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

Written evidence from Savills Planning and Regeneration (ARSS 131)


Our evidence is concerned exclusively with the planning regime for renewable energy developments but is informed by our wider experience of the planning system in England.

The former RSS was valuable as a mechanism for translating and applying national renewable energy targets at local level; and for identifying those areas of greatest potential/least constraint for renewables development at a sub-regional level, regardless of local administrative boundaries.

New arrangements are necessary to ensure that these functions continue to be fulfilled in the forward planning process and to assist decision—making at the development management stage.

A regional tier is not required to achieve this. Instead, the new national planning framework should emphasise the weight in favour of renewables projects; and require LPAs to plan positively for renewables on the basis of spatially realistic research into the potential for, and constraints to, renewables in their areas.

Co-operation between LPAs should be encouraged where it is necessary in order to achieve spatially realistic evidence.

LEPs may have a useful part to play in supporting collaborative research by LPAs.

To avoid the need for LPAs to "unpick" progress already made on new-style plan coverage in their areas, the Government should be open to revisions to LDS to allow for collaboratively produced topic-based SPDs and/or AAPs for renewables to be prepared across LPA boundaries.

The Government should consider giving statutory weight to the new national planning framework.


1.  Whilst the main focus of the inquiry is on the implications of the abolition of Regional Spatial Strategies (RSS) for house building, the call for evidence identifies a number of other topics of interest to the Committee. These include:

Arrangements which should be put in place to ensure appropriate co-operation between Local Planning Authorities (LPAs) on other matters formerly covered by RSS.

The suggestion that Local Enterprise Partnerships (LEPs) may fulfil a planning function.

Arrangements to ensure effective updating and collection of research on matters crossing LPA boundaries.

2.  Our evidence is concerned with these issues as far as they relate to planning for renewable energy projects that fall below the 50 MW "major infrastructure" threshold.


3.  The Savills Planning and Regeneration team is one of the largest of its kind in the United Kingdom. We are actively involved in advising both private and public sector clients on planning, development and regeneration throughout the country, including dealing with many challenging and controversial proposals.

4.  We have particular expertise in the renewable energy sector, once again acting for both private and public sector clients in relation to most renewable technologies, but in particular, wind energy.

5.  Our evidence is informed by our experience of the planning system in England at large but is especially concerned with its role in supporting the delivery of renewable energy and the associated electricity distribution infrastructure.


6.  In relation to renewable energy development the principal function of the former RSS was to establish a framework for translating national renewable energy targets to the local level.

7.  A subsidiary, but important, function was also (in certain cases) to identity those broad locations with the greatest potential (or least constraint) for renewable energy developments, regardless of local administrative boundaries.

8.  In other respects, whilst RSS would often contain broad spatial and development management criteria for renewable projects these policies would, in general, simply duplicate the principles embodied in national planning policy and lack the detail necessary to be applied effectively as tools in development management at a site specific level. That said, during the transition to the new local planning arrangements introduced by the Planning and Compulsory Purchase Act 2004 (The 2004 Act) RSS was, the most (and possibly only) up-to-date component of the statutory development plan in many areas. To have the principles of up-to-date national planning policy embodied in the statutory development plan is an advantage to effective planning decision making.


9.  There are, therefore, two principal functions of the former RSS that need to be addressed in whatever new arrangements are established:

A mechanism for translating/disseminating national renewable energy targets to a local level.

Ensuring that national planning principles are embodied in locally prepared development plan documents (DPDs).

10.  We comment on each in turn.

(a)  National Targets at a Local Level

11.  The Coalition Agreement indicates that the Government proposes to maintain and, possibly, to increase the previous Government's targets for renewable energy, subject to the advice of the Committee on Climate Change.

12.  Although there have been indications that insofar as any increase would be related to wind energy, the majority of the increase would be in offshore rather than onshore wind, the clear implication is that onshore wind (which is of greatest relevance to the land use planning system) will be expected to provide at least as much generating capacity as was previously planned for.

13.  The existing suite of national planning policies, including in particular PPS1 (and its accompanying supplement) and PPS22 (and its accompanying practice guide) embody a positive approach to renewable energy projects of all kinds, urging LPAs to adopt spatial policies (and take development management decisions) that facilitate renewable energy projects wherever their effects can be handled satisfactorily.

14.  In the light of the Annual Energy Statement issued by the Secretary of State for Energy and Climate Change in July 2010, it may be anticipated that the same permissive approach will be reflected in the new national planning framework, whatever its eventual form.

15.  Current national policy is that significant weight should be given to the contribution of an individual renewable energy project to meeting national targets and the draft PPS on Climate Change promulgated by the previous Government proposed that the weight in favour of renewable energy projects should be assessed in individual cases by reference to regional targets established in RSS. Neither approach envisages that targets should be viewed prescriptively, however, and there is, perhaps, a distinction to be drawn with regional housing targets in this respect.

16.  Policy is cast on the basis that there is an intrinsic weight in favour of renewable projects regardless of their size, because of the contribution they will make to the aims of national policy. The relevance of national and regional targets to individual planning decisions was principally in providing a context within which the relative weight attributable to the need for renewable energy provision as part of action to combat climate change could be weighed against other important considerations, such as landscape and countryside protection policies.

17.  The advantage of targets derived from regional studies over targets established at a national level is that they have typically reflected an assessment of both the energy potential and planning constraints applicable at a local (or at least at a sub-regional level).

18.  Although a regional tier of policy is not necessary in order to convey the significant weight in favour of renewable projects that is embodied in current national planning policy (and implicit to the current Government's energy strategy), there is a need to provide a mechanism of some kind through which the implications of national policy can be translated to a local level having regard to both potential for renewables in that area and the particular planning constraints that apply.

19.  This is a different challenge to the one presented by, for example, meeting housing need where typically the requirements can be assessed largely (if not exclusively) at a district level. In the case of renewable energy the need is a national one and the potential contributions to meeting the need that may be made at a district level will vary considerably from place to place, according to the characteristics of different areas and of the different technologies concerned.

20.  Against that background, we suggest that the following is required:

First, the national planning framework should reflect the national energy strategy and carry forward the permissive approach to renewable energy projects currently expressed in PPS1 and PPS22 giving weight to the contribution that they may be made by renewable energy projects of whatever size in achieving the national energy strategy; and requiring LPAs to plan positively for renewables in their area.

LPAs should be required to undertake realistic assessments of the potential for renewables in their area and to plan positively to achieve that potential through policies in DPDs.

21.  The latter could require collaboration between LPAs at two levels:

First, for many LPAs it will only be possible to assess the potential for renewables in their areas—and particularly for technologies such as wind energy—by considering issues that extend beyond their own administrative boundaries. The degree to which "cross border" co-operation is necessary will vary according to the size and location of the LPA concerned and there can be no "one size fits all" solution. We consider that the best incentive to LPAs to collaborate in the preparation of appropriate research as part of the evidence base for DPDs documents would be an explicit requirement to demonstrate how the spatial scope of the research that forms the evidence base properly takes into account these issues as part of the soundness testing for new DPDs.

Secondly, few LPAs will have the necessary "in house" expertise to conduct robust research and it will be logical and cost effective for adjoining LPAs to jointly commission research to inform their respective DPDs in those circumstances. That in itself would contribute to consistent policy making across local administrative boundaries.

Assisting in the collaborative preparation of robust research may be the most effective and practical contribution of Local Enterprise Partnerships (LEPs) in planning for renewables and would not be dependant upon a wider statutory planning function for LEPs.

22.  It is important to acknowledge the practical implications for LPAs of moving to a new planning policy structure whilst the transition to the arrangements created by the 2004 Act is still not complete. The 2004 Act envisages that DPDs will be prepared in sequence led by core strategies and culminating in subordinate development management and site allocation DPDs. Few LPAs have achieved full plan coverage in their areas and it would be desirable to avoid the need to unpick the progress that has already been made in order to weave in a new approach, since that would be likely to further delay the completion of comprehensive plan coverage and place unreasonable pressures on LPAs at a time of resource constraint.

23.  For these reasons we believe that the Government should consider promoting the use of either topic-based Supplementary Planning Documents (SPDs) or Action Area Plans (AAPs) to deal specifically with renewable energy needs either on a district wide basis or on a shared basis across a number of co-operating LPAs; and be prepared to allow revisions to already approved Local Development Schemes (LDS) where necessary in order to accommodate this. SPDs may offer the fastest and most flexible option in most cases but may be difficult to achieve on a "cross border" basis where existing DPDs are not already well aligned. That may well be the case where adjoining districts fell within different former RSS areas for example.

24.  We consider that this combination of:

Clear national policy.

Evidence base prepared with appropriate spatial scope, subject to explicit soundness testing.

Flexible plan making across district boundaries.

will achieve the desirable elements offered by the former RSS, but in a manner better attuned to the needs of local areas and with the potential for faster plan preparation and review.

(b)  National Policy as part of the Development Plan

25.  Under the plan-led system established by the 2004 Act the development plan has primacy and national planning policy is simply one of the "other material considerations" to be taken into account by the decision maker. As we have pointed out, the former RSS was typically closely aligned with national planning policy. As part of the development plan this ensured that national planning principles were "built in" to policy making at a local level.

26.  In our view it is important that national planning policy carries equal weight with local policy and so the prospect of given statutory weight to the new national planning framework ought to be considered.

September 2010

previous page contents next page

© Parliamentary copyright 2011
Prepared 31 March 2011