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

Written evidence from South Wiltshire Agenda 21 (ARSS 52)


South Wiltshire Agenda 21 was established in the 1990s. Our goal is to work towards a sustainable society where we do not consume more than our fair share of the earth's resources and do not compromise the ability of the earth to sustain life for future generations. We seek to achieve our aims by lobbying for policy change at global, national and local level and encouraging individual behaviour change. The group's members include over 50 individuals and 30 organisations, 4 schools and seven businesses in the South Wiltshire area (Salisbury and surrounds).


2.1  Our particular concern in respect of the abolition of Regional Spatial Strategies relates to consideration of "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, etc)."

2.2  Our evidence covers the following:

Some thoughts on sustainable development and the need for a "one planet" life style from the South West Regional Spatial Strategy (RSS) which was starting to move towards a more sustainable framework for development in the region.

An example is given from the South West in respect of transport demonstrating the need for a clear regional transport policy if infrastructure investment is to be targeted appropriately and sustainably.

There is a requirement for a Strategic Environmental Assessment (SEA) to be undertaken which considers the overall impacts of development. It is not clear how this will be provided in the absence of the SEA provided by the RSS.

We believe that the UK is likely to be in breach of the EU Habitats Directive if current regional Habitats Regulation Assessment work and the conclusions arising from this are now to be disregarded.

We are concerned that the Local Enterprise Partnerships, which seemingly will form a replacement for the RSS planning framework, focus exclusively on economic development and do not provide enough emphasis on the environment or sustainable development.


3.1   In the South West Region, where our group is based, we were pleased to see written acknowledgement in the RSS of the importance of living within environmental limits: "There is a tension which the RSS must help resolve, between further population and economic growth and the imperative to reduce resource consumption and, most importantly, the decoupling of growth and CO2 emissions. Consumption of natural resources or "ecological footprint" has a global impact. Growing demands for built development, infrastructure, food, fresh water, natural materials and energy, seriously risk the erosion of environmental quality and the life systems on which we all depend. The South West's ecological footprint is unsustainable as it stands. If everyone on the planet consumed such a quantity of natural resources and energy as an average South West resident, three planets would be needed to support life on Earth. Consequently, a shift is needed towards "one planet", lower consumption, with lifestyles which are more resource efficient."[71]

3.2   There is recognition in the SW RSS (para 1.6.7) that "The need to stabilise and then reduce the region's ecological footprint in the light of continued economic growth and lifestyle choices requires active promotion of efficient use of resources by business and individuals, adopting a "low carbon" approach. Regional action alone is unlikely to be sufficient and will require a step change in the attitude of individuals to the environmental impacts of their consumption choices in terms of the goods and services purchased and the consequences of unlimited, relatively cheap travel. National and international action is also essential."

3.3  This thoughtful and considered approach which has been one of the strands in the SW RSS has led to some challenging questioning of some long established dogmas which have held sway for decades in the shire counties of the South West. An example of one of these is the aspiration to dual the A303 for its entire length which is covered in section 4 below.


4.1  The Strategic Sustainability Assessment (SSA) of the draft SW RSS prepared in March 2006 referred back to an earlier July 2005 commentary which had noted that:

"The aim of the proposed strategy to deliver the capacity and services to encourage a switch to rail from road is commended from a sustainability point of view. However, this could easily be undermined by, firstly, the difficulty in securing the funding to deliver the improvements to rail required and the speed with which this can take place, and secondly, the upgrading of the A303/A358, which will provide a "more attractive" alternative. We recommend that SWRA needs to reconsider how it can achieve the aim of improving quality of life and access to opportunities in the region with less travel. In particular, the assumption that providing a second motorway-standard road link deep into the Peninsula is essential to the future well being of the region needs to be examined more critically." [72]

4.2  The draft RSS published in June 2006 noted that the SSA had expressed a fear "that improvements to the strategic road routes such as the M4/M5 and A303/A358 may increase traffic flows whilst not bringing the economic benefits wished for." Nevertheless despite these reservations there was at that stage still a policy (TR3) to "achieve a second strategic route into the region from London to dual carriageway standard utilising the A303-A358 in order to improve the resilience of the inter-regional network and maintain the competitiveness of the South West".[73]

4.3  The version of the SW RSS incorporating the Secretary of State's changes issued in July 2008 removed references to the policy for a second strategic route. The cancellation of the A303 Stonehenge improvement scheme in December 2007, after cost estimates for the proposed tunnel had risen to £540 million, may have had some bearing on this although this is not the reason given, which was that the policy implied that "the Exeter-London (via Taunton and/or Salisbury) [corridor] should be given greater priority over other regionally important corridors. We do not consider sufficient evidence has been put forward to support this view."[74]

4.4  The local authorities along the A303 appear to be having some difficulty in assimilating this change in policy, with the South Wiltshire Core Strategy published in July 2009 still taking the line that "Studies have confirmed the need to overcome these problems by dualling the A303 along its length" and stating that "Wiltshire Council will work collaboratively with agencies, such as the Highways Agency and the Department of Transport, to try and achieve an acceptable solution to the dualling of the A303."[75]

4.5  In the context of the inquiry into the abolition of the Regional Spatial Strategy we believe the above example serves to illustrate both the cross-boundary nature of transport planning and the reluctance which there may be to accept a policy agenda which incorporates sustainable development principles. A radical rethink of current transport policy is required if we are to meet the challenges set by carbon reduction targets in the coming decades. There is no evidence that the local planning authorities will propose or promote the greener alternatives which are required unless they are steered in that direction by strong regional and corridor based transport policies.


5.1  Linked to the RSS in the SW region—and presumably in other regions also—is the Sustainability Assessment (SSA) process which combines the requirements of a sustainability appraisal under PPS 11, and a Strategic Environmental Assessment (SEA) under the European SEA Directive. The removal of the mechanism whereby the cumulative impacts of development across the region are assessed must surely be a cause for some concern, especially as one of the reasons why the current RSS process in the South West had stalled was due to concerns regarding potential breaches of the Habitats Directive.

5.2  An example of combined impacts of development affecting environmental assets is provided by the River Avon Special Area of Conservation (SAC). The Habitats Regulation Assessment (HRA) prepared for the SW RSS concluded, inter alia, that there was no certainty that there would not be an adverse impact on the River Avon SAC[76] due to the scale of development being proposed at Bournemouth and Poole HMA, Swindon HMA, Salisbury HMA, Bournemouth, Poole and Salisbury SSCTs. It is noted in the HRA (para 3.9) that existing public water supply abstraction is already having a significant adverse effect on the interest features of the Avon special area of conservation (SAC)—before demand is increased by large RSS housing allocations in the housing management areas (HMAs) of Bournemouth and Poole, Swindon and Salisbury.

5.3  The above is just one example, the Executive Summary of the HRA lists 37 SPA, SAC and Ramsar sites where it is uncertain whether adverse effects on integrity will remain following incorporation of the HRA recommendations into the Secretary of State's Proposed Changes to the South West RSS.[77] The uncertain effects relate to the water abstraction, water quality and air quality impacts of development, and in many instances the protected site would be impacted by development in more than one local planning authority area.

5.4  It is not readily apparent, in the absence of the RSS and environmental assessments associated with it, who will be responsible for assessing the "in combination" effects of development in the future. Presumably this would require joint working between the local planning authorities involved. However it is hard to see how this would work, or how agreement would be reached regarding whose plans should be modified should "in combination" effects be identified.

5.5  It is worth stressing that an assessment of the potential effects of development on European sites is not a mere technicality which can be brushed aside. As the HRA for the SW RSS makes clear "The HRA should conclude whether or not a proposal or policy in a development plan would adversely affect the integrity of the site in question…. Significantly, HRA is based on a rigorous application of the precautionary principle and therefore requires those undertaking the exercise to prove that the plan will not have an adverse effect on the site's integrity. Where uncertainty or doubt remains, an adverse impact should be assumed".[78]

5.6  The European Union has powers to take infringement proceedings against a member state who is in breach of the regulations. Here in the South West region an example of where this could happen is given by the current ongoing investigation into the decision making process in Wiltshire and the South West region resulting from a petition (EU ref 440.053)[79] submitted on behalf of the White Horse Alliance. This relates to an alleged failure of the British authorities to comply with the EC Habitats Directive in connection with the proposed Westbury bypass and other major highway schemes.


6.1  It is not clear how, or whether, the goals of the "Local Enterprise Partnerships" which are proposed will incorporate environmental targets such as carbon reduction. The Expression of Interest in a Local Enterprise Partnership for Gloucestershire, Swindon and Wiltshire gives no indication that this is being considered. The term "environment" is only used in the context of the "environment" for economic or business growth, and an "environment" where "the role of the state, and its interventions, is significantly rolled back."[80]

6.2  Against this "laissez-faire" background it is not apparent how the current work done at a regional level to consider the "in combination" effects of development will be dealt with. The now de-coupled Local Authorities in the South West region have inherited a list of regional allocations and infrastructure schemes which could potentially breach the Habitats Directive due to their "in combination" adverse impact. As things stand we believe the abolition of the Regional Spatial Strategies and (seemingly) the shelving of the Habitats Regulations Assessments which accompanied them would lead to the UK being in breach of the EU Habitats Directive.

6.3  Our group is of the opinion that insufficient emphasis was given to environmental considerations in planning and decision making under the previous RSS regime. However, at least in the South West region, there was some evidence that the "economic growth at all costs" model was being challenged at the regional level, and environmental assessment work was questioning some of the levels and types of development being proposed. We need more environmental safeguards in place - but without the RSS and its associated studies and reports we have fewer. We hope the Communities and Local Government Committee will rise to the challenge of ensuring that the "greenest government ever" will swiftly put in place a planning framework to replace the RSS which will provide more and not less environmental protection.

September 2010

71   The Draft Revised Regional Spatial Strategy For The South West incorporating the Secretary of State's Proposed Changes - for Public Consultation July 2008 Para 1.6.2. Back

72   Strategic Sustainability Assessment of the Draft South West Regional Spatial Strategy prepared for South West Regional Assembly by Land Use Consultants with Collingwood Environmental Planning and Levett-Therivel Sustainability Consultants March 2006 (para 6.12). Back

73   Draft South West Regional Spatial Strategy, South West Regional Assembly, June 2006 Section 5 Transport. Back

74   SW RSS Schedule of the Secretary of States proposed changes & reasons for public consultation, July 2008, p.193. Back

75   South Wiltshire Core Strategy Proposed Submission Document, Wiltshire Council, July 2009, para 8.24. Back

76   South West Regional Spatial Strategy Proposed Changes Habitats Regulations Assessment Final Report Prepared for Secretary of State for Communities & Local Government by Land Use Consultants in association with Levett-Therivel Sustainability Consultants July 2008, para 3.10. Back

77   South West Regional Spatial Strategy Proposed Changes Habitats Regulations Assessment Executive Summary prepared for Secretary of State for Communities & Local Government by Land Use Consultants in association with Levett-Therivel Sustainability Consultants July 2008, Table 1. Back

78   South West Regional Spatial Strategy Proposed Changes Habitats Regulations Assessment Final Report Prepared for Secretary of State for Communities & Local Government by Land Use Consultants in association with Levett-Therivel Sustainability Consultants July 2008, para 1.5. Back

79   See http://www.europarl.europa.eu/meetdocs/2009_2014/organes/peti/peti_20100531_1500.htm Back

80   Expression of Interest The Local Enterprise Partnership for Gloucestershire, Swindon and Wiltshire, available on the web at http://www.wsep.org/media/uploads/LocalEnterprisePartnershipExpressionofInterest2.pdf


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Prepared 31 March 2011