of residual waste from London for landfilling in surrounding counties. In this instance there was agreement that apportioning waste in this manner is appropriate, however the consensus unravelled once discussions reached the stage of allocating figures for individual WPAs' apportionments (interview with County Council Planning Policy Manager). However an alternative view from the West Midlands RTAB was that members' engagement has been motivated by self-interest on occasions, "but the ethos of the group has prevailed and they have quickly taken the broader view or moved on quickly and been replaced", suggesting different experiences in the different RTABs across the country.

Despite these issues RTABs have performed a valuable role in developing effective waste planning policy, as they have proved to be an effective forum for the technical work, especially data collection and analysis, which is essential to planning effectively. A Regional Planner argued that "what it did do was enable evidence to be collated and policy discussed and developed collectively, without one authority dominating or influencing due to certain political views, for example being anti-incineration. The democratic accountability came through the Assembly as all policy decisions were made by members through Regional Planning Committee, Executive Committee and full Assembly".

At this stage it remains unclear exactly what future holds for RTABs. One local authority SERTAB member believed that as much the groups work had been led by the South East England Partnership Board, the fact that that organisation has been abolished means there is now a need for the RTAB to take stock and consider its future role. It was felt that there remains a useful role to play, however to continue there must be a reassessment of the scope and purpose of the group.

A West Midlands RTAB member was also of the opinion that RTABs have been a success and should continue. In terms of their future role, the view was not whether they are able to work with the new Government, as RTABs have thus far worked effectively in all regions regardless of political composition, but will they be allowed and continue and work with them. The inference here is that a decision to abolish RTABs would be political and not a reflection of the effectiveness of the groups.

It was argued that the continuation of RTABs will be essential under the new administration if agreed data and analysis to be available to WPAs, as good quality data is an essential requirement of assessing the need for, and therefore adequately planning for, waste management facilities (interview with former CLG officer). The West Midlands RTAB member felt that there had been some success so far in the aim of producing good quality data, as bringing together a wide range of stakeholders "has been effective in brokering sensible estimates of demand unlike the RAWP[9] which has been industry dominated and had a reputation for always overestimating need".


There is agreement that there will be a need for discussions on waste planning to continue at a strategic level at a scale between the counties and national government. The revocation of the RSSs has created "a massive vacuum in [waste planning] policy" (interview with Strategic Waste Policy officer), with the limited interim guidance issued by the Government being described as "hopelessly vague… no-one knows what the national planning policy is now". (Webb, 2010)

Without a regional tier of policy making, planning for regionally significant facilities will be difficult, as although decisions could be made locally at officer level, the local democratic process can override recommendations for political reasons. Given the inherent unpopularity of waste facilities, this situation is likely to lead to inadequate planning for the required capacity (interview with County Council Planning Policy Manager).

There is evidence that the motivation for the rapid removal of RSSs is to alleviate the burden of the housing targets they contained, as discussed above, and has involved little consideration of the effect of this action on other aspects of strategic planning. The focus on localism and local decision making may be problematic when applied to such an inherently controversial form of development as waste management which has an increasing requirement for regionally significant facilities.

In addition the abolition of RSSs will remove the strategic targets and level of policy which could be used locally and by industry to demonstrate the need for new facilities, particularly those serving a catchment regional or sub-regional catchment area (interview with Regional Planner). Without regional policy, planning applications for regionally significant facilities will be easier for authorities to reject (interview with County Council Head of Planning), jeopardising the delivery of new waste management capacity which is needed to achieve Landfill Directive targets.

RTABs could see their role enhanced as the abolition of RPBs would leave them as the only remaining regional level institution (interview with County Council Head of Planning). However, RTABs are solely a technical body with no policy making responsibilities, and as discussed above, will be reliant on decisions being implemented through local policies. However, the indication from CLG that the role of RTABs will, in due course, be transferred to local authorities casts doubt on whether this is possible without some form of structural reorganisation. As one of the reasons for the establishment of RTABs in the first place was that individual authorities were unlikely to have the resources to carry out the required data collection and analysis individually they are likely to have to form voluntary groupings along the lines of the RTABs in order to continue this essential work. This could be argued as a reversion to the situation in the mid-1990s until establishment of statutory RSSs in the 2004 Act, where regional groupings of officers, through RTABs, "offered a view on agreed common assessments of waste arisings, future need and capacity arrangements to their constituent WPAs, together with a view on the spatial pattern required to deliver it" (interview with former CLG officer).

Whilst there are clear benefits in groupings such as this, the lack of regional policy to support the technical work performed by RTABs or their replacements will be a hindrance. There are already tensions in reaching consensus on controversial strategic issues, and without statutory regional policy to deliver these objectives local authorities may not have the discipline to carry them out. In other words, without support from policies that form part of the statutory development plan the difficult decisions recommended at officer level may fail to be implemented when considered by elected representatives. In addition, "voluntary collaboration can be hard to achieve and can disintegrate following a change of political leadership" (TCPA, 2010:7), which casts doubt on the stability of any new sub-regional groupings.

A collective refusal by authorities to deal suitably with site allocations would expose the UK to EU penalties under the Waste Framework Directive. There is therefore a requirement for an effective conflict resolution system as any new grouping would be relying on a number of WPAs to implement their recommendations without clear policy support. Clear government guidance to ensure that WPAs engage with each other effectively in order to deliver the strategic facilities that are necessary would be desirable.

The lack of a single regional point of contact may also be a problem as there will be no regional voice to respond or input to policy in other areas. In addition industry may find it harder to effectively engage with the planning process on a strategic level as operators would have to communicate directly with each WPA instead of having a single regional body to liaise with (interview with Regional Planner).


The Coalition Government needs to acts swiftly to provide a strategic level replacement for RPBs at a level above counties. It is clear that adequately planning for waste management increasingly requires coordination at this level. The removal of RPBs and revocation of RSSs with no clear indication of what will replace them is damaging to the aim of moving towards sustainable waste management.

The policy vacuum has caused uncertainty and the removal of strategic level waste polices from the statutory development plan will result in more decisions being subject to political forces at county level. Several possible scenarios for a strategic replacement appear possible based on the research carried out for this report. Table two identifies these together with potential risks and opportunities:

Table 3

ScenarioOpportunities Risks
Voluntary groupings of WPAs at a sub-regional level to continue technical work performed by RTABs. More spatially coherent groupings which better reflect the nature of waste movements and interdependencies between areas, allowing more effective spatial planning. Essential data collection work would continue. Reliance on individual WPAs to devise policies at the local level to implement group decisions may be problematic. Lack of regional policy to support need for new facilities.
Groups of WPAs produce statutory development plans and policies covering sub-regional areas More spatially coherent groupings which better reflect the nature of waste movements and interdependencies between areas Regional technical work is backed up by policy to deliver the required capacity and distribution of new facilities Vulnerable to changes in political administration in constituent authorities. Difficulties in agreeing distribution of facilities amongst WPAs. Difficulties in coordinating work between a number of groups of officers. Need for effective conflict resolution.
RTABs continue in their present form to provide strategic technical support to WPAs Existing established working relationships at regional level between officers can continue. WPAs benefit from strategic level data to help preparation of DPDs Lack of regional policy support for RTABs recommendations may hinder their implementation

In the absence of a formal regional planning tier the Coalition Government must quickly engage with WPAs to develop an effective strategic coordinating system for waste planning, together with clear instructions to local authorities on the need for cooperation on difficult issues.


SLR Consulting (2005), "Delivering Key Waste Management Infrastructure: Lessons Learned from Europe", CIWM;

Webb, S (2010) cited in Planning Daily, 16.7.10 www.planningresource.co.uk/bulletins/Planning-Resource-Daily-Bulletin/News/1016027/Regions-defence-steps/?DCMP=EMC-DailyBulletin

August 2010

9   Regional Aggregate Working Party, the equivalent grouping in minerals planning. Back

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