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

Written evidence from Arup (ARSS 110)


(i)  The design of a new system of planning for housing will need to include a means of ensuring that:

locally generated housing levels meet national needs in aggregate;

local politicians are given a good understanding of the sub-regional context within which they operate, including economic drivers, demographic needs, travel patterns, and housing quality issues;

any incentives regime works within a broader spatial policy framework to ensure that houses are built where they are most needed;

effective cross-boundary working takes place, particularly in Functional Urban Regions where high levels of population growth are projected (see Figure 2 for the priority areas that we suggest);

there is a constructive interface with Local Enterprise Partnerships, without giving them a primary planning function; and

regional evidence bases of relevance to LDF preparation are made available on dedicated websites for each region.

(ii)  Local authorities should be required to set up formal cross-boundary arrangements to ensure access to technical expertise and credible interaction with private operators on resource planning and management. The most appropriate spatial scales are:

regions for minerals and renewable energy;

sub-regions for waste and flood risk management; and

local authorities for green infrastructure.


1.  Arup is an international planning, design and engineering consultancy. Its planners and economists have regularly undertaken research commissions on behalf of DCLG, other government departments and government agencies, regional and sub regional bodies and local authorities over the last 20 years. A former Arup Director had hands-on experience of the rigorous independent testing stage in the preparation of Regional Spatial Strategies (RSS) as a former Examination in Public Panel Chair.

2.  Arup has in-depth expertise in the technical aspects of energy, water, minerals and waste, ecology and landscape and their relationship to public policy issues. It also has its own horizon scanning capability and was involved in the Government Office for Science's recent Land Use Futures Foresight study.

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

3.  Although by no means perfect, regional house building targets set through RSS provided a means of stepping down national household projections to the sub-national level while taking account of factors such as the needs of the regional economy, affordability levels, housing market pressures and weaknesses, availability of suitable land and adequacy of infrastructure (PPS3, para 33). Within this framework regional bodies arbitrated between bottom up local interests and national needs, and the results of the independent testing process ensured that the pieces of the jigsaw largely added back up to the national picture. The fact that there was a shortfall rather than an exact match against national household projections in published regional plans, particularly in the southern regions, was a reflection of the discretion in the system to take account of local circumstances. The challenge under a new system will be how to ensure an equivalent measure of coordination.

4.  In constructing a new system it must be very clear what the boundaries of local discretion are, otherwise there will be false starts and delays in the process of adopting LDF core strategies. One of the reasons why RSS turned sour in the minds of many local councillors particularly in southern England was that regional bodies, led by local authorities with inputs from business and environmental interests were given the responsibility from producing RSS—it was their plan.i It was therefore considered unjust by many to have major modifications (particularly in the area of housing numbers) imposed by the Government in the final stages, in contrast to the previous system whereby regions, largely through a voluntary collaborative process, had produced "advice" and Government, taking account of a wider range of national issues, had produced the final "guidance".

5.  Without some form of externally mediated housing target, it is vital that local politicians are given an understanding of the bigger picture. Our work looking at the implications of long term demographic and economic trends across England and the scope for planning to "bend" these trendsii is something that could usefully be updated as context for the new system.

6.  Some local authorities in high demand areas with high levels of unaffordability (house price: income ratio) will find that their local evidence base suggests higher housing levels than they previously had under the RSS system. This is because National Growth Areas and to a lesser extent National Growth Points previously acted as "safety valves" in accommodating national household projections. Ways will therefore be needed to manage local expectations.

7.  Local authorities may therefore need help to understand the sub-regional context within which they operate. These specialist skills will more readily be available in the big city regions (in some instances such capability has been retained eg the Tees Valley joint strategic unit). But many of the biggest challenges will arise around freestanding cities where for example new science-based economies are growing strongly eg Oxford, Cambridge and York. Such cities are often under-bounded and are dependent on their neighbours for the provision of sufficient housing opportunities. The issues are exacerbated by demographic trends of counter-urbanisation, which are placing greater housing market pressure in the rural hinterlands of cities and city regions. Understanding the demographic profile sub-regionally and identifying the most robust population and household projections on which to base joint planning may require new skills, as we are finding in our current advice to York City Council and surrounding boroughs.

8.  In addition to the issue of housing numbers, it is also important there is a strategic cross-boundary understanding of housing markets to inform wider housing policies and investment strategies. Our work for the Northern Wayiii identified the need for a city region wide perspective in relation to policies on the type, quality, density and tenure mix of new housing, as well as interventions to improve the quality of existing neighbourhoods and housing stock. This is important to ensure that areas have the right mix of housing in the right places in order to attract and retain a skilled and creative workforce needed to drive a knowledge economy.


Rec 1 Government guidance should be provided, possibly through an update of PPS3, on the broader parameters within which local authorities should set housing levels within LDFs, the demographic basis that they should use, and the supporting evidence required.

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

9.  Current proposals are designed to incentivise local authorities to allocate more housing land through LDFs and to grant permission for more applications. This immediately raises the issue of how the additional element over and above what might ordinarily have been allocated or permitted could be identified.

10.  There are high risks that an incentive system could lead to unrealistic expectations in the areas with fewest economic prospects in the quest for housing-led regeneration. In such areas incentives may encourage new housing in greenfield areas with new occupants leaving empty properties in less desirable areas (such as former industrial or mining towns), which could then cause housing market weakness, dereliction and a downward spiral. Alternatively the prospect of revenue income from incentives could lead to additional housing provision on paper, ie in LDFs, which does not get built because it is perceived to be too risky a proposition by housebuilders.

11.  To avoid this, incentives could be focused on authorities most in need of additional housing, eg with the worst affordability ratios. However this implies skewing of local government finance towards more prosperous areas, particularly in the South, which may be politically unacceptable.

12.  It also begs the question as to whether such incentives would have a large enough monetary value to overcome perceived amenity disbenefits eg from congested infrastructure. At the level of Council Tax receipts implied in the Conservative Party Green Paper, we estimate that about 10-20% could be added to Council Tax receipts for an average District in areas accommodating about 350 units pa. However at a national total of some £1.5 billion pa this may be unaffordable to the Exchequer, and in any case the majority of Council Tax receipt goes to County Councils in two tier areas, whereas the planning incentive is needed at district level.

13.  There is also a need to consider how the incentives in terms of retention of Council Tax receipts will relate to other mechanisms that have previously been used. In many areas, local authority support for housing growth has been based on an assumption that substantial Government funding will be provided for supporting infrastructure—this implicit "deal" was a main feature of the Growth Areas and Growth Points programmes. It remains to be seen whether the previous consensus on the need to plan for growth in such areas is now broken if programmes for infrastructure investment are scaled back.

14.  The prospect of levering substantial investment from developers through Section 106 contributions has also acted as an incentive to local authorities to plan for housing growth. In more challenging market conditions local authorities are having to reconsider what they can realistically demand from Section 106 agreements. This, alongside uncertainty around the future introduction of the Community Infrastructure Levy will also act to reduce financial incentives to plan for housing growth.


Rec 2 Any incentives regime would need to work within a broader spatial policy framework to ensure that houses are built where they are most needed. In order to reduce public opposition, attention will also be needed on issues such as raising design standards, locally generated funding mechanisms for associated infrastructure improvements, and ways of giving greater voice to supporters of new housing in the planning decision process.

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.);

15.  The numerical guidance previously provided in RSS on several of these technical issues was an important means of delivering against international and national targets. It is therefore in the Government's own interests to ensure meaningful coordination at the most appropriate spatial scale for each issue.

16.  For minerals and renewable energy there could be merit in retaining a regional framework, whereas a sub-regional basis may be appropriate for waste and Flood risk management. We envisage green infrastructure for the most part being dealt with by individual local authorities. It is also vital in our opinion to acknowledge that major infrastructure needs, eg adequacy of power supplies, grid connections and water supply, must be understood at a strategic scale, such that utility companies can build up a picture across their operating areas of where major development is likely to take place.

17.  Minerals: a mechanism is needed to ensure that extraction particularly of construction materials is achieved at sufficient rates to meet demands often occurring in different parts of the country. The extent to which recycled materials can substitute for primary crushed rock and aggregates is also needed. This first process involves involves a national top-down perspective and the second a bottom-up perspective. Hence the regional level with Regional Aggregate Working Parties as the mediating body has been found to be a useful working level. There is no reason why these bodies should not continue their work.

18.  Waste: a mechanism is needed to negotiate sufficient disposal capacity in the hinterlands of the major conurbations and under-bounded cities while alternative waste management processes to enable greater degrees of city self-sufficiency are brought on stream (as driven in part by European legislation). Whilst the landfill tax provides a powerful financial incentive for local authorities to work together to plan proactively for provision of municipal waste facilities, no similar incentives exist on planning for commercial or hazardous waste facilities. An inter-regional area may be the most logical spatial unit to plan for requirements in Greater London and the Home Counties, whereas a sub-regional arrangement may be appropriate around the main conurbations in the North and West Midlands.

19.  Renewable Energy: a mechanism is needed to step down from national targets set out in international agreements to a sub-national level such that groupings of local authorities know what level of renewable energy they would be expected to provide, as context for determining planning applications. Useful lessons can be drawn from experience in Wales whereby national guidance is provided on the scale of need together with clear spatial expression where appropriate, such as the strategic search areas for on-shore wind.iv Arup has advised the Welsh Assembly Government on this topic for many years.

20.  Flood Risk and Coastal Protection: this is adequately built into LDF preparation via Strategic Flood Risk Assessments. However there is a need for a cross-boundary perspective because water catchments and coastal systems cut across local authority boundaries. In some areas (eg Hull) the solution to flood risk may be upstream catchment management measures in another local authority. The Environment Agency would be in a good position to commission cross-boundary evidence collection in areas where more widespread flood risk issues need to be tackled, working with the Flood and Coastal Risk Management partnerships that have been created as a result of the Pitt Review and the Water Management Act.

21.  Green Infrastructure: policies for protecting and enhancing the natural environment are well embedded into the local planning system. However understanding the value of land in providing ecosystems services is continuing to progress, as elaborated in the recent Land Use Future's report.v Natural England is in the best position to input this thinking into plan making and to lead cross-boundary work on projects of wider than local significance.


Rec 3 The Government should require local authorities to set up formal cross-boundary arrangements at a broad enough spatial scale to allow technical expertise to be brought to bear on resource planning and management and to allow credible interaction with private operators.

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; and

Proposed duty to cooperate

22.  Our previous research for DCLG on optimum geographies at the sub-national scalevi suggested that the sub-regional level was critical to understanding functional economic relationships and hence should inform planning for housing. It is also the level at which authorities are encouraged to collaborate through setting up Integrated Transport Authorities.

23.  There are already good examples of local authorities cooperating voluntarily eg the Greater Norwich Development Partnership where local authorities are cooperating on a joint LDF core strategy. In and around Cambridge the local authorities have successfully set up a joint think tank and delivery vehicle: Cambridge Horizons.

24.  The issue is whether the proposed duty to cooperate, together with self-interest in seeking efficiencies in planning and possibly other local government management areas, will be strong enough or whether additional proactivity from the Government will be necessary. We have some reservations about whether voluntary sub-regional partnerships will have the capacity or political will to tackle controversial planning issues around housing growth, eg involving a selective release of Green Belt in an authority area adjoining the main driver of demand.

25.  Additional guidance may be needed from national Government on the planning imperatives for joint working in particular parts of the country, in that the Government Offices for the Regions will no longer be there to provide that positive steer. We put forward our suggestions on priority areas for collaborative working in Figures 1 and 2. These are based on identifying local authorities where population growth is projected to be highest following past trends, together with those locations with journey to work areas that extend over several local authorities (termed Functional Urban Regions). The greatest need for joint working on housing growth is where both these patterns overlap (see the names in bold type on Figure 2). Where lower levels of population growth are projected within these Functional Urban Regions there would still be strong case for collaborative working on other topics, particularly transport.

26.  If the decision on whether to cooperate is left entirely to local authorities there is a risk that important relationships are missed, such that the Inspector examining a particular draft LDF core strategy may find the locally agreed housing provision unsound, hence perpetuating a policy vacuum for housebuilders and leading to decision-making "by appeal".


Rec 4 Guidance could usefully be provided by Government on the types of circumstances in which it is crucial to cooperate in order to take account of the interrelationships between housing, economy and transport.

Rec 5 Government guidance would also be useful on the merits of different vehicles for cooperation ranging from joint statutory committees (as the London Planning Advisory Committee was constituted after the abolition of the GLC), to looser strategic planning partnership approaches eg through the Leeds City Region Partnership.

Local Enterprise Partnerships

27.  LEPs are intended to be slimline business orientated organisation to give confidence to the private sector to invest in projects that are strategically important to the economy. Extending RDA responsibilities into the spatial planning arena was not generally successful, since delivery and plan making are different skills. In our opinion the function of LEPs should not be complicated by giving them a primary planning function.

28.  Constructive roles in which LEPs could interface with the planning system would be:

articulating barriers to economic growth which can be dealt with through planning, eg emerging shortages of employment land, or labour supply issues that are related to the housing stock or quality of place;

informing the economic evidence base for LDFs; and

identifying infrastructure bottlenecks with economic consequences, and where necessary acting as a conduit in joint investigations with utility companies.


Rec 6 Local authority planners and LEPs should work together to ensure that policy is coordinated in order to provide a framework to guide public investment programmes such as on regeneration and affordable housing by the Homes and Communities Agency.

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

29.  Valuable data sets have been assembled largely through Regional Observatories. Extensive research has also been commissioned by Regional Leaders Boards and their predecessors and the RDAs. These must continue to be available as context for LDF preparation. Some aspects will become part of the evidence base for LDFs, but evidence needs careful interpretation.

30.  Many smaller local authorities will not have access to specialists in critical areas like demographics, economic forecasting, renewable energy. They may need help in understanding data sources and engaging in scenario building exercises to examine uncertain economic futures. Our guidance on strengthening the economic evidence for regional plans prepared for ODPM could usefully be reinterpreted for use by groupings of local authorities in LDF preparation.vii

31.  Joint funding solutions probably based on local authority contributions will be needed for the storage and updating of regional data and research resources, possibly brokered through the regional branch of the LGA. Greater understanding of the value of existing data should build momentum for the case to maintain it.


Rec 7 Awareness raising exercises could usefully be organised by the regional branches of the LGA on the resources available from previously assembled regional evidence bases, how to access them, and how to interpret them for a particular locality.

Rec 8 The databases and research studies should be available on an easily distinguished dedicated website for each region, rather than be subsumed in the National Archives website with its inadequate search facilities.


i  Evaluation of the Role and Impact of Regional Assemblies, see section 4.4, Arup for DCLG, 2007. Available at:

ii  Regional Futures: England's Regions in 2030, Arup and Oxford Economic Forecasting for the English Regions Network, RDA Planning Leads Group, ODPM and DfT, January 2005. Available at:

iii  The North's Residential Offer: Policy and Investment Review, Arup for Northern Way, 2006. Available at:

iv  Planning Policy Wales Technical Advice Note (TAN) 8: Planning for Renewable Energy, see Annex D for a potential methodology for local authorities within Strategic Search Areas based on Arup research. Available at

v  Land Use Futures: making the most of land in the 21st century, Government Office for Science, January 2010. Available at:

vi  Planning and Optimum Geographic Decisions for Economic Decision Making: The Sub Regional Role, Arup for DCLG, 2008. Available at:

vii  Guide to improving the economic evidence base supporting regional economic and spatial strategies, Arup for ODPM, September 2005. Available at:

September 2010

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Prepared 31 March 2011