For the past 3 months I have been working 2 days week in secondment to PAS, on a project to help embed the new ‘duty to co-operate’ on strategic planning.

My day job is with East Midlands Councils (EMC), a ‘sub national’ grouping of local authorities, where I work on an eclectic range of issues including rail investment, climate change, developing CPD for council planners, and various consultancy projects for EMC member councils.   Before that I managed the regional planning function in theEast Midlandsfor 10 years, also leading on transport and housing investment. Given my background in the apparently ‘dirigiste’ world of regional planning, it may seem strange to some that I am working on a project about ‘co-operation’.But in truth, much of what we did at the regional level was based on a co-operative model.  In the East Midlands, the Regional Plan led directly to a pattern of joint and aligned core strategy arrangements covering most of the region which, at the time of writing, are all still in place. 

Co-operation is nothing new – it is something planning authorities have always done to a lesser or greater extent.  Why then is there such scepticism about the new ‘duty to cooperate’ being an effective means of delivering strategic planning?  I have lost count of the number of times officers and councillors have said to me (confidentially of course) words to the effect that:  ‘it will never work you know’. Without an element of compulsion it seems that many within local government feel that councils will not have the political will to make the tough decisions and stick to them. This attitude is even more surprising when you consider that the drive for change to the new system came from local government, and in particular the LGA.  

There may be an element of ‘be careful what you wish for’ here. But there is also potential for significant reputational damage, both to local government generally and to the LGA in particular, if it does all go ‘pear shaped’.    And yet it seems to me that the new duty should represent an important opportunity for local councils to develop their community leadership and ‘place making’ functions – surely core responsibilities for councils in the 21^st century. What is required to make it work is of course co-operation, but more importantly leadership and, in particular, political leadership.

When it comes down to it, the whole system stands or falls on the ability of local councillors to ‘pool sovereignty’ on key issues, and to make well evidenced strategic decisions on the scale, form and location of growth.  There are of course many examples acrossEnglandwhere his is happening already, but perhaps just as many (if not slightly more) of where it is not.

My colleague Catriona Riddell and I have been developing a package of resources to help both members and officers make the most of the new system – and to avoid some of the more obvious pit falls.

We will be road testing ideas at a series of seminars across the country from early February, along with speakers from DCLG, PINS and councils themselves, ending with an event aimed specifically at elected members on the 9 March in London.   Further details can be found on the PAS web-site. If you are not already down to come to one of the events, we would love to see you and hear what you think.

I decided to use open source software (QGIS), together with the newly opened Ordnance Survey data, to quickly hack together a few maps that use my local data as an attribute. The documentation I could find was either a bit worthy and slow, or expert and quick. If you half-know what you’re doing, and have a project in mind, these notes may help you make a map inside a day. 

In summary, this is what needs to happen:

1. Get QGis (and some libraries)
2. Get data from Ordnance Survey
3. Simply the OS data so we don’t go out of our brains waiting all the time
4. Export the attributes of the OS data, so we can separately add factoids about councils. I’ll be using plan status and facts about whether we’ve worked with them.
5. Import the extended table, and join it to the original
6. Ask the map to reflect the factoids – perhaps by using different colours or whether to display a council at all (the OS data includes Scotland and Wales which have different planning systems)

1. Get QGIS and some libraries

This will depend on what (and whose) machine you’re using. I’m using my ‘secret squirrel’ laptop that corporate people don’t know exists, running ubuntu and connected via the guest wi-fi to the outside world. If you’re using windows, see the all-in installer details and skip to section 2.

For some reason, the version of qgis in the stock software centre is very old. So, as per the instructions on the ‘download‘ page:

# using ‘update manager’ select settings > other software > ‘add’
deb http://qgis.org/debian oneiric main

sudo apt-get update
sudo apt-get install qgis

# note it installs python and GRASS support as standard, but I still required

sudo apt-get install python-gis

2. Get data from ordnance survey

http://www.ordnancesurvey.co.uk/oswebsite/products/boundary-line/index.html

We want two products,

• the boundary line data ™ which is vector information of each local authority (and much else besides);  and
• miniscale ™ which allows us to place the shapes of councils onto a meaninful map (with rivers, coastline etc)

You need to order them to receive a download link via mail (but so far no spam). You’ll end up with two files, minisc_gb.zip and bdline_gb.zip

I’ve unzipped everything into my file ../downloads/data (you’ll need to change your path as appropriate if following)

To begin, launch qgis and start a new project. To set up the mapping references are understood, open ‘project properties’ and click the CRS tab. Check the ‘on the fly’ transformation and change the coordinate reference system to OSGB 1936.

Let’s show a map. Use ‘open layer’ and find district_borough_unitary_region.shp

If your machine is anything like mine (a loyal but underpowered laptop) it will top out for 5 minutes while it struggles with the 60 Mb file. This happens every time we render. No one can work like this – let’s lose some resolution. [tip - if you want to play with the settings in the next step you will want to uncheck the "Render" checkbox at the bottom of the screen]

3. Simplify the data

Make sure your layer is selected on the left-hand side of the screen and (using the menus) go Vector > Geoprocessing tools > simplify geometry [if you can't see this menu, recheck that you have python-gis installed properly]. It asks for a tolerance – I used 10% to shrink the 59Mb file down to 9Mb. To keep things clean (and to allow me to revisit this step if I was ultimately unhappy with the reduction in fiedlity) I saved this altered version as district_10_percent. Tidy up by removing the original layer.

The manual also suggests using a spatial index to speed things up (right click the layer > properties > general > create spatial index) but I didn’t notice much difference in my non-scientific comparison.

4. To export the existing attributes

To manipulate the attributes I used a library called mmqgis – follow the instructions to enable 3rd party repo’s and find and install the mmqgis plugin.

To export the attribute table it is as simple as using the plug-ins menu:

plug-ins > mmqgis > Attributes export to csv

You can then load the file you just exported in excel (or libre) and take a look. To prove the theory, I just made a test file by

• deleting scotland (sorry)
• deleting Wales (sorry)
• removing all columns apart from NAME (just in case) and CODE (we’ll use this to reattach the table)

Then, I made a new column called “TEST” which had some numbers in it – I used a small range between 0 and 9 done at random. Just to see if I could link this field to some visible attribute.

Save this as a csv file.

5. Import your local data and attach it

To import and display your local attributes on a map of England

plugins > mmqgis > Attributes join from CSV file

input file = your CSV

CSV field = CODE (it will default to NAME, which will work, but let’s be strict and use code)

join layer = districts_10_percent (see above)

join field = CODE

Satisfy yourself that England has reappeared by selecting only the layer called ‘joined’. Now we want to use our test field to alter shadings. In the process of importing the attribute table, any numbers are imported as text.

plugins > mmqgis > Text to float

Select your ‘joined’ table and the field ‘test’. Convert. Your text ’1′ is now a floating point ’1.0′.

6. Using a map to display attributes

The lovely mmqgis plugin makes this very easy:

Plugins > mmqgis > Color Map [sic]

Map layer = ‘numeric’

Band = ‘test’

Choose suitably vibrant presets

Ensure that your ‘numeric’ layer is the only one selected:

And (if you’ve been able to resist the temptation thus far), check ‘Render’

Behold a thing of beauty. And all thanks to projects like qgis and mmqgis. And, less romantically, the broader availability of OS data. Now, let’s get mapping …

One part of the benchmark was customer feedback via freepost. Taking the feedback as a whole, there are some really clear messages that are really easy to respond to. One, though, is making me think a bit more. One question we asked applicants was something along the lines of “Were you helped to make your development happen ?” and this prompted lots of applicants to write comments in addition to giving marks. And what they said was “it depends on the officer assigned to you“.

We asked the question wanting feedback on the performance of the planning department, but punters wanted to feedback on the individual. Not just negative – some applicants wanted to heap praise on some individuals for their can-do approach and general friendliness. I suppose it shouldn’t be a big shock. We might pretend to be a bunch of professionals, all operating the same system in an impartial and dispassionate way. But we suspect that validator ‘A’ is really really strict when compared to validator ‘B’, and that officer ‘C’ invents a few new ‘i’s to be dotted just for fun, whereas officer ‘D’ does the minimum possible.

The feedback from agents is suggesting to me that there is real merit in collecting feedback that is tied to named people. There are some potential issues with this, but I don’t think there is anything here that can’t be overcome:

• Applications go through many hands, and there is churn the team:  This is not the applicants problem.  As an officer, it can feel a bit unfair to be handed an old, cold case but we need people to own the problem and establish a constructive relationship.
• It could encourage officers to take the easy way out: It would be dreadful for customer feedback to result in officers being afraid to give applicants the answer “no” or “unless“. But really, feedback from customers is just another perspective and (at times) will need to be taken with a pinch of salt. Good managers will use the feedback in a broader context – but will also be able to use it as evidence if complaints are clear and consistent.
• Applicants are not the only “customer” to the service: I keep being told this. This just doesn’t matter. Yes, of course we should aim for the highest standards with all our stakeholders – let’s just start by trying to collect data from the most obvious source and see how it goes. This is unashamedly a transaction thing – evaluation of outcomes is for another day.
• It’s unfair to manage people on the basis of a tiny amount of customer feedback: This is true. We have to (all together) find a way of driving up participation until it becomes representative. Otherwise the law of small numbers will render the information collected via feedback useless.

This feels like a natural corollary to the work we’re doing on the agents pilot. Let transparency and the facts be our guide. The 2012 benchmark may feel like a long way away, but I’m starting to think about the improvements I’ll put before the steering group. And if you are the officer who “is impossible to get hold of and never returns calls” you have about 6 months to improve the way you do things.

In our bit of local government, the work we want to buy is sometimes difficult to specify. It might be genuinely new, or difficult to define as “done” or “not done” – unlike a bin which is “emptied” or “not emptied”. It often contributes towards a greater endeavour, with a far-off evaluation.

And to be clear, there are good and bad suppliers. No matter how much you worry about the PQQ, ITT, interview or contract you will (on occasion) find yourself trying to work with the clueless. It is a myth that all private companies are customer-centric in a way that public organisations aren’t. We’ve done enough survey work with local authorities to know that most of them feel let down by their ICT suppliers and about half the consultancies they worth with.

We need the qualitative feedback of a reference more than anyone else. So, to refuse giving garbage reasons like “[our organisation] does not provide references to support individual contractors because of our need to remain impartial at all times“. WTF ?. “It is Welsh Government policy not to provide an opinion on the performance of a recent supplier“. Seriously, WTF ? You are spending public money, and you should have the cojones to have an opinion about how well it went. If you refuse to have an opinion, then you remove your way of giving a bad reference. Ask me about someone I think is great and I’ll tell you all about it. Ask me about someone who is a nightmare and I will confirm the dates and title.

You can see what happens when references are ill considered at trip advisor and its friends. If I fail to tell a supplier that they are not performing the work as I want it, and then rubbish them in a reference it’s not fair. And the whole process could be made fairer by all public sector works being held in a list so companies couldn’t pick the 2 good referees and ignore the 10 bad. And a cherry on the cake would be for us all to be a bit more grown up around the whole “stuff doesn’t always work out and that’s just the way it has to be sometimes” reality, rather than being risk-averse arse-coverers.

I can’t pretend completing reference requests is fun, or what you went to college for.  But we in local govt need to play more like a team. So the next time you have a good experience with a supplier encourage them to use you as a referee. It’s like giving blood – you may not directly feel the benefit but someone you love will sometime. Yes, it is an effort. But good suppliers are worth it.

Some agents are great. Others not so great. The poor ones submit shoddy schemes that require rework – and the cost of that rework is presently paid for with public money. [as an aside, if local fees happen, that rework will be paid for by the good agents. But that's for another day.]

Earlier this year I wrote a piece  asking if publishing data on how quickly and successfully different agents get planning decisions would lead to better quality applications. It’s an uncomfortable way of looking at the world – it’s a council’s-eye view, it bashes agents and leaves councils unaccountable for their part.

A better (balanced) picture

I have, instead, decided to look at the world from the customer’s (agent’s) end. I’ve asked: What’s my experience working with different councils? Do I have to play by different rules each time? Why does council ‘A’ decide my application quicker than council ‘B’?

What we’ve done

Taking data from some neighbouring district councils we’ve looked at processing times and success rates of agents that have submitted 10 or more applications across the councils. And, because not all work is equal; we have grouped similar work into 3 bands (A=quick/easy (certificates, NMAs), B= more complicated (minors, householders, C= Difficult (Majors etc.). We can now compare agents that do similar work and their experiences of working with different councils.

What we’ve found

The agent-centric view – no surprises; there are good and bad agents!?

[Notes: This is a list of agents working across a pair of District Councils. The 'Days' is total end-to-end days taken to receive a decision and the numbers across A-C are the total number of decisions within each band. If you were a punter choosing an agent who would you call first ?]

Question 1: if some agents can get things through quickly and successfully, why can’t they all?

Question 2: Which agents get quick permissions (and do they provide a service for my ‘B’ type application?)

Question 3: Is the difference down to good/bad agents or good/bad/ processes?

Same agent, different story

This box plot  compares validation and decision days at two different (neighbouring) councils.

Question 1: Why does this agent experience a difference?

Question 2: The application going through Place A ‘catches up’ when you compare the Decision days. Is there something these councils can learn form each other that has nothing to do with the agent?

Question 3: Is anyone bothered about validation taking twice as long if the decision is reached earlier?

As an applicant interested in a quick decision, it would be difficult for me to confidently choose this agent over another. I would rather choose which council my application got submitted to (!)

All Agent view

The box plot within each picture represents the agent’s (A – P) experience at two different places.

Validation times

Same set of agents – decision times:

This is where it gets really muddy or clear depending on what way you look at it. Agents get similar levels of validation sometimes, a few experience something like consistency in the time to decision, and almost invariably the council that validates slowest, issues decisions quickest. What is more important? What costs more?

So what? Where are we going with all this?

You tell us. Who cares about this? We can demonstrate how clever we are by producing interesting pictures but why bother if all it amounts to is an interesting project? We are not interested in rides that have no destination. Here are the options.

The ‘nuclear’ option

Stack agents one on top of the other, publish the facts and let the market decide who to use. Quick, easy, not customer friendly, creates enemies and most scarily, might mean some agents no longer receive work.

The customer-centric option

Classic customer focus; understand the customer experience, act on the bits that I (the council) am responsible for, and, by taking this act of ‘leadership’ seek to influence and change the bad behavior of your customers (the agents). Councils improve, agents improve and overall things get better.

Both of the above options are real and possible. The first is unpalatable, and the second lacks ‘bite’ – councils have agent forums to deal with these sorts of issues, and yes, this data may help them target their conversations, but will things change significantly unless we know whether this is hurting us or not’ ?

The ‘Stellar’ moment

What is the cost saving if the poorest 30% of agents could be as good as the best 30% of agents ? Councils taking the lead and improving their end is absolutely the way to start influencing change among agents. But, and I am also absolutely convinced of this, that unless we can put a ‘£’ sign next the additional work that poor agents/processes cost us, it will be hard to get anyone to do anything significant about this.

So what’s next?

You tell me – I mean it. I am going to continue fine tuning the work to date with our council group and most importantly try and create the £ sign for all of this.

My next installment will be the one that tells us if we have an interesting project or something that will force some widespread change.

If you would like to see / hear more about this work or can help me make it better, let me know.

I have just returned from a Peer Challenge at a really good council in the North of England. The myriad of interviews, document reading, tours and presentations that inform the review gave me the opportunity to assess, first hand, how relevant PAS services are. And I am going to slap PAS on the back and say well done. So, if you can’t bear self- congratulatory spiel look away now, if however you are interested in how PAS can help councils with some real examples, swallow hard and keep reading.

Heads of Planning are BUMs

That’s Business Unit Managers. When asked ‘what takes up your working day’? The Head of   Planning responded: HR stuff, restructuring, workflow analysis, fees preparation, benchmarking, meeting with the accountant, rarely any case work. They’re managing a business. The daily work involves asking; What work is coming in? What resources do I have to deal with it? How much does it really cost? How do I measure success? Can we do it better?

Service managers are increasingly finding themselves in a position where they are told to save £x and are left to figure out how best to do it. Often, the most natural response to this is a headcount review. This can take large chunks of cost out of a service, but is a bit of a blunt instrument and, (in my opinion) should either be a last resort, or otherwise only (and always) be one aspect of a considered and well-evidenced range of cost saving considerations.

Through the PAS benchmarking club and improvement support offer, service managers are not abandoned to do this thinking on their own. We can help create the data to support decision-making by helping councils establish the costs of individual aspects of their service. Using evidence, supplemented by workflow data, councils can properly consider how well they are using resources and evaluate the different options for how they deliver the service.

Core Strategies 

There is no doubt about the pressing need to get your core strategy in place. The Government are saying it, and my colleagues and have done a much better job of explaining why it’s important so I am not going to bang that drum. These messages have not gone unnoticed in my peer challenge council, and the service is under (healthy) pressure from their leadership to deliver and quickly. They are putting a really great Core Strategy together, and have set themselves an ambitious publication schedule. They are doing everything right but they could use some help on key resource intensive aspects e.g. evidence base, to give them that added confidence around their timetable. Add in a bit of peer support to cast a critical but friendly eye over the thing at key stages and things start to feel a little more comfortable. Once again PAS plan making direct support is a fantastic and timely offer to them.

Infrastructure planning / CIL – pulling it all together when time is tight

My peer challenge council is facing many tensions around the provision of infrastructure. A major challenge for them is how to bring forward a regionally significant, infrastructure-sparse, edge-of-town site, while remaining loyal to a firm policy-backed committment to town centre regeneration (and the significant investment required in existing and new infrastructure to attract development in).

These tensions have magnified for them the importance of getting the Infrastructure Delivery Plan (IDP) and preparation for the Community Infrastructure Levy (CIL), right. What can happen at a time of reduced resources and a tight policy production timetable, is that some aspects of policy productions fall behind the pace. I have no doubt that this place will really benefit from our CIL work which means with time and resources tight, they won’t have to start thinking about CIL from scratch.

Councillors, neighbourhoods, localism

My recent experience has also confirmed to me the value of PAS support for councillors. The community leadership role is crystallizing around neighbourhood planning and demands on the service by residents such as enforcement are providing the challenge. For my subject council, add to this a planning committee that is finding its structure challenged by the evolving nature and volume of the applications it handles, and you have an opportunity to identify some clear areas for support.

While there is a place for the ‘what’s it all about’ / ‘introduction to’ types of training and support, we are slowly moving into the ‘how do I react to this and manage expectations’? scenarios for councillors. What does ‘taking a hardline on enforcement’ actually mean? Unless you understand a bit about how enforcement operates, its powers and limitations, how are you going to manage community expectations? And then what do you do when approached about neighbourhood planning? Councillors need to be confident about their role in the delivery of planning in their places, and more than ever, they need the benefit of their peers’ experience.

The PAS delivery approach to councillor skills and training (independently produced, well researched material, leadership academy sessions and access to experienced and empathetic councillor peers) can make the difference when trying to engage councillors. Mix in a little planning reform know-how and you have a powerful councillor support offer.

Challenging yourself in challenging times

I’ll end where I began – Peer Challenge. If your service is too stretched, beleaguered or busy to consider one, then you could probably benefit from one.

I have a lot of time for councils that have the foresight to invest in challenging themselves precisely at the moment when many would batten down the hatches and just ride the storm. The council I have just visited have restructured, are in the middle of working out how best to deliver the service and still have a core strategy to deliver. But they have, through the peer challenge process, demonstrated to staff that they are interested in making change work, and that they are interested in what staff have to say about and contribute to it.

I am a bit happier about what we do. It won’t change the fact that every time I spend any significant period with real people (local government planners) it scares my how detached I can become in very short periods of time. But just for now I am quietly confident that PAS is involved in the right things.

It means moving beyond the old battle lines; lazy developers sending in poor applications so that the planners will ‘sort it out’ (for free). Moving beyond the crazy validation schemes, inconsistency and non-value adding processes that tie us all up in knots.  We’re not rewarded for how quick we are any more so let’s also stop this myopic obsession with speed. Customers are more interested in ‘can-I-do-it?’ certainty than a quick turn around.

We’re all responsible. Here are a few things to think about:

Councils

If we all agree that our customers are our (shared) priority, let’s listen to them. Any service guru will tell you that customer feedback, especially the bad kind, is your greatest weapon… if you listen to and act upon it. Our recent benchmarking work included a customer survey which told us a few of the ways that planning authorities upset their customers. Here are the things customers are telling councils. By addressing them, you will improve your customer satisfaction ratings overnight (this stuff is free – take it):

•  Can planners please answer their phones?
•  Can you remove that call centre thing; it doesn’t work?
•  When the planners answer the phone can they tell me a consistent story?
•  Once they’ve answered the phone and told me a consistent story, can they keep my application moving through the process?
•  Can someone explain what benefit I got from that pre-application discussion?
• Is there a reason you slap all these conditions on me?

What? No process re-engineering, out-sourcing, change management? No. Just treat your customers well, do your job, and take a sensible, proportionate approach to things.

Developers/Agents

Fact – many, many agents get decisions quickly and consistently. But many don’t. There is nothing to tell a prospective end customer where on the spectrum of certainty / speed of decision their choice of agent sits. I am not aware of any research that tells me what makes a good agent, but I suspect the secrets of how to be good are just as simple/obvious as the ones above that show where and why councils upset their customers.

In the absence of research, it makes sense instead, to let the facts speak for themselves. We are working with councils to look at how to encourage better applications from agents. And, before you ask, no – I am not referring to an accredited agent’s scheme – these may serve a purpose somewhere, but need resources to set up and manage, criteria for accreditation agreed, and what do you do when a customer isn’t happy with one of ‘your’ accredited agents?

No, I prefer an idea that some council’s are thinking of trying that involves publishing information on how quickly agent’s get decisions and their success rate (link to previous blog). The publishing of real data like this would act as an incentive among agent’s to want to improve their ‘performance’. To my mind it’s a cheap, quick and non-judgmental approach, and allows the applicant to make an objective decision on which agent they use.

PAS (we accept our part too)

I recently published a blog on how PAS are helping councils improve all aspects of their service delivery. Our most recent round of benchmarking has necessarily focused on planning fees, but it never was just about that. I have, from the beginning said (and still maintain) that fee setting is the easy bit – wait until you’re customers start questioning your commitment to providing value for money, keeping prices as low as possible and doing the things that make them happy.  So, we are working with a few councils to test out a model of service improvement that will help councils become more comfortable and confident about making decisions about how to improve and deliver the service.

This work focuses on:

• Benchmark data and performance metrics – focussing on what matters
• Considering alternative service delivery models
• Improvement planning – actions for change

You can’t plan to improve, change or innovate without considering all of the options available to you. Nor can you properly consider the different options of delivery unless you fully understand your present operation. Our aim is to equip the decision makers in planning departments with all of the information and data they need to be confident about making decisions, whether that be about choosing to change or a sound case for standing still.

So, some things for us all to think about. The danger of setting them all out like this is that we see them all as exclusive, when the reality is that they all work together to improve the customer experience.  

The key things I have learnt are:
– there is no one way to ‘DO’ CIL
– don’t make it too complicated
– select robust, costed, infrastructure projects as indicative evidence, and make sure there is a significant aggregate funding gap as your CIL target.
– the CIL rate will be determined by viability, but not dictated by viability; you do have choices

It might not feel like it now but setting the CIL will be the easy bit.

You need to set up the obvious administrative processes for collection, monitoring, auditing and enforcing CIL. Involve colleagues in other departments e.g. finance and legal. Will you need to change the planning system software, and will Finance have to change theirs?

What policies will you adopt for charities, and for exemptions?

What will you use CIL for and what will you use S106 for?

One of the most important things you need to do is set up the governance arrangements for CIL. I would strongly suggest that you do this before you are discussing £2 million in CIL money that has just come in. The new ‘pet’ project might be the happy recipient of the money rather than the boring but essential sewerage work extension or road junction improvement.

As planning officers, you should know your plan and you should also have a good idea of the infrastructure priorities for delivery for each of the sites that are coming forward in your plan. You should be able to say: What is essential for work to start on site? What is necessary to: mitigate, and for place making,
ensuring that existing community facilities are not overstretched? What are the nice to haves?

Take a report to Members, at the earliest opportunity, outlining proposed governance arrangements for CIL that will facilitate the delivery of their plan. Officers need to identify to Members the prioritisation of infrastructure to allow delivery and put in place the mechanisms to work with other delivery bodies such as County councils, parishes, utilities, and neighbouring authorities. Members may not agree with your prioritisation but through this process the Council’s priorities will be determined. For Members (and officers) in many authorities the idea of passing money to a different authority or body will be entirely alien and unwelcome.

As a charging authority, you are now in the driving seat for delivery. Where the developer sorted out the project planning and much of the necessary infrastructure delivery before CIL, the developer may be looking at you asking when you will have delivered the infrastructure necessary for them to get on site. The delivery of your plan and your vision will be down to you. The realisation of the change potentially created by CIL in terms of responsibility for delivery is a shock to many authorities. This realisation will no doubt require new skills not just from planners in authorities but also from other management team members – how bold and/or creative are your finance people? If the infrastructure needs to be delivered before the developer gets on site – do you have forward funding mechanisms?

As part of the governance of CIL, consider early what your mechanism for deciding what you collect CIL for and what will be s106 (or s278 of Highways Act). The choices you make may be based on delivery and/or the viability across your area and your approach to differentiation of your CIL rate.

Your ability to deliver supporting infrastructure may become a matter of reputation for the Council.

There are a lot of questions that you need to address, do that now as part of the CIL setting rather than when you have a cheque for £2 million to spend.

A lot has already been written and said about it. From my perspective some of the fogginess is around

•  the balance between the three pillars of economy, social and environmental considerations; although the government maintains that all are equally important and it isn’t all about the economy and growth, other government statements and the NPPF taken as a whole along with the last budget and the Plan for Growth, make it easy to conclude otherwise.
•  how the presumption fits with the legal requirements from the planning Act for a presumption in favour of the plan and consideration of other material considerations
• how, in the absence of an adopted plan, you can apply the NPPF policies either when taken as a whole or individually, to minor and other developments.  Will you really have to demonstrate that an inappropriate roof extension, for example, undermines national policy?

But thinking about the practicalities, and adopting a ‘let’s get ready’ rather than a ‘let’s wait and see’ approach, how might you start preparing for what may – or may not if you listen to some  – be a change to how you make decisions and define what sustainable development means for you. Bearing in mind, of course, that the current NPPF is a draft not a final document.

Para63 of the draft says ……“In assessing and determining development proposals, local planning authorities should apply the presumption in favour of sustainable development.” But how is this defined, or applied, at a local level?

Look to para 4 ‘Taken together, these policies articulate the Government’s vision of sustainable development, which should be interpreted and applied locally to meet local aspirations’ (my emphasis).

This has to be done locally – a development may be sustainable in a regeneration area that wouldn’t be so in a National Park. So your approach does need to be set out locally – but a lot of this will already have been done in the sustainability appraisal work either done or going on or perhaps through other corporate work.

In an ideal world, you would have an adopted plan which is clear about your approach to sustainable development (let’s set aside the issue of conformity with the NPPF for a moment and assume that it is). This is where you would set out how you’ve interpreted and applied the Government’s NPPF vision for sustainable development locally. But we know that many areas aren’t likely to have a plan in place by the time the NPPF is published and the presumption kicks in. What could you do as a way of articulating your position as of now to give some guidance to the community and developers of your priorities for sustainable development?

These are just some thoughts, not  tried or tested recommendations.

Starting with your evidence base – you are probably already thinking about what is still relevant (I prefer that term to ‘up to date’; some evidence could have been done a few years ago but probably won’t have changed). Other evidence will need reviewing if the recession has had an impact on it. Even without a plan and with the presumption, your evidence is a material consideration relevant to decision making.

Secondly – what about making an explicit statement, which sets out your priorities for sustainable development for your place. This work will already have been done, or underway, in the SA and any statement would draw from that.

Finally, what about a statement (or whisper it), an SPD which sets out how you are going to look forward and implement policies to achieve your sustainable objectives. Of course getting the plan in place would be better, but if that isn’t going to happen quickly, would a statement outlining your approach help give some guidance and certainty to developers?

Would that work…………….wave that nobody knows flag now.

Your core strategy IS your local plan.

A local plan is not a single document. It is where you set out all your policies. You have several tools to deliver this. You have your ‘overarching, strategic plan’, your ‘other DPDs’, your ‘neighbourhood plans’. Sound familiar? It should!

Do you remember when you last felt confident, bold, innovative or inspired? We should stop being fearful of changes made at the centre. I understand that we are all nervous when change comes in. However, say this quietly, these reforms aren’t as radical as has been trumpeted.

This is still a plan-led system, and plans should be evidence-led. That evidence starts with the vision and objectives you are trying to achieve. You understand where these have come from because your communities have told you. There is empirical evidence which tells those communities that there are some issues that will have to be tackled head-on by the plan. There is then a conversation between you and your communities, including key people who hold other information that you need, and who own sites you are going to have to look at.

You develop policies that will help deliver the aspirations, the needs and demands of the place. You refine them through conversations with the community and you produce a plan which will deliver the change needed to meet the vision for the place.

Today, this is called a ‘Core Strategy’. Some time next year, it will be called a ‘Local Plan’. Call it ‘Brian’. Call it whatever you like. Just make sure it has been prepared with the involvement of the community, using evidence they understand, and containing policies you are certain will turn the place you are planning into the place that everyone wants to see.

I also hear a general concern about what is not in the NPPF which was in the old suite of PPS or even the RS. Here’s where you need to be innovative, even bold. If it’s important to you, grab it and use it. Don’t get side-tracked by it. Make a statement that you intend to adopt it locally, then keep on track with the core strategy. The policies in the PPS and RS are still extant now. You’re not introducing anything new. What’s to stop you? Actually, I suspect you may want to take legal advice on this point, but don’t start by thinking you can’t.

This is my other main point. We are all used to being constrained by regulations. When the Government says ‘it’s up to you’, they mean it. Think about the easiest, most logical way to bring national and regional policies into your local plan, and then…..do it!

So, please, please, don’t get side-tracked by new language. Underneath it all, good planning is still good planning. Yes, there are things you have to do. Yes, some of these are ever so slightly different from now. If you’re still not convinced, come and talk to anyone at PAS. There’s plenty of stuff we can help you with, and all at no cost to the authority.