Written evidence from the Royal Town Planning
Institute (RTPI)
INTRODUCTION
1. The Royal Town Planning Institute (RTPI)
is the largest professional institute for planners in Europe,
with over 23,000 members who serve in the public service and as
advisors in the private sector. It is a charity with the purpose
to develop the art and science of town planning for the benefit
of the public as a whole. As well as promoting spatial planning,
RTPI develops and shapes policy affecting the built environment,
works to raise professional standards and supports members through
continuous education, training and development.
2. The RTPI has noted the terms of reference
of the Inquiry and the topics in which the Committee is particularly
interested. In this evidence we deal with all the specific questions
posed by the Select Committee following an initial statement on
the RTPI's overall view on the revocation and proposed abolition
of RSSs.
THE RTPI'S
POSITION
3. The RTPI welcomes the fact that the CLG
Select Committee has chosen to hold an Inquiry into the abolition
of Regional Spatial Strategies (RSSs). The RTPI has already undertaken
significant work and thinking on this issue and this evidence
reflects that work and reflects the views of RTPI members through
discussions at our Executive Board and a call for member comments
through our website
4. The RTPI clearly sees the abolition of
RSSs within the context of the Coalition Government's "localism'
agenda. Whilst we find aspects of this overall agenda challenging
we feel that the essence of a properly considered and implemented
localist approach to be a key component of effective and inclusive
planning and spatial investment system and we have already been
working with the Government to discuss and inform the issues that
this approach raises and to suggest ways in which its implementation
may be improved.
5. Within this overall stance, the RTPI
is very concerned about the policy vacuum that has been created
by the revocation and promised abolition of RSSs and the institutional
support structures, such as Regional Development Agencies and
Regional Partnership and Leaders Boards. This is exacerbated but
the DCLG's stated antipathy to issuing any guidance on strategic
planning.
6. We wish to make to absolutely clear,
however, that we are not calling for the status quo pre
the Election as we have already expressed a concern in our 2010
Manifesto for Planning[5]
that:
We need plans above the local level to deliver
development and infrastructure that crosses administrative boundaries,
but there is a lack of faith in the current system of regional
planning. ....
7. The RTPI recognises that the Government
is putting into place a range of structures and initiatives to
enable a degree of strategic planning at this level and we will
be working with the Government and with local authorities and
other interested parties to help to inform, evaluate and support
or challenge these proposals as they emerge.
THE IMPLICATIONS
OF THE
ABOLITION OF
REGIONAL HOUSE
BUILDING TARGETS
FOR LEVELS
OF HOUSING
DEVELOPMENT
8. There have already been a number of reactions
to the revocation of RSSs and their proposed abolition. It appears
from work undertaken by the National Housing Federation that some
100,000 homes have been taken out of the planning process as a
result of the removal of housing targets. The figure includes:
9,600 cut by Bristol City Council, 3,000 cut by Exeter, 10,750
by North Somerset, and 9,200 by North Hertfordshire and Stevenage.[6]
9. This study follows on from earlier indications
that removal of housing targets followed by the revocation of
RSSs had led to a slowing down in overall planning activity. The
following situation applied to LDF progress in June 2010:
- South Oxfordshire: abandoned
work on its core planning strategy.
- West Oxfordshire: abandoned
work on its core planning strategy.
- Surrey Heath: abandoned
work on its core planning strategy.
- Vale of Whitehorse:
abandoned work on its core planning strategy.
- Bristol: housing
part of public examination of core strategy delayed.
- Castlepoint:
housing part of public examination of
core strategy delayed.
- Bury St Edmunds:
public examination of core strategy delayed
to re-consult.
- South Wiltshire:
public examination of core strategy delayed
to re-consult.
- Forest Heath: suspended
work on local development documents.
- Cotswold: cut
annual housing target from 345 to 300.
- South Northants:
deferring all applications submitted on
basis of unidentified five-year land supply.[7]
10. It needs to be noted that, as with the discussion
on the New Homes Bonus, below, the position is not universal across
England. Indeed, it can be seen from the examples given above
that the slowing down of planning activity and of major housing
schemes is concentrated in the South West and wider South East.
In other areas, it may well be that the opposite position is found,
with those local authorities that see the benefits of housing
growth and which felt constrained by an RSS which allowed for
less growth than they would have wished for.
11. Amongst other things, there is a current
legal challenge to the revocation of RSSs[8]
on the basis that the revocation goes against the overall purpose
in the rest of the Act and that the environmental and other impacts
of this have not been assessed.
12. Additionally, on 29 July 2010, a grouping
of some thirty organisations from a range of sectors including
housing, transport, infrastructure, the environment and the economy
wrote to the Secretary of State expressing their desire to work
with the Government to try to ensure that the revocation and abolition
and the systems that were put in their place did not hamper the
ability of Government to achieve its own key objectives in the
fields represented by this grouping. This initiative was co-ordinated
by the RTPI.
The likely effectiveness of the Government's plan
to incentivise local communities to accept new housing development
13. It is relevant to note at the outset that
the Minister for Decentralisation has stated in a speech to the
Local Government Association[9]
on 6 July:
Those housing incentives are the other side of
the ending of the regional spatial strategies. Ideally, I would
have liked to announce them together.
14. As at the date of the preparation of this
evidence, the Government have not spelt out any details of the
incentive scheme beyond that contained in the Conservative Party
Housing Green Paper[10]—
Strong Foundations. This stated that:
we will match the additional council tax raised
by each council for each new house built for each of the six years
after that house is built.
15. In fact, the latest letter sent to local
authorities in August[11]
went into less detail about the scheme than previously announced.
Instead it promised to publish a formal consultation after
the outcome of the Spending Review. Despite this, it is worth
examining this proposal in a little more detail to see whether
it really does provide the incentive to match the choice.
16. The average Band D council tax set by local
authorities in England for 2010-11 is £1,439.[12]
Taking this band as an example, local authorities will gain £8,643
over the six years of the scheme for market homes and £9,318
(125%) for affordable homes. Opinion seems to be divided as to
whether such amounts will be sufficient to sway electorates who
previously resisted housing development.
17. It needs to be borne in mind that the funding
for this will come initially from savings from the abandoned Housing
and Planning Delivery Grant and, thereafter, from top-slicing
a proportion of annual increases in formula grant for councils.
This will not, therefore, be new money for communities but will
be a re-distribution of grant. Strong Foundations states
that:
This policy is a cost-neutral reallocation of
existing government funding, ....
18. First, it should be noted that the resistance
to development which this incentive is designed to overcome is
not universal in all parts of England. Some areas will welcome
such development as supporting the vitality of communities and
providing much needed accommodation.
19. In other areas, however, some communities
and local authorities may well feel that, for example, the gain
from a small infill development of, say, seven market and three
affordable homes (£88,455) does not compensate for real or
perceived loss of amenity—but they may feel that the gain
from a scheme ten times that size is worth serious consideration.
20. However, one of the major hurdles could be
the overall cost of the scheme. For example, in 2008, 150,580
new market homes were built and 32,100 affordable homes.[13]
This was an historically low figure but even this would cost more
than the £146 million allocated to the Housing and Planning
Delivery Grant in the current financial year. It may be, therefore,
that the New homes Bonus may have to be capped—thus proving
even less of an incentive.
21. An important consideration for effective
and transparent planning decision making is whether the existence
of the New Homes Bonus is a material consideration in making that
decision. If a development is deemed unacceptable in planning
terms, for example through its impact on the local environment,
then should the planning process "balance" this with
the knowledge that the development will bring in extra resources
for communities. This does appear to be a potential dangerous
path to follow in a system that has been wrongly accused in the
past of "selling" planning permissions through the process
of making Section 106 agreements.
22. The second form of incentive is that of obtaining
approval to build some housing without the need for planning permission.
The proposed Government scheme for this is the Community Right
to Build.[14]
Once again, the scheme is not fully explained by the Government
as yet but appears to schemes of around ten homes and where the
great majority (80 or 90 per cent of the local electorate in a
referendum) of the local community vote for it.
23. The RTPI believes that local plans, developed
by elected members in partnership with local people and businesses
are the most democratic way to deliver the aspirations of local
communities for housing provision. In the first three months of
this year (2010), 71% of minor housing applications (10 homes
or less) were approved through the planning system and that 83%
of decisions were made within three months.[15]
The arrangements which should be put in place
to ensure appropriate cooperation between local planning authorities
on matters formerly covered by regional spatial strategies;
24. The RTPI believes that this issue has not
been considered adequately by Government in the revocation of
RSSs. There has been too much emphasis placed, by the Government
and others, on the role of RSSs in setting housing numbers and
not enough on the implications of their revocation and abolition
on the other policy areas that they were designed to deal with.
25. Planning Policy Statement (PPS) 11 on Regional
Planning (now revoked and no longer available on the DCLG website)
states that, in addition to the identification of the scale
and distribution of provision for new housing, and RSS shall
contain:
- priorities for the environment, such as countryside
and biodiversity protection;
- transport, infrastructure, economic development,
agriculture, minerals extraction; and
- waste treatment and disposal.
26. There is also the misguided perception that
policies in the former RSSs were always imposed on local authorities
and local communities. The RTPI has a number of examples of where
local authorities themselves worked to have policies included
in an RSS which would benefit their local areas. Such policies
include examples on renewable energy, on sub-regional sport and
recreation, on biodiversity and on regional parks.
27. The revocation and abolition of RSS has left
these vital issues un-catered for at the regional level. Clearly
some of the initiatives that the Government has already announced,
including the establishment of LEPs and a duty to co-operate,
covered below, will fill some gaps but the RTPI fears that these
arrangements will lead to an ad hoc approach to environmental,
economic and social policy. The RTPI feels that it is most useful
at this stage to set out the criteria against which Government
proposals should be judged rather than trying to design a new
system in abstract. The RTPI believes that the following criteria
must be addressed.
- Are areas or communities adversely affected if
they are not covered by one or more of the new initiatives?
- Do structures and policy vehicles have statutory
definition where this is required?
- Have the proposals made necessary linkages to
the existing planning system and to proposals at both national
and neighbourhood levels?
- Are new bodies and structures enabled and encouraged
(and, if necessary, required) to adopt a spatial planning approach
as part of their responsibilities?
- Are the suggested structures and policy vehicles
enabled and encouraged (and, if necessary, required) to engage
with and be influenced by local and other communities in exercising
their functions?
- Given that the new system is community led, will
the suggested structures and policy vehicles form a comprehensive,
transparent and inter-related whole if all communities opt to
adopt these proposals?
- Do the suggested structures and policy vehicles
explicitly link planning with investment?
- Will relevant clauses of legislation give equal
weight to the economic, environmental and social remit of spatial
planning?
- Will the suggested structures AND policy vehicles
provide a framework of certainty within which development beneficial
to local communities can take place?
- Will they serve to retain and develop the expertise,
skills and information that exists to undertake this type of planning?
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 fulfill
a planning function
28. In this section, the RTPI evidence comments
on the adequacy of four current Government proposals; proposals
at the national level, Local Enterprise Partnerships (LEPs), the
duty to co-operate and joint working.
NATIONAL PLANNING
29. The Royal Town Planning Institute has long
advocated—and campaigned for—some form of English
national spatial framework. The RTPI, therefore, welcomes the
Coalition's thinking on this level of planning and is keen to
work with the Government on developing all these initiatives.
30. However, we feel that there is currently
uncertainly as to the nature of the National Planning Framework.
Is it, as Open Source Planning states, a simple and
consolidated bringing together of all national planning policies
(PPSs and PPGs) or will it go further, as the Coalition Agreement
states, set out national economic and environmental priorities?
This implies that there would be sections on aspects which are
not covered by existing DCLG guidance. In this case, what is its
relationship with; the existing and proposed National Policy Statements,
other Government policies and the National Infrastructure Plan?
31. Equally importantly, what will its relationship
be with Government spending decisions, including the Regional
Growth Fund, which will impact in different ways in different
parts of the country? Additionally, will it act as a material
consideration (in practice or in statute) for neighbourhood and
local planning?
32. The RTPI believes that the current thinking
and plans of the Coalition Government could provide the opportunity
to achieve an integrated approach to planning and investment at
national level which has not been previously achieved in England.
However, there is the equal risk that the plethora of different
plans, policies and proposals set out in this Briefing Note could
lead to a fragmentation of policy making and to inefficient investment
which would impact adversely on the abilities of the Government
to achieve its own bold objectives.
LOCAL ENTERPRISE
PARTNERSHIPS (LEPS)
33. The RTPI has submitted general evidence to
the BIS Select Committee's inquiry into LEPs. Specifically on
planning, however, the RTPI very much welcomes the encouragement
to those putting forward outline proposals to include some form
of planning function in those proposals. Now that the proposals
have been submitted, we trust that one of the assessment criteria
for them—criteria which have not been published— will
be how they propose undertaking this function.
34. We cannot see how LEPs can fulfil their main
stated function without a clear understanding of the role of spatial
planning in achieving economic renewal and development.
35. However, the RTPI looks in vain for any encouragement
for those proposing LEPs to demonstrate how they will work within
an existing planning and investment system or relate to the Government
other proposals and, importantly, how they will add value to that
system.
36. The vacuum left by the revocation of Regional
Spatial Strategies (RSSs) and intended abolition of them and of
the Regional Development Agencies, Regional Partnership and Leaders'
Boards and Government Offices for the Regions has not been filled
by Local Enterprise Partnerships and it is disingenuous for Government
to suggest that LEPs in some way "replace" RDAs.
37. It may be desirable in some places for LEP
plans to have a statutory basis in forming a joint LDF core strategy
leaving individual Local Planning Authorities to produce neighbourhood
or Area Action Plans. Additionally, overall, it would be prudent
for the statutory basis for LEPs to include their purpose.
38. Finally, but importantly, if the LEPs are
to become involved in the development of a long-term vision, then
there is a need to ensure that the community have an opportunity
to comment on and shape the future of planning policy within their
areas.
A DUTY TO
CO -OPERATE
39. There is already a limited
duty co-operate in the Local Government and Public Involvement
in Health Act 2007. This refers only to the preparation of Local
Area Agreements (LAAs).
40. The RTPI will be looking to
the wording of a similar duty embodied in the Decentralisation
and Localism Bill with the following questions:
- Will this duty apply at all local
authorities, or to all statutory bodies or will it only be applied
to Local Economic Partnerships?
- Will it apply to all activities
including local development planning, local infrastructure planning,
sub-national working and the preparation of the national planning
framework?
- Is co-operation defined? In effect,
the duty in the 2007 Act was discharged by taking part in the
process of drawing together an LAA whatever the outcome was.
- Will, therefore, failure to co-operate
be defined?
- Will there be any sanctions specified
for failure to co-operate and which may be responsible for encouraging,
monitoring and taking action on co-operation?
JOINT WORKING
41. There are already numerous examples of joint
working in spatial planning including the preparation of joint
Local Development Framework core strategies; Sub-regional working
and sub-regional strategies and the RTPI would be pleased to provide
details of examples of these should the Committee feel that this
would be useful. This is very much to be encouraged and the RTPI
accepts that it has a role in working with others, notably the
Local Government Group and the Planning Officers Society to provide
guidance and examples of effective practice and will be looking
to Government to endorse this activity.
42. The RTPI will be evaluating the Bill to see
whether it strengthens the opportunities for voluntary joint working
already embodied in the 2004 Act—or whether it introduces
a degree of coercion into the process.
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
43. The RTPI considers that the retention and
development of the evidence base that informs strategic planning
is vital. We note that the letter sent to Chief Planning Officers
on 6 July announcing the revocation of RSSs stated that:
the planning data and research that they [Leaders'
Boards] currently hold will still be available to local authorities
… whilst they put in place their own alternative arrangements
for the collection and analysis of evidence.
44. This implied that regional level data and
evidence may not be held in the longer term and, certainly, that
it will not be updated and developed. This is unacceptable and
will seriously compromise the abilities of sub-regional groupings
and LEPs to have an informed wider view of the dynamics of the
area and the overall context within which they are making policy.
45. There are already regional based "Observatories"
and it would seem sensible to make best use of the expertise that
they represent in tackling this issue.
46. The RTPI would be pleased to add to and elucidate
any of the points made in this evidence, either in writing or
in oral evidence to the Select Committee.
September 2010
5 http://www.rtpi.org.uk/download/9076/RTPI-Manifesto-for-Planning-2010-full.pdf Back
6
Channel 4 News: Faisal Islam: 2 Sept 2010 Councils Axe 100,000
Planned Homes in England
http://blogs.channel4.com/faisal-islam-on-economics/councils-axe-100000-planned-homes-in-england/13133
Back
7
Source: House Builders Association. Back
8
Planning 3 September 2010. Back
9
http://www.communities.gov.uk/speeches/corporate/lgaconference2010 Back
10
Conservative Party (2009) Strong Foundations: Building
Homes And Communities, Policy Green Paper 10. Back
11
www.parliament.uk/deposits/depositedpapers/2010/DEP2010-1688.doc Back
12
http://www.communities.gov.uk/publications/corporate/statistics/counciltax201011 Back
13
DCLG live tables. Back
14
http://www.communities.gov.uk/documents/housing/pdf/1648333.pdf Back
15
DCLG Live tables: P103. Back
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