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

Written evidence from Community and Regional Planning Services (ARSS 28)


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.


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.


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.


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


Selected land-use planning topics and their suitability for some form of strategic planning


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.


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.



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.


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 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.


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

previous page contents next page

© Parliamentary copyright 2011
Prepared 31 March 2011