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

Written evidence from the British Property Federation (BPF) (ARSS 90)


1.    This submission by the British Property Federation has been prepared in response to the CLG Select Committee's request for evidence on the revocation and abolition of regional spatial strategies. We understand that the inquiry will have a particular focus on the abolition of regional house building targets; the likely effectiveness of incentives for local communities to accept housing development and the nature and level of the incentives needed to ensure long-term supply of housing. Evidence will also be sought on arrangements to be put in place to ensure appropriate cooperation between local planning authorities on matters formerly covered by regional spatial strategies; the adequacy of proposals already put forwards by Government; and how the data and research collated by the Regional Local Authority Leader Boards should be made available to the local authorities.

2.     The British Property Federation (BPF) is the voice of property in the UK, representing companies owning, managing and investing in property. This includes a broad range of businesses— commercial property owners, financial institutions and pension funds, corporate landlords, local private landlords—as well as all those professions that support the industry.


We have no problem with the revocation of regional spatial strategies. However, there is a need for a degree of strategic planning in some areas above that of local authorities.

It is imperative that the transition to a new system does not lead to a hiatus in development at a time in which there is a need both to meet a major housing shortage and stimulate business growth.

The duty to co-operate must be clearly defined in order to assist local authorities to work together collaboratively. However, we do not believe that such a duty will be sufficient in itself to achieve the degree of strategic planning required.

In view of the need to have a proper degree of strategic planning, we believe that there should be some requirement on authorities to demonstrate that they have put workable procedures in place.

We agree, in principle, that LEPs could take on some sort of strategic planning role but we see a lot of potential problems in their doing so

Few local authorities can possess the full range of skills that they may need across areas such a regeneration and planning. There will be a much greater need in future for local authorities to share skills and even on occasions merge departments. LEPs could in theory be a vehicle for achieving this.

We welcome the proposals to introduce incentives to encourage local authorities to promote growth. We believe that a gradual move towards even greater relocalisation of rate income would provide a much stronger motivation for local authorities to back new development that generates economic activity and creates new jobs


We fully accept that the Government has a clear mandate to scrap Regional Strategies (RS). However, it is important that the reforms are carried out with the minimum of disruption both to local authorities and to the private sector. The revocation of RS sparked fears that:

Local authorities would pull the plug on housing schemes in their areas which they had never wanted but had felt compelled to accept to meet their housing targets.
There is evidence that this has been happening. However the Government has stressed its commitment to increasing the overall level of housing supply and that it intends to offset the revocation of RS and associated housing targets by giving local authorities new incentives to approve new development. We look further below at how effective these incentives are likely to be but it is clearly desirable that they are put place as soon as possible.

Local authorities would respond to the revocation of RS and other uncertainties around planning by delaying or rejecting applications for large scale schemes of commercial and mixed use schemes as well as residential schemes.
The anecdotal evidence that we are getting about this is inconclusive. There is a need to establish more clearly what is happening on the ground. We are seeking evidence from our members about this.

Those aspects of RS that were genuinely useful, including a lot of the supporting data, could be lost, leaving local authorities or successor strategic bodies to reinvent the wheel at additional and unnecessary expense.
Both we and others have flagged up this issue and we hope that, as the regional structures are dissolved and regional staff are made redundant, proper procedures will be put in place to safeguard valuable material. This is an important issue for the select committee to explore.


Strategic planning can bring clear benefits. There will always be some elements of planning (such as minerals, waste and strategic infrastructure) that will require some form of co-operation between neighbouring local authorities. If properly organised and implemented, strategic planning can offer a more joined-up approach to help deliver more efficient services and infrastructure as well as deal with environmental issues that do not respect local authority boundaries such as flooding. In the current climate, in which the private sector often lacks the confidence to invest, collaborative working between local authorities can also help provide the certainty needed to ensure investment. Such working can make best use of resources and specialist skills in plan-making.

Accordingly, we welcome the Government's recognition that co-ordination of some strategic issues at a higher level than that of individual local planning authorities is necessary. The key then is to work out how that strategic planning can be organised in a way that is compatible with the Government's overarching commitment to localism.


From what we can glean, the Government seems to be suggesting that the degree of strategic planning needed can be delivered though the imposition of a duty on local authorities to co-operate with each other and possibly through some more structured co-ordination, maybe via Local Enterprise Partnerships (LEPs).


We welcome the proposed duty on local authorities to co-operate with their neighbours. This will be a helpful starting point for any new framework for strategic planning. However, such a duty to co-operate is not easily defined or understood, and so will need further elaboration to avoid confusion and to ensure that each local authority plays their part. If the duty is to take effect as it should, enabling authorities to work together effectively to produce cross boundary agreements and facilitating collaborative working, this should be clearly defined in the forthcoming legislation. The emphasis should be on continual planned engagement rather than sporadic communication to ensure that the most effective collaborative systems and methods of working can be put in place.

Cross-Border Structures

Whilst we agree that imposing a duty on local authorities to co-operate with each other would be helpful, it would need to be coupled with some clear structure within which that co-operation can take place. The Government is keen that any new strategic planning structures should, in the spirit of localism, reflect the wishes of relevant authorities. We have no difficulty with that but, in view of the need to have a proper degree of strategic planning; we believe that there should be some requirement on authorities to demonstrate that they have put workable procedures in place.

The Government has suggested that Local Enterprise partnerships could have a role to play in this context. We agree in principle that LEPs could take on some sort of strategic planning role. However, also see a number of stumbling blocks:

A strategic planning role would be more practical if, as originally intended; LEPs genuinely reflect natural economic areas. However, the likelihood that there will be over 50 LEPs does not fill us with confidence that such bodies will operate at an appropriately strategic level.

The function and structure of LEPs have been defined in only the broadest terms at present and so it is unclear how such a planning function would fit with other LEP functions.

There is also uncertainty over the amount of funding likely to be available to LEPs. The £1 billion Regional Growth Fund (spread over two years) is unlikely to stretch very far given the many different claims upon it. It is likely, therefore, that strategic planning could only be delivered via LEPs if local authorities were prepared to contribute their own staff and resources to the process. This might be difficult in light of the cuts that are certain to fall on local authorities.


It is not feasible for all local authorities to possess in-house the full array of specialist skills that they may from time to time require. This is particularly the case in regeneration and planning. When a comparatively small authority takes on a major regeneration project, it generally needs to access outside expertise. LEPs could be a vehicle for fostering the greater sharing of skills (in areas such as land assembly, decentralised energy, regeneration and conservation) that is needed between local authorities. It might be that LEPs could also play a role where local authorities decide to go even further in improving service delivery by merging some of their activities which those of neighbouring authorities (for instance, Westminster and Hammersmith and Fulham are looking to merge educational services, whilst Cambridgeshire and Northamptonshire are looking to merge back-office services). There is no reason why the potential for doing this in an area such as planning should not be examined too.


Whilst the government has scrapped housing targets, they have stressed that this is not a signal for local authorities to sit on their hands. They are looking to local authorities to respond positively to the country's housing need and are committed to incentivising local authorities to meet that need. They are equally committed to incentivising business growth.


We applaud the Government's commitment to incentivise local authorities to take a more positive approach to development proposals. It proposes to do this for housing under the New Homes Bonus scheme by matching the council tax raised on each new house for six years. It is also proposing to use rating incentives to encourage business expansion via a Business Increase Bonus.

With house building is at its lowest since the 1920s, there is a danger that the hiatus in construction will continue as planners and local authorities readjust from the previous "top-down" system to the new "bottom-up" approach. It is imperative therefore, that full and complete proposals are published as soon as possible to expedite more housing, job creation and regeneration.

We note that the money to pay the bonuses to authorities will come from the overall grant that authorities receive and that those authorities who fail to authorise development will, therefore, not only lose out on the bonus but would actually see their income fall. In the light of this, our view is that this approach could be more successful than some people think in motivating authorities to approve new development.

We believe, however, that the Government should be even bolder. Breaking the link between local authorities and rating income has led to a position where local authorities gain little from actively seeking or fostering beneficial development. A gradual move towards even greater relocalisation of rate income would provide a much stronger motivation for local authorities to back new development that generates growth and creates new jobs. It would show, perhaps more than anything else, just how seriously the Government is taking its localism agenda.


We welcome the Government's commitment to introducing a presumption in favour of sustainable development. This too could act as a counterbalance to the abandonment of housing targets. It will, however, need careful drafting. The danger is that such a presumption could be hedged with such a lot of caveats and exemptions as to be totally meaningless.

September 2010

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