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

Written evidence from The Campaign to Protect Rural England South East (CPRE SE) (ARSS 42)


CPRE has a long record of close involvement in housing and planning issues.

CPRE welcomed the removal of regional housing targets because they were top down, but we are sure some form of strategic planning will be needed to fill the void left by the abolition of the overall strategies.

The RSS involved extensive consultation and planning work in the region especially on directions for sustainable development. This work should remain accessible for the next, more local work on strategic planning.

The RSS set the framework within which current local plans (LDFs) are prepared, and has created the current "action mandate" through core strategies and other local development documents (LDDs). There is therefore a large gap following the revocation of the RSS. The strategic issues remain, now looking for locally focussed policies and solutions.

Housing development targets are being reset locally; some, but not all, are lower. Local authorities will continue to manage land supply and approve planning applications: they do not deliver the housing.

Local Enterprise Partnerships may have to take on some strategic planning of housing, infrastructure and transport, to fill the gap left by the removal of regional plans, but only if they are given a wider remit than solely promoting economic growth.

Provision of affordable housing—still a back log, is key in the South East.

More cooperation between authorities will be essential, and will need to be based on mutual benefit.

Data from the regional strategy work including ideas, plans and data should be made available to the new LEP teams, through the South East Councils secretariat, which is based at Hampshire County Council.


1.    This submission is made by the Campaign to Protect Rural England group in the South East of England (CPRE South East). It complements the submission made by CPRE nationally. CPRE has a long record of involvement in housing and planning issues, and especially working at a strategic level. This submission was prepared after discussions with CPRE county branches in the South East.

2.    CPRE is pleased that the regional housing targets have been revoked by the incoming government. We were always opposed to housing targets because they imposed on local councils who have no way of regulating the housing market except by means of land use allocations. Despite its ill founded structure the RSS process in the South East did a lot of good work to understand sustainable development in a pressured region where the environment and development are often in conflict. Many local authorities and interested parties were involved and there was a sound consultation process. Nevertheless the whole process was widely disliked, because of the constant pressure for higher housing numbers, disregard for local knowledge and valued land uses including greenbelts. The parallel diversionary initiatives of Growth Points and Eco-town housing targets added to the disrepute of the RSS process. It is very important that the good evidence base work and understanding is not completely lost as the people involved move on and the current radical restructuring takes place. As a new definition of strategic planning beings to emerge with the Local Enterprise Partnerships (LEPs), many of the same questions: on housing, the environment, transport and minerals, waste and water will be asked.

3.    The Planning and Compulsory Purchase Act 2004 brought in a statutory system of regional spatial strategies. These presented a vision for what the region will look like in 15 years' time. Regional planning became more important for the future of local communities, effective infrastructure and countryside protection than previously. This is because:

The Regional Spatial Strategy influenced what happens locally, because the Local Development Frameworks have to conform to it.

It was part of the local authority's development plan that has to be taken into account when deciding planning applications and making other planning decisions.

The majority of the planning body's members were councillors from the local authorities in the region, so they had regard to both region-wide and local issues.

It set out how its policies would be delivered: the focus was on deliverability and on implementation; on getting things done.

It had to help make things happen that were included in other strategies on issues such as tourism and energy.

Other strategies had to pay attention to what the regional spatial strategy said, for example on sustainability and climate change; the aim was for the various strategies to complement each other.

It was not intended to repeat or counteract guidance contained in national statements.

It was the only layer of planning between national policy and local development frameworks. It took over sub-regional planning and replaced the structure plans that county councils had produced since the Town and Country Planning Act 1968.

Their removal creates a very large gap in the planning system.

4.    It is also relevant to note that regional strategies were developed over a lengthy period of time. This allowed much buy-in by local authorities and stakeholders, and the ability of all participants to influence outcomes was significant. The South East Plan was given two periods of formal consultation, and this was regarded as an important element of democratic involvement at these stages. The public and local organisations had become familiar with the consultation process, and with the level of options available. This process of buy-in went some way to countering the fundamental flaws of an excessively top down, target driven system. It may also account for the fact that some very good groundwork was done to understand the sustainability agenda of a complex region containing huge differences in economic and social and environmental performance.

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

5.    There is a widespread view that removing targets will simply allow councils to avoid significant levels of development in their areas. However not all local councils want less. Many councils - perhaps as much as 50 per cent in the South East—want to maintain the present momentum as part of economic growth and regeneration strategies. The uncertain economic situation makes establishing reliable figures for house building very difficult in the short term. But the base data of house building ambitions in each local authority combined with five-year housing land availability land may give some idea soon of how the new locally generated figures relate to the previous RSS figures.

6.    In the absence of a regional level strategic plan it will become necessary for there to be some similar strategic level integrated approach with declared strategic aims for a sustainable approach to development covering economic assumptions; employment and housing ambitions and vision for the community or Local Economic Partnership area being planned. In the context of the South East, and applying experience learned under the previous system, the aims should generally be for reasonable levels of housing taking account of infrastructure provision; making better use of land; and a step change in affordable housing; together with making better use of existing stock; and working within the constraints of the local environment.

7.    The work on housing targets at regional level, wrestled with complex problems of household composition, age structure, and housing types. In the absence of a continuation of regional housing strategy, these factors will continue to be important but at local level, and plans will need to be based on locally relevant national data and local knowledge. The back log of affordable housing provision and the under provision recently of family houses will be issues that go forward to the new locally based strategic planning.

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

8.    The present incentive suggestion from the Coalition Government announced by the Housing Minister, Grant Shapps on 9 August is to pay local authorities a New Homes Bonus equivalent to the council tax of the new property over six years. It is said to be payable on approval of planning permission, and the money not ring fenced. While the money will no doubt be welcome to local authorities, it will be a minor element of local authority budgets and no more than a small proportion of the money needed to fund essential strategic planning work in a local authority to ensure houses are built in the right places and in the right numbers to match provision of infrastructure, comply with environmental constraints including flood assessments and local transport plans.

9.    The need for a five-year housing land supply is still in place and is well exceeded in many areas. This makes the need for incentives per se redundant. The councils involved need simply (and are required to) grant the applications that comply with their development plans. Housing land supply is a key factor in determining where houses are provided. There are wide variations in housing land supply distribution, from constrained areas like Surrey having only five years and the Isle of Wight 15 years. In 2008, there was enough land in the region for 235,000 dwellings, which is 8.5 years supply, on past targets.

10.  There are already incentives for affordable housing in the South East. These come mainly from the traditional funding streams of the Homes and Communities Agency, via social landlords, and have resulted in some 8,000 such houses being built annually in the region. Other provision has come from local agreements with large scale developers. Given the very significant demand for affordable housing in the South East it will be important that incentives regimes do not remove or replace funding for affordable homes.

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 and renewable energy)

11.  Co-ordination of policies and strategies is essential. Councils already have to work jointly with adjacent authorities, but this will not necessarily address wider issues on a geographical or practical basis to address the gaps arising from the revocation of regional strategy and organisation. Many local authority planning officers will have experience of life before RSS: in the South East, prior to the spatial strategies, there were regional planning conferences. Notably SERPLAN started in 1962 was a wholly-owned entity of the local government sector. This body was able to provide guidance for local councils on a wide range of subjects and policy areas, including energy, the rural economy, minerals and waste. The process of arriving at figures and policies was participatory, and included expert working groups reviewing policies and developing strategic positions. Similar arrangements pertained in other regions, and these were essentially voluntary with a degree of outside interested party involvement.

12.  In public sector work today there is a need for greater transparency, and wider consultation and involvement of communities. The agenda has also moved on as sustainability has become central and climate change adaptation and mitigation are always a consideration. Pressure on water supply and waste water provision in the South East and the requirements of the Habitats and Strategic Environmental Assessment Directives set a very different context from that under SERPLAN. Residents and communities now have strong opinions on and affiliation to green space and provision of safe cycling and walking and more recycling of waste, and better air quality and less noise and congestion. These and other changes argue for a different approach going forward, which will be necessarily quite complex even if locally based, and with cooperation. If the SERPLAN model were to be considered, as an approach to strategic level planning, it would therefore need to be evolved.

13.  A duty to co-operate will be difficult, if councils are not minded to do this, or share common aims. Many local authorities are competitive with their neighbours, for employment, resources, and may have long standing contested relations. A good example of this is the desire of Oxford city to expand its borders, and the view of surround authorities that it should remain closely contained. If a formal duty to cooperate is combined with mutual financial or other benefit of doing so, it will have greater potential. Cooperation based on a wider jointly agreed strategic objective is more likely to be achieved if there is a level of strategic planning shared across local authorities.

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

14.  Local Enterprise Partnerships will have to work on the tasks fulfilled by previous strategies, and fill some of the policy gaps left by the loss of RSS. As models of local cooperation and determination to succeed, they may have a defined geography, as exemplified by some of the proposals submitted. They may use or cross regional administrative boundaries as the Milton Keynes and South Midlands area has done for some years. It will obviously be difficult to decide which LEP bids should be approved in the absence of a national planning framework, but in this situation the geographical pattern and spatial planning intentions of approved LEPs may be a key factor for the national framework preparations. It the present time, and looking at the range of LEP bids, it is unclear how the strategic planning functions could be fulfilled.

15.  The new approach would have to encapsulate both the challenges and the dilemmas of the region. On the one hand, some consider that economic growth and concomitant development has been a necessary condition for prosperity and social and environmental action in the South East. On the other, it is increasingly apparent that the price of that growth, in terms of resource consumption and other net impacts, including noise, congestion, air quality and loss of tranquillity is very high and needs to be addressed to avoid destroying the physical, social and environmental assets that have account for the success of the South East. In recent years the use the Sustainability Appraisal has proved to be a useful tool for working through these dilemmas.

16.  LEPs would need a core statement of policy or vision, and this would need to take into consideration other influences outside of their boundaries. The South East has long been conscious of its global and European position. It is also aware of its relationship to other English regions. There has been an evolving relationship with London, as a capital region. There is a need to have a sustainable development context set by Government policies and local frameworks. There are continued imbalances between the east and west of the region, and a strong urban influence from previous regional statements. All this requires working at a level between national and local. The need for efficiency in the use of natural resources is overriding. There is also a need to identify investment priorities for health, education and affordable housing. LEPs will be looking to supplement their own visions with an understanding of outside influences and opportunities, at whatever geographical level they are operating.

17.  LEPs in the South East will emphasise economic opportunity and enterprise aspects, but should also celebrate its varied and attractive countryside. They can only fulfil a planning function if promoting a more sustainable pattern of development, a more bio-diverse environment, as well as reducing levels of natural resource consumption. The scale of development they propose will be scrutinised carefully, as will the timely delivery of infrastructure on which any development is dependent. It might be possible to give LEPs a spatial planning function if this were carried out in an integrated way, respecting the principles of sustainable development. This would also avoid the proliferation of structures at this strategic level.

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

18.  As stated in the Introduction, a great deal of work, including data collection and research has been done to understand the characteristics of the South East and consider—through implementation plans as well as strategy and policy, how to evolve the region in the direction of more sustainable development including behaviour change. It is important that this work is not lost, and that it remains useable and accessible. It will also assist monitoring and evaluation purposes in the longer term. In the South East, much of the data collected over recent years has been deposited with a new group: South East England Councils SEEC. SEEC is based at Hampshire County Council, and will provide a limited updating facility, based on local authority returns and manage access to previous strategy work and topic papers.


19.  The removal of RSSs, although widely anticipated, has happened more quickly and suddenly than expected and there are concerns that the vacuum that has followed their revocation undermined established good principles of plan-led development. The current period of "creative destruction" to remove the top down target driven system, needs to be followed soon by a new sub national or supra local system that enables spatial strategic planning to be rebuilt.

20.  The new LEPs will have a lot of choice about what to include in their strategies. Public involvement is essential throughout this process. Local people should be asked to consider what is important to them about their areas or sub-regions, particularly if the remit includes planning. This should include wildlife and landscape, and cultural heritage in the planning options. The new bodies should deal with the issues people care about, as well as ensuring a healthy economy.

21.  The LEPs must strive for openness in their planning and monitoring, whatever their mandate. They must meet in public, with papers freely available in advance to the press and public. The results should not be judged on the basis of rightness or wrongness, but on the overall soundness. Implementation plans will essential, and the Government should be committed to continued partnership delivery. We are pleased to note that the voluntary and community sector will be encouraged to come forward and take part in strategy development and monitoring. All future stages of LEP development should include involvement by all sectors. LEP plans should include details about investment needs to facilitate proposals, monitoring and local delivery vehicles, where appropriate.

September 2010

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Prepared 31 March 2011