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

Written evidence from Star Planning and Development (ARSS 15)


By reason of the current revocation and proposed abolition of Regional Spatial Strategies:

There is a need for a framework at national and sub area level for the provision of housing to at least provide a metric for monitoring housing provision if only to assist with the distribution of financial incentives and to potentially act as a "stick" in default of a locally derived and robust housing provision;

There is the inherent potential for conflicts between local planning authorities wanting growth or financial purposes versus the local community who may remain resistant to new development; and

As a consequence of the abrupt policy vacuum caused, there will inevitably be delay in the preparation of Local Development Frameworks (or Local Plans).


1.    The proposed abolition of Regional Spatial Strategies (RSS) is not a new idea and there has been a period of at least 12 months for the current Government, when in opposition, to devise robust alternative arrangements. However, such arrangements were not devised and are still not in place other than the proposal to encourage Councils to accept housing growth via financial incentives.

2.    The Select Committee will receive more detailed evidence on this matter but, based on Star Planning and Development's experience, it is clear that local planning authorities are revisiting previously accepted policies concerning housing provision and this is resulting in delays to the preparation of Local Development Framework/Local Plans (a minimum of six months and perhaps up to 18 months) and refusing schemes which might otherwise have been approved (whether on application or appeal).

3.    As part of this submission, Annex 1 comprises a letter is attached dated 8 October 2009 to Bob Neil MP covering the concerns of Star Planning and Development following his presentation to a RTPI sponsored event in Manchester during the Conservative Party Conference. From a cursory inspection of the letter's contents the reader will note that some of the issues now identified by the Select Committee were highlighted to Mr Neil in October 2009 and an approach suggested which could potentially have avoided the current malaise and uncertainty in the planning system caused by the blunt approach of revoking RSSs. Further, the suggested approach would ensure generally that the process of distributing housing growth would be democratic and major decisions locally based albeit with a "stick" to ensure that the wider housing needs of the country are met through the planning system. No response was forthcoming from Mr Neil.

4.    An area of particular concern is that there is an established link between house prices, housing supply, economic growth and social well-being which was demonstrated by Kate Barker's Review of Housing Supply. Without some form of national context or framework for the provision of new dwellings, how can there be a reasonable degree of certainty that the housing needs of the country would be being met in a co-ordinated manner, including the wider issue of infrastructure providers providing the necessary capacity and services?


5.    The financial incentives being advocated by the Government as the preferred approach to encourage additional housing do have some merits if allied to disincentives for those authorities failing to provide their "fair share" of country's new dwelling requirement. However, there are two specific concerns which arise:

(a)  Will there need to be a benchmark against which the housing provisions and financial incentives will be tested? If this is the case, what will the benchmark be and how will it be established?

A clear framework to allocate the available funds needs to be established and, logically, there must be a "target" housing provision, whether nationally, regionally or locally, against which the payment of financial incentives can be measured. The only other alternative is a metric based on the number of new homes provided within each administrative area. Accordingly, some of the rural areas, especially those in National Parks and Areas of Outstanding Natural Beauty, would materially "loose out" because of the very tight controls on new house building.

(b)  The tension (or as the Government refer to the matter an "honest debate) between an authority which is perhaps seeking to maximise the financial benefits associated with new housing versus the local community who may be against any new development. The so called NIMBY to YIMBY argument raised by Mr Neil last year.

Many local communities welcomed the revocation of RSSs because they perceived the potential threat of new development was removed (Star Planning and Development currently has such experiences). However, given the financial incentives being suggested by the Government, together with the potential for new development to fund wider community benefits via a reformed Community Infrastructure Levy, pursuing growth may well be attractive to a significant number of authorities. Accordingly, the growth originally envisaged in a particular location identified the in revoked RSSs would potentially only be delayed. It should be noted that the RSS locations were generally based on robust evidence bases and new studies are unlikely to come to different conclusions. When it is again suggested by an authority that growth should occur at a previously identified RSS location there will be an undermining of the community's perception of the Government's original "promise" about abolishing the undemocratic planning system inherent in the RSS process.


6.    Star Planning and Development has sought to clarify with the Department for Communities and Local Government why the Regional Strategies (RSs) were revoked and the exchange of e-mails is attached as Annex 2. Clearly, the Secretary of State's decision was politically based and could be justified by reference to Collation Agreement. However, other than this political dimension, there appears to be no specific or sound technical reasons why all or parts of the various RSs were withdrawn, including both RSS and Regional Economic Strategy elements.

7.    The revocation of, in particular, RSSs has left a significant policy vacuum in terms of employment and housing land provision and targets for mineral extraction which might be considered to be the more contentious matters. However, RSSs included important environmental and sustainability polices and targets such as overarching affordable housing targets, the basis for co-ordinating transport provision, a clear framework for cross-boundary working between individual authorities and general sustainability matters and green infrastructure provision. There is now a policy vacuum associated with these important matters. Little thought appears to have been given by the Secretary of State to the provision in the Local Democracy Economic Development and Construction Act 2009 which allows for "any parts" of an RS to be revoked. A more selective approach could have been adopted to retain the less politically contentious aspects of RSS policies.

8.    It may have been politically expedient to revoke the contentious parts of the RSSs but it remains unclear why they were revoked in full. Unless the vacuum for the less contentious policies is expediently filled by the National Planning Statement, all that will now happen is that Local Development Frameworks/Local Plans will inevitably become significantly longer and more detailed than originally envisaged. This level of detail will add to the timescale to produce these documents. In this regard, sight must not be lost that the preparation of any planning policy document has to comply with wider requirements concerning sustainability and environmental assessments, the preparation of a sound evidence base and ensuring a democratic basis for drafting policies. It is generally these matters which cause the delay in the process rather than the actually writing of the policy document itself.


9.    As with any significant change to the planning system, the revocation and future abolition of RSSs has and will continue to result in Local Development Frameworks/Local Plans being delayed with the need for the significant policy vacuum to be filled at local level. The inevitable frustrations associated with this delay will more than likely result in further tinkering in about two years time to try and speed up the development plan system. Further, the likely disappointment of the community in the planning system because the abolition of the RSS will not stop growth pressures combine with authorities wanting growth to secure the Government's financial incentives has the potential for significant conflicts to arise which may not be capable of successful mediation.

September 2010

previous page contents next page

© Parliamentary copyright 2011
Prepared 31 March 2011