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

Written evidence from the Association of Directors of Environment, Economy, Planning and Transport (ADEPT)

The Association of Directors of Environment, Economy, Planning and Transport (ADEPT) represent local authority Strategic Directors who manage some of the most pressing issues facing the UK today. ADEPT membership is drawn from County, Unitary and Metropolitan authorities from all four corners of the United Kingdom. The expertise of ADEPT members and their vision is fundamental in the handling of issues that affect all our lives. Operating at the strategic tier of local government they are responsible for delivering public services that relate to the physical environment and the economy.


  • Revocation of Regional Spatial Strategies has wider implications than simply removing targets for new homes.
  • New arrangements need to be put in place to enable local authorities and the house building/development industry to move forward with confidence.
  • Strategic planning recognises the need to address issues that cross boundaries. It should form part of a reformed planning system.
  • A robust Sub-regional partnership approach, taking Local Enterprise Partnerships as a starting point for planning at the strategic level, is supported.
  • New homes and other development requires infrastructure to deliver sustainable communities. Further debate is needed to ensure the infrastructure required for sustainable communities is funded.
  • New Homes Bonus—concerns about take-up by councils/communities and the ability of the tool to influence new homes completions.
  • Community engagement, however effective, is unlikely to bring consensus. Strong local leadership is needed to make the difficult decisions.
  • Suitable arrangements can be made for updating data and research.

1.  Implications of the abolition of regional house building targets for levels of housing development

1.1  It is important to note at the outset that the revocation of, and the eventual abolition, of Regional Spatial Strategies will have implications for a wide range of issues not just house building targets. Regional Spatial Strategies also set regional priorities for where new development should go, economic growth, transport and other infrastructure and the natural environment. There is a continued need to plan for these issues in a co-ordinated way at a level that is wider than local.

1.2  The revocation of Regional Spatial Strategies has brought a number of immediate implications in terms of uncertainty for local authorities, the development industry and local communities. These include: withdrawal of Local Development Framework documents by councils, uncertainty about appropriate policies on which to base decisions on planning applications, and disruption of ongoing work on infrastructure planning, due to a lack of clarity on the development levels for which infrastructure is required..

1.3  It will take time for local authorities to establish a robust position from which to go forward. Currently, this process is being hindered by a drip feed of new policy changes for planning and other areas, proposals for new responsibilities and working arrangements and public sector funding cuts. Clarity on these issues is needed to enable local authorities and their partners as well as investors to move forward with confidence.

1.4  Progress on national planning issues and solutions to the strategic planning vacuum will be key in helping local authorities to deliver positive outcomes for communities. These are considered in turn, as follows.

1.5  Work needs to be completed as soon as possible on the National Planning Framework and National Infrastructure Plan. These will help guide local areas on national priorities. National guidance should include the government's position on meeting the nation's housing needs and aspirations.

1.6  There must be recognition of the strong case for carrying out strategic planning at a level between national and local levels. ADEPT strongly supports the case for strategic planning and is a signatory to the letter to the Communities and Local Government Secretary, Rt Hon Eric Pickles MP on "Larger than local planning".

1.7  Strategic planning is needed because local needs cannot be addressed in isolation. Many issues cut across local authority boundaries or have a national or international context. These matters include:

  • Ensuring that housing provision is based on a sound understanding of housing markets and their interrelationships with economic and social factors (demographic change, overall supply, mix, type and tenure of housing, economic growth levels and labour supply).
  • Making provision for economic growth based on an understanding of functional economic geography (skills levels, employment land supply, promotion of key sectors, etc).
  • Meeting Gypsy and Traveller needs.
  • Ensuring the sustainable, efficient and effective movement of people and goods through integrated transport strategies.
  • Providing other strategic infrastructure (eg flood management, water supply and disposal, health, education).
  • Taking account of the cumulative impacts of development, such as those upon sensitive environmental assets or the transport network (trip generation, commuting patterns, etc).
  • Moving towards a low carbon future, which will rely in part upon an integrated approach to matters such as renewable energy opportunities, climate change adaptation, and reducing the need to travel.
  • Understanding future needs of communities (i.e. dealing with the need to plan responsibly for future residents, including the children of existing communities and possible migration patterns, in the face of political tensions arising from existing residents who are fearful of new development pressures).

2.  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

2.1  The delivery of new homes is a key issue. New and affordable homes must be built in the right places to support economic growth, population change and address existing unmet housing needs— particularly for affordable housing. New homes and economic growth must be supported by appropriate infrastructure. Local councils have a key role in enabling this to happen.

2.2  The low levels of house building over the last two years reflect the economic situation. The rate of house building is strongly linked to the state of the economy and less in the hands of local communities or councils. However, planning for housing is necessary to provide greater certainty for developers in terms of the supply of housing land in the longer term. Local councils can enable new housing development by developing local policy and granting planning permission but have little power in terms of when the development is built.

2.3  Three key issues are relevant to the Government's incentives proposals for new homes:

  • Determining what is an adequate supply of new homes.
  • Gaining the support of local communities for the building of new homes.
  • Infrastructure to support housing development.

2.4  Robust assessments of local housing need and the opportunities to meet that need will be required to inform discussions on how much housing there should be and where it should go. These assessments will need to take account of demographic, economic and housing market factors, as well as supply-side issues, taking account of the effect of environmental considerations. With regard to the latter, there must be consistency of approach with the emerging Government policy on the natural environment, as promised in a forthcoming White Paper. It is recommended that best practice guidance on making local assessments for housing is prepared.

2.5  New ways need to be found to improve democratic involvement and community engagement at all levels of government in terms of how and where new housing should go. Community engagement is important but it costs time and money, so a balance needs to be found to avoid excessive delay. A key issue is that those who tend to get involved are those who are least likely to benefit directly from new development and most likely to oppose change. The challenge lies in finding ways to engage those who are least likely to get involved but are more likely to benefit such as younger people and disadvantaged groups. At the same time, it must be recognised that community engagement, however effective, is unlikely to bring consensus. Strong local leadership is needed. Difficult decisions will still have to be made by democratically elected members in the light of the evidence and differing community views.

2.6  Along with developing greenfield land, infrastructure to support new development, particularly new homes is a key concern of existing local communities in terms of accepting new development. To build sustainable communities new housing must be supported by transport, social, community and green infrastructure. This should be funded as far as possible by development and user charges, but it must be recognised that there are limits to this source of funding. Whilst alternative infrastructure models are sought, there is great concern about the continuing lack of investment in infrastructure particularly at the strategic level. Further debate is needed about this issue.

2.7  In terms of the government proposals, at this stage the information on the New Homes Bonus scheme gives little detail on which to gauge its potential effectiveness. It is understood that the level of funding will not exceed that previously provided through the Housing and Planning Delivery Grant.

  • 2.8  The incentive scheme (proposed in the green paper) of council tax match funding for house building may not be sufficient to encourage local residents and councillors to endorse housing growth. The following are issues to consider for the New Homes Bonus:
  • The Bonus will need to be significant to incentivise local communities to see a benefit from new housing but this will have to be balanced against overall cost. Given that we do not have the full picture in terms of the spending review, developer contributions arrangements etc, it is difficult to determine the level of incentive that will encourage local communities to take it up.
  • The Bonus needs to be set up in a way that is open and transparent so it does not appear that planning permission is being bought. Linkages to community benefits must be realistic—for example, robust assessments should be made and published of development levels needed to retain schools, shops and other community facilities.
  • The Bonus will need to be long-term to build trust and certainty for local councils, local communities and the development industry.
  • There may need to be restrictions in terms of the amount of Bonus given to each local authority. This could be linked to growth rates above a threshold level.
  • The Bonus is billed to ensure that communities who go for growth will reap the benefits. It is questionable that the potential option open to councils to cut council tax levels will bring wider community benefits for the long term.
  • A direct link, such as a link to Council Tax, between the granting of planning permission for new homes and the Bonus appears to make sense. However, there is no guarantee that these homes will be built. There is a balance to be made in terms of recognising what local authorities can enable and getting new homes built.
  • In two tier areas, arrangements will need to be in place for both tiers of local government to benefit from the Bonus.
  • A clearer picture of the arrangements for the Bonus, successor Community Infrastructure Levy and section 106 agreements is urgently needed to enable local authorities to make informed decisions about infrastructure funding and to mitigate impacts of new development.

3.  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)

3.1  As explained earlier, strategic planning at larger than local level is necessary to prevent a haphazard approach between new housing, economic priorities and supporting infrastructure. County and unitary councils should lead working on strategic spatial plans working through robust sub-regional partnerships.

3.2  Minerals and waste planning are currently undertaken by county and unitary authorities. In many areas a partnership approach to preparing joint local development frameworks takes place. Over many years, planning authorities have worked together through Regional Aggregates Working Parties to determine the scale of mineral aggregates. This arrangement is set to continue. Similar arrangements exist for waste planning.

4.  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

4.1  The "duty to co-operate", proposed in the green paper, was proposed as a way to encourage councils and other service providers to work together in terms of infrastructure planning. Whilst partnership working at the sub-regional level is supported it is necessary to develop robust partnerships arrangements. Voluntary agreements may be relevant for some aspects but not all. Sub-regional partnerships need strong legitimacy and the necessary freedoms, flexibilities and resources. Local authorities taking a leading role will provide the necessary democratic accountability. There should not be a plethora of local partnerships.

4.2  ADEPT supports the creation of Local Enterprise Partnerships—joint local authority-business bodies brought forward to promote economic development. These should normally operate at the sub-regional scale.

4.3  The government recognises that to create the right environment for business growth in their areas, LEPs will want to tackle issues such as planning and housing, local transport and infrastructure priorities, employment and enterprise and the transition to the low carbon economy. LEPs have the potential to provide leadership for these and other cross boundary issues that would benefit from a strategic approach. However, their primary role is an economic one. Further clarity is needed as to whether LEPs are to take on a wider remit and how the wider issues will be balanced against the economic role. Clarity will also be needed with regard to democratic accountability, with the balance of power in LEPs residing in the private sector, but delivery of many of the potential outcomes being the responsibility of the public sector and, in particular, local authorities.

4.4  LEPs offer an opportunity to address the strategic planning gap, although much will depend on the scale and geographies of the final set of LEPs. If they are large sub-regional entities, then the danger is that strategic planning at this scale will attract the same criticism as attached to RSSs. However, smaller-scale entities would be able to marry wider strategic considerations with local aspirations, and come to more acceptable solutions.

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

5.1  The existing data and research collated by the abolished Leader's Boards can be made available by placing in convenient and secure place on the internet and other relevant archives. For example, South West Councils Leaders' Board/South West Councils have made arrangements with the British Library/National Web Archive to preserve the evidence base behind the draft RSS for the South West to ensures that the pages and their content are preserved for future use.

5.2  At the sub-regional level, data collection and further research concerning cross boundary issues can be co-ordinated by the relevant sub-regional partnership, which may be the LEP, or a sub-regional partnership of upper tier authorities, building on their existing capability and capacity. This data and research will provide a common and consistent evidence base for the preparation of development plans, as well as informing any future strategic planning activity. Also, the data should be collected in a way that can be useful at the local level but can be aggregated for use at larger levels.

September 2010

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