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Abstract: An underlying aim of European territor-

ial cooperation initiatives, such as INTERREG,is that they will lead to mutual understandingand learning across national boundaries. How-ever, the effect of mutual learning on nationalsystems and policies of planning is uncertain.After all, spatial planning systems are deeplyembedded in their socio-economic, politicaland cultural context, which can potentially con-strain the scope for mutual learning. Moreover,planning systems may have a certain degree of

path-dependency, such as the persistence of in-stitutions and cultures. In this paper, we explorethe relationship between planning systems andtheir context and assess the extent to which co-operation and learning might contribute to con-vergence in styles of planning in Europe, as wellas why and how this might be taking place.

We take as our context the prevailing so-cial model or model of society, the collectionof common social and cultural values. We ex-amine and compare typologies of planning sys-tems and typologies of social models and find a

degree of correspondence between them. Theexamples of England and the Netherlands areused to illustrate this interdependence. How-ever, they also reveal how planning systems andpolicies in different contexts are changing insimilar ways, and perhaps even demonstrate ameasure of convergence. In other words, ex-ternal factors may be overriding or undermin-ing the influence of the national social model.The implementation of planning reforms maybe running ahead of wider changes in the so-cial model.

1. Introduction

The notion of models of society (or ideal typesof societies) is used to generalize about the di-verse values and practices that shape relation-ships between the state, the market and citizensin particular places. The closely related conceptof the social model is used to generalize aboutthe collections of values that underpin policypositions. Both concepts make use of ideal typesto help to explain the more complex reality of

models in specific nation-states and regions.The abstract ideal types allow us to compare and

Vincent Nadinis Professorof Spatial Planning and Strategyin the Faculty of Architectureat Delft University of Technology,The Netherlands.

Dominic Steadis a SeniorResearcher at the OTB ResearchInstitute for Housing, Mobilityand Urban Studies ofDelft University of Technology,The Netherlands.

An earlier extended version of thispaper was presented at the Inter-national Planning Cultures inEurope Conference in Hamburgin June 2007 (where it won theprize for best paper) and at theAssociation of European Schoolsof Planning (AESOP) Conferencein Naples in July 2007.

European Spatial Planning Systems,Social Models and LearningVincent Nadin and Dominic Stead

explain approaches to real world problems inparticular places, not least, reconciling the com-peting objectives of economic competitiveness,social cohesion (or social justice) and environ-mental sustainability. While social models havebeen employed most extensively in explainingapproaches to social welfare policy, we proposethat they might also assist in providing explana-tions for variation in spatial planning systems.

The concept of the spatial planning systemhas been used as a generic term to describe

the ensemble of territorial governance arrange-ments that seek to shape patterns of spatialdevelopment in particular places. Comparativeanalysis of planning systems in Western Europehas led to a clustering of systems into idealtypes that have been applied to the real prac-tices in nations and regions. These might betermed models of spatial planning. Enquiry intomodels of spatial planning (comparative spa-tial planning) parallels to a degree the debateabout comparative societal models, includingquestions about how planning systems adjust

to external and internal pressures for changethrough reform, and the result of this in termsof convergence or divergence of systems (Healey,

Williams 1993) or the Europeanization of spatial

planning (Dhr et al. 2007). At the Europeanscale, there has been no serious suggestion ofa European planning model, although the con-cept of territorial cohesion, now dominant inthe European spatial planning discourse, hasbeen described as a spatializationof the Euro-pean social model (Davoudi 2007).

The form and operation of planning systemsare embedded in their historical context, thesocio-economic, political and cultural patternsthat have given rise to particular forms of gov-ernment and law. Underlying the contextual dif-ferences is the social model. This is exemplifiedparticularly well in some countries where strongstate intervention in spatial development wasestablished as part of the post-war welfare state.However, planning systems and policies arecoming under increasing influence from otherfactors, notably the need to respond to globaleconomic competition, international agree-ments and European integration (Dhr et al.

2007). Extensive cooperation between plannersacross national and regional borders has led to


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36 disP 172 1/2008 a wide exchange of ideas and practices, particu-larly over the last decade. This learning processhas undoubtedly shaped spatial planning sys-tems and policies, and led to a certain degreeof convergence or harmonization, which may

be in tension with the underlying social model.The European Spatial Development Perspective(ESDP) made reference to this point, caution-ing that spatial development policies must notstandardize local and regional identities in theEU, which help enrich the quality of life of itscitizens (CSD 1999: 7).

In this paper, we examine the relationshipsbetween social models and models of planning.We summarize how typologies of social modelsand models of planning have developed over thelast 20 years with increasing division into morenumerous types, and how the typologies have

been applied to particular countries. We dem-onstrate a strong correspondence in the appli-cation of social models and models of planningto particular countries. We then explore the re-lationship between the dominant social modeland the planning system in two countries ofnorthern Europe: the Netherlands and England.This comparison demonstrates the strong rela-tionship between the two. We explain how exter-nal forces and learning have combined to shapesignificant adaptations in the form of planningin the two countries and how this confronts the

underlying model of society. This in turn ex-plains why the reform of planning systems hasbeen so challenging and raises questions for fu-ture reform.

2. European Social Model(s)

Despite many years of discussion in both aca-demic and political circles, neither the term Eu-ropean Model of Society nor the term EuropeanSocial Model have been defined with any pre-cision (House of Lords 2004; Jepsen, Serrano2005; Alber 2006). These two terms are oftenused interchangeably, although some authorsidentify distinct differences between them (e.g.,Delanty, Rumford 2005). The lack of precisionin defining these two concepts has both advan-tages and disadvantages.1Alber (2006) suggests,for example, that the concept of the EuropeanSocial Model can be seen as a deliberately am-biguous and elastic political metaphor that aimsat fostering an epistemic European policy com-munity with a shared view of social problems(p. 414).

In EU policy, one of the first references to theEuropean Social Model appeared towards the

end of Delors 10-year presidency of the Euro-pean Commission in the 1994 White Paper onSocial Policy where it was defined in terms ofshared values: democracy, individual rights, freecollective bargaining, the market economy, the

equality of opportunity for all, social welfare andsolidarity (CEC 1994). Since then, the conceptof the European Social Model has appeared invarious EU policy statements.

The Presidency Conclusions of the LisbonEuropean Council meeting in 2000, from whichthe EUs Lisbon Strategy originates, made spe-cific reference to the European Social Model.Modernizing the European social model, in-vesting in people and combating social exclu-sion was identified as one of the main strategiesfor achieving the Lisbon Agendas goals (CEC2000a). What was meant, however, by the term

European Social Model was not fully elaboratedin the document. Later in 2000, this was pro-vided in an annex of the Presidency Conclu-sions of the Nice European Council meeting(CEC 2000b). The idea that the European SocialModel refers to a common set of values is clearlyapparent:

The European social model, characterizedin particular by systems that offer a high levelof social protection, by the importance of thesocial dialogue and by services of general inter-est covering activities vital for social cohesion, is

today based, beyond the diversity of the Mem-ber States social systems, on a common core ofvalues (CEC 2000b: 4).

In 2002, the Commissions first report oneconomic and social cohesion made passing ref-erence to the idea of a model of society, statingthat cohesion policy is the guardian of a par-ticular model of society (CEC 2002: 17). Alsoaround this time, a number of high-level re-ports were being commissioned by the EU (allof which were searching in various ways for anew impetus for the floundering Lisbon Strat-egy), which also took up the issue of the Euro-pean Social Model. These include the Sapir Re-port (Sapir et al. 2004), the Strauss-Kahn report(Strauss-Kahn 2004), the report of the Michalskigroup (Biedenkopf et al. 2004) and the Kok re-port (CEC 2004).2

More recently, there have been debatesabout whether there is not just one model ofsociety in Europe but rather a number of vari-ants or related models. There are, after all, largedifferences in welfare systems and levels of in-equality across European countries (Giddens2005). Speaking about the future of the Euro-

pean Model at Harvard University in Septem-ber 2005, the European Commissioner for Eco-


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disP 172 1/2008 37nomic and Monetary Affairs, Joaqun Almunia,argued that there is no such thing as a singleEuropean social model (Almunia 2005). Thecontent of his speech suggests that there is theviewpoint that there are a number of different

social policy models but that they share a set ofcommon features or underlying aims, notably,reducing poverty and social exclusion, achiev-ing a fairer distribution of income, providingsocial insurance and promoting equality of op-portunity.

Ideal types and classificationsof social models

Publication of Esping-Andersens Worlds ofWelfare thesis in 1990 (Esping-Andersen 1990)led to an increase in interest in welfare state

classification and the subsequent emergenceof several competing typologies (Arts, Gelissen2002; Bambra 2007). Esping-Andersens typol-

ogy was based on the criterion of decommodi-fication (i.e., the degree to which social servicesare provided as a matter of right and the extentto which individuals can maintain a normal andsocially acceptable standard of living without re-

liance on the market). Esping-Andersens workhas provoked an extensive and ongoing debateabout typologies of models of society; the prin-ciples or criteria that ought be used for theirconstruction, and the classification of welfarestate regimes into types (Bambra 2007).

Criteria that have been used to constructtypologies of social models in the welfare stateliterature have included the decommodifica-tion approach (Esping-Andersen 1990), basicincome (Leibfried 1992), poverty rates (Ferrera1996; Korpi, Palme 1998) and social expen-diture (Bonoli 1997; Korpi, Palme 1998). The

typologies that result from these analyses aresummarized in Table 1. In general, the numberof different regime types has increased over time

Esping-

Anderson 1990

Social-

democratic

DK, FI, SE,NL

Liberal

IE, UK

Conservative

AT, BE, FR,DE

Liebfried 1992 Scandi-

navian

DK, FI, SE

Anglo-Saxon

UK

Bismarck

AT, DE

Latin Rim

FR, GR,IT, PT, ES

Ferrara 1996 Scandi-

navian

DK, FI, SE

Anglo-Saxon

IE, UK

Bismarck

AT, BE, FR,DE, LU, NL

Southern

GR, IT,PT, ES

Bonoli 1997 Nordic

DK, FI, SE

British

IE, UK

Continental

BE, FR, DE,LU, NL

Southern

GR, IT,PT, ES

Korpi,

Palme 1998

Encom-

passing

FI, SE

Basic

Security

DK, IE, NL,UK

Corporatist

AT, BE, FR,

DE, IT

Sapir 2006 NordicDK, FI, SE,NL

Anglo-SaxonIE, UK ContinentalAT, BE, FR,DE, LU

Mediter-ranean

GR, IT,PT, ES

Aiginger,Guger 2006

Scandina-

vian/Nordic

DK, FI, SE,NL

Anglo-

Saxon/

Liberal

IE, UK

Continental/

Corporatist

AT, BE, FR,DE, LU, IT

Mediter-

ranean

GR, PT,ES

Catching-up

CZ, HU

Alber 2006 Nordic

DK, FI, SE

Anglo-Saxon

IE, UK

Continental

AT, BE, FR,DE

Southern

GR, IT,PT, ES

New Mem-

ber States

CY, CZ, EE,HU, LV, LT,

MT, PL, SK,SI

Other

LU, NL

Tab. 1: Welfare state typologies(based in part on Arts, Gelissen2002)


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38 disP 172 1/2008 as a consequence of more sophisticated ana-lyses of welfare systems. Since 1990, the numberof regime types in Europe has increased fromEsping-Andersens original three (social-demo-cratic, liberal and conservative) to five or six

(Aiginger, Guger 2006; Alber 2006). A num-ber of countries appear in the same position inalmost all classifications whereas the positionof other countries is quite different for eachclassification. Finland and Sweden, for exam-ple, consistently appear together in the encom-passing Nordic/Scandinavian/social democraticcategory, Ireland and the United Kingdom inthe Anglo-Saxon/basic security/liberal category,France and Germany in the Bismarck/conserva-tive/continental/corporatist category and Portu-gal and Spain in the Latin Rim/ Mediterranean/southern category. In contrast, countries such

as Luxembourg and the Netherlands find them-selves together with a different group of coun-tries in almost every classification.

It is important to note here that the variousregime types are ideal types that owe their ori-gins to different historical forces (Arts, Gelissen2002). The allocation of countries to types isnot always clear-cut and they may sometimeslie somewhere between types. Contrary to theideal world of welfare states, the real world ex-hibits hybrid forms in every country. There maysometimes be quite a lot of variation between

welfare systems of countries that appear in thesame regime type. Even countries with similarsets of welfare institutions are frequently foundto display widely divergent patterns of develop-ment (Alber 2006). It is also important to notethat the classification of countries into regimetypes is time-dependent: governments, policiesand economic activity can all change over timeand directly influence the position of a countryin the classification system.

3. European Models of Planning(Planning Systems)

Two main approaches are evident in classifyingspatial planning systems. The first starts fromother classifications (or families) of the legaland administrative systems within which plan-ning operates, while the second seeks to applya wider set of criteria but nevertheless producesa similar set of ideal types. Four specific stud-ies of planning systems are discussed below. Asummary of the typologies of these studies canbe found in Table 2.

Ideal types and classificationsof models of spatial planning

Davies et al. (1989) considered planning con-trol in five northern European countries 3 and

made a broad distinction between the planningsystem in England4 and continental systems.This conclusion followed an earlier compari-son of the English and Dutch planning systems(Thomas et al. 1983) which drew attention to thelegal certainty provided by systems in continen-tal Europe (at least in the ideal sense) based onthe Napoleonic or Scandinavian legal systems,in contrast to the high degree of administrativediscretion in the English system created by thelegal framework of English common law. New-man and Thornley (1996) also concentrated ona classification of planning systems according

to legal and administrative structures, drawingon the five European legal families defined byZweigert et al. (1987).5

Zweigert et al. (1998) explain how all thecontinental legal systems (Roman, Germanicand Nordic) share a similar legal style: they seekto create a complete set of abstract rules andprinciples in advance of decision-making. This,they argue, corresponds to particular continen-tal mentality: The European is given to makingplans, to regulating things in advance, and todrawing up rules and systematizing them (p.

71). In contrast, the English common law sys-tem offers far fewer rules. Government does notprovide a complete set of legal rules in advance,rather the law has been built up case-by-caseas decisions of the courts are recorded. Thus,there is much more emphasis on case law thanon enacted law, which provides for more admin-istrative discretion. Faludi (1987) made the samedistinction when referring to the continentalsystems as imperative and the English systemas indicative.

Using legal families and administrativestructures to explain differences among plan-ning systems has obvious validity because thelegal style and the administrative structure ofgovernment provide very strong frameworksfor the operation of planning systems. This ap-proach tends to emphasize the differences inthe role of plans in the formal regulation of de-velopment, such as whether decisions are madethrough legally binding plans (broadly followedin continental countries) or as and when pro-posals arise (the main approach in England).We should note here that this approach tends toover-emphasize the formal system of planning

in principle as opposed to the reality of its op-eration in practice.


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disP 172 1/2008 39The EU Compendium of Spatial PlanningSystems and Policies(1997) used a wider set ofcriteria to create four ideal types or traditions ofspatial planning (see Table 2). The word tradi-tion was used to emphasize the way that forms

of planning are deeply embedded in the com-plex historical conditions of particular places.The legal family context was used along with sixother variables: the scope of the system in termsof policy topics covered; the extent of nationaland regional planning; the locus of power orrelative competences between central and localgovernment; the relative roles of public and pri-vate sectors; the maturity of the system or howwell it is established in government and pub-lic life; and the apparent distance between ex-pressed goals for spatial development and out-comes. As with the models of society, the four

traditions of spatial planning are ideal types,that is, a synthesis of the real complex mixtureof observable phenomena. They serve as meas-ures against which reality can be compared suchthat at a point in time and space a planningaction might exhibit features of more than oneideal type/tradition. To some extent, the criteriaalso address the nature of systems in operation,though the idea types still emphasize the formalstructure of planning.

The comprehensive integrated approachcorresponds quite well to the Scandinavian le-gal family in the geographical area it covers.The name suggests that the planning system ex-plicitly seeks to provide a measure of horizontal

and vertical integration of policies across sec-tors and jurisdictions. This is in contrast to theland-use planning tradition, which correspondswell to the British legal and administrative fam-ily and has the much narrower scope or purposeof regulating land-use change. The other twoplanning traditions do not correspond so closelyto the legal families. The regional economicplanning approach cuts across the Napoleonicand Germanic legal families. The urbanism tra-dition falls within the Napoleonic tradition butfor southern Europe only.

The classification of ideal types in the EU

Compendium (and the limitations this imposes)were used in a modest update on the movements

that took place since as part of the ESPONprogram (Farins Das 2006: 112). It givesmore emphasis to the distribution of powersrelevant to planning among levels of govern-ment with a finer analysis of state structures andthe decentralization and devolution of compe-tences, especially the varying forms of regionalgovernance and local powers. It concludes, like

Davies et al.

1989*

Common

lawEngland

Napoleonic

codesDK, DE,

FR, NL

Newman,Thornley 1996

Nordic

DK, FI, SEBritish

IE, UKGermanic

AT, DENapoleonic

BE, FR, IT,

LU, NL, PT,ES

East

European

CEC 1997** Comprehensiveintegrated

AT, DK, FI, DE,NL, SE

Land use

regulation

IE, UK(and BE)

Regional

economic

FR, PT(and DE)

Urbanism

GR, IT, ES(and PT)

Farins Dasi2007***

Comprehensiveintegrated

AT, DK, FI, NL,SE, DE

(and BE, FR, IELU, UK)BG, EE, HU,

LV, LT PL, RO,SL, SV

Land useregulation

BE, IE, LU,UK(and PT,

ES)CY, CZ, MT

Regionaleconomic

FR, DE, PT,(and IE,SE, UK)

HU, LV, LT,SK

UrbanismGR, IT, ES

CY, MT

* Davies et al. (1989) do not give a specific name to the two groups but contrast England and other systemsbased on their legal frameworks.

** The EU Compendium identifies ideal types of planning traditions. Each country may exhibit combinationsof ideal types in different degrees. The ideal types are dominant in the countries indicated here.

*** The ESPON project took the EU Compendium traditions as a starting point and examined how countries,including the transition states of central and eastern Europe, were moving between them. Tab. 2: Planning system typologies.


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40 disP 172 1/2008 the Compendium, that variation is the hallmarkof planning systems and that it is difficult toclassify, since the member states vary in differentaspects of styles or according to which criteriais given prominence. It argues that Belgium,

France, Ireland, Luxembourg and the UK aretaking up elements of the comprehensive inte-grated approach. It also asserts that Germany,Ireland, Sweden and the UK are moving towardsthe regional economic planning style, and thatSpain and Portugal are moving towards moreland-use regulation.

Learning and convergence?

Comparative analysis of planning systems sug-gests that continuous adaptation is leading to ageneral convergence. Some changes are rather

detailed institutional and legislative matters, butothers reflect a more general transformation ofthe style of spatial planning (Healey et al. 1997:290). Farins Das (2006) argues that the com-prehensive integrated and regional economicplanning styles are becoming more common,and, moreover, that this process is producinga neo-comprehensive integrated planning ap-proach. His argument supports the thesis thatthe northwestern perspective on planning is be-coming more widespread (Rivolin, Faludi 2005).As Healey and Williams noted (in 1993), there

are pressures for the convergence of certain as-pects of planning systems as cities and regionsbecome increasingly oriented to competitionwith European space (p. 716). Davies (1994:67) also anticipated such convergence throughthe triple effects of cooperationbetween citiesand regions in other countries the competi-tion for investment, tourists and other benefitsfrom the single market, and the learning pro-cess in working with the [European] Commis-sion (emphasis added). The limited evidencethat we have suggests that Davies was right.There has been a measure of convergence asformal national arrangements for planning havebeen adapted to address common challenges ofglobal competition and sustainability to whichthey were unsuited. The debate at the Europeanlevel has played a part in this (Nordregio 2007)alongside extensive transnational cooperationthat has raised awareness and promoted mu-tual learning. It would be difficult to argue thatthere is (or could be) a single European modelof spatial planning, but there does seem to bea strengthening of the common elements, par-ticularly those that are central to the European

debate on planning as a method of securingconvergence and coordination between various

sectoral policies (Report on Community Poli-cies and Spatial Planning 1999).

4. The Evolution of Planning Systems

In this section, we explore the recent trajectories

of planning systems, within the wider changes tomodels of society, in two countries: England andthe Netherlands. These countries make for aninteresting comparison. The English planningsystem is very distinctive and corresponds verywell to a particular social model while the Neth-erlands is difficult to classify according to idealtypes of social models. Both countries have ma-ture planning and welfare systems but are never-theless experiencing considerable changes inattitudes and values in society and in the role

and guiding principles of the planning system.

England

The ethos of the planning system in England isinfused with the dominant and distinctive lib-eral social model, the pragmatic approach togovernance, the common law legal system andthe long history of stable national state bound-aries. The very idea of spatial planning in the lib-eral model of society gives rise to fundamentaltensions and questions that have characterized

planning in England. Though most of the funda-mental mechanisms of planning have been sta-ble since the 1950s, its operation and role havefluctuated considerably in parallel with vacillat-ing political ideology and economic conditions.Learning from other countries has also playeda part, with a long history of exchange of ideasabout planning with other European countriesand North America.

The original intellectual arguments for plan-ning came from the social reform movementand its progressive ideological roots, but thenotion of planning that arose in practice wasdominated by questions of physical form (Ash-worth 1954; Sutcliffe 1981; Hall 1992: 49). Thiswas planning with a relatively narrow ambitionand, although there was a period of proactiveplanning in the 1950s and a consistent and firmapplication of urban containment policy, theformal system of planning in England has beengenerally reactive and passive, for example, inits emphasis on regulating private sector devel-opment (or the public sector acting as privatedeveloper). This form of planning fits squarelywithin the ideal type of land-use management.

However, it does address the spatial dimensionof tensions that arise in a liberal economy that


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disP 172 1/2008 41seeks to achieve a more even distribution of so-cial and economic welfare. National governmenthas a dominant position in decision-making, al-though the system is operated by local authori-ties. Although formally described as plan-led,

there is much negotiation around decisions ofany significance and the system offers consider-able discretion: decisions on development aremade on their merits with no binding zoninginstruments. There are extensive opportunitiesfor consultation and objections to policies anddevelopment projects.

Shifts in the nature of the dominant liberalsocial model have been closely interlinked withreforms of the planning system in the past. Therise of neo-liberalism in the 1980s and 1990swith its antagonism toward the welfare state andits adherence to individualism and choice pre-

sented a fundamental challenge for planning. Itmight be argued that the dominant lessons (inthe sense of a learning system of planning) atthis time were coming from the United States.Evans (1995) argues that planning changed froma welfare profession serving the public inter-est to a skills-based profession selling a ser-vice. The ambitions of pre- and post-war granddesigns and social and economic goals largelydisappeared as planning instead adopted a pro-cedural role in managing the statutory planning described as little more than bureaucratic

proceduralism (Evans, Rydin 1997; Tewdwr-Jones 1996).

The 2004 reforms

In this context, attention was concentratedon the efficiency of the system and a govern-ment program of Modernizing Planning (DETR1998) brought forward incremental changes.But contributions from agencies and NGOs tothis debate pointed to deep-seated tensionsin deregulation in the face of increasing eco-nomic competition and sustainable develop-ment (TCPA 1999; RTPI 2000; Allmendinger,Tewdwr-Jones 2000). Starting in the late 1990s,transnational cooperation on spatial planninghas had a critical influence on the direction ofthe planning system (DTLR 2001; Nadin 2007).The reform of planning subsequently calls for astronger role for the planning system in shap-ing change and a shift in the very culture ofplanning. Subsequently, the 2004 Planning andCompulsory Purchase Act is at the heart of themost significant reform of the planning systemin England since 1968.

The essential features of the system as de-scribed above remain the same. The accent has

been on reworking the tools of planning to offerplanning authorities more opportunities to takethe initiative in development, to provide a stra-tegic framework, and to engage stakeholdersmore effectively. This is summed up in the gov-

ernments guidance in the notion of the spatialplanning approach (Nadin 2007). It seeks tomeet a desire for more plan-led developmentand coordination of private investment and sec-tor public policies within the market-driven andfragmented policy environment that arises in aliberal model of society. In some ways, the lib-eral model is stronger than ever, but at the sametime, there are demands for more and more ef-fective public intervention. The solution offeredsees planning as a coordinative and collabora-tive activity injecting a spatial or territorial di-mensioninto sectoral strategies and policy; and

creating new policy communities that reflect therealities of spatial development and its drivers.Planning is being promoted as a learning pro-cess. Planning tools have been amended consid-erably with the objectives of strengthening re-gional strategic planning capacity and enablinglocal planning authorities to positively promoteappropriate development.

The changes to planning in England haveundoubtedly been influenced by transnationallearning, particularly ideas coming from theESDP (Shaw, Sykes 2003, 2004, 2005). Never-

theless, the ESDP exhibits very different as-sumptions about planning, which arise fromcontinental systems and their roots in differentmodels of society. The key ideas in the Euro-pean dialogue on planning have been reworkedto fit the dominant model in England, but arenot proving easy to establish. Reports in 2007suggest that central aspects of the reformedsystem are struggling to take root in practiceand among the profession (Baker Associates etal. 2006).

The Netherlands

According to Shetter (1988), planning is one ofthe central cultural institutions in Dutch society.Alexander (1992) describes spatial planning inthe Netherlands as relying on a passive regula-tory system in which interventions are permittedsubject to prior assessment, with stakeholdersbeing consulted at an early stage of the planningprocedure. TheEU Compendiumdescribes theDutch planning system as one of the most elab-orate examples of the comprehensive integratedapproach to planning in which plans are more

concerned with the coordination of spatial thaneconomic developments (CEC 1997). Rather


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42 disP 172 1/2008 than working with master plans, national plan-ning in the Netherlands works with indicativenational policy documents.

Statutory plans are the responsibility of theprovinces and municipalities and only the lat-

ter have the power to make plans that providegrounds for the refusal of planning permits(Faludi 2005). Much consultation and persua-sion therefore takes place to integrate policiesof higher levels of government into the plansand policies of lower levels of government (Zon-neveld 2006). Central government is the chiefsource of funding for planning at all levels, andso wields much influence by means of this rela-tionship (Faludi 2005). The Dutch planning sys-tem is plan-led: nothing can be developed that isnot in accordance with the local land-use plan,since this is legally binding. However, property

developers can exert strong influences on thecontent of a plan, which also gives developmenta development-led character (EC 1999). Plan-ning practice is strongly influenced by informalways of using formal rules (administrative prag-matism) (Needham 2005).

The most significant changes in spa-tial planning in the Netherlands over re-cent years have been the development of anew national spatial strategy and a new spa-tial planning act, both adopted in 2006.Zonneveld (2006) characterizes the dominant

shifts in Dutch spatial planning that are cur-rently taking place as being from welfare statespatial planning to development planning6,which clearly indicates a link between the plan-ning system and the welfare state. The natureof these changes is summarized below (moredetail can be found in Needham 2005; Spaans2006; Vink, van der Burg 2006; Zonneveld2005, 2006).

The National Spatial Strategy

The National Spatial Strategy (Nota Ruimte), ap-proved by the Senate in January 2006, indicatesa departure from the restrictive planning dis-course (Spaans 2006). It makes a radical breakwith the centralist tradition in which the na-tional government determines in detail whatwill be built and where. The National SpatialStrategys dictum is decentralize if possible,centralize if necessary, mirroring that of thepredecessor of the National Spatial Strategy, theFifth Memorandum on Spatial Planning. Theonly difference was that the phrase has beenreversed: centralize if necessary, decentralize

if possible. This is perhaps not just a ques-tion of semantics but an expression of a deeply

perceived difference in government control(Vink, van der Burg 2006).

According to Zonneveld (2005), the NationalSpatial Strategy marks a radical departure fromtraditional Dutch spatial policy in that a new

division of responsibilities between the threetiers of government is outlined. Central govern-ment takes a step backward in favor of allowingthe local authorities, particularly the provinces,to play a key role. The National Spatial Strat-egy, for example, gives a stronger role to lowerlevels of government in terms of developmentcontrol. Vink and van der Burg (2006) con-tend that there is more focus on development;the Strategy seeks to tie in with social trends,rather than combating them. The documentitself reports that the main difference betweenthis strategy and previous ones is primarily the

method of governance (the how) rather thanthe policy content (the what). It asserts that themost important objectives, policy concepts andbasic principles from the previous strategieshave been retained (Ministry of Housing, Spa-tial Planning and the Environment 2006). Thedocument also signals a shift in emphasis fromplanning to development: more emphasis ondevelopment-led planning and less on devel-opment control planning (Ministry of Housing,Spatial Planning and the Environment 2006).The Strategy also announces the amendment of

the Spatial Planning Act (Wet ruimtelijke orden-ing) to bring it more into line with the philoso-phy of governance of the new Spatial Strategy(see below). According to Vink and van der Burg(2006), the National Spatial Strategy strength-ens the role of the provinces and reduces thenumber of rules and regulations imposed bycentral government on others, while creatingmore scope for local and regional governments,social organizations, private actors and citizensin the planning process. At the same time, how-ever, the National Spatial Strategy also intro-duces stronger national and provincial powers national and provincial governments will beable to intervene more forcefully when nationalor international interests are at stake (e.g., bio-diversity, national landscapes).

The Spatial Planning Act

The first comprehensive Dutch spatial plan-ning act dates from 1965, and has since beenamended several times. In the 1990s, for exam-ple, legislation was amended to speed up largeprojects (e.g., infrastructure development, river

dikes). Most of the changes to the spatial planningact have been marginal, but the overall result


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disP 172 1/2008 43is a patchwork of different instruments andprocedures (Needham 2005). Since 1965, theidea has always been that planning is primarily acoordinating activity (Hajer, Zonneveld 2000).

Work started on a new spatial planning act

in 2000, when it was decided not to work withinthe old 1965 framework, but to develop a newone. Most of the content is uncontroversial orregarded as inevitable (Needham 2005). Thenew spatial planning act was approved by theSenate in October 2006 and will enter into forcein 2008. It has been five years in the making,and many changes to the proposed content havebeen made in those five years. All have reducedthe extent and significance of the proposedchanges (Needham 2005). While the new actgives the opportunity for negotiation in plan-ning, the planning system nevertheless retains a

strong plan-led orientation.According to Needham (2005), one of the

changes in the planning act that might prove tobe very significant is the strengthening of theplanning powers of central government at thecost of the planning powers of the municipali-ties (despite the focus on decentralization in themost recent National Spatial Strategy). The newplanning act will, for example, give the nationaland provincial governments stricter powers forrequiring a municipality to follow their policiesthrough the issuing of directives. Vink and van

der Burg (2006) report that the new planningact will make it possible for central and provin-cial government to be able to intervene moreforcefully than previously when higher interestsare at stake, which can be interpreted as the cre-ation of a more centralized planning system andat odds with the principle of the Netherlands asa decentralized unitary state (Zonneveld 2006).It remains to be seen how centralized the newsystem will be in practice. Despite new roles forprovinces under the new spatial strategy andpowers under the new spatial planning act, theDutch Council of State anticipates serious con-sequences for the position of the provinces inspatial planning and a strong decline in theimportance of the provincial spatial planningpolicy. Strangely, however, the fate of the prov-inces in the new Dutch planning system has notgenerated much debate in the professional do-main (Zonneveld 2006).

Reflection

According to Hoekstra (2003: 63), the Dutchsystem of spatial planning in the 1980s and

1990s was typical of a social-democratic wel-fare state, and as such very much in line with

the position of the Netherlands within Esping-Andersons typology (see Table 1). While the1980s and 1990s marked a period of relativestability for Dutch spatial planning, the begin-ning of the twenty-first century signaled the

start of more wide-ranging changes, primar-ily in the direction of a more liberal approachto planning. These developments can be in-terpreted as a movement towards the develop-ment-led planning approach that is also evidentin England. The recent changes in the Dutchplanning system mirror the general direction ofwelfare reform in the Netherlands over recentdecades.

The Netherlands has played an active rolein the international spatial planning arena overrecent decades, particularly at the Europeanlevel, which has unquestionably led to learn-

ing processes both for the planning communityin the Netherlands and, perhaps more import-antly, for the planning community outside theNetherlands (who have learnt about the Dutchapproach). Indeed, one of the main reasons forthe countrys active role in the internationalarena was arguably to try to promote or exportconcepts and processes from the Dutch spa-tial planning system, and set the agenda forspatial planning debates. In the 1990s, for ex-ample, the Netherlands was one of the driv-ing forces behind the European Spatial Devel-

opment Perspective (Faludi, Waterhout 2002).More recently, the Netherlands has played anactive role in the development of the TerritorialAgenda of the EU (Faludi 2007c). Learning hasnot however just been a one-way process for theDutch planning community: involvement in theinternational planning arena has also exposedDutch policy-makers to a wide variety of spatialplanning systems, which has inevitably influ-enced developments back home.

5. Conclusions

The comparison of models of society and mod-els of spatial planning is a first step in clarifyingunderstanding of the comparative evolution ofnational forms and policies of planning and theprocess of convergence in the context of mutuallearning. There is first a reasonable correspon-dence between the ideal types (or categories)of models of society and planning systems (seeTables 1 and 2), which was perhaps to be expected.

The planning system is in part an expression ofsome fundamental values in a society in rela-

tion, for example, to the legitimate scope andaspirations of government, the use of land, and


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44 disP 172 1/2008 the rights of citizens. The definition of types re-mains much the same even when different cri-teria are used.

The correspondence of the model of societyand the type of planning system is particularly

strong for the British/Anglo-Saxon and Nor-dic models. They are consistently distinguishedbecause of their specific characteristics, dem-onstrate a very close association between thedominant model of society and the form of theplanning system. There is less consistency in thedefinition of models for continental countries.A few countries are apparently very difficult toclassify, including the Netherlands. Countries ofcentral and eastern Europe are most difficult towork into the existing typologies. The classifica-tions of both social models and models of plan-ning are becoming more elaborate and differ-

entiated, recognizing more accurately the realdiversity and dynamics in societies.

The examples of England and the Nether-lands illustrate how the planning model is em-bedded in the wider model of society. However,the recent history of change in spatial plan-ning in the two countries has some parallels,despite their different social models and plan-ning systems. The planning systems of bothcountries are in a process of substantial reform,which seems to be directed by forces that chal-lenge the received models of society. Prominent

among these external factors is the learning orthe exchange of experience and developmentof a common reference framework for spatialplanning that has arisen from extensive coop-eration at European and transnational scales. Itis perhaps not surprising, therefore, that recentreforms are creating considerable uncertaintyand controversy in each country.

In England, the notion of planning as a toolfor spatial policy integration is at the center ofthe spatial planning approach. This is not a newconcern for planning and was perhaps part ofthe dominant culture in different ways in its earl-ier history. The aspects of reform that requireclose partnerships between public, private andcivic sectors fits well with the Anglo Saxon lib-eral model of society, but other changes, such asmore long-term strategy and greater policy in-tegration, are more difficult to incorporate. Thisis recognized in the governments call, along-side new tools and procedures, for a changein the culture of planning (Shaw, Lord 2007).Although it is too early to evaluate the reforms,it appears that they are proving difficult to putinto practice and the process remains contro-

versial with uncertain outcomes. It is now moredifficult to categorize the planning system in

England as dominated by the land-use regula-tion model.

In the Netherlands, the old system of spatialplanning (i.e., before the introduction of thenew national spatial strategy and spatial plan-

ning act in 2006) is very much congruent with asocial-democratic welfare model. Furthermore,the new national spatial strategy and spatialplanning act signal substantial shifts that arecurrently taking place in Dutch spatial planningand welfare policy more widely, and a move to-wards a more liberal approach. Because boththe spatial planning strategy and act have onlyrecently been adopted (and the act had not yetcome into force at the time of writing), it is tooearly to say exactly how spatial planning pro-cesses and practices may change. The changesin spatial planning closely reflect the trends in

various recent welfare reforms (e.g., social secur-ity, labor market policy, healthcare and immi-gration), where the Dutch social model has alsoundergone some significant changes (see, forexample, de Gier et al. 2004). Despite changesin the spatial planning and welfare systems, webelieve that the Netherlands still has a planningsystem that can be categorized into the com-prehensive integrated approach (CEC 1997)and still has one of the most elaborate examplesof spatial planning in Europe.

There are clearly limitations in the use of

ideal types or models to classify planning sys-tems and explain their evolution. Any modelwill be a considerable abstraction of the truevariety that the nation states and regions ex-hibit. Zweigert et al. (1998) note the dangers inreducing the complexity of variation betweencountries to a few families. Much depends onthe particular criteria employed. In this paperwe have explored the potential for explainingthe evolution of the formal arrangements forspatial planning with reference to the under-lying social model, in the context of transna-tional learning and Europeanization. The find-ings suggest that there is potential in continuingsuch an investigation. European, transnationaland cross-border spatial planning initiativesthat provide learning opportunities could beusefully informed with a deeper understandingof the dynamic interrelationships of planningreform and social model.

More recent analysis of both social modelsand planning systems has called for a finer clas-sification of systems that recognizes more di-versity and divisions. The examples of Englandand the Netherlands also show how very similar

arrangements can be developed in practice inquite different settings. They suggest that the


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disP 172 1/2008 45received models may overemphasize the Brit-ish-Continental divide. The practice of planningmay develop in a similar fashion despite theirdiffering legal and administrative contexts (ashas happened in the United Kingdom). External

factors including learning through transnationalcooperation seem to be leading to a measure ofconvergence or harmonization of systems, al-though this creates tensions as changes in ad-ministrative systems run ahead of changes inthe social model.

Notes

1 Analogous to the debates about spatial planningconcepts such as polycentricity (e.g., Richardson& Jensen, 2000; Shaw & Sykes, 2004).

2 See Faludi (2007a, b) for more detailed accounts

of these reports.3 The five countries are Denmark, England,

France, The Netherlands and West Germany.4 The focus of this paper is on England, although

the same arguments also apply to the rest of theUnited Kingdom in matters of principle.

5 Zweigert et al. (1998) also identify three otherlegal families (South East Asian, Islam and Hin-duism), making eight legal families in total.

6 The term development planning in this contextimplies development-led planning.

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Vincent NadinFaculty of ArchitectureDelft University of TechnologyP.O. Box 5030NL2600 AA [email protected]

Dominic SteadOTB Research InstituteDelft University of TechnologyP.O. Box 5030NL2600 AA [email protected]

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