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

Written evidence from David Lock Associates (ARSS 66)


S1.1  The abolition of the Regional Spatial Strategies has led to confusion and uncertainty in the planning process. It has led to delays and abandonment in preparing development proposals and in local planning functions.

S1.2  Housing delivery rates will fall. This is a result of delays due to uncertainty, and as a result of planning authorities believing that they have the opportunity to reduce delivery targets. I do not agree that the presumption that housing targets can be reduced is well founded, and I believe that the disparity between housing need and housing delivery will increase.

S1.3  Some important planning functions previously undertaken by the Regional Spatial Strategy will need to be addressed by different means. This includes strategic infrastructure planning and the mediation of national and local planning objectives.

S1.4  The proposed community incentive fails to link housing need and delivery and instead establishes a crude financial incentive. There will be a need to establish a transparent and democratic method for managing communities' expectations of incentives available, and to ensure effective delivery of community benefits in a way which benefits all parts of society.

S1.5  I believe that the void created between national and local planning must be filled where a need for delivering specific national objectives arises.


1.01  My name is Lawrence Revill, I am the Managing Director of David Lock Associates. I am a Chartered Town Planner and have more than 30 years of professional experience. My company provides consultancy advice on matters relating to town planning, urban design and master planning. It was formed in 1987 and operates nationally and internationally employing 47 professional staff. Our clients are drawn from the public and private sectors and include local planning authorities, non-departmental public bodies, other public agencies, private landowners and developers.

1.02  My firm is employed to advise on planning strategy and other planning matters and to prepare planning guidance, strategies and development proposals (including outline and full planning applications). It specialises in providing advice at a strategic scale and for proposals where complex planning and design issues arise. Our projects may last for just a few months to a decade or more.

1.03  My colleagues and I deal with Local Development Frameworks and, until recently, Regional Spatial Strategies on a daily basis. We have represented a broad range of clients at Regional Spatial Strategy Examinations across the country, and previously provided an equivalent role in relation to Regional Planning Guidance. We are therefore very familiar with the role of regional planning and its interrelationships with and implications for national and local planning and the delivery of development. The health of the development sector has real and early consequences for the business performance of David Lock Associates.

1.04  My evidence is presented in the following order. First, I set out my and my colleagues' experience of the immediate consequences of the abolition of the regional spatial strategies; I then consider the implications. I then consider the emerging proposals for housing delivery incentives and set out my views on what should then be done.


2.01  The abolition of the Regional Spatial Strategies (RSS) has led to confusion, prevarication and uncertainty amongst those proposing development and to uncertainty and inertia amongst those responsible for planning for sustainable growth in planning authorities. This is particularly true for medium and large scale proposals (which I consider to be in the order of around 200 to 1,000 dwellings, and 1,000 or more dwellings, respectively).

2.02  In the case of the public sector, decisions (which have seldom been timely) on how to proceed, if at all, with the various Local Development Documents forming part of the Local Development Framework have been beset by further delay, uncertainty and political procrastination. In the case of the private sector, investment decisions have been delayed. I deal with these in turn.

2.03  There has been a well-publicised destabilisation of both the political and technical aspects of public sector forward planning functions. The removal of a key component of the statutory Development Plan has led to uncertainty about the validity and robustness of plans prepared in accordance with the now abolished RSS. It has caused uncertainty as to how to continue, if at all, with plans in preparation.

2.04  Our recent experience suggests that there is a widely-held expectation among local authorities of the emergence of further guidance about how to proceed. It is becoming evident that government believes that planning authorities have all they need to proceed with their forward planning[104], but this has not been made explicit and so is not reflected amongst Councillors or planning officers. This has translated into planning paralysis. This in turn has compounded confusion in the private sector, reinforcing general uncertainty and perception of risk. Risk is the greatest disincentive to investment, irrespective of need and demand.

2.05  In terms of the private sector, my experience (and that of my colleagues) is that there has been massive uncertainty which has led to delays in decisions about whether to invest in drawing up proposals for new housing development and leading to a reduction in the level of investment. This trend is particularly acute where development is dependent on major upfront investment. This has meant stalling and, in some cases, the abandonment of development proposals. This is a consequence of a forward planning and development control process which has no clear or consistent understanding about which planning policy carries material weight, which may be subject to early review, and a lack of clarity as to whether any new (and decisive) guidance is to be issued. In simple terms, the rules by which any planning application may be judged are no longer clear to the judges, and the rules that govern how proposals should be formulated have yet to be re-written.

2.06  This has led directly to fewer new proposals being commissioned from companies such as mine, and a slow down in the progress of those proposals already being promoted. A number of clients have decided to defer the preparation or submission of planning applications, including delaying master planning work which will underpin those development proposals.

2.07  There has been much greater emphasis on progressing small scale proposals (typically those with fewer than 200 dwellings) which can progress without reference to a regional spatial planning perspective or emerging Local Development Frameworks. In the short term such proposals will make a modest contribution to housing supply, but it is likely that there will be a catastrophic reduction in housing delivery in the medium term as the gap in delivery from currently stalled strategic sites becomes more apparent.

2.08  The initial consequences of the abolition of the RSS has therefore been uncertainty among development promoters and the stalling of housing delivery.

Implications for housing delivery

2.09  The abolition of the RSS has created a gap in the hierarchy of planning policy whose functionality was steered by the existence of a regional planning process. That is not say that the RSS was always the most effective or appropriate tool (the regional planning process was undoubtedly flawed), but it was nonetheless the only link between the abstractions of national planning and site specific local planning. The LDF structure was the local manifestation of the Regional Plan. Its removal therefore gives rise to a vacuum in strategic planning terms. I return to the question of whether this void should be filled in subsequent sections of this submission.

2.10  In the absence of the RSS, and in the absence of anticipated guidance about what local planning authorities should do next, Councils have prevaricated. This situation has allowed some political posturing to occur that is unconstrained by a proper understanding of community needs. This, in my view, is regrettable. My company has direct experience of many local planning authorities where the production or approval of Local Development Framework documents is delayed because Councillors now believe that they are free to determine much lower development targets and Council officers have not been robust on the evidence that they already have on requirements and needs. Certainly, the previous system established a higher housing delivery target than many Councils may wish to meet, but that alone did not mean that those targets were wrong. Local evidence of requirements and needs regularly indicates targets higher than those adopted in RSSs. As yet the joy that comes with the freedom to set local targets is not tempered by awareness of the responsibility to plan properly for all members of the communities; those who have not as much as those who already have and shout loudest while pulling up the drawbridge.

2.11  So an impression that this was an entirely top-down target is inaccurate—the targets were generally based on discussions between constituent authorities, drawing on statistical evidence published by government and local research. The final RSS targets were usually the result of horse-deals between elected Authorities to address the forecasts of household growth and job needs that are not contested by the new Government. So the demographic that underpin the requirements and needs are unchanged. Reducing targets without having actually considered the reality of the underlying demographic and local community requirements and needs is a false dawn.

2.12  Powerful evidence is already available to planning authorities in the form of their Strategic Housing Market Assessments, although many elected members appear to be blissfully unaware of their existence, contents and their consequences. This evidence has usefully been collated by Shelter[105] and provides a stark picture of the consequences of failure to meet housing need.

2.13  It is clear to our company that a significant number of planning authorities believe that the inevitable consequence of the abolition of RSSs is that housing delivery can and should reduce. We tend to agree that delivery rates are likely to fall, but needs will grow. A general housing shortage and continued house price inflation will turn this into a housing crisis.

Other implications

2.14  Alongside the matter of identifying what level of development is appropriate for an area sits the question of how that development should be served in terms of infrastructure? I consider the term "infrastructure" to encompass social, community, transportation and utilities networks.

2.15  The RSS provided a basis for the identification and co-ordination of strategic and cross-boundary infrastructure by providing a framework for assessment, investment and delivery, aligned with the spatial distribution of development proposed. This provided useful (though not faultless) guidance to infrastructure providers as to the broad location and scale of development for which investment would be required. The RSS process also allowed infrastructure providers—including those proposing strategic infrastructure as part of their development proposals—to have an influence over the spatial planning of the region in a single forum. I have direct experience where this forward planning of development and infrastructure has provided certainty to both Core Strategy Examinations and at Inquiry into Section 78 planning appeals. I do not believe that such certainty exists any longer.

2.16  It is not clear to me or to my colleagues how this coordination of infrastructure and development will now happen. This uncertainty may result in uncoordinated and ineffective infrastructure investment that will adversely affect the deliverability of new housing. Private sector developers alone do not have the capacity or capability to deliver strategic infrastructure. While it is right for them to contribute to the cost if its delivery, they cannot and should not be expected to coordinate, plan and deliver this infrastructure in response to other proposals beyond their control. This can and must be undertaken in response to an overall spatial plan.

2.17  The RSS also provided a mechanism for mediating between the local and the national interest. I firmly believe that securing an adequate supply of housing to meet demonstrated needs is a matter of national importance. I can only assume that in choosing not to revoke specific and relevant sections[106] of Planning Policy Statement 3 (PPS3) Housing in June 2010 (when other sections were removed), that the Government shares that view. The revocation of RSSs has eliminated an important balancing mechanism, removing the means of reconciling local and national interests when undertaking forward planning. This is a fundamental weakness which will give rise to considerable housing under-supply in the medium and long term. There is also considerable danger that short-term political influences will have a negative impact on housing delivery by disrupting supply or periods of instability relating to the local political cycle.


3.01  Some details of the proposed housing delivery incentives have been announced, although there remain uncertainty about the affordability of that mechanism and how and when it is to be implemented.

3.02  It is unclear how the incentive scheme will relate to housing need—the mechanism announced so far appears to provide a financial reward for delivering housing, regardless of whether the amount of housing delivered is sufficient to meet identified local housing requirements and needs. Thus the mechanism appears to ignore any national objectives for housing delivery (in relation to demographic need and household formation rates), and will emphasise housing as a commodity rather than a fundamental human right. There is considerable potential for those authorities not in need of further financial support to simply turn away housing proposals and for those in need of financial support to find it difficult to refuse proposals, irrespective of local requirements and needs. This approach appears to fundamentally distort the principle that housing supply should respond to assessed housing needs and be underpinned by rational spatial planning.

3.03  Such additional financial demands could simply divert payments from existing mechanisms. It is not realistic to expect that existing S106 obligations, with or without a further or offset CIF contribution, can be maintained alongside a third mechanism for financial contribution to the mitigation of impacts of development.

3.04  It is also unclear if and how monies received to ring-fence them so that they are spent in a way that relates to the proposed development and its local context. There will be a need for Councils to define who benefits and how they should benefit—there is no clarity on what process will be used to manage this, or who should be the decision makers. There will immense pressure on Elected Members because of the very significant financial incentives which could conflict with other planning considerations. Sophisticated mechanisms will be needed to effectively balance financial considerations against environmental, infrastructure and social issues.

3.05  Information released to date suggests limited control or "ring-fencing", which offers affected communities little certainty that they will benefit from the payments received by the planning authority and how a mechanism for accountable and transparent decision making will be established. Crucially, a mechanism would need to ensure that the widest needs of a community are met—not just the needs of those who present their case most forcibly or most eloquently.

3.06  Finally, I consider that this mechanism has the potential to encourage a disproportionate negative response. There is a significant risk of an increase in opposition to planning applications as a covert means of trying to extract further mitigation measures. This leads to the potential for corruption of true opinions of the acceptability of development that could divert monies away from mitigating impacts and delivering higher quality services and facilities.

3.07  In our view, increasing the scale of the incentive to ensure that all authorities deliver some level of housing is not a plausible answer. This will simply increase the potential for financial distortions and still fails to link housing need with housing supply. Much better to create an obligation to meet needs as the fundamental starting point.

3.08  Critically, we believe that any incentive to deliver housing must link to a demonstrable need for housing in a locality. We see no evidence of that in the proposals set out. We have little confidence that this mechanism is an appropriate or effective means of ensuring that housing needs are met.


4.01  I believe that there is a need to bridge the newly created gap between national and local planning. This need not mean the creation of an alternative regional planning approach—there was much that was cumbersome and ineffective in the regional planning system and subsequent regional spatial strategies. What is needed, however, is a means of ensuring that national planning policy objectives are achieved, and of coordinating effort to deliver specific objectives within identified spatial areas.

4.02  The identified spatial areas may be defined by central government as areas in which change is necessary to meet national policy objectives, or could be defined by partnerships in local government as areas where change is sought and promoted. These would tend to be functional areas related to settlement patterns with social and economic relationships, unconstrained by administrative boundaries. In any event, there needs to be a basis for infrastructure investment decisions, and where necessary, effective cross boundary working and cooperation. It is in this context that a "duty to cooperate" would be necessary to ensure effective spatial planning.

4.03  Under a localism agenda the nature and scale of such change would be driven by local views, delivered in a "bottom-up" approach, in the context of local evidence of requirements and needs. However, it should be recognised that in some areas where critical issues arise, encouragement must be supported by enforcement and a formal duty to cooperate should be established.

4.04  These spatial areas would respond to a requirement to plan beyond narrow local interests, respond to national inequalities, provide for strategic and inter-local infrastructure or to address pressures arising from demographic change. The ambition must be to balance strategic and local interests to ensure that neither dominates. The underlying principle however, is to recognise that unfettered localism has the potential to lead to isolationism and unenlightened self-interest. This should be avoided, and need not preclude collaborative and accountable local-decision making.

4.05  The issue of which organisations should be tasked with this supra-local planning will need careful consideration. The previous regional planning bodies developed a reputation for being cumbersome, remote and out of touch with local planning sensitivities. There was often antagonism between regional and local planning bodies. Locally-generated structures would conform to the localism agenda, but need to transcend a purely local standpoint—they should have a responsibility to wider interests and deliver in the context of wider needs. Critically, there needs to be adequate professional input, and a participative and democratic localism.

4.06  It is not clear to us whether Local Economic Partnerships are the solution—proposals were prepared to meet an unrealistic deadline at a time of significant change and uncertainty. Careful consideration needs to be given to ensuring appropriate and robust mechanisms for dealing with supra-local planning—this is unlikely to have happened in this first burst of restructuring.

September 2010

104   Steve Quartermain, Chief Planner CLG, remarks during closing speech, TCPA Planning Summer School, 10 September 2010. See also the reporting of this by the President of the Planning Summer School at

105   See http://localhousingwatch.org.uk/ Back

106   See paragraphs 10 and 33 of Planning Policy Statement 3 (PPS3) Housing, CLG, June 2010. Back

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Prepared 31 March 2011