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European Spatial Planning Systems, Social Models and Learning

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European Spatial Planning Systems,
Social Models and Learning
Vincent Nadin and Dominic Stead
Abstract: An underlying aim of European territor­
ial cooperation initiatives, such as INTERREG,
is that they will lead to mutual understanding
and learning across national boundaries. How­
ever, the effect of mutual learning on national
systems and policies of planning is uncertain.
After all, spatial planning systems are deeply
embedded in their socio-economic, political
and 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 explore
the relationship between planning systems and
their context and assess the extent to which co­
operation and learning might contribute to con­
vergence in styles of planning in Europe, as well
as why and how this might be taking place.
We take as our context the prevailing so­
cial model or model of society, the collection
of 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. The
examples of England and the Netherlands are
used to illustrate this interdependence. How­
ever, they also reveal how planning systems and
policies in different contexts are changing in
similar ways, and perhaps even demonstrate a
measure 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 may
be running ahead of wider changes in the so­
cial model.
1.  Introduction
The notion of models of society (or ideal types
of societies) is used to generalize about the di­
verse values and practices that shape relation­
ships between the state, the market and citizens
in particular places. The closely related concept
of the social model is used to generalize about
the collections of values that underpin policy
positions. Both concepts make use of ideal types
to help to explain the more complex reality of
models in specific nation-states and regions.
The abstract ideal types allow us to compare and
disP 172 · 1/2008 35
explain approaches to real world problems in Vincent Nadin is Professor
particular places, not least, reconciling the com­ of Spatial Planning and Strategy
in the Faculty of Architecture
peting objectives of economic competitiveness,
at Delft University of Technology,
social cohesion (or social justice) and environ­ The Netherlands.
mental sustainability. While social models have
been employed most extensively in explaining Dominic Stead is a Senior
Re­searcher at the OTB Research
approaches to social welfare policy, we propose
Institute for Housing, Mobility
that they might also assist in providing explana­ and Urban Studies of
tions for variation in spatial planning systems. Delft University of Technology,
The concept of the spatial planning system The Netherlands.
has been used as a generic term to describe
the ensemble of territorial governance arrange­
ments that seek to shape patterns of spatial
development in particular places. Comparative
analysis of planning systems in Western Europe
has led to a clustering of systems into ideal
types that have been applied to the real prac­
tices in nations and regions. These might be
termed models of spatial planning. Enquiry into
models of spatial planning (comparative spa­
tial planning) parallels to a degree the debate
about comparative societal models, including
questions about how planning systems adjust
to external and internal pressures for change
through reform, and the result of this in terms
of convergence or divergence of systems (Healey,
Williams 1993) or the “Europeanization of spatial
planning” (Dühr et al. 2007). At the European
scale, there has been no serious suggestion of
a European planning model, although the con­
cept of territorial cohesion, now dominant in
the European spatial planning discourse, has
been described as a spatialization of the Euro­
pean social model (Davoudi 2007).
The form and operation of planning systems
are embedded in their historical context, the
socio-economic, political and cultural patterns
that have given rise to particular forms of gov­
ernment and law. Underlying the contextual dif­
ferences is the social model. This is exemplified
particularly well in some countries where strong
state intervention in spatial development was
established as part of the post-war welfare state.
An earlier extended version of this
However, planning systems and policies are
paper was presented at the Inter­
coming under increasing influence from other national Planning Cultures in
factors, notably the need to respond to global Europe Conference in Ham­burg
economic competition, international agree­ in June 2007 (where it won the
prize for best paper) and at the
ments and European integration (Dühr et al.
Association of European Schools
2007). Extensive cooperation between planners of Planning (AESOP) Conference
across national and regional borders has led to in Naples in July 2007.
36 disP 172 · 1/2008 a wide exchange of ideas and practices, particu­
larly over the last decade. This learning process
has undoubtedly shaped spatial planning sys­
tems and policies, and led to a certain degree
of 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 not
standardize local and regional identities in the
EU, which help enrich the quality of life of its
citizens” (CSD 1999: 7).
In this paper, we examine the relationships
between social models and models of planning.
We summarize how typologies of social models
and models of planning have developed over the
last 20 years with increasing division into more
numerous 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 planning
to particular countries. We then explore the re­
lationship between the dominant social model
and the planning system in two countries of
northern 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 shape
significant adaptations in the form of planning
in the two countries and how this confronts the
underlying model of society. This in turn ex­
plains why the reform of planning systems has
been 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 European
Social Model have been defined with any pre­
cision (House of Lords 2004; Jepsen, Serrano
2005; Alber 2006). These two terms are often
used interchangeably, although some authors
identify distinct differences between them (e.g.,
Delanty, Rumford 2005). The lack of precision
in defining these two concepts has both advan­
tages and disadvantages.1 Alber (2006) suggests,
for example, that the concept of the European
Social Model can be seen as “a deliberately am­
biguous and elastic political metaphor that aims
at 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 the
European Social Model appeared towards the
end of Delors’ 10-year presidency of the Euro­
pean Commission in the 1994 White Paper on
Social Policy where it was defined in terms of
shared values: democracy, individual rights, free
collective bargaining, the market economy, the
equality of opportunity for all, social welfare and
solidarity (CEC 1994). Since then, the concept
of the European Social Model has appeared in
various EU policy statements.
The Presidency Conclusions of the Lisbon
European Council meeting in 2000, from which
the EU’s 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 strategies
for achieving the Lisbon Agenda’s goals (CEC
2000a). What was meant, however, by the term
European Social Model was not fully elaborated
in 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 Social
Model refers to a common set of values is clearly
apparent:
“The European social model, characterized
in particular by systems that offer a high level
of social protection, by the importance of the
social 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 of
values” (CEC 2000b: 4).
In 2002, the Commission’s first report on
economic and social cohesion made passing ref­
erence to the idea of a model of society, stating
that “cohesion policy is the guardian of a par­
ticular model of society” (CEC 2002: 17). Also
around this time, a number of high-level re­
ports were being commissioned by the EU (all
of which were searching in various ways for a
new 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 Michalski
group (Biedenkopf et al. 2004) and the Kok re­
port (CEC 2004).2
More recently, there have been debates
about whether there is not just one model of
society in Europe but rather a number of vari­
ants or related models. There are, after all, large
differences in welfare systems and levels of in­
equality across European countries (Giddens
2005). Speaking about the future of the Euro­
pean Model at Harvard University in Septem­
ber 2005, the European Commissioner for Eco­
nomic and Monetary Affairs, Joaquín Almunia,
argued that “there is no such thing as a single
European social model” (Almunia 2005). The
content of his speech suggests that there is the
viewpoint that there are a number of different
social policy models but that they share a set of
common features or underlying aims, notably,
reducing poverty and social exclusion, achiev­
ing a fairer distribution of income, providing
social insurance and promoting equality of op­
portunity.
Ideal types and classifications
of social models
Publication of Esping-Andersen’s “Worlds of
Welfare” thesis in 1990 (Esping-Andersen 1990)
led to an increase in interest in welfare state
classification and the subsequent emergence
of several competing typologies (Arts, Gelissen
2002; Bambra 2007). Esping-Andersen’s typol­
ogy was based on the criterion of decommodi­ disP 172 · 1/2008 37
fication (i.e., the degree to which social services
are provided as a matter of right and the extent
to which individuals can maintain a normal and
socially acceptable standard of living without re­
liance on the market). Esping-Andersen’s work
has provoked an extensive and ongoing debate
about typologies of models of society; the prin­
ciples or criteria that ought be used for their
construction, and the classification of welfare
state regimes into types (Bambra 2007).
Criteria that have been used to construct
typologies of social models in the welfare state
literature have included the decommodifica­
tion approach (Esping-Andersen 1990), basic
income (Leibfried 1992), poverty rates (Ferrera
1996; Korpi, Palme 1998) and social expen­
diture (Bonoli 1997; Korpi, Palme 1998). The
typologies that result from these analyses are
summarized in Table 1. In general, the number
of different regime types has increased over time

Esping- Social- Liberal Conservative

Anderson 1990 democratic IE, UK AT, BE, FR,
DK, FI, SE, DE
NL

Liebfried 1992 Scandi­ Anglo-Saxon Bismarck Latin Rim

navian UK AT, DE FR, GR,
DK, FI, SE IT, PT, ES

Ferrara 1996 Scandi­ Anglo-Saxon Bismarck Southern

navian IE, UK AT, BE, FR, GR, IT,
DK, FI, SE DE, LU, NL PT, ES

Bonoli 1997 Nordic British Continental Southern

DK, FI, SE IE, UK BE, FR, DE, GR, IT,
LU, NL PT, ES

Korpi, Encom­ Basic Corporatist

Palme 1998 passing Security AT, BE, FR,
FI, SE DK, IE, NL, DE, IT
UK

Sapir 2006 Nordic Anglo-Saxon Continental Mediter-

DK, FI, SE, IE, UK AT, BE, FR, ranean
NL DE, LU GR, IT,
PT, ES

Aiginger, Scandina- Anglo- Continental/ Mediter- Catching-up

Guger 2006 vian/Nordic Saxon/ Corporatist ranean CZ, HU
DK, FI, SE, Liberal AT, BE, FR, GR, PT,
NL IE, UK DE, LU, IT ES

Alber 2006 Nordic Anglo-Saxon Continental Southern New Mem- Other

DK, FI, SE IE, UK AT, BE, FR, GR, IT, ber States LU, NL
DE PT, ES CY, CZ, EE,
HU, LV, LT,
MT, PL, SK, Tab. 1: Welfare state typologies
SI (based in part on Arts, Gelissen
2002)
38 disP 172 · 1/2008 as a consequence of more sophisticated ana­
lyses of welfare systems. Since 1990, the number
of regime types in Europe has increased from
Esping-Andersen’s 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 in
almost all classifications whereas the position
of other countries is quite different for each
classification. Finland and Sweden, for exam­
ple, consistently appear together in the encom­
passing Nordic/Scandinavian/social democratic
category, Ireland and the United Kingdom in
the 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 various
regime types are ideal types that owe their ori­
gins to different historical forces (Arts, Gelissen
2002). The allocation of countries to types is
not always clear-cut and they may sometimes
lie somewhere between types. Contrary to the
ideal world of welfare states, the real world ex­
hibits hybrid forms in every country. There may
sometimes be quite a lot of variation between
welfare systems of countries that appear in the
same regime type. Even countries with similar
sets of welfare institutions are frequently found
to display widely divergent patterns of develop­
ment (Alber 2006). It is also important to note
that the classification of countries into regime
types is time-dependent: governments, policies
and economic activity can all change over time
and directly influence the position of a country
in the classification system.
3.  European Models of Planning
(Planning Systems)
Two main approaches are evident in classifying
spatial planning systems. The first starts from
other classifications (or families) of the legal
and administrative systems within which plan­
ning operates, while the second seeks to apply
a wider set of criteria but nevertheless produces
a similar set of ideal types. Four specific stud­
ies of planning systems are discussed below. A
summary of the typologies of these studies can
be found in Table 2.
Ideal types and classifications
of 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 planning
system in England 4 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 the
legal certainty provided by systems in continen­
tal Europe (at least in the ideal sense) based on
the Napoleonic or Scandinavian legal systems,
in contrast to the high degree of administrative
discretion in the English system created by the
legal framework of English common law. New­
man and Thornley (1996) also concentrated on
a classification of planning systems according
to legal and administrative structures, drawing
on the five European legal families defined by
Zweigert et al. (1987).5
Zweigert et al. (1998) explain how all the
continental legal systems (Roman, Germanic
and Nordic) share a similar legal style: they seek
to create a complete set of abstract rules and
principles in advance of decision-making. This,
they argue, corresponds to particular continen­
tal mentality: “The European is given to making
plans, to regulating things in advance, and to
drawing up rules and systematizing them” (p.
71). In contrast, the English common law sys­
tem offers far fewer rules. Government does not
provide a complete set of legal rules in advance,
rather the law has been built up case-by-case
as decisions of the courts are recorded. Thus,
there is much more emphasis on case law than
on enacted law, which provides for more admin­
istrative discretion. Faludi (1987) made the same
distinction when referring to the continental
systems as imperative and the English system
as indicative.
Using legal families and administrative
structures to explain differences among plan­
ning systems has obvious validity because the
legal style and the administrative structure of
government provide very strong frameworks
for the operation of planning systems. This ap­
proach tends to emphasize the differences in
the role of plans in the formal regulation of de­
velopment, such as whether decisions are made
through legally binding plans (broadly followed
in continental countries) or as and when pro­
posals arise (the main approach in England).
We should note here that this approach tends to
over-emphasize the formal system of planning
in principle as opposed to the reality of its op­
eration in practice.
 The EU Compendium of Spatial Planning
Systems and Policies (1997) used a wider set of
criteria to create four ideal types or traditions of
spatial 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 six
other variables: the scope of the system in terms
of policy topics covered; the extent of national
and regional planning; the locus of power or
relative competences between central and local
government; the relative roles of public and pri­
vate sectors; the maturity of the system or how
well 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 mixture
of observable phenomena. They serve as meas­
ures against which reality can be compared such
that at a point in time and space a planning
action might exhibit features of more than one
ideal type/tradition. To some extent, the criteria
also address the nature of systems in operation,
though the idea types still emphasize the formal
structure of planning.
The comprehensive integrated approach disP 172 · 1/2008 39
corresponds 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 the
land-use planning tradition, which corresponds
well to the British legal and administrative fam­
ily and has the much narrower scope or purpose
of regulating land-use change. The other two
planning traditions do not correspond so closely
to the legal families. The regional economic
planning approach cuts across the Napoleonic
and Germanic legal families. The urbanism tra­
dition falls within the Napoleonic tradition but
for 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 ESPON
program (Farinós Dasí 2006: 112). It gives
more emphasis to the distribution of powers
relevant to planning among levels of govern­
ment with a finer analysis of state structures and
the decentralization and devolution of compe­
tences, especially the varying forms of regional
governance and local powers. It concludes, like

Davies et al. Common Napo­leonic

1989* law codes
England DK, DE,
FR, NL

Newman, Nordic British Germanic Napoleonic East

Thornley 1996 DK, FI, SE IE, UK AT, DE BE, FR, IT, European
LU, NL, PT,
ES

CEC 1997** Comprehensive Land use Regional Urbanism

integrated regulation economic GR, IT, ES
AT, DK, FI, DE, IE, UK FR, PT (and PT)
NL, SE (and BE) (and DE)

Farinós Dasi Comprehensive Land use Regional Urbanism

2007*** integrated regulation economic GR, IT, ES
AT, DK, FI, NL, BE, IE, LU, FR, DE, PT,
SE, DE UK (and IE, CY, MT
(and BE, FR, IE (and PT, SE, UK)
LU, UK) ES) HU, LV, LT,
BG, EE, HU, CY, CZ, MT SK
LV, LT PL, RO,
SL, SV

* Davies et al. (1989) do not give a specific name to the two groups but contrast England and other systems
based on their legal frameworks.
** The EU Compendium identifies ‘ideal types’ of planning traditions. Each country may exhibit combinations
of 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.
40 disP 172 · 1/2008 the Compendium, that variation is the hallmark
of planning systems and that it is difficult to
classify, since the member states vary in differ­ent
aspects of styles or according to which cri­teria
is given prominence. It argues that Belgium,
France, Ireland, Luxembourg and the UK are
taking up elements of the comprehensive inte­
grated approach. It also asserts that Germany,
Ireland, Sweden and the UK are moving towards
the regional economic planning style, and that
Spain and Portugal are moving towards more
land-use regulation.
Learning and convergence?
Comparative analysis of planning systems sug­
gests that continuous adaptation is leading to a
general convergence. Some changes are rather
detailed institutional and legislative matters, but
others reflect a more general “transformation of
the style of spatial planning” (Healey et al. 1997:
290). Farinós Dasí (2006) argues that the com­
prehensive integrated and regional economic
planning styles are becoming more common,
and, moreover, that this process is producing
a “neo-comprehensive integrated planning ap­
proach.” His argument supports the thesis that
the 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 regions
become increasingly oriented to competition
with European space” (p. 716). Davies (1994:
67) also anticipated such convergence “through
the triple effects of cooperation between cities
and regions in other countries… the competi­
tion for investment, tourists and other benefits
from the single market, and the learning pro­
cess in working with the [European] Commis­
sion” (emphasis added). The limited evidence
that we have suggests that Davies was right.
There has been a measure of convergence as
formal national arrangements for planning have
been adapted to address common challenges of
global competition and sustainability to which
they were unsuited. The debate at the European
level has played a part in this (Nordregio 2007)
alongside extensive transnational cooperation
that has raised awareness and promoted mu­
tual learning. It would be difficult to argue that
there is (or could be) a single European model
of spatial planning, but there does seem to be
a strengthening of the common elements, par­
ticularly those that are central to the European
debate on planning as “a method of securing
convergence 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 to
models of society, in two countries: England and
the Netherlands. These countries make for an
interesting comparison. The English planning
system is very distinctive and corresponds very
well to a particular social model while the Neth­
erlands is difficult to classify according to ideal
types of social models. Both countries have ma­
ture planning and welfare systems but are never­
theless experiencing considerable changes in
attitudes and values in society and in the role
and guiding principles of the planning system.
England
The ethos of the planning system in England is
infused with the dominant and distinctive lib­
eral social model, the pragmatic approach to
governance, the common law legal system and
the long history of stable national state bound­
aries. The very idea of spatial planning in the lib­
eral model of society gives rise to fundamental
tensions 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 have
fluctuated considerably in parallel with vacillat­
ing political ideology and economic conditions.
Learning from other countries has also played
a part, with a long history of exchange of ideas
about planning with other European countries
and North America.
The original intellectual arguments for plan­
ning came from the social reform movement
and its progressive ideological roots, but the
notion of planning that arose in practice was
dominated by questions of physical form (Ash­
worth 1954; Sutcliffe 1981; Hall 1992: 49). This
was planning with a relatively narrow ambition
and, although there was a period of proactive
planning in the 1950s and a consistent and firm
application of urban containment policy, the
formal system of planning in England has been
generally reactive and passive, for example, in
its emphasis on regulating private sector devel­
opment (or the public sector acting as private
developer). This form of planning fits squarely
within the ideal type of land-use management.
However, it does address the spatial dimension
of tensions that arise in a liberal economy that
seeks to achieve a more even distribution of so­
cial and economic welfare. National government
has 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 of
any significance and the system offers consider­
able discretion: decisions on development are
made on their merits with no binding zoning
instruments. There are extensive opportunities
for consultation and objections to policies and
development projects.
Shifts in the nature of the dominant liberal
social model have been closely interlinked with
reforms of the planning system in the past. The
rise of neo-liberalism in the 1980s and 1990s
with its antagonism toward the welfare state and
its adherence to individualism and choice pre­
sented a fundamental challenge for planning. It
might be argued that the dominant lessons (in
the sense of a learning system of planning) at
this time were coming from the United States.
Evans (1995) argues that planning changed from
a “welfare profession” serving the public inter­
est to a skills-based profession selling a ser­
vice. The ambitions of pre- and post-war grand
designs and social and economic goals largely
disappeared 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 concentrated
on the efficiency of the system and a govern­
ment program of Modernizing Planning (DETR
1998) brought forward incremental changes.
But contributions from agencies and NGOs to
this debate pointed to deep-seated tensions
in 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 planning
has had a critical influence on the direction of
the planning system (DTLR 2001; Nadin 2007).
The reform of planning subsequently calls for a
stronger role for the planning system in shap­
ing change and a shift in the very culture of
planning. Subsequently, the 2004 Planning and
Compulsory Purchase Act is at the heart of the
most significant reform of the planning system
in 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 offer disP 172 · 1/2008 41
planning authorities more opportunities to take
the initiative in development, to provide a stra­
tegic framework, and to engage stakeholders
more effectively. This is summed up in the gov­
ernment’s guidance in the notion of “the spatial
planning approach” (Nadin 2007). It seeks to
meet a desire for more plan-led development
and coordination of private investment and sec­
tor public policies within the market-driven and
fragmented policy environment that arises in a
liberal model of society. In some ways, the lib­
eral model is stronger than ever, but at the same
time, there are demands for more and more ef­
fective public intervention. The solution offered
sees planning as a coordinative and collabora­
tive activity injecting a spatial or territorial di­
mension into sectoral strategies and policy; and
creating new policy communities that reflect the
realities 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 enabling
local planning authorities to positively promote
appropriate development.
The changes to planning in England have
undoubtedly been influenced by transnational
learning, particularly ideas coming from the
ESDP (Shaw, Sykes 2003, 2004, 2005). Never­
theless, the ESDP exhibits very different as­
sumptions about planning, which arise from
continental systems and their roots in different
models of society. The key ideas in the Euro­
pean dialogue on planning have been reworked
to fit the dominant model in England, but are
not proving easy to establish. Reports in 2007
suggest that central aspects of the reformed
system are struggling to take root in practice
and among the profession (Baker Associates et
al. 2006).
The Netherlands
According to Shetter (1988), planning is one of
the central cultural institutions in Dutch society.
Alexander (1992) describes spatial planning in
the Netherlands as relying on a passive regula­
tory system in which interventions are permitted
subject to prior assessment, with stakeholders
being consulted at an early stage of the planning
procedure. The EU Compendium describes the
Dutch planning system as one of the most elab­
orate examples of the comprehensive integrated
approach to planning in which “plans are more
concerned with the coordination of spatial than
economic developments” (CEC 1997). Rather
42 disP 172 · 1/2008 than working with master plans, national plan­
ning in the Netherlands works with indicative
national policy documents.
Statutory plans are the responsibility of the
provinces and municipalities and only the lat­
ter have the power to make plans that provide
grounds for the refusal of planning permits
(Faludi 2005). Much consultation and persua­
sion therefore takes place to integrate policies
of higher levels of government into the plans
and policies of lower levels of government (Zon­
neveld 2006). Central government is the chief
source of funding for planning at all levels, and
so wields much influence by means of this rela­
tionship (Faludi 2005). The Dutch planning sys­
tem is plan-led: nothing can be developed that is
not in accordance with the local land-use plan,
since this is legally binding. However, property
developers can exert strong influences on the
content of a plan, which also gives development
a development-led character (EC 1999). Plan­
ning practice is strongly influenced by informal
ways 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 a
new 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 state
spatial planning” to “development planning” 6,
which clearly indicates a link between the plan­
ning system and the welfare state. The nature
of these changes is summarized below (more
detail can be found in Needham 2005; Spaans
2006; Vink, van der Burg 2006; Zonneveld
2005, 2006).
The National Spatial Strategy
The National Spatial Strategy (Nota Ruimte), ap­
proved by the Senate in January 2006, indicates
a departure from the restrictive planning dis­
course (Spaans 2006). It makes a radical break
with the centralist tradition in which the na­
tional government determines in detail what
will be built and where. The National Spatial
Strategy’s dictum is “decentralize if possible,
centralize if necessary”, mirroring that of the
predecessor of the National Spatial Strategy, the
Fifth Memorandum on Spatial Planning. The
only difference was that the phrase has been
reversed: “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 National
Spatial Strategy marks a radical departure from
traditional Dutch spatial policy in that a new
division of responsibilities between the three
tiers of government is outlined. Central govern­
ment takes a step backward in favor of allowing
the local authorities, particularly the provinces,
to play a key role. The National Spatial Strat­
egy, for example, gives a stronger role to lower
levels of government in terms of development
control. 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 document
itself reports that the main difference between
this strategy and previous ones “is primarily the
method of governance (the how) rather than
the policy content (the what).” It asserts that the
most important objectives, policy concepts and
basic principles from the previous strategies
have been retained (Ministry of Housing, Spa­
tial Planning and the Environment 2006). The
document also signals a shift in emphasis “from
planning to development”: more emphasis on
development-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 the
number of rules and regulations imposed by
central government on others, while creating
more scope for local and regional governments,
social organizations, private actors and citizens
in 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 be
able to intervene more forcefully when national
or 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 been
amended several times. In the 1990s, for exam­
ple, legislation was amended to speed up large
projects (e.g., infrastructure development, river
dikes). Most of the changes to the spatial planning
act have been marginal, but the overall result
is a patchwork of different instruments and
procedures (Needham 2005). Since 1965, the
idea has always been that planning is primarily a
coordinating activity (Hajer, Zonneveld 2000).
Work started on a new spatial planning act
in 2000, when it was decided not to work within
the old 1965 framework, but to develop a new
one. Most of the content is uncontroversial or
regarded as inevitable (Needham 2005). The
new spatial planning act was approved by the
Senate in October 2006 and will enter into force
in 2008. It has been five years in the making,
and many changes to the proposed content have
been made in those five years. All have reduced
the extent and significance of the proposed
changes (Needham 2005). While the new act
gives 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 to
be very significant is the strengthening of the
planning powers of central government at the
cost of the planning powers of the municipali­
ties (despite the focus on decentralization in the
most recent National Spatial Strategy). The new
planning act will, for example, give the national
and provincial governments stricter powers for
requiring a municipality to follow their policies
through the issuing of directives. Vink and van
der Burg (2006) report that the new planning
act will make it possible for central and provin­
cial government to be able to intervene more
forcefully than previously when higher interests
are at stake, which can be interpreted as the cre­
ation of a more centralized planning system and
at odds with the principle of the Netherlands as
a decentralized unitary state (Zonneveld 2006).
It remains to be seen how centralized the new
system will be in practice. Despite new roles for
provinces under the new spatial strategy and
powers under the new spatial planning act, the
Dutch Council of State anticipates “serious con­
sequences” for the position of the provinces in
spatial planning and a “strong decline in the
importance of the provincial spatial planning
policy.” Strangely, however, the fate of the prov­
inces in the new Dutch planning system has not
generated much debate in the professional do­
main (Zonneveld 2006).
Reflection
According to Hoekstra (2003: 63), the Dutch
system 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- disP 172 · 1/2008 43
Anderson’s typology (see Table 1). While the
1980s and 1990s marked a period of relative
stability 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 approach
to planning. These developments can be in­
terpreted as a movement towards the develop­
ment-led planning approach that is also evident
in England. The recent changes in the Dutch
planning system mirror the general direction of
welfare reform in the Netherlands over recent
decades.
The Netherlands has played an active role
in the international spatial planning arena over
recent decades, particularly at the European
level, which has unquestionably led to learn­
ing processes both for the planning community
in the Netherlands and, perhaps more import­
antly, for the planning community outside the
Netherlands (who have learnt about the Dutch
approach). Indeed, one of the main reasons for
the country’s active role in the international
arena was arguably to try to promote or export
concepts and processes from the Dutch spa­
tial planning system, and set the agenda for
spatial 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 an
active role in the development of the Territorial
Agenda of the EU (Faludi 2007c). Learning has
not however just been a one-way process for the
Dutch planning community: involvement in the
international planning arena has also exposed
Dutch policy-makers to a wide variety of spatial
planning 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 clarifying
understanding of the comparative evolution of
national forms and policies of planning and the
process of convergence in the context of mutual
learning. There is first a reasonable correspon­
dence between the ideal types (or categories)
of models of society and planning systems (see
Tables 1 and 2), which was perhaps to be expected.
The planning system is in part an expression of
some fundamental values in a society in rela­
tion, for example, to the legitimate scope and
aspirations of government, the use of land, and
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 society
and the type of planning system is particularly
strong for the British/Anglo-Saxon and Nor­
dic models. They are consistently distinguished
because of their specific characteristics, dem­
onstrate a very close association between the
dominant model of society and the form of the
planning system. There is less consistency in the
definition of models for continental countries.
A few countries are apparently very difficult to
classify, including the Netherlands. Countries of
central and eastern Europe are most difficult to
work 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 real
diversity 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 both
countries 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 or
the exchange of experience and development
of a common reference framework for spatial
planning that has arisen from extensive coop­
eration at European and transnational scales. It
is perhaps not surprising, therefore, that recent
reforms are creating considerable uncertainty
and controversy in each country.
In England, the notion of planning as a tool
for spatial policy integration is at the center of
the spatial planning approach. This is not a new
concern for planning and was perhaps part of
the dominant culture in different ways in its earl­
ier history. The aspects of reform that require
close partnerships between public, private and
civic sectors fits well with the Anglo Saxon lib­
eral model of society, but other changes, such as
more long-term strategy and greater policy in­
tegration, are more difficult to incorporate. This
is recognized in the government’s call, along­
side new tools and procedures, for a “change
in the culture of planning” (Shaw, Lord 2007).
Although it is too early to evaluate the reforms,
it appears that they are proving difficult to put
into practice and the process remains contro­
versial with uncertain outcomes. It is now more
difficult to categorize the planning system in
England as dominated by the land-use regula­
tion model.
In the Netherlands, the old system of spatial
planning (i.e., before the introduction of the
new national spatial strategy and spatial plan­
ning act in 2006) is very much congruent with a
social-democratic welfare model. Furthermore,
the new national spatial strategy and spatial
planning act signal substantial shifts that are
currently taking place in Dutch spatial planning
and welfare policy more widely, and a move to­
wards a more liberal approach. Because both
the spatial planning strategy and act have only
recently been adopted (and the act had not yet
come into force at the time of writing), it is too
early to say exactly how spatial planning pro­
cesses and practices may change. The changes
in 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 also
undergone some significant changes (see, for
example, de Gier et al. 2004). Despite changes
in the spatial planning and welfare systems, we
believe that the Netherlands still has a planning
system that can be categorized into the “com­
prehensive integrated approach” (CEC 1997)
and still has one of the most elaborate examples
of 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 model
will be a considerable abstraction of the true
variety that the nation states and regions ex­
hibit. Zweigert et al. (1998) note the dangers in
reducing the complexity of variation between
countries to a few “families”. Much depends on
the particular criteria employed. In this paper
we have explored the potential for explaining
the evolution of the formal arrangements for
spatial 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 continuing
such an investigation. European, transnational
and cross-border spatial planning initiatives
that provide learning opportunities could be
usefully informed with a deeper understanding
of the dynamic interrelationships of planning
reform and social model.
More recent analysis of both social models
and planning systems has called for a finer clas­
sification of systems that recognizes more di­
versity and divisions. The examples of England
and the Netherlands also show how very similar
arrangements can be developed in practice in
quite different settings. They suggest that the
received models may overemphasize the Brit­
ish-Continental divide. The practice of planning
may develop in a similar fashion despite their
differing legal and administrative contexts (as
has happened in the United Kingdom). External
factors including learning through transnational
cooperation seem to be leading to a measure of
convergence or harmonization of systems, al­
though this creates tensions as changes in ad­
ministrative systems run ahead of changes in
the social model.
Notes
1 Analogous to the debates about spatial planning
concepts 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 the
United Kingdom in matters of principle.
5 Zweigert et al. (1998) also identify three other
legal families (South East Asian, Islam and Hin­
duism), making eight legal families in total.
6 The term development planning in this context
implies development-led planning.
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Zweigert, K. (author); Kötz, H. (author) & Weir, T. NL–2600 AA Delft
(translator) (1998): An Introduction to Com­ v.nadin@tudelft.nl
parative Law. Third Edition. Oxford University
Dominic Stead
Press, Oxford.
OTB Research Institute
Delft University of Technology
P.O. Box 5030
NL–2600 AA Delft
d.stead@tudelft.nl