“The Tyne and Wear Structure Plan (1981) and RPG7 – Regional Planning Guidance for the Northern Region, (1993) are two of my favourite planning documents. The Structure Plan was prepared by a small planning team led by Alan Wenban-Smith and the RPG was prepared by the Regional Government Office liaising with the LAs
Both short and sharp, timeously prepared, and providing clear strategic guidance to local councils and local communities on where the new homes, jobs, infrastructure, hospitals, schools etc would be built. And they were.
They stimulated a longstanding support for strategic planning. But recent experience leads to an increasingly critical assessment of whether locally prepared, strategic plans can now be delivered within sensible timescales, in England? And therefore, is it a realistic policy objective? Are there other ways to deliver effective regional guidance without the risk of 10-15 years of stasis in local plan making.
On the basis that 1 volunteer is worth 100 conscripts, one would expect that the voluntary strategic plans prepared over the last 15 years to provide a positive justification for making strategic planning mandatory. But they don’t. Some have worked well, say Newcastle/Gateshead, Greater Norwich, West Northants and North Northants. But most have taken too long, failed at the final fence or not delivered as envisaged.
Places for Everyone in Manchester was started in 2014. It will not be adopted in 2023 and will not cover Stockport. The West Midlands has been unable to plan strategically for Birmingham’s population growth since the 1990’s. The housing target in the London plan is way lower than the Standard Method or need. The West Country Joint Structure Plan (JSP), the South Essex JSP, and the OxCam Arc Spatial Framework all failed to achieve adoption. The North Essex JSP was found fundamentally unsound by PINS prior to being adopted without two of its three proposed garden communities. The MK and South Midlands sub-regional strategy was withdrawn soon after adoption.
If we are striving for evidence-based planning, then we can’t ignore that for reasons of local politics and overlapping governance geographies, many of England’s regions and sub-regions no longer seem have the capacity and governance to prepare strategic plans. And not within timescales which support the delivery of infrastructure and homes when they are needed. Even when they have voluntarily agreed to do it!
Preparing sub-national strategic plans, which define the winners and losers has always been hard. Is it now arguably too hard in some areas, no matter how mandatory we try to make it.
Many will argue we have no choice – if we don’t have strategic plans then (a) we can’t plan effectively for the population growth generated in cities, nor (b) ensure infrastructure spending is aligned with new homes and jobs. The Duty to Cooperate is said by most to have failed in this.
This is where recent ideas for a high-level National Spatial Plan for England are so exciting. A succinct timeously prepared document dealing with the broad regional distribution of new homes, jobs and infrastructure. Done well, a light-touch National Spatial Plan (NSP) could be prepared quickly and become a keystone spatial document for a new Government. And perhaps signposting the preparation of a more comprehensive National Plan which would provide more detail on how Government objectives for prosperity, housing, transport, health, jobs and environment, will be joined-up in both spatial and investment terms. A Levelling-Up plan some might say.
But how would the regional housing numbers in this initial light-touch NSP be translated to deliverable local housing requirements for the purposes of preparing local plans and determining planning applications?
Given my view that locally prepared strategic plans just seems too difficult, there perhaps seems 4 possible options?
The first could be return to LPAs setting their own objectively assessed need – cognisant of the National Spatial Plan regional targets and a revamped Duty to Cooperate or Alignment Test. Unfortunately this provides a mandate for anti-housing LAs to prepare local plans with unduly low housing targets by citing falling household growth projections and a need to avoid development on Green Belt.
The second could be a tweaked Standard Method which would total 300,000 homes per year, accord with the National Spatial Plan, and be attached greater weight for plans and decisions. Again, some Green Belt LAs would simply ignore it unless it was made crystal clear in a revised NPPF that housing need justifies a review of Green Belt.
The third could be a return to the August 2020 White Paper – namely an aim for ‘policy-on’ local housing targets, set by Government having completed consultations with LAs. The starting point for those consultations being that England WILL prepare local plans to deliver 300,000 homes, and the distribution WILL accord with the National Spatial Plan. A new Government could publish that distribution within 30 months and if it had a sizeable majority this would help deflect any democratic deficit accusations. As someone unashamedly pro-housing, I liked this DLUHC idea at the time and still do. Albeit recognising the huge political difficulty of imposing local targets absent positive engagement with local areas.
The fourth and final option could be a return to an ‘RPG-lite’ approach to strategic planning, as practiced in the 1990’s. Perhaps only in the areas where it is crystal clear that the Duty-to-Cooperate has failed and there is a demonstrable problem in addressing the housing need generated by cities.
Those of a certain age may remember the 80’s/90’s when Regional Government Offices worked with LPAs and then issued short sharp RPG’s giving LPAs guidance on the distribution of housing numbers and strategic employment sites etc. With a quickly prepared light-touch National Spatial Plan setting housing numbers for regions, Government could then work collaboratively and speedily with regional stakeholders to distribute the regional housing numbers to districts.
A timeous high level NSP, plus ‘RPG-lite’ documents where they are needed, could effectively distribute a 300k/year target down to both Regions and then LPAs within 18-24 months of a new Government. With a tweaked Standard Method and existing local plans operating in the meantime to ensure no stasis in local plans and decisions.
This could potentially offer a good balance between the objectives to (a) meaningfully address the housing crisis within sensible timescales, (b) capitalise upon the democratic mandate created by a general election victory and (c) ensure LAs and regional bodies have a meaningful say in the location of the new development essential to both drive economic growth and create housing hope for younger generations.
Tin hat now firmly on!
Philip Barnes - Blog 