Levelling up is a worthy aspiration, but implementation is everything: there is no strategy without a plan. As the Levelling-Up and Regeneration Bill (LURB) progresses through Parliament, it is vital that its inconsistencies are resolved. I believe a regional planning framework and a national spatial plan are the best way to achieve this.
There is no doubt that some form of UK-wide levelling up is required to meet housing need in the south, and bring the economic benefits of regeneration to areas of the north and Midlands that require it most. At the same time, we need to acknowledge that the problem is more complex, and pockets of deprivation in the south and housing shortages in the north must also be looked at.
But while the bill provides an impetus for nationwide regeneration, it lacks a framework for implementation. There is a clear need for a national plan to support this national aspiration. Instead, however, the bill includes a raft of disparate policy objectives and plethora of tactics, some of which are inconsistent with the overall aims of levelling up.
The UK is the only major European country that lacks a national spatial plan and a framework for regional planning. A national vision or a structured regional planning system, which has been shown to work in countries such as the Netherlands and Germany, produces a more consistent and less adversarial approach to planning and development.
Such a plan would identify suitable locations for growth. Promotion of land through the strategic planning process would then be smoother, and could be linked with new and existing infrastructure. It would also provide a spatial framework for development across the county while allowing for local involvement in the detail. Fostering a more positive, joined-up and pro-development approach to the housing crisis, it would build on the National Planning Policy Framework's presumption in favour of sustainable development and enable land to come forward more easily.
This could resolve the two central problems with the local plan process: that often too little land is allocated for development, and local councillors can be disproportionately influenced by anti-development politics, which then takes precedence over the need for development.
The introduction of a national plan would also enable the streamlining of local plans – something that was proposed in the levelling-up white paper, but is only partially dealt with by the bill.
Building in Marzahn, Berlin
As the white paper states, the housing market is one of the biggest catalysts for economic development. Combined with appropriate investment in employment and transport infrastructure, housing can kick-start regeneration where it is most needed, also raising the value of land that was not previously in demand. A national approach would enable a better spread of new development in line with the levelling-up agenda, as well as speeding up housing delivery.
At the heart of the levelling-up agenda is a contradiction concerning housing provision though: while the policy aims for growth, specifically in those areas needing regeneration, there is no commitment to housing targets. In fact, the UK government appears to be moving away from housing targets completely.
Targets are rarely seen as desirable to those whose role it is to implement them. They are invariably aspirational but rarely attainable; when missed, they run the risk of public approbation and even sanctions. And yet abandoning the targets almost reduces the likelihood of that ambition being realised, as well as reducing demand in the land market.
Removing housing targets will result in fewer homes being built. As a result, risk and uncertainty in the planning system will increase, perpetuating house price escalation in the most popular areas, and hampering the potential for levelling up.
Under a national framework, housing allocations and distribution could be strategically planned in a way that has been lacking since regional spatial strategies were revoked by the coalition government in 2010.
By determining housing allocations at a higher level, contentious decisions could be removed from local politics. A more consistent approach would result in the allocation of sustainable locations for development in the context of nationwide levelling up, regional transport proposals and designated Freeports.
The bill proposes changes that may be regarded as coming from the top down; for example, removing policies on matters such as heritage, conservation and green belt from local plans and putting them in a set of national development management policies. Alongside these are bottom-up proposals such as strengthening neighbourhood planning, introducing street votes, giving residents a say in the development process, and three mandatory rounds of consultation on design codes.
Top-down policies can create greater consistency, but bottom-up policies put this at risk. The political aspiration for the latter is clear: when the 2020 planning white paper proposed changes that reduced local input, the electorate was quick to register its opposition and the government lost subsequent by-elections partly for this reason. Localism is undoubtedly a vote-winner, but ensuring it is compatible with a national initiative will be a difficult balance to strike.
The unwillingness of politicians and public alike to entertain a review of the green belt demonstrates just how badly its purpose is understood. There are undoubtedly areas of land wrongly designated green belt, which suggests a review is necessary. But a review is not a green light for developers to build anywhere they like.
A national green belt review could simultaneously increase the availability of land suitable for development, provide clarity for local authorities, and offer greater protection for land that accords with the objectives of the green belt. If politicians framed a review as a way to increase the amount of land designated green belt, this could be another vote-winner.
The notes that accompany the LURB state that local plans, neighbourhood plans and spatial development strategies proposed by mayors or combined authorities will each be strengthened. This prompts the question of whether every level of planning can be strengthened without weakening the others. And does putting more weight behind each constituent part of the planning system benefit it, or simply increase the potential for clashes?
It seems inevitable that an imbalance will occur. In specific areas, local and national policies could collide; and on a national level, some areas would benefit from a regionally led devolved administration while those without would continue to be governed by local and neighbourhood plans.
The bill also removes the statutory requirement for local planning authorities to consult neighbouring councils when preparing local plans. In my view, this duty to cooperate was a useful tool in the context of levelling up. This move is therefore disappointing, because the duty has been one of the few levers in national policy to encourage compatibility between local plans at a regional level, and in many cases has led to effective collaboration between authorities.
Landowners benefitted from the duty to cooperate if their holding straddled boundaries between local authorities, which is often the case. What is, in land terms at least, an arbitrary line across a site should not affect its potential for development; but the likelihood of success is reduced without a more regional approach.
In place of the duty, the bill will introduce initiatives to enable neighbouring councils to prepare joint spatial plans through a more flexible alignment test – to be included in a future revision of the National Planning Policy Framework – and a voluntary spatial development strategy on specific cross-boundary issues.
The removal of the statutory requirement for cross-boundary communication does not prevent it continuing where it currently works well. But the potential for any new collaboration will be lost. Some local authorities will end up pursuing a more independent route, which will again mean that a local focus will be preferred to a view of the bigger picture that a national levelling-up initiative should encourage.
The sentiment of localism remains in the bill, primarily through the increased role of local input in mandatory design codes, the strengthening of neighbourhood plans and the potential street votes.
With three rounds of consultation being required on a design code, local involvement on specific developments inevitably increases. However, it cannot do so in a consistent way across the country. In this respect, it runs against the objectives of levelling up. As neighbourhood planning has demonstrated, the potential for influence among a specific community lies in its own demographic.
Those with a professional, prosperous and permanent demographic are likely to exert more power on local issues than deprived areas and those with more transient communities. This cannot be changed by legislation but only through long-term investment in community development, and raising the profile of the consultation stages.
Education in planning as well as educating planners will also be necessary to engage more effectively with hard-to-reach groups of people. It cannot be achieved quickly or cheaply. Furthermore, design is the most subjective area of planning, over which consensus is rarely achieved.
Many in our sector berate localism as a scourge of planning, noting that it does not help when excessive influence is exerted by laypeople and their personal interests, at the expense of professional opinion. I do not see local input and professional expertise as opposites, however, but as potentially compatible forces. There is undoubtedly a role for local views in the planning process. But in a house of cards where local voices represent the lower level and the national intent the top, taking a card from the lower level means the house cannot stand.
My message on behalf of the land sector to politicians as they debate this extremely important bill is simple: planning is better with input from many levels, neighbourhood, local, regional and national. But an overall aspiration such as levelling up can only be achieved efficiently and effectively if each element of the planning system is part of a consistent whole.
Read more about RICS' policy and ten-point plan on the Levelling-Up and Regeneration Bill.
Dr Paul Beckett 22 May 2023
Fiona Mannix 18 May 2023
Antony Parkinson MRICS 15 May 2023