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

Written evidence from Robert Hitchins Limited (ARSS 26)


The abolition of the Regional Spatial Strategies and with them regional house building targets without the putting into place of any clear transitional arrangements is unfortunate and will inevitably reduce the levels of housing development, in contrast to the Government's stated objective of increasing house building levels. This is as a result of:

delays as local planning authorities adjust to the "localism" agenda;

reduced locally set housing targets;

disruption to projects/planning applications already in the planning pipeline; and

lack of cross border coordination.

Local communities will not accept new development on the basis of some form of financial incentive. Virtually all larger scale housing developments already bring about substantial benefits to the receiving community, which does little if anything to reduce levels of objection. Indeed objectors often accuse local planning authorities of giving undue weight to such benefits. It is not difficult to see objectors viewing any proposed governmental incentivisation scheme in exactly the same way.

There is an urgent need to reinstate a strategic level of planning to ensure that cross boundary issues, including the collection and dissemination of research are fully addressed. Local Enterprise Partnerships may, depending on the responsibilities given to them, be a means of achieving this.


1.1  The Robert Hitchins Group was founded in 1958. It has its headquarters on the outskirts of Cheltenham. The company is one of the most active developers in the Gloucestershire area and has constructed around 15,000 houses and 1,700,000 ft2 of commercial property and manages around 2,000,000 ft2 of commercial property. Although no longer a house builder the company does bring significant quantities of serviced consented housing land to the market which the Company has promoted through the development plan and development control systems and thus provides a vital component in the land supply chain and the house building industry.


2.1  The abolition of regional house building targets will inevitably reduce the levels of housing development. This is as a result of:

delays as local planning authorities adjust to the "localism" agenda;

reduced locally set housing targets;

disruption to projects/planning applications already in the planning pipeline; and

lack of cross border coordination.

Delays as local planning authorities adjust to the "localism" agenda

2.2  Within our area of operation there are already a number of examples of delays to Local Development Frameworks brought about as a direct result of the abolition of Regional Spatial Strategy.

Gloucester, Cheltenham, Tewkesbury—Joint Core Strategy:
"In May and July, the new Government announced major changes to the planning system which give more power to communities. The South West Regional Spatial Strategy—which set targets for housing and jobs—was scrapped and councils must now establish their own needs locally. The Government also committed to protecting the natural environment and promoting renewable energy for example.
These are important changes so the JCS team is monitoring all further Government announcements while reviewing its own work and timetables."

South Worcestershire Joint Core Strategy:
"Before the Government announcement it was proposed that the SWJCS could be presented to the three South Worcestershire Councils for approval n the autumn this year with submission to the Secretary of State in January 011. This is now unrealistic as we will require additional time to consider how he SWJCS should be revised."
Letter to Parish and Town Councils and for publication on websites 15 June 2010

Wiltshire Joint Core Strategy:
"In the light of the CLG letter and in anticipation of the "Localism Bill", Wiltshire Council intends to continue to develop the evidence base and the work commenced during the "Wiltshire 2026" consultation. However, it is important to recognise that in this period of policy upheaval, the process of building a sound Wiltshire Core Strategy is likely to take longer than originally perceived."

South Wiltshire Core Strategy:
"Wiltshire Council will review housing figures across the county following the Government's decision to abolish binding, planning strategies.
As a result of the abolition of Regional Spatial Strategies (RSS), the council's South Wiltshire Core Strategy proceedings will be suspended.
The core strategy outlined the spatial vision, key objectives and overall principles for development in the former Salisbury District Council area.
Full Council agreed to submit the South Wiltshire Core Strategy to the Secretary of State in November last year and it was subject to formal Examination in Public (EIP) for six weeks during the spring.
However, before the inspector issued his final report, the Communities and Local Government (CLG) Secretary Eric Pickles revoked the RSS which was key to the development of the council's South Wiltshire Core Strategy.
Wiltshire Council and the inspector agreed that proceedings should now be suspended while the council carries out a full review of housing and employment needs in South Wiltshire."

Reduced locally set housing targets

2.3  As indeed there is already an example of a reduced locally set housing target:

Cotswold District Council:
"In the light of the Government's intention to abolish Regional Spatial Strategies (RSS) and the subsequent CLG letter (a material consideration) to return decision making powers on housing and planning to local councils, decisions on housing supply rests with the LPAs (Letter from the Rt. Hon Eric Pickles MP to Chief Planning Officers, 27 May 2010).
As the RSS for the South West will no longer form the basis for calculating housing supply, the District Council has decided that the RSS (July 2008) requirement of 345 dwellings pa will be replaced by 300 dwellings pa. The latter requirement was proposed in the Draft RSS (June 2006) following extensive joint work by the local authorities. This is broadly in line with the average build rate 1991-2010 (291pa), and the Structure Plan Third Alteration proposal (280pa), which, although ultimately not adopted, was tested at EiP."

Disruption to projects already in the planning pipeline

2.4  We have direct experience of an application for outline planning permission for 175 homes on a site the officers considered "is generally suitable for housing and the proposed development would enable an inherently sustainable development to take place" being refused. The reasoning including:

"In returning decision making powers on housing and planning to local councils it is highly likely that any new supply targets will be significantly lower than those set out in the West Midlands Regional Spatial Strategy Preferred Options"


2.5  This is just one example of a Local Authority acting to disrupt projects. What however, is going to be significantly more damaging to the future housing supply is the fact that the abolition of the RSS combined with the absence of any transitional arrangements has led companies such as ours to halt investment in projects that are in the pipeline because the road ahead is totally uncertain. This is already a risky business and we can not justify continuing to invest large sums in projects that rely for their success on a planning system that does not yet exist and for which there is little or no guidance as to its future shape save for various "on the hoof" Ministerial statements.

2.6  This "parking" of projects in this manner is widespread, these projects have lost momentum and a few months delay now will lead to years of delay in the future; this is our experience and the experience of other companies engaged with the planning system and it will lead to very significant "black-holes" in the land supply and housing supply chains for many years to come. It has to be understood that most housing projects take years of planning to come to fruition, to obtain a planning permission and to finally provide homes and this loss in momentum now occurring will be severely damaging to the progress and delivery of these projects.

Cross border co-ordination

2.7  The Gloucestershire County Council's latest household projections for Gloucester City indicate that household growth in the City will greatly outstrip its capacity to accommodate its growth within its boundaries. The administrative area of Gloucester City is tightly hemmed in by the Districts of Stroud and Tewkesbury to the extent that the majority of growth in the City is now taking place or was (before the abolition of the RSS) planned to take place outside of its administrative boundaries. In the absence of the strategic tier of planning there are no effective mechanisms to secure the cross boundary solution required in such situations. In short it is difficult to see why one district would locally decide to accommodate another's needs. This point is picked up again in section 5 below.

3.  The likely effectiveness of the Government's plan to incentivise local communities to accept new housing development, and the nature and level of the incentives which will need to be put in place to ensure an adequate long-term supply of housing.

3.1  It is naïve to assume that any local community will accept new development on the basis of some form of financial incentive particularly one that is likely to be severely constrained by what the Country can afford.

3.2  It should be remembered that virtually all larger scale housing developments already bring about substantial benefits to the receiving community, for example new and improved schools, new job opportunities, enhanced and new social, recreational and community facilities and affordable housing. This however does little if anything to reduce levels of objection and indeed objectors often accuse local planning authorities of giving undue weight to such benefits. It is not difficult to see objectors viewing any proposed governmental incentivisation scheme in exactly the same way.

3.3  Our direct and long experience in this field and in particular with consultation with the local community is that local people, in the majority of cases, object to the principle of the development itself and no amount of collaborative working with them in redesigning/altering the scheme to mitigate their professed concerns will remove the in principle objection. The payment to the Local Authority of an incentive to grant the planning permission therefore, will not be translated into local community acceptance, but the converse, namely a greater resistance because the local community will regard the receiving of the incentive as the Local Authority "selling out" the community's wishes.

3.4  Moreover, incentives for the receiving community are proposed to be paid to the local authorities (county/district councils) and phased over the period of the development, and as such any direct tangible benefit to the local community is likely to be significantly diluted.

4.  The Committee understands that the Government intends to announce further details of its plans for incentives "shortly", and would welcome comments on the adequacy and appropriateness of those incentives when the details are available.

4.1  The much trailed six times council tax, even if the country can afford that rate, would hardly amount to a significant sum insofar as a local authority is concerned. It is of course significantly less than is often already made available to local authorities through S106 for improved and new infrastructure (including social and community infrastructure) which has absolutely no influence on those who are opposed to development.

5.  The arrangements which should be put in place to ensure appropriate cooperation between local planning authorities on matters formerly covered by regional spatial strategies (eg, waste, minerals, flooding, the natural environment, renewable energy, &c.);

5.1  There is an urgent need to reinstate a strategic level of planning on these matters and in doing so it would seem eminently sensible, given the sort of problems highlighted in paragraph 2.7 above, that the same strategic approach be taken in respect of housing and employment land. It should also be borne in mind that planning cannot be separated into discreet topic areas and housing and employment are inextricably linked to the topics listed in 5 above. In short a "joined up" approach is essential.

6.  the adequacy of proposals already put forward by the Government, including a proposed duty to co-operate and the suggestion that Local Enterprise Partnerships may fulfil a planning function; and

6.1  There has always been a duty for local authorities to deliver and perform and evidence of abject failure to do so. It is therefore difficult to see that this in itself would ensure co-operation.

6.2  Local Enterprise Partnerships (LEPs) could be part of the solution depending on the nature of the planning function they might fulfil. If the LEPs are to have a planning function it must be sufficient to address cross boundary issues whatever the planning topic and provide a bridge between national policy statements and localism where needed.

7.  How the data and research collated by the now-abolished Regional Local Authority Leaders' Boards should be made available to local authorities, and what arrangements should be put in place to ensure effective updating of that research and collection of further research on matters crossing local authority boundaries.

7.1  The internet would seem the obvious means by which such information should be disseminated. It should however be available to all and not just the local authorities.

7.2  In terms of collecting/updating research on matters that cross local authority boundaries this again could be a responsibility of the LEPs.

September 2010

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Prepared 31 March 2011