Written evidence from Baker Associates
(ARSS 138)
Introduction
This submission on spatial planning without Regional
Spatial Strategies is made by Baker Associates, consultants with
a track record in making spatial planning work. Our experience
in partnering planning authorities to prepare development plans
of all types is second to none, we assemble evidence on all types
of planning issue to inform choices, we facilitate many types
of engagement activity, and we promote strategic and local residential
and commercial development schemes. We have advised CLG and its
predecessors on the form and use of the development plan system,
and we support planning authorities as consultants to the Planning
Advisory Service and in our own right.
We are committed to achieving worthwhile change through
the positive use of development plans as the core of the planning
system.
We set out in this submission our view of how the
coalition government's concern for localism should be developed
and applied in the field of planning, maintaining this principle
whilst local and central government carry out their essential
roles. We use a live case study to illustrate what needs to happen.
The submission begins as requested, with a bullet-point summary.
SUMMARY
spatial planning needs to address the issues of the
place; there are strategic issues and so plans have to be able
to be strategic
"locally determined" means decisions being
taken by the local planning authority, but cannot mean only taking
the local area into account or handing decision making to limited-interest
groups
there is no need to create new strategic planning
areas; plans can be for existing districts which are understood
and accepted, and having only one plan covering each area will
make planning simpler and faster
housing is an issue that transcends administrative
boundaries, and cannot be divorced from other issues such as economic
development, movement and infrastructure
the housing provision within a plan must be determined
according to evidence, the evidence must look at the functional
area rather than the administrative area, and there must be a
reciprocal relationship between plans that deal with the same
functional area
the planning system must work to create an unavoidable
obligation on planning authorities to plan to address the situation
that is demonstrable from independent evidence—this is
the fundamental requirement for a positive and successful planning
system.
BACKGROUND
There is a need for a strategic component to the
development plan. Nobody who has any appreciation of planning,
or cares for the issues planning deals with, has ever doubted
the need for planning to have local and strategic components.
Definition of "strategic"
Strategic matters can be defined as matters that
are very important, which concern more than one authority and
topic, relate to extended timescales, and on which decisions need
to be made in order to give priority and common purpose to the
objectives for an area.
The development plan system had evolved to its most
appropriate form so far in order to address the issues places
and communities face. The strategic part of the two-part development
plan was prepared at the regional level, and ultimately made by
the Secretary of State, with the Government advised by regional
assemblies comprising local government elected members and co-opted
social, environmental and economic partners. A further stage of
evolution of the two-part development plan system was needed,
with a full cycle of plan preparation allowing a review of RSS
to be informed by a round of LDF preparation. The bottom-up element
of the process as well as the equally necessary top-down element
would thereby be called into play. The two parts to the development
plan should be developed alongside each other in a dialogue, with
the necessary decisions being taken at the appropriate level.
This is a fundamentally different approach to the hierarchical
relationship objected to by supporters of good planning as well
as by the opponents of development to meet other peoples' needs.
THE COALITION
GOVERNMENT'S
TASK
The coalition government is right that people should
be involved in choices for their area, and this principle is embedded
in the modern planning system. Whilst the need for involvement
can never not be true, there are limitations to the matters that
need to be addressed that can be resolved in this way. The wholesome
model of people working amiably and creatively on the future of
a patch of land within an established community to provide a desirable
facility cannot be extrapolated to deal with the housing needs
of the country or of less favoured groups in society, and it cannot
deal with waste management, energy generation, transport infrastructure
or major arts, sports or leisure facilities. There are some matters
to be dealt with that arise from and affect wider areas and greater
timeframes than are of interest to people "acting locally".
There are essential checks and balances needed in
any arrangements to empower people involved in making decisions
on matters of such consequence. Any arrangement that transfers
power to self-appointed bodies and away from elected and accountable
politicians taking leadership responsibly is likely to have damaging
implications. The coalition government must be mindful of these
matters of governance when formulating an approach to fill the
very real gap created by the removal of the most recent form of
strategic planning.
Some matters that are capable of influence by spatial
planning and which should be addressed can only be addressed through
a strategic response. Climate change is acknowledged by most people
to be the biggest issue facing the planet, and the connections
with energy use and emissions means that how much and how people
travel is an issue in tackling climate change. Travel demand is
a consequence of the distribution of homes, jobs and shops, and
health, education, leisure and cultural facilities, as well as
social networks. These are all to do with the distribution and
form of settlements and nothing at all to do with administrative
boundaries. Shaping settlements and the relationship between settlements
is a role of strategic spatial planning. Incidentally and ironically,
green belt policy, a little understood and anachronistic favourite
of many proponents of localism, was intended to perform this strategic
settlement-shaping role before effective development plans were
part of the planning system, but has been completely misused and
has had perverse effects in its influence over travel demand.
Any form of planning system that confines itself
to only local areas and to the short term will do nothing to address
climate change and indeed will exacerbate the problem through
the tendency under market influences for development to become
more dispersed.
Economic development is generally seen as desirable
in giving more people greater opportunity, and nurturing economic
development in partnership with businesses and employers is seen
as a vital activity of government at all levels. Neither people
looking for work nor the investment decisions of employers respect
administrative boundaries. There is a relationship between the
number of people in employment and the number of homes required.
If housing is not available, either potential economic development
is stifled by the absence of a suitable workforce or long distance
commuting increases, and probably both will occur to some degree.
Infrastructure is self evidently strategic. The collection,
treatment and distribution of water for instance, is determined
by natural systems (and gravity) and by the pattern of need. It
cannot be dealt with by neighbourhood units, and administrative
boundaries have no role to play.
Housing provision is the most sensitive issue for
development plans and the controversy caused by housing numbers
has led to the removal of regional planning. If nothing else happened
the likelihood is that the same sized population as we have now
would occupy about 10% more dwellings in 20 years time because
of the falling average household size. Without at least this level
of provision the population of some settlements will fall. Areas
that have the potential to make a useful contribution to the economy
need to be assisted with greater levels of housing, but the same
successful settlements cannot accommodate all of the growth required
in the existing built up area whilst maintaining the levels of
accessibility that urban areas should provide, or the quality
of life that residents seek. The sustainable way to provide for
further development is through well-planned development at the
nearest available point on the urban edge. A consequence of historic
boundaries is that this may be in a different administrative area.
The coalition government must now find a way for
the very proper concern for genuine local involvement to be married
with the need to address wider areas and the longer term.
INCENTIVES
Incentivisation is suggested by the coalition government
as the preferred alternative to the imposition of targets to achieve
the delivery of sufficient development. The idea is entirely unconvincing
and will come to nothing. Payments to local authorities or direct
to communities (who?) would not deal with the profound political
objection to development rooted in members' expectations of strong
objection from vocal groups of established residents. The mechanics
of payment as suggested to date would in any case be unworkable
and the likely consequences regressive. If there is money it should
instead be directed to local authorities to fund the provision
of strategic infrastructure that is identified as part of a locally
made integrated strategy that addresses development requirements
according to sound evidence.
HOW TO
ACHIEVE LOCALLY
DETERMINED STRATEGIC
PLANNING
The form of spatial planning that we go forward with
has to promote the coexistence of the small view and the big picture.
"Localism" is right if its proper interpretation is
essentially that of subsidiarity; that is, decisions being made
at the most local scale at which they can properly be made.
The geography of the English regions is not very
helpful as a basis on which to plan and the regions need not concern
us further.
There is not across the country a readily identifiable
administrative unit for which plans should now be prepared, and
the coalition government should not specify 'new' strategic planning
areas.
Strategic planning has to deal with areas that present
themselves as where functional relationships exist. The form of
such areas will inevitably be fuzzy, because different considerations
have different spatial relationships. Retailing, work, education,
leisure and social networks have different geographies and these
will vary for different groups in the community.
Plans should be prepared for the existing Districts,
in that they are as good as anything, and they are known and understood.
What the coalition government must do is establish beyond doubt
the obligation for any plan to take account of what the evidence
says about its place, and for the plans for each part of a functional
area to have a reciprocal regard for the other parts. Evidence
includes evidence of the implications of ignoring the evidence
of need.
At the same time decision making must stay firmly
within the democratic system, with elected leaders being responsible
and accountable. Engagement is essential, with community groups
(including communities of interest as well as of place) and stakeholders
all having the opportunity to be involved through well designed
and well understood programmes which involve both deliberative
and inclusive activities. There should be a duty on planning authorities
to assist participants to become informed. The weight that is
attached to community and stakeholder views on planning matters
should take account of:
how representative of the community they profess
to act for, the proponents seem to be; and
the extent to which the views are informed, by for
instance the evident issues and possible responses.
Local spatial plans must meet a standard before they
can carry any weight. The standard must relate to the way the
plan flows from the evidence, and from informed engagement. The
means of testing that the standard is met must be rigorous. The
test must be applied independently, and the findings of the examiner
must be binding.
A very significant consequence of this way forward
would be for the development plan for any area to be one plan.
The tendency to wait for the "higher" level of plan
has caused huge delays in putting plans in place, meaning they
have rarely been topical and influential, and has led to a colossal
waste of resources. A one-part development plan could be the flexible,
dynamic and effective tool that has eluded the system for decades.
Though the skills are currently not present in sufficient quantity
amongst local authorities to make plans of the quality required,
these skills can be brought to bear.
A CASE STUDY—THE
WEST OF
ENGLAND
The West of England (the former Avon County, comprising
the cities of Bristol and Bath, the town of Weston-super-Mare,
and their rural hinterland) demonstrates the need for strategic
planning and provides a real example of what can happen when authorities
believe they are under no obligation to plan properly. This rapidly
developing situation calls for a form of responsible localism
and a process with bite that prevents authorities planning as
though the world ends at their administrative boundary.
The West of England functional area can be delineated
according to a range of statistical information relating to housing
markets, travel to work areas, transport infrastructure and flows,
retail catchment and spheres of influence, and clusters of industries.
Bristol is a "Core City", the eighth largest English
city, and it has the third highest GDP of any urban area. There
is an important interrelationship between Bristol and its surrounding
areas, with very high work in-commuting as well as use of higher
order retail culture and leisure facilities. A substantial part
of the urban area of Bristol is in South Gloucestershire, and
the immediate periphery of the urban area is within the areas
administered by South Gloucestershire, Bath and North East Somerset
and North Somerset Councils. These Councils administer areas that
are seen as rural and have always turned away from Bristol.
Previous joint working for the greater Bristol area
with the Joint Structure Plan did not lead to strategic decisions
being made and implemented. The emerging South West RSS set out
a spatial strategy with clear links made between development and
infrastructure planning and delivery. With the RSS in place Unitary
Councils could make their plans knowing what was required to be
in the plans of neighbouring Districts. The RSS recognised that
the city of Bristol has an essential role within the region, identified
from (tested) evidence the level of development needed for the
West of England, and determined how the need should be met from
potential brown and green sources of supply according to the principles
of sustainable development.
It is interesting that in some of their activities
the four Unitary Authorities recognise a functional relationship
across the West of England and the merit of a strategic and cooperative
response. Multi Area Agreements exist which promote strategic
relationships, and a submission has been made to the coalition
Government for a West of England Local Enterprise Partnership
which seeks to "lay the foundation for a long-term sustained,
prosperous and productive West of England". A LEP may provide
the appropriate structure to address the strategic housing need
that exists for an area, building on the economic functionality
which exists, and coordinating the infrastructure requirements
with housing delivery. This is not proposed in the West of England
LEP submission.
The mutual feeling between the West of England Unitary
Authorities does not extend to making provision through the LDFs
for the delivery of essential homes required to support the economic
strategy and the claims for achievable growth.
The table below indicates the level of housing need
from a number of evidence sources, as required to be used by PPS3:
Housing, and from the emerging RSS (which used evidence). It also
shows what authorities are currently proposing to provide following
the removal of the RSS, based on latest statements or consultations
on their LDFs.
WEST OF ENGLAND HOUSING REQUIREMENT/PROVISION
2006-2026
| | Latest National Household Projections (2006)
| Draft RSS 2006 | RSS Proposed Changes 2008
| Affordable housing need (from published SHMAs)
| Emerging Core Strategies 2010 |
| Bristol | 63,000 | 28,000
| 36,500 | 30,520 | 26,400
|
| South Glos | 33,000 | 23,000
| 32,800 | 18,060 | 21,500
|
| North Somerset | 36,000 |
26,000 | 26,750 | 18,080
| 15,000 |
| B&NES | 19,000 | 15,500
| 21,300 | 16,940 | 15,500
|
| West of England | 151,000
| 92,500 | 117,350
| 83,600 | 78,400
|
There is clearly a large gap between evidence-based need and currently
proposed planned provision. The opportunity to make their own
decisions on the level of housing provision is encouraging the
Unitary Authorities to get on with their LDFs, but there are clearly
significant potential implications of every authority acting only
on its own agenda, encouraged by its interpretation of localism.
If left unchecked, the consequences will be felt in increased
housing need, the inability to deliver infrastructure, and the
constraint of economic development.
The Independent Examination of the Bristol Core Strategy is currently
taking place. The Inspector has handled matters wisely so far,
but recognises that his conclusion of the Examination may well
turn on his interpretation of where the appropriate balance should
lie "between evidence and localism". There are general
issues illustrated by the West of England situation, but there
are particular circumstances too and how the Inspector finds on
these will affect what messages emerge and influence other planning
authorities. Bristol City Council cannot realistically plan for
the level of housing that will be needed by the future population
of the plan area to be met within the plan area. The Inspector
could find that this is what the evidence shows and simply note
that this leaves the need unmet—because he can do nothing
else in the absence of a larger area strategic plan or any control
over the neighbouring authorities. Alternatively he could report
in a way that allowed others to draw the conclusion that it was
"alright" for a planning authority to do what it wanted,
by reference to an inevitably selective set of local views, in
spite of evidence indicating that the proper response should be
something else. This would be a most unfortunate message.
This case study demonstrates that the obligation on plan-making
authorities to follow the evidence, the test that plans have to
meet, the way the test is carried out and how its findings are
applied, will all be fundamental to the value the planning system
can make to the social, economic and environmental needs of the
country in the future.
CONCLUSION
Unwanted paternalism cannot be replaced by undesirable parochialism.
Whilst local plans and their approach to housing provision have
to be locally determined rather than imposed, there is an irrefutable
need for strategic planning. Rather than strategic planning areas
being prescribed by government, local authorities preparing plans
for their areas should be placed under obligation to make plans
that address what the evidence says about how their places work
and what they need. Plans for districts that form part of an identifiable
functional area should acknowledge and address their role as part
of that area. Plans must still be subject to some form of independent
testing, with the test defined in terms of the plan properly addressing
evidence as well as the influence of informed engagement, and
the findings from the test have to carry weight.
September 2010
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