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

Written evidence from Thames Water (ARSS 143)


We recognise the Government's intention to abolish regional spatial strategies as part of a broader policy of decentralisation, and trust that the advantages of the old system for planned infrastructure delivery can be retained under forthcoming arrangements.

Water and sewerage companies require as much certainty as possible about housing growth figures in order to plan ahead and provide adequate water and drainage infrastructure when needed.

We are concerned that the abolition of regional spatial strategies (RSSs) reduces this certainty, which could lead to negative environmental impacts and poor outcomes for customers.

RSSs provided the strategic policy framework on large-scale water and sewerage infrastructure of regional importance. Their abolition makes it unclear who will decide on strategic policy matters in future.

It is vital that strategic water and wastewater matters are considered at the appropriate level. Planning policy must then support delivery of required infrastructure at the right time.


We welcome the opportunity to submit evidence to the Committee to assist with its inquiry on the abolition of regional spatial strategies. This submission sets out our views on the issue.

We trust this submission will help inform the Committee's analysis and we would, of course, be happy to discuss our views in more detail.


The implications of the abolition of regional house building targets for levels of housing development

1.  Thames Water is the UK's largest water and wastewater services company. We serve 8.7 million water customers and 13.8 million wastewater customers across the London and Thames Valley area, from Kent and Essex in the east to the edge of Gloucestershire in the west. This area is governed by more than 100 local authorities and falls into four regions:

London (unaffected by the abolition of RSSs)

the South East;

the South West; and

the East of England.

2.  Every new commercial or housing development in our area is entitled to connect to our local clean water and drainage networks, so we need a clear view of expected levels of housing growth in order to deliver the infrastructure needed to serve our customers. Regional spatial strategies (RSSs) provided this clarity, because their housing targets told us where growth would happen and how fast it would come. Accordingly, we produced our £4.9 billion investment programme for 2010-15 in line with RSS housing growth figures to minimise the risks of unfunded costs and inadequate infrastructure. Failure to provide appropriate infrastructure can have serious consequences for customers and the environment, including sewer flooding or localised water shortages. A lack of clarity could lead to investment in areas that do not experience growth, which would waste money and resources.

3.  Even before the advent of RSSs, there were still regional plans such as Regional Planning Guidance note 9 (RPG9) which provided housing figures. These plans were not part of the statutory development plan and were therefore of a lesser status but still provided us with useful projections on housing levels. At county level, these housing figures were also included in structure plans, which no longer form part of the development plan. The revocation of regional spatial strategies therefore represents a significant departure from previous approaches.

4.  Following the revocation of regional spatial strategies in July 2010, we wrote to all local authorities within our area (outside London) to ask whether they would review or retain their RSS targets.

5.  Out of 46 local authorities who responded, only 21 had actually taken a decision. It is clear that many authorities' housing strategies will be delayed, sometimes by around six to seven months. We are concerned that this ongoing uncertainty around future housing levels makes it difficult for us to plan for growth and avoid poor outcomes for customers.

6.  Furthermore, we believe that the revocation of RSSs has removed an important strategic level of planning policy. We recognise the Government's intention to abolish regional spatial strategies as part of a broader policy of decentralisation, and hope that the advantages of the old system can be retained under forthcoming arrangements. Our region requires large-scale investment in infrastructure to address urgent environmental needs, such as river water quality or increasing demand for water. The RSSs contained detailed policies on these issues and were essential guides to local authorities when deciding on planning applications.

7.  For example, the South East Plan (May 2009) provides for new water and wastewater infrastructure to address population growth and rising environmental standards[177]. The Plan identified new water resource schemes in the policy, which required local authorities to work extensively with the water companies and the Environment Agency to deliver these schemes. These schemes were identified on the basis of water companies' Water Resource Management Plans or through regional modelling of water supply-demand balance while the Plan was being prepared. The Plan also required local authorities to allocate and safeguard sites that could host the necessary infrastructure. Even where schemes were not certain to progress, authorities were told to safeguard the sites nonetheless so as not to limit any options in future. Revoking the RSSs has removed this strategic perspective without identifying any replacement.

8.  The absence of the strategic framework that RSSs provided leaves a gap in planning policy between local and national levels. This gap is unlikely to be filled in the short to medium term and could make it harder for us to provide strategic infrastructure when it is most needed. This is particularly important because some local authorities have not covered water and drainage infrastructure in local development frameworks on the grounds that the issues were already covered in the RSS. In other words, the need for strategic investment in water resources is no longer recognised at either regional or local level.

The implications for cooperation and data-sharing between local planning authorities

9.  We manage our water resources on the basis of river basins, not administrative boundaries, so strategic resource management is better done at a regional level to reflect the water resource zones that companies use. For example, the South East Plan, which examined the relationship between our plans and regional housing growth projections, recognised that the proposed Upper Thames Reservoir in Oxfordshire would act as a strategic regional resource for customers in the Swindon-Oxfordshire and London water resource zones[178]. Our preferred long-term option is to build a new reservoir in Oxfordshire by 2026.

10.  It is essential to take a strategic approach to planning such a key resource, given the reservoir would be located in one region while providing water to three regions (the South East, London and the South West) and more than 20 different local authorities.

11.  It is unclear how this gap in regional planning will be filled and the relevant data captured, in particular on issues that affect many local authorities. There is potentially an increased risk of inconsistency between local authorities that may lead to confusion, shortfalls or unfunded obligations for companies. To avoid this risk, it is critical that water companies and Environment Agency are directly involved in all water and wastewater matters previously covered by the RSS.

12.  More generally, mechanisms should be put in place to allow Local Enterprise Partnerships or other strategic bodies to assume a coordination role in regional planning. This could also be achieved through groups of local authorities co-ordinating together. In the absence of a formal regional framework such voluntary groupings, involving authorities with common issues, could provide a route for the sort of co-operative approach that is needed. By jointly considering issues such as housing and infrastructure provision this would help ensure a coherent, co-ordinated approach, promoting sustainable economic development while providing the necessary clarity around the need for new infrastructure. The members of such groupings would need to be able to adopt binding housing targets to ensure a co-operative approach was maintained.

13.  While their impact is limited to the water sector only, we believe that Water Cycle Studies (WCSs) could potentially help, if undertaken widely. Many local authorities have undertaken WCSs to determine what sustainable water and wastewater infrastructure is required, and where and when it is needed. A WCS considers environmental capacity and technological constraints, and involves other stakeholders in the process including water companies and the Environment Agency. We believe that WCSs should be carried out by all local authorities and they clearly must reflect the particular environmental and growth circumstances of that area. Where stakeholders raise a strategic issue, local authorities should work together to consider the issues on a catchment-wide basis. Where there are issues of a more strategic, regional nature, there may be a role for county councils and unitary authorities? to work together, drawing upon the WCSs, Water Resource Management Plans and Surface Water Management Plans. Equally, there may be a role for the Environment Agency in coordinating the process of determining which infrastructure is required, with input from water companies and local authorities.

14.  Ultimately, whether or not WCSs are used as a vehicle, it is vital that strategic water and wastewater matters are considered at the appropriate level. Planning policy must then support delivery of required infrastructure at the right time.


15.  We believe that the evidence base prepared by the Regional Local Authority Leaders' Boards is a valuable resource that provides a basis on which individual planning authorities could seek to establish their own housing targets. This data should be made publicly available in the interests of transparency and accountability, possibly through an online database. Once this data is published, local authorities should be held accountable for keeping the information up to date.

September 2010

177   See policies NRM, NRM2 and NRM3 of the South East Plan, May 2009. Back

178   See policy NRM3 of the South East Plan. Back

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Prepared 31 March 2011