• Issue 50

  • Sep 2019

The Source

The Rise of Strategic Planning – A Solution or a Hinderance?

Strategic Planning is well and truly back on the agenda, although in reality, it never really went away. But is the move towards a more strategic approach to future growth going to speed up the preparation of Plans or are the issues and complexities involved with working across multiple authority areas simply going to throw up new challenges and potential delays.

It is clear that planning on the basis of individual local authority areas can have severe limitations, especially where there are considerable cross-border issues such as meeting the growth aspirations of a major urban area, accommodating unmet housing or employment needs, delivering strategic infrastructure improvements or assisting an authority which is heavily constrained or underbounded.

The National Planning Policy Framework 2019 (NPPF 2019) supports the preparation of strategic plans stating in Paragraph 17, that strategic policies can be contained in individual local plans, joint plans or a spatial development strategy. But there is an important distinction between the latter two strategic plans mentioned.

Joint Plans have continued to be prepared across the country and have, in some instances, been recently adopted; examples include the Nottingham City Region Aligned Core Strategies and the Gloucester-Cheltenham-Tewkesbury Joint Core Strategy. Others are currently in preparation, with notable examples being the Oxfordshire Joint Strategic Spatial Plan, Exeter City Region Joint Plan and the West of England Joint Spatial Plan. But major issues have arisen in some of these cases which has led to potentially significant delays in the plan making process.

Spatial Development Strategies are produced by elected Mayors or combined authorities where plan-making powers have been conferred through the Combined Authorities (Spatial Development Strategy) Regulations 2018.

Currently there are nine combined authorities with directly elected mayors which cover over 50% of the population of England. These are; Tees Valley, North of Tyne, Greater Manchester, Liverpool City Region, Sheffield City Region, West Midlands, West of England, Cambridgeshire and Peterborough and Greater London. Only 5 of these have strategic plan making powers with four plans currently in preparation; Greater London, Greater Manchester, Liverpool City Region and West of England.

The content of Spatial Development Strategies is bound by the aforementioned Regulations. They cannot allocate sites and may only show broad locations for growth. However, they can undertake strategic Green Belt reviews to identify potential broad locations for strategic Green Belt release, leaving formal de-designation and site locations to subsequent Local Plans. They also require unanimous support from the constituent Local Authorities, with the exception of London where the Mayor can impose his Plan upon the London Boroughs. This latter criterion has subsequently led to delays in the preparation of the Greater Manchester Spatial Framework, as gaining unanimous support for the Plan from 10 authorities is an unenviable task and may ultimately lead to sub-optimal planning as concessions are made to try to gain the support of the various authorities,

Tensions have also arisen between the London Mayor and some of the London Boroughs as the new London Plan seeks to impose housing requirements and some quite detailed development management policies on the Boroughs. Many consider that the housing requirements set out in the New London Plan are undeliverable and that the detailed policies go beyond the strategic remit of a high-level Spatial Plan. This has consequently led to lengthy debate at the recent New London Plan Examination.

The recently published Inspectors’ letter on the West of England Joint Spatial Plan (JSP) has also raised fundamental concerns with the Plan as submitted which, in all likelihood, will lead to a significant delay to its eventual adoption.

In their initial findings, the Inspectors’ were not persuaded that there was evidence to demonstrate that the Strategic Development Locations (SDLs), and thus the overall spatial strategy, had been selected for inclusion in the plan, against reasonable alternatives, on a robust, consistent and objective basis. They suggested that it might be appropriate to consider developing a high-level strategy for the plan area which, not based on specific SDLs, identifies how housing, employment and other development should be broadly distributed. Proposals for specific strategic development locations would then follow on from this. This approach, they suggest, would also potentially provide the plan, and the follow-on local plans, with the flexibility to select alternative/additional SDLs should this be necessary if one were to “fall away” or if the quantum of development needs were to change over time.

The Inspectors’ letter also sets out other initial concerns with the Plan and highlights their intention to prepare a further letter on some more detailed concerns in due course. We therefore await their final conclusions and how these may impact upon the future progress of the JSP. Delay is almost inevitable.

We are all well aware of the limitations of individual Local Plans to meet the strategic needs of their wider areas. However, preparing plans on a wider strategic basis brings its own challenges. Strategic Plans can help to meet unmet housing and employment needs from other areas and provides a more appropriate vehicle for tackling cross-boundary issues such as infrastructure provision and waste treatment and disposal. They can also establish strategic policies and strategic locations for growth which can make the preparation of supporting Local Plans quicker and easier.

However, strategic plans require the support of the constituent authorities (unanimous support in the case of Spatial Development Strategies). They can lead to sub-optimal planning as difficult decisions are avoided and concessions are agreed in order to ensure the support of the constituent authorities. The preparation of strategic plans may also lead to delays in delivery, as decisions may have to await the subsequent preparation of supporting Local Plans. In addition, any failure of a Strategic Plan to deliver, is likely to result in the need to review the strategic plan, thus causing further delays in the preparation of supporting Local Plans.