6 Evidence and monitoring
A lack of consistent, current
planning evidence
134. Local authorities need current, relevant data—and
skilled people—to ensure that their planning decisions are
seen in context and are based on sound evidence. Local Development
Frameworks must be underpinned by evidence and it is for local
authorities to demonstrate that they have produced reasonable
plans. Much of the evidence to support LDFs was provided by the
regional spatial strategies. Without RSSs, local authorities need
to ensure, extremely quickly, that their current and future LDFs
are supported by robust evidence. Greg Clark, the Planning Minister,
reinforced this point in oral evidence:
It is open to the local authority to collect the
evidence that they feel justifies the decisions they want to take.
If they feel that the number imposed on them by the RSS does not
make sense and they can collect evidence that demonstrates a different
number is appropriate, we have been clear from the outset that
that is what they should do.[153]
135. Regional Observatories were established to provide
analysis of data to support planning and other decisions at a
regional and sub-regional level, including local authorities.
The Association of Regional Observatories summed up their work:
The Association of Regional Observatories represents
England's Regional Observatories that historically have satisfied
the data and intelligence needs of the Regional Development Agencies,
amongst others. Our work covers the economy, labour market, employment
and skills, as well as sustainability and environmental issues.[154]
136. The Association notes that information previously
collected as part of the RSS monitoring process will still remain
crucial for local authorities, including housing information and
waste management data.[155]
The same point is also made by other witnesses. The RSPB, arguing
that the local economy and the state of the environment should
be assessed by 'robust evidence', suggested that the location
of regional environmental, economic and social data is a key priority.[156]
The West Midland Regional Sustainability Forum wrote "there
is an urgent need to consider at what level future data will be
collected, especially where it is appropriate at a level between
the sub-regional and national level (eg journey to work areas)".[157]
The Chartered Institute of Housing agreed, and added concerns
about the potential lack of consistency of data when RSSs are
abolished:
The research gathered at the regional level enabled
a greater methodological consistency across local areas, and the
regional structures and process were well developed; it is likely
that, in some areas, there will be a gap in the policy and evidence
at the local level, where there was reliance on the shared evidence
base.[158]
137. The guidance issued by the Chief Planner at
DCLG, Steve Quartermain, covering the period between revocation
and abolition, states the following about data and research currently
held by Regional Local Authority Leaders' Boards:
The regional planning function of Regional LA Leaders'
Boards—the previous Regional Assemblies—is being wound
up and their central government funding will end after September
this year [2010]. The planning data and research they currently
hold will still be available to local authorities in the preparation
of their local plans whilst they put their own alternative arrangements
in place for the collection and analysis of evidence. Notwithstanding,
the new Government regards the Regional Leaders' Boards as an
unnecessary tier of bureaucracy.[159]
138. However, the data held at the time of the dismantlement
of the Regional LA Leaders' Boards, while relevant, is fast becoming
out of date, a point made by Cameron Watt, from the National Housing
Federation:
CLG has said it has made good arrangements for the
data that were previously collected by regional leaders' boards
to be looked after and updated by other organisations. I believe
that for the south-west the data have been deposited with the
British Library, which to me does not suggest that these are living,
active data sets that will be made freely available to local authorities
to help inform their new-style local plans. We have real concerns
that the evidence base for local authorities to develop their
new housing numbers just won't be there.[160]
Who should have responsibility
for data collection?
139. The Secretary of State told us that local authorities
should have the responsibility of collecting data relevant to
planning:
We are very content for local authorities to collect
that information that is important to them. We will continue to
produce national indices to help them in that process, but leaders'
boards existed before and had the ability to bring authorities
together to retain that information. We are confident that they
will continue to do so.[161]
He added: "We are trying to get away from prescribing,
and over-prescribing, the kind of data that it is necessary to
keep".[162] When
asked whether it was important that there should be consistency
in the methodology used in collating data from one authority to
another, he replied,
I am very confident that, without the need to legislate
or bother them, local authorities between them will be able to
put together this package in a sensible way. I do not think this
is something that the Mother of Parliaments should prescribe.[163]
140. It is unclear how to reconcile the Secretary
of State's initial comment with the Government's view that Leaders'
Boards are "an unnecessary tier of bureaucracy". Without
Leaders' Boards providing the skills and budget to collate the
information, it is hard to see how local authorities will 'continue'
to be brought together. More fundamentally, the Minister's answer
presumes that local authorities are equipped with the relevant
resources to collate such data. However, Christina Howick, from
Roger Tym and Partners, told us of the practical problems local
authorities face when attempting to collate the relevant data
to inform their planning decisions:
Inspectors and common sense require reasoned evidence
for things like housing targets. It is not straightforward. Economic
and employment targets are even harder. A lot of officers have
said to me over the past months that they simply do not have the
skills and resources to do what they are now expected to do.[164]
141. A report from our predecessors in the last Parliament,
Planning Matters, published in July 2008, drew attention
to this skills shortage in planning and made recommendations for
change:
Wider economic well-being and delivery of the Government's
environmental priorities could well be hindered simply because
the system cannot cope. Two linked and chronic problems need to
be urgently addressed to prevent this—a drastic shortage
of planning officers, estimated to affect 46 per cent of local
authority posts by 2012, and a significant and growing skills
gap among those planners who remain within the system.[165]
The Report was published before the recent economic
decline and before the significant recent cuts in grant to local
authorities, so its conclusions are even more pertinent. There
is almost universal concern in our evidence that local authorities
will not have the capacity—in terms of money or skills—to
collect relevant evidence.
142. Even if that were not the case, there remain
the questions of, first, whether it is an efficient use of public
resources to leave it to individual local authorities to undertake
work which all our witnesses who commented on the matter considered
had been carried out very effectively under regional structures;
and second, who will take the strategic view of the type and comparability
of the data collected. The Association of Regional Observatories
made the following point:
There is a role here for CLG to provide information
and guidance on definitions of datasets to be collated by local
authorities for planning purposes; to ensure that datasets remain
comparable with previous years' data; to provide appropriate mechanisms
to enable this information to be shared across local authorities
(allowing comparisons between areas to be made); and to facilitate
cross-region comparisons as appropriate.[166]
The Joseph Rowntree Foundation suggested that "a
central website could be developed collating all relevant data,
research and guidance" and proposed that an innovative use
of online technology would enable local authorities to share resources
and work together effectively".[167]
143. It is crucial that evidence is assembled on
a consistent basis across local authorities, to ensure that planning
decisions are soundly based. Local Development Frameworks must
be underpinned by evidence and it is for local authorities to
demonstrate that they have produced sound plans. There must then
be clear opportunities for individuals and groups to challenge
decisions that apparently pay insufficient attention to the evidence.
This will be extremely difficult when there is no consistency
of data collection. The Government is optimistic in its view that
local authorities will collate such data. We are not so optimistic,
particularly given the shortage of planning skills—which
our predecessors highlighted—and the shortage of financial
resources in local authorities.
We recommend that the Government bring forward proposals which
will ensure that robust and consistent evidence to support local
development plans is produced and regularly updated in the most
effective and efficient manner. It is not acceptable for Ministers
to abdicate their responsibilities in this regard by leaving all
the responsibility with under-resourced and under-skilled local
planning authorities.
153 Q 266. See also paras 43 and 100, above. Back
154
ARSS 15, Association of Regional Observatories, para 3.1 Back
155
ARSS 35, Association of Regional Observatories, para 4.2 Back
156
ARSS 122, RSPB, para 12 Back
157
ARSS 17, West Midlands Regional Sustainability Forum, p3 Back
158
ARSS 135, Chartered Institute of Housing, para 3.5 Back
159
Letter from the Chief Planning Officer, Department for Communities
and Local Government, to local planning authorities in England,
6 July 2010, accessed at www.communities.gov.uk. Back
160
Q 235 Back
161
Q 331 Back
162
Q 332 Back
163
Q 334 Back
164
Q 11 Back
165
Eleventh Report of the Communities and Local Government Committee,
Session 2007-08 (HC 517), Planning Matters-labour shortages
and skills gaps, para 6. Back
166
ARSS 35, Association of Regional Observatories, para 4.5 Back
167
ARSS 32, Joseph Rowntree Foundation, p 2 Back
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