Planning Summer School

September 2003

MODERNISING PLANNING SYSTEMS IN EUROPE:

A COMPARISON

Vincent Nadin
Director, Centre for Environment and Planning
University of the West of England, Bristol
Vincent.Nadin@uwe.ac.uk

The attention of planners in the UK over the last few years has been
concentrated on the review and reform of their own planning systems. I want to
use the opportunity of this paper to tell you something about what is happening
to planning systems and policies in other countries.

I don’t think I need any special reason for doing this except that it is interesting,
and spending some time examining ‘how others do it’ is an antidote to
introspection. However, I do think that comparison has great value; and the main
benefit is that it helps you to understand your own system. Since I was first
presented with the opportunity of learning about planning systems in other
countries I feel that I have understood planning in the UK much better, and I can
set our proposals for reform within a wider context. Much of the impetus for
reform results from initiatives and forces from outside this country and other
countries are having to address the same issues – but often from a different
starting point.

Because we have four planning systems in the UK which differ in important

respects I am concentrating primarily on the English planning system. Also my
comparison countries are mostly northern European because these are probably
the most appropriate comparisons and because it is in part the European
planning agenda that is stimulating most international comparisons. My main
sources are some of the recent projects that I’ve been involved with: The EU
Compendium of Planning Systems and Policies and an Update of information
for some countries prepared for the ODPM, and a comparison of environmental
planning systems undertaken for the Royal Commission on Environmental
Pollution.

There are five areas that I want to briefly discuss

 institutions and the planning competences that they hold;

 the question of integration and the notion of spatial planning;
 developments in the creation and use of planning instruments and tools
(plans); and
 policy themes.

I will also conclude with a few comments about what these cross-national
comparisons – indeed the whole international planning scene has got to do with
you: although I would also be interested to hear your comments on that point.

But first, we need to note that cross-national comparison is a tricky business and
it comes with a serious health warning. Planning systems and policies can’t be
understood in isolation from their context. Great care is needed in transposing
approaches and tools from one country (or even region) to another because
conditions vary so much. I might assume sitting in my office in England that
some other countries are similar when in fact there are very important difference
in conditions or context that make a big difference to the operation of planning
include

 the form of governmental systems - assignment of competences and capacity

at different levels;
 the physical geography; spatial development patterns and trends
 the legal systems and constitutional safeguards
 the relative roles of the public sector and the market
 and less tangible matters like political will and public awareness, values and
attitudes especially about land, property and government.

So the context in some other countries can vary dramatically. Take Scotland for
instance; it varies from England in all these categories. I use Scotland
deliberately because having issued the health warning, I feel that it is overplayed
sometimes –England and Scotland obviously have very similar approaches to
planning despite these differences. Indeed, it is the similarity among many
European countries in their formal planning systems that is more remarkable
than the differences (especially in comparison to the US). This is because they
are trying to do the same job in the face similar issues and problems.

What is most apparent to me after studying comparative systems for some years
is that the formal parts of the system matter much less than the context. The
reason that planning is less effective in Greece (and that is the conclusion of my
Greek colleagues) is not for lack of plans or planning institutions, but rather it is
about people’s attitude to government and regulation and how they value land.
So the formal system may be perhaps less important than the more informal less
tangible factors.
Am I doing myself out of a job? No because the value of cross-national
comparison of systems is that it highlights the importance of these conditions,
which otherwise we tend to take for granted. This is why I think the ODPM have
got it right when they talk about ‘changing the culture of planning’ as much as
the formal institutions and instruments.

The first thing that comparison reveals is that the task of modernising planning
is not unique to the UK. The following words could be taken from the UK
document on modernising planning.

‘The increase in the scale of … planning, renewed economic growth and

technological developments have all affected the way decisions are made
– this means decisions have to be better, more integrated and made more
quickly… The system has to be simplified; responsibility has to be shared
properly…’

In fact they are from a Dutch discussion paper on proposals to revise the
Netherlands Spatial Planning Act. There are many other examples from across
Europe and indeed, the world, where the same things are said. Many
governments are undertaking reform of planning policies and tools with a view
to using planning more effectively. Indeed, it may be true to say that there is a
‘worldwide renaissance’ in spatial planning.

Before starting on my five main comparisons, I do want to mention specifically

one contextual factor that obviously has a determining effect on the planning
system and how it is used – geography.
The left hand slide indicates the population density of a selection of countries;
the right hand figure shows various formulations of the economic heart of
Europe, where there is the greatest concentration of economic activity and
investment. It is fairly obvious that what suits Sweden with its very low
population density will not suite the Netherlands which has a very high
population density and is it at the heart of the central economic zone. The impact
of geography is immediately apparent on planning systems. For example, the
special conditions of Sweden have contributed to its strongly decentralised
system planning; a heavy emphasis on natural environmental issues (eg
forestry), and although there is provision for regional plans, in practice, only the
Stockholm region plan has been prepared.

Again, I find myself presenting an argument for not making comparisons, but it
is simply an illustration that these and other contextual factors must be taken
into account.

1. Institutions: government competences for planning

The starting point is all important in terms of structure and then ‘enumeration of
competences’. You will know that there are broadly three types of system

● Unitary - centre has power, weak regions but may be autonomy at local
level
● Regionalised – unitary but competences devolved to regions
● Federal – extreme case is Belgium where no national competence for
planning

It is in fact more complicated than this because a number of systems are

hybrid or asymmetrical, and this is increasing. Structures are changing, in
particular with strong regionalisation – and there may also be a measure of
recentralisation – I’ll explain these little later. The slide also notes that we
should also bear in mind here the different issue of state v. private
institutions which is important

At the regional and local levels the UK is distinctive.

The figure on the left shows the size of regions by population and area for
EU member states. The UK has the largest populations and is amongst the
largest in size. The figure on the right shows the size of local authorities in
the EU member states by population. Again the UK stands out. Only Greece
has larger local authorities and I understand that that may have changed since
these figures were put together. So the UK has by some way the largest
authorities responsible for planning - but fewer competences and less
autonomy than much smaller local authorities in some other countries. Take
the regional comparison with Germany for example. The figures here are for
the Länder (states) and not the regions that exist in some states. The states
have their own parliaments and planning legislation.

Although I’ve said that institutions and instruments are less important that
other factors, I would argue that the size of planning authorities in the UK
has had a big impact on the way the system works. I’ll come back to this.

The comparative picture on institutional structures and the enumeration of

planning competences is mixed and an attempt to summarise the overall
effect for some countries is given in the figure.

To the left are countries with highly decentralised structures, the federal
systems are in the middle, and to the right more centralised systems.
Relatively speaking, England has the most centralised system in western
Europe apart from Greece. There are four main points here.

1. Structures are changing, and there is a strong process of regionalisation

which has important implications for planning. The competences of the
regions are generally extending and they are building identity and seeking
further autonomy. One result of this is more variation in planning systems.
Examples are Spain and Italy (not on this slide) and France.

2. At the same time, many central governments are safeguarding and

strengthening their competences in some areas of decision making. For
example the Netherlands and Denmark have both strengthened national
powers.

3. The result of this in countries that have strengthened the regional level is
that there can be a recentralisation of power around the region.

4. There is a general trend to address the fragmentation caused by many

small local authorities by providing incentives for them to work together
more to produce joint plans and policies; as for example in France.

You will see that I have ‘hedged my bets’ where the UK is concerned.
Obviously we are seeing asymmetrical regionalisation as exists in Spain and
Italy, but also a fairly tight hold on ‘central government’ planning powers,
and perhaps evidence of recentralisation.
2. Integration and spatial planning

Integration is the Holy Grail of planning. Much of the modernising planning

agenda in the UK has revolved around the notion of spatial planning –
particularly in relation to proposals for ‘better integrated’ strategies at the
regional level (to use the ODPM’s words). This is not a new phrase but its
increased use now may signal a significant change in the role of planning and
not just in the UK. So what is this change?

In England like all other EU countries we have a planning system that is largely
based around physical land use regulation. In our work on the Compendium we
suggested that planning systems can be characterised in different ways – as
shown in the figure. Systems are generally a mixture of these characteristics.

land use management

urbanism
regional economic planning
comprehensive integrated planning.

The land use management tradition is where the system primarily pursues the
control of land use change at different spatial scales through a hierarchy of land
use plans and policies and a well established process for regulating
development. Urbanism is the dominant tradition of planning in the
Mediterranean countries. The accent is on building and land use regulation
through rigid zoning and codes and with a strong architectural and design theme.
The regional economic planning approach makes use of a wider range of
regulatory and economic instruments to address social and economic disparities
across regions and cities and with a strong territorial approach. Such planning is
closely linked to public sector investments and regional economic policy, and
thus central government plays an important role. The comprehensive integrated
approach to spatial planning has the clear objective of spatial co-ordination of
public policy across different sectors. This approach requires well established
planning institutions, strong political commitment and mechanisms for the
public sector to realise objectives and lead development.
Whatever mixture of characteristics the planning system comprises a sector
within public policy which has the principal task of regulating land use.But
many other sectoral policies have impacts on spatial development. (Spatial
policy is the term used to describe the spatial or territorial impacts of sectoral
policies.) All sectors have some aspect of spatial policy (although this is usually
not made explicit) from the fairly obvious impacts on spatial development of
transport and agriculture to the less obvious but no less important spatial impacts
of education and health policies.
All planning systems have mechanisms by which they try to coordinate and
integrate the spatial development impacts of the other sectors – represented by
the yellow dotted lines on the figure.

But over recent years, and particularly in debates at the EU level, the term
‘spatial planning’ has come to represent a more fundamental approach to
coordinating spatial policy. The idea is of spatial planning as cross-sectoral
coordination. I’ve tried to show this in the second figure.

In this second sense, spatial planning has been described as a method of securing
‘convergence and co-ordination between various sectoral policies’ through a
territorial development strategy (CEC 1999, Bastrup-Birk and Doucet, 1998).
(Thus, the central task of this sort of spatial planning is to identify and address
the contradictory effects of sectoral policies and the opportunities for synergy
and complementarity in their spatial effects.)

Many countries are seeking to improve this cross-sector policy coordination and
integration role of planning; and everyone is finding it difficult.

There is a view among some in the UK that this is borrowing from practices in
other EU countries. I don’t think this is correct. It doesn’t exist. Some countries
have paid more attention to cross-sectoral coordination. France is perhaps the
closest; especially with the creation of new national sectoral plans which are
intended to be more explicit about the regional and territorial impacts of sector
policies.

It is difficult to generalise; there are many different approaches. In England the

approach is to grow the land use planning system into a wider ‘spatial planning
system’. I have some reservations about that. The diagrams on the figure
illustrate in an ‘ideal type’ kind of way some alternative approaches to
coordination looking especially at planning, environment, and transport. I’ve
taken the detail out and I’m using these just to illustrate four aspects of
approaches to integration that are being taken.

1. The first is to establish ‘composite long term goals’ at the national level and
give them legally binding authority to apply for all sectors which continue to
operate separately at the lower levels. Sweden has moved someway towards this
by establishing an environmental code, but there is a big step between this at
national government level and individual sector actions at local level in the
absence of a strong regional strategic structure.

2. Number 2 is illustrates how the traditional ‘policy silos’ or sectors are

encouraged to work together on non-statutory and non-binding policy
frameworks at all levels of government. The non-statutory approach is now
much more common, because it frees up the system somewhat from worries
about legal competences and the like. The Netherlands has made much progress
on this and inter-sectoral vision statements are produced at national and local
levels.

3. Number 3 illustrates the situation where there are parallel policy and
regulation regimes in place but where there are strong mechanisms of co-
ordination among them; horizontally at each tier of government and vertically
between the tiers. This is a feature of the German system where there are
separate land use and landscape planning systems.

4. The final diagram is the ‘total integration ideal model’. There is again a strong
lead on objectives and decision criteria at the top and a single resource planning
and management system. To find something like this you would have to go to
New Zealand. Even in a small country with relative consensus about goals this
approach has proved very difficult to implement. It has its supporters but the
demands it makes on government, professionals and the development industry
suggest it is not one to be recommended for Europe. Some compartmentalisation
is inevitable. However, at least one province in the Netherlands, Limburg, has
made progress on replacing separate policy plans with regional corporate plans
covering environment, water, transport, economy, welfare and culture.

5. Another feature of interest, and which is not illustrated, is the preparation of a

national review of spatial development, or set of national accounts on the effect
of policies. The Dutch prepare national accounts which have this function and
although they don’t have a national plan, the German Federal government does
produce a very interesting spatial development report. In fact most of the
national spatial planning reports or perspectives are reports on spatial
development trends and their consequences – looking across and directed at an
audience in all sectors.

What model might best represent the approaches to policy integration in the UK.
Your homework from this session is to draw a diagram which represents the
policy integration approach in England, Wales, Scotland, Northern Ireland or
wherever.

So the story here is mixed. Everyone would like to see more integration but
there are very different approaches to achieving it.

Instruments
The effort going into integration of sectoral policy and other factors has led to
some similar trends and developments in terms of planning instruments or tools.
Again there are a lot of different approaches being taken but there are three
things I’d like to mention under this heading

More countries and in some cases regions of large countries are producing
national spatial strategies, visions or perspectives. As I’ve already said, from
what I’ve seen the visions are more ‘statements of what is’ rather than of ‘what
will be’. That is, they are a record of spatial development trends rather than
strong policy statements, but they are still thought to be valuable. They are also
addressing the transnational dimension of national and regional policies. The
smaller countries lead on this, partly because the planning issues are easier to
manage at the national scale in a small country and partly because they are the
ones that are most affected by developments in neighbouring countries. I
understand that the Wales Spatial Plan is expected to be published anytime now,
and of course Scotland is undertaking similar work.

Following on from what I said previously about central government

safeguarding its competences, another development at this level is the creation
or strengthening of instruments that enable central government (or region) to
impose decisions on lower tiers, as in the Netherlands and Denmark where local
authorities and interest groups were previously blocking government intentions.

Perhaps most noticeable is how in various systems the boundary problem is

being tackled in different ways, with more emphasis on planning instruments
that cut across administrative boundaries to cover functional planning areas or
areas of cooperation or networks of towns. Procedures and incentives are put
into place for local authorities to cooperate more effectively on strategy and the
creation of networks or partnerships of cities and regions to work together on
common problems. Closer to the local level, flexibility is the key issue for plans.

4. Flexibility and commitment

This is where the UK systems have differed most from continental European
land use planning systems. In most countries the decision is effectively made
with a plan – a binding regulation plan – the permit that follows is simply an
administrative (non-professional) procedure – if the development matches the
plan, your permit is given. Faludi uses the term ‘decision moment’ to explain the
difference. In one approach the decision moment is with the plan in the other it
as the point the proposal comes forward.
The two approaches are sometimes explained as at the opposite ends of a
spectrum – with the UK characterised as discretionary or flexible and
continental systems as rigid and inflexible. But it isn’t quite as simple as that.
Some continental systems have mechanisms that allow for some discretion –
that is for decisions to be made contrary to the plan. Conversely, in the UK we
have been trying to give our development plans more influence in the decision,
and so have restricted discretion. And in any case, everyone wants the planning
system to be both flexible and rigid – depending on the circumstances.

This figure illustrates one interpretation of the real situation in practice. The x
axis has three categories for level of discretion in the system (the method and
criteria for judging where systems go on this scale are spelled out in my paper).
For interest I have also put the extent of inter-sectoral coordination on the y axis.
(Note that I have used the UK here and not England.)

The two arrows at the bottom of the diagram illustrate the general trends. There
is a very strong move to reduce the rigidity of the system in countries such as
Greece and Italy where the lack of flexibility and the time needed to get plans
changed contributes to the lack of credibility of the system and helps to explain
why in some cases people ignore it altogether. This also applies though in
northern European countries where new approaches are being introduced to
allow for developments contrary to or without a regulation plan. I wonder if
more people had understood these differences at the beginning of the 1990s if
we would have ended up with a different approach to the ‘plan-led system’.

In the UK we have been heading in the opposite direction and trying to put in
place a ‘plan-led system’, but not perhaps not such a strong trend – we have not
changed the law to facilitate this for example. Essentially the fundamental
differences remain. I believe we will end up with both approaches in some
countries. I wonder why the idea of regulation plans (or advanced planning
permissions) has never caught on in the UK? It probably has something to do
with the very professionalised and politicised nature of our planning system. A
related issue here is accountability – including procedures for objection,
consultation and participation.

5. Policy themes

I’ve picked out two related issues here – sustainable development and urban
containment. Since the adoption of Agenda 21 most countries have prepared a
sustainable development strategy with the intention of influencing public policy.
Sustainable development is now routinely cited as the principal goal of planning
systems in Europe. But there is some variation in how this is done as illustrated
in this figure.

There are three categories – starting from the left

 environmental or ecological principles established in law;

 a wider notion of sustainability established in policy;
 more ambiguous attitude to the environment and sustainability.

The inclusion of the US in the far right column may be a bit unfair to those
American states that are taking sustainability seriously. You might also argue
that I have been unfair to the countries of the UK.

My suggestion is that there has been a trend from the far right category to the
middle group, and some countries have gone further but I’m not optimistic about
that continuing. There is likely to be a clustering in the middle.

The discussion of sustainability is raising questions about many other spatial

development policies, and urban containment in particular. Some planners in
England (and the Institute itself I think) have called into question the current
formulation of green belts. On this we may be swimming against the tide. Urban
sprawl is perhaps the biggest spatial development issue in Europe (and the rest
of the world). Comparatively England performs exceptionally well on
containment (I know some interests won’t be satisfied by this).

This figure shows the net annual conversion of land from rural to urban uses in
the UK and Germany, on the left in absolute terms and on the right as a
proportion of the total land area. The statistics on land use are notoriously
dodgy, but the point is still made. Not surprisingly, there is strong pressure in
Germany to establish green belt policy – and in doing so, restrict the autonomy
of the local authorities to agree to new development. The same applies to other
countries including, I understand, Wales – and it is going to be a very big issue
for the accession countries.

The comparison of land take is rather dramatic if we extend it to North America.

This is what happens to the figure when the USA is included.

In conclusion: what’s all this got to do with you?

Perhaps you will agree that reviewing how others do it can produce some
interesting ideas. A number of EU initiatives, especially Interreg, are providing
opportunities for much more co-operation among planners from different
countries and regions – which I’ve illustrated here. So many more people are
now learning about planning in other countries, and I expect that to start to
influence the shape of our planning systems in time.

I hope that a by-product of this is that more planners and plans reflect on the
position of their authority or region or country in a European rather than just a
UK context. It is a great disappointment to me to see for example regional
guidance (and even the issues papers for new regional spatial strategies) only
seeing the region in its UK context.

Comparison with other countries might also help in thinking about how we
respond to European wide initiatives such as the European Spatial Development
Perspective. On this front there is more to come, including the proposed
Communication on Planning and Environment, and possible measures to
encouraging links between spatial planning, the structural funds and other public
investments.

But as I said at the beginning, I think with cross-national comparison, the main
benefit is a better understanding of aspects of your own planning systems and
the proposals for reform. You will reach your own conclusions, but for me
comparison first of all gives me some confidence that we are broadly doing the
right thing. But it also raises a number of questions.

The principal ones are about

 Despite devolution, the UK and England planning is still relatively centralised

and top-down.
 Our discretionary and professionalized system is viewed with envy (as is the
ability to work with the private sector) and we need to safeguard that, but is
there a role for regulatory plans or zoning in the UK?
 Are we tackling the boundary problem effectively? Local authorities are
large, but tend to have fewer competences and there are fewer incentives to
collaborate. For me part of the solution for tackling the boundary problem
would be to have smaller authorities – which would need to collaborate; but
that is someway off!
 The proposed vague statutory purpose of planning in England in ‘contributing
to … sustainable development’ looks very weak in comparison with some
countries we would like to be compared with.

Overall, whilst we should not read too much into cross-national comparisons; it
is difficult to escape the conclusion that the modernisation of planning in the UK
is not as fundamental as claimed. If emerging proposals from the EU come to
anything in the next year or so, another round of ‘modernisation’ will follow
shortly.