Written evidence from Community and Regional
Planning Services (ARSS 28)
INTRODUCTION
1. Community and Regional Planning Services
is pleased to submit this evidence. Our evidence is not confidential.
2. Community and Regional Planning Services
is an independent planning consultancy operating throughout England
and offering a full range of planning advice and resources to
both public and private clients at national, sub-national and
local levels. We specialise in "third party" work for
small businesses, parish, town and community councils, amenity
groups and private individuals. We have particular experience
in responding to development plans including strategic plans,
and have represented clients at a number of Examinations-in-Public.
We also undertake studies, research and policy advice for NGOs
and statutory agencies. We provide training in the planning system
through seminars and workshops. Through all our work runs the
thread of a high level of environmental awareness and commitment
together with community sensitivity.
3. We do not purport to represent any particular
clients or other interests in responding to the Committee's Call
for Evidence, but do so from the perspective of our lengthy experience
across a wide range of land-use planning issues.
4. We are not specifically requesting to give
oral evidence.
SUMMARY
This Evidence:
finds that the abolition of RSSs, though welcomed
in many ways, leaves a gap in strategic planning which needs to
be filled for certain land-use planning topics;
points out the pitfalls of financial incentives to
local authorities for housebuilding and suggests that these should
meet certain criteria;
suggests strategic planning based principally on
travel-to-work areas for cities and large towns; and
calls for LEPs (if these are to have a strategic
planning role) to have an environmental and social remit as well
as an economic one, and fully and transparently to engage with
the public and special-interest sectors.
EVIDENCE
The implications of the abolition of regional house
building targets for levels of housing development.
1. Community and Regional Planning Services accepts
the need to ensure that the planning system should be able to
facilitate the provision of sufficient housing to meet the needs
of households, and also of industry and commerce in ensuring that
they can find a sufficient local supply of skilled and professional
workforce.
2. A particularly acute need is for the supply
of "affordable" housing (using the definition in Annex
B of PPS3, June 2010). This applies to both urban and rural areas—although
the nature and scale of the affordable housing needs in those
two types of area are different.
3. That said, mere housing numbers were given
too great an emphasis in the RSSs. Many of these proved to be
undeliverable and insufficient importance was given to meeting
local needs as opposed to regionally-aggregated requirements.
It was likely, therefore, that had the RSSs been fully implemented
(which itself depended on market conditions and the capacity of
the construction industry to deliver), there would have been serious
misalignment between where the housing was to have been built
and the location of employment, leading to unsustainable travel
patterns.
4. The short-term consequences of the abolition
of RSSs appear, so far, to be varied. Some local authorities have
called a halt to their LDF Core Strategies (where these have not
already been adopted) with the intention of revising downwards
their housing supply by stripping out regionally-imposed provision
and concentrating on meeting local needs. Others have sought to
continue an expansionist policy by retaining or even increasing
their proposed provision. It is too early to tell whether current
sub-optimal construction rates result from the economic downturn
or from the change from regional planning.
5. Whilst the loss of RSSs will not be lamented
in many places, their abolition does leave a gap in sub-national
planning policy. Local planning authority boundaries are relatively
arbitrary when it comes to land use. The housing needs of many
cities and towns are partially met over the border in neighbouring
authorities, as indeed is employment too. However imperfectly,
the RSSs (and their sub-regional policies, where these existed)
sought to reconcile and to plan for these cross-boundary issues,
and some level of strategic planning is essential. We consider
this matter in more detail under the Committee's third and fourth
Questions, below.
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.
6. The danger of financial incentives for housebuilding
is that the incentives may bear little relationship either to
local housing needs or to environmental constraints. If the incentives
are there for any local authority willing to embrace them, we
may end up with a very uneven distribution of new housing, possibly
in quite the wrong places in respect of employment and proximity
to other services such as schools, colleges, hospitals, major
leisure facilities and transport networks.
7. Whilst some local authorities are very conscious
of environmental constraints in their areas (nationally- and locally-valued
landscapes, wildlife sites and habitat, areas of heritage interest,
woodland, Green Belt, flood plain etc), others may be tempted
to take a more cavalier approach to environmental issues if money
is at stake and to approve housing proposals or development plan
allocations that would otherwise be unacceptable in normal planning
terms. Incentives may have the further effect, not unlike RSSs,
or promoting mere numbers of dwelling units rather than encouraging
quality and a high standard of design.
8. It is insufficient for the Government to say
that incentives would only be given for housing provided in accordance
with the development plan. Local planning authorities will bear
in mind any incentive scheme when drawing up their development
plans and so that is likely to be self-fulfilling.
9. The general availability of incentives may
also have the perverse effect or rewarding local authorities where
housebuilding is proceeding (or likely to proceed) anyway. Housebuilders
have many unimplemented permissions across the country where only
market conditions (including the availability of mortgage finance)
rather than any aspect of the planning system are holding back
construction. In addition, developers hold considerable landbanks
and options on land which they pursue for allocation through the
development plan system.
10. That is not to say that housing incentives
have no role but they must be subject to:
assessments of local need;
a proper spatial relationship to employment, local
services and transport networks; and
environmental constraints.
11. The greatest value that incentives can have
is in the provision of affordable housing. A mistake of the past
has been in expecting most affordable housing to be delivered
on the back of market housing developments. Market housing does
have a role, although forecasts of how much affordable housing
a particular market housing development can deliver and still
remain viable are often exaggerated.
12. Direct grants to housing associations (and
equivalent bodies) are likely to be much more effective in meeting
affordable housing needs. This approach would be less subject
to the variations in market conditions that afflict housing for
general sale and would concentrate scarce financial resources
where they are most needed.
The arrangements which should be put in place to
ensure appropriate co-operation between local planning authorities
on matters formerly covered by regional spatial strategies (eg
waste, minerals, flooding, the natural environment, renewable
energy, &c.)
13. The abolition of RSSs, and the sub-regional
strategies that many of them contained, has left a gap in strategic
planning. That said, RSSs probably tried to provide too much policy,
extending beyond what was strictly necessary to deal with cross-boundary
issues. This stemmed from a regional agenda which extended beyond
the realms of town and country planning and which is no longer
being pursued by the present Government.
14. So it is necessary to consider what land-use
planning issues cannot be left merely to be handled locally. It
would be unwise to leap to a solution to the strategic planning
problem without first understanding both what exists "in
the field" and what needs to be planned at a sub-national
(but supra-local) scale. We identify (or otherwise comment on)
some of these in the Appendix to this Evidence.
15. Another reason for having a strategic level
of planning is to arbitrate between differing local aspirations.
(We do not here mean local disagreements within the same authority,
eg between a town and a peripheral village: these should be able
to be handled locally.) Where an urban authority wishes to expand
its built-up area across the boundary into a neighbouring rural
authority and bilateral agreement cannot be reached, then strategic
planning can look at the options and recommend the best planning
solution—which may in this example involve a combination
of a review of proposed development levels, some cross-boundary
urban expansion and a greater emphasis on urban regeneration.
16. The different drivers justifying strategic
planning mentioned in the previous two paragraphs would each point
to a different geographical coverage or scale of plan, although
few justify a regional plan. But if one considers that the two
greatest influences on built development are housing and employment,
then we advocate strategic plans based loosely on travel-to-work
areas centred on cities and the large towns. In this way the housing
and employment (and shopping and leisure) development needs of
those urban areas can be considered across an area which is not
constrained by local authority boundaries.
17. These strategic planning areas may be quite
large in the case of the larger cities, covering most of their
metropolitan hinterlands. For smaller cities and the larger towns
the areas would be correspondingly smaller. More remote rural
areas, not under the strong influence of a city or large town,
would be excluded: they should not be "swept up" into
an urban-based strategic plan merely to provide 100% coverage.
18. There have been some suggestions that we
should revert to structure plans based on the historic counties,
as was the case prior to 2004. We reject this. The boundaries
of the counties (where these still exist: some have been split
into separate unitary authorities) no longer represent isolated
economic or housing areas. This is true even for counties which
retain a strong sense of local identity.
19. Where the housing/economic strategic planning
areas do not fit well with the needs of other spatial planning
topics, then there would be nothing to stop separate non-statutory
plans being developed for those matters on different geographical
scales, with their findings incorporated into the housing/economic
strategic plans.
20. Whatever the shape of sub-national plans,
and whether they attempt to cover all land-use planning topics
or whether separate plans are devised for different topics, it
is essential that the bodies responsible include, at both "board"
and working levels, a variety of relevant stakeholders, such as
representatives of environmental and community bodies, as well
as local authority and economic development interests. For all
the faults and expense of the former Regional Assemblies, they
did achieve stakeholder representation of some 30% and we are
convinced that their work benefited from this.
21. All sub-national plans should be prepared
transparently with the widest possible public participation in
the development of options and full consultation on the proposed
plans themselves. The evidence base should be made publicly available.
22. We would go further and call for public consultation
on the proposed sub-national planning arrangements themselves
for each area. These should not be decided merely by local authorities
and economic (or other) interests "behind closed doors".
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.
23. Local Enterprise Partnerships may indeed
be appropriate bodies to exercise the strategic planning function,
if they meet the criteria set out in our paragraphs 20-22 above.
However, in the absence of Government guidance for setting up
these bodies, there is a danger that almost random proposals will
emerge across the country, of different shapes and sizes and not
necessarily based on useful planning areas but driven by certain
local authorities (or even prominent individuals!) wanting to
"steal a march".
24. We do not advocate statutory or even mandatory
strategic planning bodies, although they are to be strongly recommended
for the reasons outlined above. But Government guidance is urgently
needed in order to set out their objectives. Local authorities
and others can then come together and devise the best local solution
to meet their needs, consistent with those objectives.
25. We emphasise again that the LEPs or other
cross-boundary bodies established for strategic planning must
integrate the environmental and social aspects of planning and
not concentrate merely on the economic. Town and country planning
is all about mediating between competing interests and resources.
26. The LEPs or other cross-boundary bodies need
not be expensive to run. They would be resourced largely by the
participating local authorities and we would in most cases expect
little in the way of permanent staffing other than, perhaps, a
small secretariat. It is accepted, however, that the strategic
planning bodies for major metropolitan areas will need greater
resources. Any contributions to running expenses from other parties,
eg the business or development sectors, should be on the clear
understanding that this would be on a neutral basis with no planning
benefits accruing to contributors.
27. If the strategic planning organisations remained
non-statutory, then the outcome of their studies and planning
work could not be binding even on the participating local authorities,
although we would expect those participating authorities to uphold
and support their own strategic plans. Strategic plans would be
a "material consideration" in the determination of planning
applications where relevant, and we would expect them to influence
local development plans.
28. A good maxim is not to burden the strategic
planning level with what can properly be decided locally, but
to recognise at the same time that cross-boundary issues cannot
be decided unilaterally.
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.
29. Recent data collected from the former RSS
and sub-regional planning process should be retained by a nominated
local authority on behalf of each LEP or new strategic planning
area and should remain accessible (preferably online) to all who
need it.
30. However, the relevance of such data will
decrease over time and its updating and any necessary new studies
will need to be commissioned by the strategic planning bodies,
especially in advance of their drawing up new plans. Again, all
such studies and reports should without exception be in the public
domain, readily accessible online and in many cases open to public
comment, consultation and scrutiny.
ABBREVIATIONS
AONB Area of
Outstanding Natural Beauty
LDF Local Development Framework
LEP Local Economic Partnership
PPG Planning Policy Guidance (Note)
PPS Planning Policy Statement
RSS Regional Spatial Strategy
RTS Regional Transport Strategy
SSSI Site of Special Scientific
Interest
APPENDIX
Selected land-use planning topics and their suitability
for some form of strategic planning
HOUSING
The housing needs of any one local authority may
have to be met in an adjacent authority, if all internal potential
and regeneration options have been exhausted. Large cities that
have extensive public transport networks have a history of commuting
from suburbs likely to be located in other authorities' areas.
Strategic co-ordination of housing provision in such areas is
essential.
EMPLOYMENT
There are two reasons why employment planning should
be considered strategically. One is to avoid unnecessary and wasteful
competition between local authorities in the provision of large
employment sites. Secondly, a balance should be sought which aligns
employment and housing provision, both in timing and location,
in an attempt to reduce commuting distances.
ENVIRONMENTAL
Landscape
The landscape does not respect local authority boundaries.
Besides National Parks and AONBs, there are more locally-valued
landscapes, some of historical importance, which cross boundaries
and which need protection and a "greater-than-local"
level of planning to retain their integrity.
Wildlife interest and habitat
Again, some of the larger sites of wildlife interest
such as SSSIs and those benefiting from European designations
cross local authority boundaries. In order to retain their integrity
and to facilitate enhancement projects, woodland, heathland and
other habitat—where this is more than of very local importance—need
co-operative planning and protection.
Green infrastructure
Some "green infrastructure" (eg a country
park) is provided for the use of people besides those residing
in the local authority area in which the facility is located.
This "higher level" provision has to be planned on a
larger-than-local scale: existing provision needs recording and
analysing and plans put in place to remedy any deficiencies.
National, regional and sub-regional cycle and recreational
walking routes (including the new Coastal Access) also cross authority
boundaries. Whilst these have never been "planned" by
regional organisations such as Regional Assemblies, sub-regional
strategies need to take account of their existence and to integrate
proposals for access land with such routes.
Green Belt
Green Belts exist to pursue the criteria specified
in PPG2, para 1.5. Almost all of them cross local authority boundaries
since, by definition, Green Belts are a strategic land-use planning
tool. In order to avoid isolated local areas of Green Belt (for
which the objectives can be met in other ways, eg strategic gaps,
green wedges etc), Green Belts need to be contiguous and consistent
with those identified in adjacent authorities. RSSs had a history
of specifying where strategic Green Belt reviews should be conducted
and, as with regional housing targets, this was highly unpopular.
Any releases of—or increases in—Green Belt land should
be left to the local authorities concerned but for consistency
need to brought to the attention of the strategic planning process.
Flood risk
Flood risk is a particularly important topic which
requires planning on a strategic scale, especially in respect
of built development which could either cause or be susceptible
to flooding. Upstream development can exacerbate and accelerate
run-off which could put land and buildings at risk downstream.
Alternatively, flood-plain development downstream can impede water
flow and lead to increased upstream flood risk. None of this respects
local authority boundaries: strategic planning is essential here.
Whilst the Environment Agency may be responsible for flood protection—and
it does comment on some planning applications—ultimately
it is a local authority's decision whether or not to grant planning
permission for built developments which may increase flood risk.
Transport networks
Whilst motorways and trunk roads are the responsibility
of the Highways Agency, other roads are the responsibility of
the local highways authority—county councils in two-tier
areas or unitary authorities. Network capacity is a major factor
in planning the size, nature and location major developments.
This is not something that can merely be handled locally since
the principal access to a particular major development may be
through another highways authority area and may indeed have implications
for road capacity over a much wider area.
It is worth adding here that RSSs contained a "Regional
Transport Strategy" (RTS) which proved to be little more
than a "wish list" of regional and sub-regional transport
projects. Since the Highways Agency and Network Rail have their
own criteria and procedures for evaluating and bringing forward
improvement schemes, the RTS was considered by many to be of little
value. However, there is a vital link between proposed strategic
road and rail improvement projects and large built developments.
Such improvement schemes may facilitate development and in turn
large developments may contribute towards such schemes.
Energy
Regional targets for renewable energy have never
worked since they were introduced. Attempts were made to assess
such targets on the basis of the perceived potential energy source
available area by area, but other factors have intercepted any
hope of achieving them. It is suggested that renewable energy
is taken out of strategic land-use planning and other, separate
procedures be used to plan provision. It is not a matter that
needs to be strategically planned and sites which cross local
authority boundaries can be subject to bilateral agreements.
Minerals
Minerals can only be extracted where they are found
and, although local sources are preferred where these are available,
minerals are often transported considerable distances to their
destination uses. This makes them an unsuitable topic for strategic
planning on the scale which we consider appropriate for other
purposes. Minerals were probably one of the few topics where regional-scale
planning worked (although even then some products were scarce
in some regions and so had to be planned nationally): it is suggested
that this should continue, albeit in a low-key and inexpensive
way. This would then feed into local minerals development frameworks.
Waste
Landfill operations, whilst they continue, albeit
at a reducing scale, are a sub-regional resource and as such need
to be planned accordingly. Similarly, energy-from-waste schemes
need a waste supply from a wide area for viability. However, there
may not be a good "fit" with the pattern of mainstream
strategic planning that is advocated in this Evidence. A separate
form of strategic waste planning should take place, again in a
low-key and inexpensive way. This would then feed into local waste
development frameworks.
September 2010
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