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

Written evidence from Young Planners' Thought Leadership Group (YPTLG) (ARSS 73)


1.1  The YPTLG is not an organisation or body; it is a collective of opinions and ideas from a group of young planners (defined loosely as under 35 years of age). The group is open to all with an interest in attending discussion meetings with a view to generating ideas and influence on a range of spatial planning matters. Meetings will be held when necessary. The intention of YPTLG is to give a voice to young planning professionals, notably through the present period of planning reform. The outcomes of the group will be shared with other organisations who express an interest.

1.2  The YPTLG has no formal membership; the submission has been signed by individuals who are practising planning professionals. As such, within this submission "YPTLG" simply refers to those individuals who are signees to the submission.


2.1  General:

2.1.1  England (with the exception of London) has become the only country in the UK and EU without an effective strategic planning system required to make strategic decisions at spatial scales below the national, but above the local level. This makes it increasingly difficult to ensure the sustainable management of the country's natural resources. It also makes it difficult to coordinate and combat the effects of climate change below the national level, as local solutions may not be of significant scale to make a substantive impact. The YPTLG is concerned that while until now other countries have looked to England and the UK for inspiration and guidance in town and country planning best practice, in the future, this learning relationship may be reversed.

2.1.2  The art and science of Town Planning was borne out of the "localism" agenda with local communities and entrepreneurs taking direct action, as evidenced by the garden cities movement and philanthropically-delivered housing developments in the northern coalfields in the nineteenth. The YGTLG is concerned that the current "localism" approach is too "politically driven" without foresight into understanding the limits and restrictions on locally-led action, socio-economic impact on future generations, and the sustainability of town planning as a respected profession.

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

2.2  Implications:

2.2.1  Many Local Authorities have delayed or restarted the production of Local Development Frameworks (LDFs), resulting in continued delay with local plan making. However in certain areas without adopted LDF Core Strategies there is now limited planning policy from which to direct sustainable development. As a consequence there is now much reduced development industry certainty to invest in development proposals (notably owing to the complete lack of any transitional arrangement). This is affecting development investment, and investment into the required professional skills to deliver sustainable places. The planning consultancy and urban design industries are shrinking. The YPTLG is concerned that future generations will bear the brunt and unintended consequences of these rushed reforms by not having access to affordable homes close where they work and to high quality of living. There is a need to understand how the newly formed Local Enterprise Partnerships (LEPs) will integrate with spatial planning, to help ensure economic growth is continually fostered and supported across England at local, sub-regional and national levels.

2.2.2.  Sub-national development redistribution has also now been curtailed (the former "sustainable communities plan"). The former RSS provided a mechanism from which to direct growth elsewhere in the south (essentially from the Home Counties to Cambridgeshire/Milton Keynes/Northamptonshire). Local level planning alone cannot achieve this spatial rebalancing, and may cause unnecessary development pressures in locations of environmental sensitivity. The YPTLG believes in a balanced and prosperous England and is concerned at the potential for increasing regional disparities in housing affordability and access to quality housing exacerbated by the reforms. The RSS was not perfect, but the vacuum caused by its loss is not helping.

2.2.3  There is now a severe threat to the art and science of Town Planning which will result in less individuals being attracted to the profession, which in turn will result in a major skills shortage in three-five years' time. The driving principles of a positive spatial planning system, enshrined in reforms since the mid- 1990s have seemingly been lost. The principles are not important in themselves, but there is a hope in the profession that positive spatial planning will continue—we can make things better for local communities through good spatial planning. In addition, the ongoing uncertainty (and reduced planning applications) is resulting in job redundancies. Many experienced strategic planners currently in the abolished regional planning bodies and regional development agencies will have their employment terminated, and the YPTLG is concerned that future generations will not have the benefit of access to quality mentors and inspiration. We need new planners, but we need the breadth of experience from others too. This is true across local government and the private sector, where a drop in the level of development is reducing the pool of talent we will be able to draw on in the future.

2.2.4  Further uncertainty about the future of Community Infrastructure Levy (CIL) and recent changes to planning obligations policy may result in reduced infrastructure delivery as few Local Authorities are progressing with a Levy and the scope of Section 106 has been reduced. The general reduction in infrastructure delivery may cause more conservative development growth scenarios than required to enable wider economic growth or meet demographic needs (notably housing). The YPTLG would like to see the Committee clarifying the responsibilities and any potential changes to the infrastructure planning and delivery process with CLG.

2.3  Ideas as Solutions:

2.3.1  The YPTLG strongly believes that changes will be needed to ensure that new development and construction will help fuel the economic recovery, respond to the threat of climate change and create a more sustainable England, within a UK context. It will also permit current and future regenerations to have access to a decent home, responding to the acute housing crisis. These objectives need to be at the heart of the proposed reforms.

2.3.2  The YPTLG presents the following ideas for the Committee's considerations:

1.    National government should take a more proactive role in building more high quality homes for current and future citizens of this country, and not merely pass responsibility to local government, local communities or developers.

2.    The proposed National Planning Framework (NPF) should be introduced as a National Spatial Framework (NSP) in order to a) benefit reduced level of PPS/PPG b) and critically also form a fully tested, consulted, and sustainable national strategic planning framework which outlines high-level strategic development principles. The NSP could also incorporate the emerging National Planning Statements (NPS). The NPS should be put into effect from 1 April 2012 once all LDF Core Strategies are adopted for transitional purposes (to avoid a policy deficit scenario of there being no PPS/PPG). The NPS should form part of the development plan, and where it may conflict with the LDF, it should take supremacy (when in the national interest). The NPS should be supported by evidence, building on the existing evidence base.

3.    It would have been beneficial to retain the policies in the RSS on a transitional basis, to minimise the uncertainty we currently have in the system. The YPTLG await the outcome of the current court case with interest. The RSS system was however not perfect, notably with regard to the democratic deficit. Instead therefore a strategic planning system should be created which better links democracy with planning, for example through the introduction of city Mayors, or elected sub-regional authorities;

4.    The proposed Local Enterprise Partnerships (LEP) should be provided with Government incentives to enable the "duty to cooperate", notably via the production of effective sub-regional planning strategies and/or joint LDF core strategies. In doing so, LEPs as future strategic leaders for guiding sustainable development should be directly accountable, democratically elected bodies, and given housing and planning powers.

5.    Local Authorities to be set national targets (with incentives) to have adopted Core Strategies by 1 April 2012.

6.    The Infrastructure Planning Commission should be retained.

7.    The Government should provide certainty over CIL or any new development tariff system at the earliest convenience.

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

2.4  Likely Effectiveness:

2.4.1  The new proposals for "Community Right To Build" or "Neighbourhood Plans" aspire to provide the link between local need and local delivery. However without a proper skills framework and oversight, they threaten the standing, and transparency of planning process. The YGTLG believes giving greater roles for regional and local community organisations (ie with the assistance of regional Planning Aid community officers) and utilising best practice tools for community engagement should be the pre-requisites for improving local housing outcomes. Planners want to work with communities to achieve positive outcomes and believe that improvements could be made utilising the existing planning system.

2.4.2  Proposals to allow developers to "compensate" local residents also risk undermining the planning process and could be viewed as bribery. The YGTLG continues to support the current fundamental principle of Section 106 planning obligations that "planning permission should not be "bought or sold". Local government as a whole has worked hard to separate monetary gain from decision making processes and the current reforms are difficult to reconcile with these experiences.

2.4.3  YPTLG would like to see a programme of training for Member Review Panels and are concerned that, unlike the proposed enhancement elsewhere in the proposals, there is a risk to the legitimacy of the right to appeal.

2.4.4  The principle of additional Council tax arising from new development is laudable; however, we would like to see the funding used to benefit the new development and those directly affected by it (i.e. mitigation and compensation) rather than simply being used as an overarching Council grant.

2.4.5  A coherent mechanism for greater than local spatial planning is required, particularly with regards to infrastructure and transport planning. It appears that the Government do not want to be overly prescriptive in their guidance to LPAs, however to think that the "duty to consult" will ensure that LPAs engage in greater than local spatial planning is naive. There is a suggestion that LPAs within regions could "co-operate" to prepare a spatial plan to sit above the LDF Core Strategy. The Select Committee should ask the how such a duty will operate.

2.5  Ideas as Solutions:

2.5.1  The principles for localism and greater democratic accountability or involvement can be achieved via modest alterations to the present planning process. Most of the measures announced may not be necessary to meet the Governments agenda, or to meet the aims of sound town planning. The YPTLG presents the following ideas for the Committee's considerations:

2.5.2  Greater engagement and partnership working with businesses and the private sector to kick-start the step change in house-building. This includes ensuring the private sector has a greater long-term stake in local development.

2.5.3  LDF Statement of Community Involvements could be abolished as being time and resource intensive. Instead statute should make clear that the process of creating LDFs and all major planning applications should be accompanied by a minimum level of community engagement. A resource saving measure could be to require Councils produce a general community involvement statement that applies to all functions, including planning.

2.5.4  Improving the skills of Elected Members should be prioritised as a key area to enable them play a far greater role with the determination of applications, possibly by setting out core parameters for major schemes at the outset, or getting involved with the process. This could mean a shift from the present planning officer "recommendation" to Elected Members role to once of greater partnership with Members.

2.5.5  Permitted development rights should be extended further to save resources. This measure would have benefits of streamlining planning, allowing focus on more critical major or strategic issues, whilst also increasing the rights of individuals.

2.5.6  The role of Local Development Orders (LDOs) should be better incentivised to provide suitable (and local) methods to encourage sustainable development.

2.5.7  Greater certainty over CIL (and potential additional Government grant funding) would be preferential to the proposed Council tax incentive proposal as the monies generated from development would be directed to infrastructure and community needs associated with it. In terms of the "Duty to Cooperate' the following questions should be asked:

What will the duty involve to ensure that LPA's do co-operate on a spatial planning level?

What are the parameters for identifying if a LPA has not complied with the duty?

Who will regulate it and what are the penalties?

Of significant importance, with most LAs facing up to 40% budget cuts, how is this going to be resourced???

What are the transitional arrangements to plug the gap between RSS policy and Core Strategy policy (as legislation dictates that DPDs cannot replicate RSS policy)?

2.5.8  In terms of ensuring greater democracy and planning, cities—or city-regions—led by a democratically elected Mayor could provide clear leadership and be highly effective for strategic planning as well as other functions. Where this model is not appropriate, LEPs formed on a sub regional basis could have a formal strategic planning role. The opportunity exists to radically rethink local government and governance arising from the proposed reforms to the planning system.

3.  Signatories to the submission

This submission represent the views of the YPTLG who were willing to sign the submission.

September 2010

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