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

Written evidence from Baker Associates (ARSS 138)


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.


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.


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 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.


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.


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.


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.

Latest National Household Projections (2006) Draft RSS 2006RSS Proposed Changes 2008 Affordable housing need (from published SHMAs) Emerging Core Strategies 2010
Bristol63,00028,000 36,50030,52026,400
South Glos33,00023,000 32,80018,06021,500
North Somerset36,000 26,00026,75018,080 15,000
B&NES19,00015,500 21,30016,94015,500
West of England151,000 92,500117,350 83,60078,400

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.


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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Prepared 31 March 2011