I’m an architect by training and now a Senior Associate Urban Designer. But I’m also a planning enthusiast. I see it as a brilliant tool for making, not hindering, great places. As a system it holds together and balances such a wide range of complex issues that contribute towards our built environment. And it must operate on a vast range of scales, from household to national projects.
And so, I was very keen to read Planning for the Future which outlines the Government’s plans for ‘landmark reforms to speed up and modernise the planning system and get the country building’.
After waking up on the morning of its release to a host of criticism from trusted sources, I had significant reservations. The reasonably brash introduction, listing the apparent failings of the planning system and suggestion that a quick simplification was the answer, only added to my scepticism.
However, despite having lots of questions, I reached the end with a different attitude – and, dare I say it, some excitement. For me, once you disconnect from what feels like an introduction of political lobbying and forewords from Johnson and Jenrick (let’s face it, his public trust is at an all-time low following the Westferry Printworks scandal), there are actually several welcome ideas and suggestions.
Below I have listed, some pros and cons on the proposals. These thoughts are my own, and I welcome discussion and debate on the matter.
1. Bringing planning systems into the 21st century
Today, there is an app for everything. We no longer carry actual wallets because our phones do it all. So much information is at our finger tips, and yet accessing and interacting with planning material still feels mechanical and laborious. This means that only those paid to deal with it, or those few individuals who are passionate about particular issues in their community, bother to dig into the clunky planning websites.
For me, using the software available to make planning accessible and easy to engage with will mean a lot more people will be inclined to get involved in placemaking and planning issues.
Those digital plans should be carefully designed with the user in mind and to ensure inclusivity, so that they can be accessed in different formats, on different devices, and are accessible and understandable by all. Geospatial information associated with plans, such as sites and areas, should also be standardised and made openly available online. (Page 38)
To make this work, central government needs to invest in technical and digital expertise to create software that will work for all local authorities so it will be common in its operation and accessibility through the country. And it looks like this is included in their proposals:
We will work with tech companies and local planning authorities to modernise the software used for case-managing a planning application to improve the user-experience… (Page 36)
This engagement process with all users is essential to ensure that any apps (unlike recently released central government apps) are effective in their purpose and use.
2. Optimising plan-making
Creating local plans is time-consuming and laborious. It takes years to agree a document that is often very long, overwhelming to interact with, and out-of-date the moment it is adopted. The lifespan of a local plan is around 10-15 years with each taking 7 years from conception to adoption. It’s a lot of work for something that has such a comparatively short shelf-life.
So the proposal to turn plan-making into a shorter process, with a shorter lifespan and more fluid renewal, is certainly appealing.
Having recently worked with a local authority without an adopted local plan, decision-making for sites in the borough was challenging and time-consuming. So I certainly support a process to optimise the plan-making process.
Furthermore, if central government creates common policies that are currently typically repeated across all local authorities (and therefore the overlap in workload is inefficient), this will enable local plans to focus on local priorities and principles that are critical to delivering them.
3. Reinforcing planning with design codes and guides
I may be biased on this one, as I’ve been involved in writing several design guides and codes for different scales and stages of the planning and development process, including the National Design Guide. But well-written codes and guides, put together in an inclusive and engaging way, have the ability to build local support and define principles based on local issues, evidence and research. They can bring different stakeholders in the design, planning and development process together to illuminate barriers and, in doing so, identify solutions to local priorities and processes. They can also drive high-quality placemaking, rather than leave local authorities in a position where they are constantly reactive to proposals.
The White Paper is proposing that the responsibility for creating these guides and codes will fall to local authorities rather than developers. And as long as local authorities have the necessary resources, I support this proposal. I believe these documents have the ability to reach more key stakeholders and gain public support when driven by the local authority, who have the wellbeing of people and the environment as a higher priority than profit (as is often the case with developers). This will be a particularly important factor when design guides and codes will become a more common and important supporting document to local policy.
4. Flat, non-negotiable levies
While the financing of local authorities is not my specialism, it’s apparent that many local authorities are treading water. Yes, a few central London authorities are doing well and the issues around why that’s the case is a separate discussion. But it seems non-negotiable flat rates for infrastructure levies is a sound step. And particularly those that are based on values on occupation, rather than speculation.
1. No diversity of the authors or engagement with the national bodies
Diversity is essential to obtain a thorough and broad range of understanding, ideas and opinions. It’s even included in the proposals in relation to improving community engagement:
The Government has heard how the combination of technical jargon and traditional models of community engagement discourages people from having their say on decisions. At the same time, it disproportionately encourages engagement from people from a narrow set of demographic groups – typically older, better off and white. (Page 74)
So it’s extremely disappointing that this White Paper was compiled with an older, better off and white panel. It’s equally disappointing that senior members of the RTPI weren’t engaged as key stakeholders to represent the country’s planning specialists.
2. It won’t necessarily speed up planning application processes
In fact, it may be more complicated. While the plan-making process could become much more fluid, the proposed application and review process raises more questions.
Although the outline application process could be removed if a scheme is in a Growth area and compliant with the local plan, it must also be compliant with a local design code or guidance which has been prepared with community involvement. So time needs to be factored in for local design codes, their engagement, and their adoption (they must be adopted in order to carry any weight). Also, the outline design of a scheme must still take place and the local authority needs to review and confirm if a scheme is compliant or not. It is likely there will be items and issues that are not in full compliance which will need negotiation. Finally, the reserved matters application process is also still needed before development can be built.
For applications in the Renewal and Protected zones the application process is likely to be similar to the current situation.
3. Net-zero by 2050 is not quick enough and speeding up the environmental impacts assessment stage of the process is not the answer to solving the climate and carbon crisis
The biggest threat to our country, and to our health and wellbeing, right now is the climate and carbon crisis. Burying our heads in the sand on this while we ‘speed up and simplify’ planning and the house-building processes will bring bigger issues down the line. While I believe that standards to create zero carbon homes and buildings should be part of Building Regulations rather than policy, we need to ensure that any planning reform has environmental sustainability at its core. Proposal 15 states:
We intend to amend the National Planning Policy Framework to ensure that it targets those areas where a reformed planning system can most effectively play a role in mitigating and adapting to climate change and maximising environmental benefits.
However, we need to be combating, not adapting to climate change.
As the planning system was created to protect our health and wellbeing, this needs to be the central goal for any reform in 2020 when we have scientific evidence showing that we have about a decade to make the big changes necessary to slow down and stop climate change. This area of the White Paper needs particular scrutiny and review.
4. It’s all about housing
The planning reform, as well as several other recent government announcements, are focused around the delivery of housing. The White Paper images are quite a giveaway.
We are well aware that homes are in short supply, as are jobs, so it’s a market worth focusing on. However, surely the construction of non-residential buildings (hospitals, schools, theatres and community buildings) which make up the key buildings of our local centres, need more scrutiny than compliance or non-compliance, as suggested in the White Paper? Will design codes be detailed enough to capture the design qualities of community, public and commercial buildings? Will they capture the local issues, character and identity of a place? It feels like a tall order.
As it’s a White Paper, it naturally raises many questions. Some that stand out for me:
1. How do local authorities fund themselves if there is little development happening in their area? If levies are set but no development takes place, then local authorities won’t receive the funding that may be needed to support general infrastructure costs.
2. Despite the aspiration for better community engagement at the plan-making stage, engagement isn’t referenced in relation to specific planning applications. It’s great that engagement is clearly identified in a more dynamic way in the plan-making stage – this will enable communities to be proactive rather than reactive to new development. But working with local stakeholders on specific sites can produce really positive, supported and sustainable outcomes with stakeholders invested in the ongoing management and maintenance of a place, fostering long-term stewardship. We engage with people not just to see if they like it or object to it, but to shape how a site is designed – local people know their neighbourhood and how it’s used. How can developers and designers that decide what a scheme is like without working with a local community deliver high-quality, fit-for-purpose development?
3. There is more scope and responsibility placed on local authorities for improved local engagement, the production of design guidance and codes (including a Head of Place-making) and the creation of new roles to review policy compliance for applications as well as managing the reserved matters applications and general applications for the Renewal and Protected zones. Therefore, more resourcing and skills will be needed within their teams. This is good, but how will it initially be funded?
4. Design codes – if these become key compliance requirements for Growth and Renewal areas, they must be produced by the local authority and be area specific. How will local authorities get up to speed to produce these codes and guides before landowners want to get development underway?
5. We need more clarity about how central government define design codes and design guides. Especially with the upcoming National Model Design Code. Will they be material considerations? Will they be adopted as Supplementary Planning Documents to give them more weight? What will be required for negotiation and how will those negotiations happen in the planning application process? Even more importantly, how do we make sure that the majority of local authorities don’t fall back to the National Model Design Code, which may have the effect of creating ‘copy-paste’ housing replicated throughout the country? Without effective preparation, placemaking could quickly become monotonous and indistinguishable.
To summarise, I’m excited about the prospect of using technology to enable better information sharing and engagement in planning. I’m also very interested in a more fluid plan-making process, including design guidance and codes.
However, I don’t see how land allocation can really be split between three simple zones with simple processes to follow for applications. And I do have concerns over how climate change will become front and centre, as it needs to be, for us to have a prosperous future.
Looking a little wider, there are confusing messages coming from the government on their wider announcements to deregulate aspects of permitted development alongside tightening up design codes for new build. How do these work together? And, when people are looking for stability and security, is now the right time to ‘tear it down and start again’ as Boris Johnson puts it?
The devil is in the detail and we look forward to debating and creating a company-wide response to the White Paper to ensure all the key issues are brought to light.
We’d love to hear your thoughts. Get in touch with Sarah or join the conversation on our social media channels #TalkingSpaces013.