Written evidence from the Planning Officers
Society
The Planning Officers Society (POS) represents the
most senior professionals and managers of planning functions in
the English Local Authorities. We are rightly styled as "the
credible voice of public sector planning".
We set out to:
- enable public sector planners to work together
with Government and partners;
- be a strong and united voice for public sector
planners supporting and shaping planning policy and practice in
local communities;
- be a preferred point of contact for public sector
planners where they can access learning, support and networking
opportunities;
- find common ground with other disciplines, organisations
and the media to improve the planning process, policy and implementation;
and
- broaden our membership and create a strong cohort
of young planners, representative of the ethnic and gender diversity
of the UK.
The Society's aim is to make planning more effective
in delivering sustainable development to support the well-being
of our communities.
SUMMARY OF
RESPONSE BY
THE PLANNING
OFFICER SOCIETY
- The needs of local people, as well as people
outside the area with housing needs, should be taken into account
in the local determination of housing targets.
- The replacement of regional house building targets
by financial incentives is likely to be ineffective in terms of
realising the house building rates needed to kick start and maintain
economic recovery.
- The extraction of non energy minerals and provision
for the management/disposal of waste are not generally welcome
neighbours. In the absence of a strategic context, local authorities
could well make uninformed decisions that disregard the wider
consequences of their actions.
- At a time when local authority resources will
be stretched as never before there may be more incentive to work
sub-regionally if authorities recognise that to do so will better
enable them to defend their plans.
- The evidence on which the abolished RSSs were
based remains valid and should be taken into consideration, thus
the extensive evidence base must be preserved and maintained;
the solution to this predicament chosen by South West Councils
is recommended.
The Committee inquiry into the revocation and abolition
of regional spatial strategies is focussing on a number of identified
matters (these are shown in italics below) together with
the POS response.
1. The implications of the abolition of regional
house building targets for levels of housing development
POS Response:
1.1 Although abolition has created uncertainty
in terms of future housing development there is little evidence
to suggest that housing delivery is currently constrained by a
lack of land. Instead it appears to be constrained by a lack of
mortgage finance and adverse market conditions caused by wider
economic uncertainty. The removal of regional housing targets
is, therefore, likely to have little impact on housing delivery
but could well lead to a reduction in supply in the long term
if NIMBYism prevails. However, this situation could change rapidly
once economic growth recovers.
1.2 There are significant fears that that the
local determination of housing targets will turn into a NIMBY
charter with local communities resisting anything other than their
immediate needs. However, recent research by Colin Buchanan and
University College London for DEFRA revealed that the predominant
view of local communities was that the needs of local people,
as well as people outside the area with housing needs, should
be taken into account in the allocation of local affordable housing.
If this proves to be widespread this bodes well for the local
determination of housing targets.
1.3 We should not forget that RSS was wider than
housing.
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
POS Response:
2.1 We have some concern as to how effective
the replacement of regional house building targets by financial
incentives are likely to be.[2]
We would highlight the incentive effect on public opinion of something
like the Milton Keynes tariff, which involved: (a) a large sum
of money fixed in advance paid up front, rather than over a six-year
period after the development has taken place.
2.2 A more local approach could lead to more
building in villages which could be in unsustainable locations
or could lead to difficulties in gaining consensus for building
in rural areas with the suggested 90% support via referendum being
unlikely
2.3 Some local authorities such as green belt
authorities may not want to take full advantage of incentives
which could undermine green belt policy
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)
POS Response:
3.1 Among the targets affected by the abolition
of the Regional Spatial Strategies (RSSs) are those for non energy
minerals supply and the management/disposal of waste. Neither
of these essential activities is particularly welcome neighbours
and, in the absence of advice as to the strategic context could
result in local authorities making uninformed decisions about
the wider implications of local decisions.
3.2 It has been clearly recognised by successive
governments that planning for minerals and waste is different
from other forms of development. Both the supply of minerals and
management of waste support the economic and social well being
of the nation, and they are resources that need to be managed
in a sustainable way that requires strategic planning. There are
major geographical imbalances between provision of and demand
for strategic waste facilities—landfill, energy from waste,
mechanical-biological treatment—plant between conurbations
and surrounding counties.
3.3 The implications of the Government's approach
to planning generally suggests that in planning for waste communities
should take responsibility for managing their own waste. This
is an objective that should be supported in principle, but the
technologies, economies of scale and sustainability issues involved
in waste developments make planning for waste facilities a matter
of more than local significance. In particular, this relates to
energy production from waste, its connection to the wider infrastructure
provision, links with household waste management and, the need
to still provide for landfill for residual waste. Waste planning
authorities cannot plan in isolation, particularly as so much
of the waste stream—less than 25% is of municipal origin—is
generated by business. Accordingly, local authorities are not
in control of how waste should be managed let alone where. Nevertheless,
waste planning authorities have to plan for all wastes.
3.4 Since the 1990s Waste Technical Advisory
Bodies (TABs) have been used to inform regional planning bodies
and in turn waste planning authorities with information, data
and advice on the need for waste facilities. This strategic overview
of provision has been essential in planning major facilities.
3.5 With the end of RSSs, which the TABs used
to be an integral part in policy preparation process, the question
does arise how planning authorities will have available strategic
advice for making planning decisions for waste development. It
is recognised that local decision making is paramount and that
"top down" targets do not have the role to play they
had hitherto. However, it is essential planning authorities do
have available strategic advice based on up to date information
to make fully informed decisions about the provision of waste
facilities. Without a strategic context to aid decision making
for waste infrastructure, national aspirations for recycling and
diversion from landfill are in jeopardy. Accordingly some
arrangement needs to be made to reconcile the principles of localism
with the need to achieve these national aspirations.
3.6 In due course the Local Enterprise Partnership
could provide this role, but these will not be in place until
2012 and it is unclear what their remit will be regarding planning.
What is important that some strategic planning arrangements are
put in place in the near future so that planning for minerals
and waste does not go into a hiatus. There are a number of possible
"joint working" models to do this. Examples are the
use of lead authorities providing services to others as in Greater
Manchester or sub regional arrangements as in the West Midlands.
3.7 However, the simplest arrangement would be
to continue with the TAB system with reporting lines directed
to the constituent planning authorities for the following
reasons:
- economies of scale—it would clearly be
cheaper, for example, to commission and maintain a single data
base to serving many local authority areas than each local authority
doing the work;
- ease of administration— the more fragmented
the arrangements becomes, the more time is spent in liaison and
duplication of activity;
- better interaction with the industry— the
key players function beyond local authority level and would find
it beneficial to have a single point of contact and a common approach
to dealing with strategic matters;
- more scope for sharing expertise—a larger
area offers a wider pool of expertise on which to draw, and reduces
the possibility of unreasonable burdens falling on individual
people or authorities; and
- continuity—minerals and waste data sets
and planning for minerals and waste has been based on existing
TAB ie regional areas for many years and there obvious advantages
to build on this.
3.8 The planning for minerals and waste are issues
of more than local importance and a strategic input needs to be
incorporated into decision making by local authorities.
3.9 It is recommended that the strategic role
of TABs, which have been crucial to promoting a strategic distribution
of waste facilities, should be maintained. Moreover, national
policy should endorse this role as part of a duty on local authorities
to co-operate.
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
POS Response:
4.1 At a time when local authority resources
will be stretched as never before, joint strategic planning arrangements
will involve a considerable investment of staff time and other
resources, not to mention political capital. However, there are
strong incentives to produce voluntary sub-regional strategic
context statements, in being able to show a logical context for
core strategies, and at examination in being able to show the
Inspector that the impacts upon adjoining authority areas have
been taken into account. POS is of the view voluntary sub-regional
work should be a key aspect of the way forward in planning post
RSS abolition.
4.2 The emphasis might be on:
- identifying those strategic issues that impact
across a sub-region;
- jointly commissioning the production of an evidence
base that could inform policy on them (cheaper done jointly than
individually); and
- suggesting a basis for policy derived from this
evidence, which individual authorities could either choose to
enshrine in their statutory local plans, or make a reasoned case
for departing from (given that the joint evidence base would be
in the public realm).
POS is of the view that authorities should adopt
an expedient approach to put something in place, with a view to
its agreement with relevant neighbours in due course.
4.3 If LEPs were to perform a planning
function, this could be either as a statutory consultee to the
plan-making authorities; or, alternatively, it could imply some
sort of plan-making role. In that scenario LEPs will need to recognise
that meaningful policy areas do not always coincide with administrative
boundaries. Sensible policy areas might even need to be defined
on a policy-by-policy basis, and local authorities will need to
hone skills in working across porous boundaries (and engaging
with the different populations potentially affected by particular
policies).
4.4 Whilst LEPs will have interests other than
planning and their main thrust will be on the economy, they offer
significant attractions in that they will be voluntary groupings
incorporating local authorities, and will have a statutory basis,
a ready-made secretariat and governance arrangements, and a strategic
view. Given that any sub-regional strategy will not be statutory,
and its content will only take on statutory status through incorporation
in development plans, the issue of democratic deficit is not significant.
4.5 It would be for the local authorities to
decide the appropriate scope and detail of strategic policy. Strategic
policy would only be developed where it could be demonstrated
that there was a genuine need for issues to be addressed at above
the level of the individual authority. Strategic policy documents
would therefore be more limited in scope than their predecessors.
4.6 The one planning role (but not a duty) proposed
in the Green Paper to be allocated to upper-tier authorities is
producing an infrastructure plan. The same resource issues apply
to this area of work, and the concern must be that authorities
either will not do it at all, or will only produce a plan for
those items of infrastructure they are responsible for delivering
(as a means of strengthening their hand in any bidding war for
scarce resources). Currently the main function of infrastructure
delivery plans is to underpin development plans; thus, it is suggested
there should remain a strong link between infrastructure planning
and the spatial planning of the area, so that a more holistic
view of infrastructure needs is taken. Given that the spatial
planning principles will emerge at a very local level, there would
need to be an iterative process, involving districts, upper-tier
authorities and other infrastructure providers.
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
POS Response:
5.1 With the abolition of RSSs POS is of the
opinion that the evidence on which they are based remains valid
and should be taken into consideration.[3]
5.2 The solution to this predicament chosen by
South West Councils is recommended. SW Councils have taken steps
to ensure that the evidence base behind the draft RSS, for which
the Assembly (as Regional Planning Body) and South West Leaders'
Board/SW Councils was responsible, is preserved. Both the Assembly
and South West Councils' websites have had a snapshot taken of
them by the British Library/National Web Archive.[4]
This ensures that the pages and their content are preserved for
future use.
September 2010
2 See POS media release at
http://www.planningofficers.org.uk/file/7b1a7f1f1e556caa59cd4608cc120e32/pos-responds-to-suggested-new-homes-bonus.html
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See
http://www.planningofficers.org.uk/file/a947d3927cacfdb3c88bd1a3dbdd19e9/pos-expresses-great-disappointment-at-abolition-of-regional-strategies.html Back
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The South West Councils website is at: http://www.webarchive.org.uk/ukwa/target/55148544/source/search.
The RSS evidence can be found at:
http://www.webarchive.org.uk/wayback/archive/20100811113549/http://www.swcouncils.gov.uk/nqcontent.cfm?a_id=538&tt=swra Back
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