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

Written evidence from the Royal Society for the Protection of Birds (RSPB) (ARSS 122)

The Royal Society for the Protection of Birds (RSPB) is the charity that takes action for wild birds and the environment. We are the largest wildlife conservation organisation in Europe with over one million members.


The natural environment does not respect the administrative boundaries of districts or counties. This is why strategic planning has an important role in delivering the Government's aspirations for biodiversity and sustainable renewable energy. How will the new planning structures enhance the delivery of the Government's objectives?

The RSPB's view is that:

The revocation of regional spatial strategies has removed strategic policies for the natural environment that overcame such administrative restrictions.

Voluntary arrangements may work well in some areas, but in others a more formal mechanism for strategic planning may be required.

The proposed duty to cooperate must extend further than adjacent local authorities, and must include a mechanism to resolve disputes.

Local Economic Partnerships must have an environmental voice.

Environmental data must be kept up-to-date and be accessible to local authorities and the public.


1.    The RSPB does not wish to comment in detail on the abolition of regional house building targets or the Government's plan to incentivise local communities to accept new housing development. When we commented on the former regional spatial strategies, we raised concerns about the implications of significant housing growth in environmentally-pressured regions, particularly the East and South East of England, and the impact on biodiversity and water resources. We accept the need to make adequate plans for future household growth around the country and the need to do so in a way that commands democratic support, but we are not convinced that the combination of local decision-making and financial incentives will achieve this, or be affordable.

2.    The decision to revoke regional spatial strategies (RSS)s appears to have been almost entirely driven by the contested nature of housing targets, particularly in the south and east of England. However, the revocation has swept away a raft of policies on other issues, such as the natural environment, that were largely not contentious and were the product of close cooperation between local authorities and other interested parties. It has also removed part of the statutory development plan for those authorities that have already adopted Development Plan Documents (DPD). This potentially undermines their effectiveness until these DPDs can be revised.

3.    Regional spatial strategies provided a spatial framework within which to address the restoration and creation of priority habitats and the recovery of species populations. Facilitating that process, the biodiversity fora in each region identified the best areas of opportunity. For example, the South West Nature Map, a habitat opportunity map prepared by Biodiversity South West, was incorporated into the draft regional spatial strategy. The map identifies landscape-scale blocks of land termed "strategic nature areas" where most of the major biodiversity concentrations are found and where targets to maintain, restore and re-create wildlife might best be met. Its inclusion in the RSS would have helped local authorities to meet the requirement to "identify areas or sites for the restoration or creation of new priority habitats..." in their local development frameworks, as set out in national planning policies (paragraph 5(ii), Planning Policy Statement 9).

4.    Strategic planning does not necessarily need to be located at a regional level, and the evidence and guidance assembled in regional spatial strategies on matters such as biodiversity can continue to be used following their revocation (although see our comments on data and research below). However, the loss of regional spatial strategies has removed an essential driver for local authority plans and decisions. For example, the previous government had intended to negotiate regional renewable energy targets. This raises the question of how local authorities will together make adequate contributions to national renewable energy targets.


5.    The natural environment does not respect the administrative boundaries of districts or counties. One should consider the role and functioning of species and habitats within whole landscapes or ecosystems. This is why strategic planning is essential for the delivery of the Government's aspirations for biodiversity and sustainable renewable energy (eg ensuring appropriate location of wind farms). Voluntary arrangements may work well in some areas, but in others a more formal mechanism for strategic planning may be required. In our experience conflicts over the shared protection of the natural environment have arisen between local authorities where their respective interests are not aligned.

6.    Areas statutorily designated for their biodiversity value illustrate this need. Many designated Special Protection Areas (SPAs), part of the Natura 2000 network, fall within multiple local authorities; 28 SPAs in England contain no fewer than five local authorities, and six SPAs contain at least ten. In these areas, special arrangements may be required to ensure that development can take place which respects the environment and the legal obligations of the Birds and Habitats Directives.

7.    For example, the Thames Basin Heaths Delivery Plan, part of the arrangements for delivering housing growth around the Thames Basin Heaths SPA, involves no fewer than eleven local authorities. Prior to the preparation of the Delivery Plan, the development of even small-scale housing was problematic because satisfactory mitigation measures could not be put in place. For the Delivery Plan to work all of the authorities must adopt a common approach to mitigation, otherwise house building around the SPA will not be possible, even where local authorities wish to see that development go ahead. The Plan was until recently given a statutory framework by policy NRM6 of the South East Plan. It is uncertain whether an effective mitigation solution could ultimately have been developed in the absence of the policy requirements of a formal tier of strategic planning.

8.    The proposed duty to co-operate may help to address this issue. However, it must be more than a mere duty to consult, and it must extend to all authorities which share protected environmental features. An analysis of SPAs in England shows that many, like the Thames Basin Heaths SPA, cover multiple local authorities. Many are in areas of development pressure where local authorities need to work together to ensure that development can take place whilst continuing to protect these important wildlife sites. Nevertheless, we have found that not all local authorities will willingly do so. The duty to co-operate must therefore also include a mechanism for resolving disputes between authorities. Upper tier authorities could have a role to play in this, but upper tier authorities may themselves be interested parties (the Thames Basin Heaths Delivery Plan, for example, involves two county councils and three unitary authorities).

9.    Strategic working arrangements will vary and must be tailored to the needs of the sector, for example, cooperation amongst local authorities in the same river basin districts. Certain sectors should be considered together because they are complementary, for instance, waste and minerals restoration may assist flood alleviation and contribute to biodiversity targets through habitat creation or restoration. The challenge will be to create appropriate groupings, based on an understanding of who needs to work with whom, and for what purpose. As discussed above, it is essential that local authorities work together on joint issues, to deliver shared solutions which are more cost effective and can provide more benefits for residents and the natural environment.


10.  Our engagement with regional development agencies showed us that they did not have sufficient in-house capacity, experience or expertise to deliver economic development within environmental limits. With their narrower remit and lack of funds, we consider that it is unlikely that Local Economic Partnerships (LEPs) will be able to bridge this gap in capacity and skills either. This takes place at a time when the need to halt the loss of biodiversity and degradation of ecosystem services, and ensure their adaptation and resilience to climate change, is most urgent.

11.  Previously regional sustainable development champions (e.g. sustainable development roundtables) and social, economic and environmental partnerships (SEEPs) have provided valuable advice and helped to shape regional policies. These were often hosted by the regional assemblies. That they have continued to exist in various forms after the assemblies' demise is a testament to the strengths of the partnerships that have been created. For example, in the East of England, "Sustainability East"[148], an independent sustainable development champion body, is running a joint event with Business in the Community to ask "how can we deliver the Big Society sustainably?" This forthcoming event is oversubscribed—illustrating the vacuum left by the abolition of the regional tier. The decentralisation minister recently said that he welcomed the involvement of voluntary organisations. The RSPB calls for emerging LEP proposals to build on their strengths and include environmental partners.

12.  The RSPB believes that it is essential that environmental, as well as social and economic, representatives continue to have an effective voice in decision-making and help ensure genuine improvements in environmental and social wellbeing. However, we do not have all the answers. We ask the Select Committee how they consider the environmental voice should be included in local decision-making in the absence of the RSS.


13.  Significant gaps remain in the data available on environmental resources across England, for example, on the location of key species, and the condition of local wildlife sites and Biodiversity Action Plan habitats. A robust evidence base must assess the state of the environment as well as that of the local economy. Therefore, finding a new home for regional environmental, economic and social data is a key priority. Much of this data is currently held by a variety of organisations in a number of different formats and is often difficult to access. While evidence will need to be "owned" and kept up to date by appropriate groups, information previously gathered from the regions should be kept in one place, and be accessible to local authorities and the public.

September 2010

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