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


Written evidence from Devon County Council (ARSS 79)

SUMMARY

In the absence of regional housing targets it will be important to demonstrate how the cumulative levels of provision made by LDFs address wider housing need and demand at the sub regional level as individual LDF areas do not relate in any way to Housing Market Areas or economic functional areas.

Government needs to re-assess national forecasts to ensure their robustness and regain ownership of them at a strategic level. This national framework needs to be the starting point from which more local (sub regional or LEP area) assessments are be undertaken in order to underpin LDF preparation.

The concept of incentivisation is welcomed in principle. The concept does however need to be accompanied by clear rules about apportionment as there are distributional issues, particularly in two tier local authority areas.

It is essential that LDFs are not prepared solely on the basis of the individual planning authority's area, but rather in the context on the surrounding areas, utilising a shared evidence base. Government should therefore ensure that there is a focused but robust sub-regional approach underpinning LDF preparation, based on a consensus established through a clearly defined "duty-to cooperate" between local and strategic planning authorities in order to address major cross-boundary strategic investment and planning choices which need to be made.

A "duty to co-operate" would help to promote consensus but the scope and nature of such a duty needs to be clearly set out and the specific responsibilities of co-operating authorities defined. Local Enterprise Partnerships do offer a potential mechanism through which a strategic context can be established for LDF preparation, but this role should be formally identified, if and when such partnerships are endorsed by Government, as a key element of the "duty to cooperate".

It would be helpful for upper tier authorities to be given a duty to monitor cross boundary strategic issues and maintain the evidence base necessary to inform a shared and agreed sub regional evidence base for LDF preparation. This could be secured through the LEP mechanism or cross boundary cooperation of upper tier authorities.

It would be helpful for Government to ensure there is a clearly defined duty-to-cooperate between upper tier authorities to achieve sub regional minerals aggregates apportionment and waste facility provision.

Question 1—The implications of the abolition of regional house building targets for levels of housing development;

Historically, the publication of population and housing forecasts at national and regional level by central Government has provided a broad framework within which overall housing supply could be assessed against housing need. More recently, however, the targets included within emerging regional strategies have been driven more by policy aims and aspiration than technical evidence. Regional targets have therefore become less robust, and have been based on short term trends that cannot be use as a foundation for long term planning.

It is critical that housing provision within LDFs takes account of patterns of population change, migration pressures and assessments of housing need and demand. In the absence of regional housing targets it will be important to demonstrate how the cumulative levels of provision made in LDFs address wider housing need and demand. These assessments can be undertaken at a sub regional scale, but individual LDF areas do not relate in any way to Housing Market Areas, or indeed economic functional areas. In areas such as Devon, the pressure and need for new housing is not derived from within each locality but primarily from migration and movement between Districts.

In the absence of regional targets a purely "bottom up" approach will therefore tend to focus on development constraints and fail to provide a sound basis for assessing need and demand. The essential relationship between housing supply and demand would be lost.

Current evidence suggests that while some LPAs are retaining their previous regional targets, a number are looking at significant reductions. As a result, even assuming every LA meets their own targets the overall level of provision is bound to be below the original regional target.

In reality, however, the former regional targets were not fully deliverable and not related either to the capacity of the development industry or the availability of essential infrastructure investment. In areas such as the SW, the removal of the regional targets may not therefore necessarily reduce actual housing development rates in the medium term.

In the longer term context, two key issues need to be addressed. Firstly Government needs to reassess the national forecasts, ensure their robustness and regain ownership of them at a strategic level. Secondly, this national framework needs to be the starting point from which more local (sub regional or LEP area) assessments are be undertaken in order to underpin LDF preparation. This will ensure that the planning system secures a level of housing provision that is deliverable and can be seen to meet the immediate and longer term needs of the wider community.

Question 2—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

The concept of incentivisation is welcomed in principle. Development brought forward should however be done so within the context of adopted Local Development Frameworks which have been tested for sustainability.

The concept does however need to be accompanied by clear rules about apportionment as there are distributional issues, particularly in two tier local authority areas. Whilst it will be District Councils preparing and adopting LDFs, the County Councils will bear the major cost of upgrading key infrastructure particularly for transport and education provision. This also needs to take account of the impact of development across local authority boundaries where development is close to the boundary with another authority and may have significant impact in terms of issues such as transport and education on the adjoining authority.

Question 3—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, &c)

It is essential that LDFs are not prepared solely on the basis of the individual planning authority's area, but rather in the context on the surrounding areas, and utilising a shared evidence base. This is especially the case where there are major cross-boundary strategic investment and planning choices to be made (eg on strategic housing and employment growth, transport and communications investment, education and green infrastructure, renewable energy and the management of the natural environment). Individual LDF authorities need to be able to make informed decisions about these strategic choices, or understand the cumulative effects of their decisions. This does not require an additional level of plan making—but consensus must be formally agreed, and tested through the LDF examination process.

Government should therefore ensure that there is a focused but robust sub-regional approach underpinning LDF preparation, based on a consensus established through a clearly defined "duty-to cooperate" between local and strategic planning authorities. A broadly defined duty to cooperate would not be sufficient to ensure the effective use of resources or secure efficient and joined up decision making.

The duty to cooperate must ensure that advice is both sought and acted upon if it is to be effective. Without the direct involvement of upper tier authorities there is a real danger that LDF authorities, while willing to "cooperate", will not be able to reach agreement on major policy choices.

County Councils and Unitary authorities already have the knowledge, expertise and experience to inform LDF preparation at the sub regional level. In order to address major infrastructure choices and strategic delivery issues, it must be recognised that upper tier authorities have extensive experience in assessing strategic housing needs and economic growth, mineral and waste planning and, critically, infrastructure planning across LDF authority boundaries. County Councils already take a strategic view in relation to minerals and waste Local Development Frameworks, Local Transport Plans and economic assessment and strategy.

Experience in Devon's "Growth Points" has shown the significant benefits of formal co-operative strategic planning by groups of local authorities and other partners as a pre-requisite for delivering sustainable economic and housing growth. County Councils continue to have a lead role in infrastructure planning in relation to their own service provision, and in relation to the responsibilities of other agencies and authorities, and the phasing and delivery of this infrastructure is critical to the delivery of development proposed in Local Development Frameworks.

Mineral and Waste Development are matters which are already determined by upper-tier authorities.

Minerals Planning: In planning for minerals supply there is a strategic balance to be made to ensure that supplies in one part of the country are secured to meet economic needs in another part. The abolition of RSSs creates a risk that, in those regions such as the South West where the sub-regional aggregates apportionment is not yet formally resolved, the apportionment may stall. Failure to complete the sub-regional apportionment could cause uncertainty and delay to mineral planning authorities in preparing their development plan documents and to the minerals industry wishing to seek planning permission for new resources.

The existing Regional Aggregate Working Parties (RAWPs) are technical advisory bodies and determination of the apportionment is outside of their terms of reference and they are not publicly accountable. Government should ensure there is a consensus established through a clearly defined "duty-to cooperate" between upper tier authorities to achieve this.

Waste Planning: There are similar issues with Waste development. Waste development is determined by higher-tier authorities, but even at this strategic level, it is still necessary to work with other Counties/ Joint Waste Partnerships.

Since the 1990s Waste Technical Advisory Bodies (TABs),have provided planning authorities with information and data the need for waste facilities. This strategic overview of provision has to be maintained.

Question 4—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

A "duty to co-operate" would help to promote consensus but the scope and nature of such a duty needs to be clearly set out and the specific responsibilities of co-operating authorities defined. Co-operation across local authority boundaries could help inform the evidence base and the context for progressing Local Development Frameworks within sub regions. Given the critical importance of strategic infrastructure delivery, to support the delivery of major housing and other development, upper tier authorities must however be required to play a direct role in supporting coordinated LDF preparation.

Local Enterprise Partnerships (LEP) do offer a potential mechanism through which a strategic context can be established for LDF preparation, but this role should be formally identified, if and when such partnerships are endorsed by Government, as a key element of the "duty to cooperate".

A Local Enterprise Partnership submission has been made covering the areas of Devon County Council and the unitary councils of Plymouth City Council and Torbay Council. Through LEPs the strategic authorities and their partners would be able to provide a clear link between the strategic remit of Local Enterprise Partnerships and the delivery of economic development through Local Development Frameworks.

Question 5—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

For the South West Region the data and extensive studies which were used in preparation of the draft Regional Spatial Strategy, and supporting it at public examination, have been archived and will remain accessible by local authorities, other agencies, academic institutions and the wider public. While it will remain an interesting "snapshot" and resource base, the data is now becoming out of date.

The future of the South West Observatory appears uncertain, and in the current economic context it is unlikely to be easy to assemble funding to maintain such discretionary activity.

Upper tier authorities will need to conduct a certain amount of data collection and analysis to support their local economic assessments, and plan for their ongoing responsibilities in relation to functions such as transport, waste management, education, social care and perhaps health care. However, this may fall short of the needs of the planning system.

It would be helpful, therefore, for upper tier authorities to be given a duty to monitor cross boundary strategic issues and maintain the evidence base necessary to inform a shared and agreed sub regional evidence base for LDF preparation. This could be secured through the LEP mechanism or cross boundary cooperation of upper tier authorities.

September 2010



 
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Prepared 31 March 2011