How should we plan for a better environment?

This is a question that’s been rattling around in my head for quite a long time – at least as long ago as 2018 when Defra launched its 25 Year Environment Plan (25YEP). Since then, a lot has happened, at a national and local level.

Nationally, as a result of the Environment Act, biodiversity net gain (BNG) is going to be mandatory in 8 months’ time. We are expecting 50 or so Responsible Authorities to be appointed by the Secretary of State to begin work on developing Local Nature Recovery Strategies (LNRS) officially next month, and local authorities have an enhanced duty to report on biodiversity. We have had the LURB, which will introduce planning reforms including Environmental Outcome Reports and mandatory Design Codes. Natural England has launched a new Green and Blue Infrastructure Framework and I, of course, am very mindful that we have 74 local authorities affected by nutrient neutrality. I could go on.

I often use the jigsaw analogy when talking about environmental planning. Another piece of the jigsaw arrived recently in the form of Defra’s Environmental Improvement Plan (EIP23), which provides a welcome degree of coherence to the Government’s ambitions on the environment.

Locally, since at least 2019, most councils and combined authorities have declared climate and/or ecological emergencies. Alongside the lessons from the Covid pandemic, this has had a transformative effect in the way that local leaders consider the challenges and opportunities of the environment agenda and it has driven a significant shift towards a more corporate and partnership-led approach. In turn, this has put a spotlight on place-making and the role of planning as an important vehicle for change.

So recent opportunities to have joined-up conversations with local authority planners, Defra and DLUHC, including at our Heads of Planning Conference, about how we should plan for a better environment have been very welcome and timely. 

But what have I learned and are we any closer to having a fully integrated set of environmental outcomes for planning?

It is evident that planners see a lot of complexity and uncertainty, which brings significant opportunities as well as challenges. Overall there is a tremendous amount of enthusiasm and positivity but a strong message that planning can’t do everything. I really like the way Rich Cooke at Essex talks about this – the need for planners to work with and through others to deliver outcomes.

I think there are 3 take-home messages from our recent engagement with local authority planners:

  1. the importance of leadership – to ensure that the environment is central to policy and decision making
  2. the need for land use to be multi-functional and deliver multiple benefits – how do we ensure enough land in the right place to provide food and energy security, housing, economic growth and meet the challenges of climate change and biodiversity loss?
  3. the need to develop more innovative ways of coordinating and targeting funding and investment in people and projects to make change happen.

So back to my starting point. How do we do this?

Well, it isn’t one thing – it’s a collection of things involving 5 principles of good planning – leadership, policy, evidence, decision-making, and delivery.

Since the 25YEP was published, I’ve followed the trajectory of the natural capital concept and the idea of being able to measure environmental net gain, following the introduction of BNG. I like the concept of Natural Capital because it offers a broad framework for thinking about the environment and the benefits that nature provides. I like it because it introduces the idea of quantifying the value of nature which can help to inform land use policy and decision making about what we need, where and why. And I like it because it is understood by both the business and environment sectors, and therefore offers a common language for politicians, planners, developers, and communities. In other words, natural capital supports those 5 principles of good planning.

Many local authorities have initiated natural capital assessments, some have gone further and published natural capital investment plans, and others have started to model the data to inform development schemes, working with willing developers. However, from talking to planners and reviewing Local Plans, it is evident that natural capital is some way off becoming mainstreamed in planning. It is there, as part of the policy narrative, drawing on paras. 174 & 175 of the NPPF, but we seem to lack the means to implement it in a meaningful way, at least, that’s how I see it. Planners tell me that there is an inconsistent level of understanding of natural capital in a planning context and the lack of tools and strong policy context means that green and blue infrastructure is often the default policy framework for enhancing the provision of the benefits from nature.

The consensus is that whilst natural capital is useful as part of an evidence base, we need to learn how to use it and apply it in practice, so that it becomes more mainstream.

I’m optimistic that natural capital and environmental net gain will have their day. Planners are already thinking about natural capital benefits in the context of BNG and LNRS, and I know of one planning authority (Bedford) blazing a trail for environmental net gain with a policy requirement (DM7) for major development in the submission version of their Local Plan (currently in examination so watch this space!). There will surely be others I don’t know about.

The last few months spent talking to planners about this has taught me one big lesson – Government provides the framework but the really good stuff happens at the local level. Planners continue to push the boundaries and we all need to learn from and share with each other.

So, as a starter for ten, we’ll be sharing some information on our website summarising our conversations with planners, and a snapshot of what we think the different bits of the jigsaw are. If you have ideas and experience of natural capital and planning for the environment that you would like to share, we’d love to hear from you.

Returning to the start again, I don’t know if natural capital is the ‘one ring to bind them all’ (sorry for mixing my metaphors) but my instinct is that it is an important piece of the jigsaw that will help us deliver a fully integrated set of environmental outcomes for planning.

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Harder Better Stronger Tougher BNGer

Back in November 2022 we held a couple of workshops for some volunteers from our BNG network. They were quite small events that Defra had asked us to arrange to road-test some guidance they are making to support the new “strengthened” version of a duty to report on the actions local authorities are taking to conserve and enhance biodiversity. You can see the deck we used on the main site. I recommend the timetable on slide 10 to get some sense of the changes required, and the survey results towards the end of it if you want to spoil the surprise of this post.

Some of what I go on to write will inevitably get a bit whingey, so let me start by being very clear that I think this sort of informal testing and engagement is truly EXCELLENT. Well done Defra. Working with the people who do the work can make policy and guidance more robust and pragmatic. We have established networks of clever and experienced people (BNG, NSIP and CIL are three we have set up in the last year) and they are very generous with their brains and thoughts. More, please. We don’t bite.

The “weak” duty

To recap slightly, there has been a duty for public bodies to consider biodiversity for many years, but it wasn’t particularly effective. The House of Lords select committee in 2017 does a great job at setting out the problem, and leads to the conclusion that the duty (in something we call the NERC Act) was weak because it lacked a reporting mechanism.

This missing reporting mechanism was therefore addressed in section 103 of the epic Environment Act 2021. This requires Local Authorities to regularly publish what they have been up to, and extends the duty to include how biodiversity net gain is working.

So, problem fixed? We roadtested the guidance contents and template in the workshops to see what our network thought. Whilst we were focused on seeing if the guidance was helpful, inevitably we spent some time talking about how the whole duty might work out in the real world. I thought the headlines worth sharing more widely. This is quite new to me, so any errors and misunderstandings are mine to own.

Resources and Capacity

Let’s get this one out of the way. It wouldn’t be a local government event if we didn’t talk about the difficulty of introducing change, especially change that

  • relies on a very rare resource (ecologists in this case) that local government has to compete with consultancies to employ
  • seems to be unfunded [edit: there is a big pot of money to prepare for BNG, so perhaps some of it is also for reporting, enforcement and the rest of it?]
  • is landing in stressed organisations where there are already lots of other things on the corporate radars

Who reports?

The Act says (confusingly) that the Act applies to Local Authorities and Local Planning Authorities. But Local Government can be a complicated animal. In places where there is an obvious lead  unitary authority (probably also a responsible body for LNRS) the exercise should be straightforward. But big chunks of the country have several tiers of local government. Are County councils supposed to collate this on behalf of districts? Should all the districts do their own reporting to ensure local buy-in and political oversight? What about MCAs?

These sound like nit-picky points but they mean you can’t be sure that the duty to report is being applied everywhere. Imagine a map that gets coloured in when a report is published. There might be gaps in the map. Or the map might be coloured in twice. Or 3 or 4 times if there is an AONB or protected site strategy also reporting on biodiversity. It’s not just a compliance problem – things (interventions, results) might be double-counted, or triple counted. Messy.

Where to put the reports?

Where should the reports live? I know from bitter experience that trying to find reports on council web pages is grim. Our audience wanted some way of finding them, partly at this early stage so they could follow the noble Planner’s tradition of copying each others work. Publishing them all together in one place was one idea.

You can see from north of the border that it is not easy to run this kind of library, and any suggestion that we in PAS were to have some kind of role here is one tried to ignore.

I don’t know how much of a problem this will be for members of the public and other stakeholders. I’d imagine if you are a local you might not worry too much about the minute or two it might take you to find the report on your own council’s website – but if you want to compare and contrast or keep an eye on all the councils trying to improve some particular  class of habitat it could get boring really fast.

We also had a useful segue into how BNG registers might work, and how it will be a challenge to knit together the various data stores for onsite, offsite and national projects. This difficulty is going to be compounded if registers are kept by lots of different organisations some of whom might not last forever or have a great deal of interest beyond their own boundary.

It may be that the LNRS process might be the driver for some collaboration more generally, and that the duty data will be integrated with other organisational reports. But it would be nice to give some pushes in the right direction.

What to report?

The idea of a template was warmly welcomed. Common structures and approaches make for easier reporting and improve read-across and compatibility.

However the idea that there wouldn’t be any numbers (even voluntary numbers) baffled people. Many of the national targets (subsequently published in the EIP) can only be understood in numerical terms, so why not take the opportunity to hoover them up from local authorities? In fact there was a genuine gap between the LPAs, who wanted this to be based on facts and evidence expressed as numbers, and Defra who didn’t see that as important.

There is an unhelpful difference between the thinking behind this NERC reporting duty with where we are heading in the “digital planning” arena. The NERC duty is still in the “lets put a narratives in a pdf”, and the wider world of planning is thinking about machine-readable data in discoverable containers.

Why report?

This for me was the question we didn’t spend enough time on. In short I think there are probably two views:

  • Local Authorities have to report because they have to comply with the duty. This is a compliance thing. 
  • Making big organisations think about their potential to positively and negatively influence the environment and then doing something about it is big & difficult and we can learn from each other what works. This is a learning thing. 

Unfortunately I think the first view tends to crowd out the second. I don’t do “cross” in public so I’ll say no more.

It might be “stronger” but is it going to be a “better” duty?

Clearly only time will tell but my audience thought that it would not. Against which, I suppose, it is worth remembering the very low base we start from. This new model might not be perfect, but it represents a step on the way. Better perhaps to begin rather than waiting for perfection. 

Merely having anything to report – perhaps even something that requires clearance from cabinet might improve political visibility and traction. It might work well for those councils who have declared a biodiversity emergency to have a vehicle to explain what they are doing about it. It might also be a good way of playing to the council strength of convening partnerships and encouraging organisations to do the right thing by showcasing action in a public document.

It is also true that mandatory “must dos” can be quite helpful for officers in cash-strapped organisations where anything that isn’t statutory is unlikely to survive member scrutiny.

Lastly there was definitely a sense that while we might whinge about some of the implementation details, there was an enormous appetite to genuinely improve how councils work to improve nature. Better understanding, and better reporting, and avoiding greenwash are all things our audience was very keen to do. The reporting duty appears to be in force since January, and we’re still waiting for guidance and forms. Perhaps there’s hope that it will have picked up some of these helpful points from our group.

Modern local plans

For various reasons we’ve been doing some more thinking about digital local plans. I last wrote about them 18 months ago and I’m not entirely sure what’s happened since. In some ways there have been lots of exciting alphas and betas, and probably several months’-worth of show-and-tells. But in other ways, to be totally honest, I don’t know that I’m much further forwards in my own understanding of what they really are.

However, by happy chance, last week I went on a two day training course that I’d put my name in the hat for many months ago [side bar: it was good and you should go even if you think you know all this stuff inside out]. The course was called digital and agile for local government, which I worried would be a slightly paternalistic push for stuffy old councils to get on board the digital groove train. Instead it was an opportunity to think about what all this stuff means from first principles in the comparative calm and clarity of two days away from work.

Where I think have got to is that we should stop talking about digital local plans. The term is too loaded – to the point where I think it is unhelpful. I will try to explain, and to persuade you that there is a better way of approaching a better version of the local plan system.

Reminder: what is digital?

Let’s begin with a recap then, from first principles. What is “digital”? and what might a “digital local plan” be therefore?

I think an obvious and helpful place for us to start is the local digital declaration. Five years ago it established a set of commitments, ambitions and principles. It is worth reading properly (and going on a course to reflect on) but the principles are

  • Service redesign around user need
  • Using modular technology and open standards
  • Sharing information safely
  • Leadership of organisational change
  • Working in the open and sharing good practice

This is all good stuff, and we can probably add a bit of arm-waving about the changing power relationship between the citizen and service providers, and how organisations operate and innovate in the internet age. Plus (for councils) the caution of digital exclusion.

And the reason my course was called digital and agile is that digital principles (and change) are often partnered with agile working practices. Out with boring old waterfall project management, and in with nimble and iterative value generation.

So, what is a digital local plan?

Well, having had a good look around the internet I think it’s fairly easy to explain what digital local plans are not. They are not

  • Published as pdfs
  • only readable by humans
  • Documents with “baked in” data and maps as rasters

It is much more difficult to say positively what they are. The planning for the future white paper twice places them in sentences with positive adjectives, but I’m not sure much is revealed about the substance of what makes them new:

The new-style digital Local Plan would also help local planning authorities to engage with strategic cross-boundary issues and use data-driven insights to assess local infrastructure needs to help decide what infrastructure is needed and where it should be located. [..]

Reform should be accompanied by a significant enhancement in digital and geospatial capability and capacity across the planning sector to support high-quality new digital Local Plans and digitally enabled decision-making. 

Planning for the future white paper consultation 2020

There are also lots of examples of people sprinkling other related words and concepts, each of them fine in their own way but taken together make it almost impossible to know how or where to start. The language of user needs combine with agile processes and improvements in technology and accessibility. It sounds great so why are plans still slow, expensive and difficult?

This was my revelation. A Local Plans IS NOT A SERVICE, so the language and culture of digital promotes lots of distracting but plausible concepts and methods to confuse us all. [clearly PLANNING APPLICATIONS ARE TOTALLY A SERVICE but let’s get to that elsewhere]. A local plan is the bunch of policies you need to deliver services against. More certain (and more rule-based) policy = more digitally enabled consenting service.

So, talking about digital local plans encourages confusion. Lots of well-meaning but misapplied models. A mismatch between agile (where responsiveness is prized) to local plan policies (where stability is prized). So what should we be talking about?

Modern local plans

Modern local plans will share some qualities. They will not all look and feel the same, for the obvious reason that places are very different. This bears repeating. Some places have coastlines, others have mountains. Setting out to make local plans consistent is wrong. Go and look at Southend, then look at Hereford. However that is not to say they should all be unique – planning has a long and noble history of copying and pasting, and that should not stop now.

In no particular order here are some qualities of modern local plans – if you like this is how I would organise and challenge a plan to see if it is “modern” and fit for purpose. To make it easier to use and explain I have divided it across 3 dimensions:

Currency (what does up to date mean?)

  • Plans must be based on the 2023 NPPF
  • They must mesh with National DM Policies
  • Plans cannot ever be more than 5 years old without a genuine review
  • Between reviews the plan should be stable and unchanging (or go through well understood phases of waxing and waning versions)

Utility (how does it work?)

  • Data and measures should reflect standards and be spatial where necessary
  • Spatial policies should be made available in response to a query – eg “which policies apply at this point?”
  • Policies should be made available in response to a query – eg “what is policy XYZ?”
  • Policies should where possible be expressed in measurable ways and reflect how they might be best monitored – they should be designed with a feedback loop in mind

Accessibility: (Will people be interested in it?)

  • Plans should address both technical and non-technical audiences.
  • Plans should explain what they are trying to achieve, and the choices that flow from the strategy
  • Where appropriate plans should use maps, diagrams and pictures to show what they mean
  • Where appropriate plans should link wider themes to the specifics of places
  • The success of a plan should be reviewed routinely and reported publicly

Onwards

I love lots of what “digital” gets us. I love lots of the mindset and some of the tools and methods when correctly applied. But it’s time to stop talking about “digital local plans” as if that means something in particular, and explain in simple language what a modern local plan should be, do, and look like. In my amateurish way I have started a list of what I think they are, and hopefully in another 18 months we will have some real examples to see how far away I was.

Standard Method ‘advisory’: what’s exceptional about that?

A planning journalist has asked for my views on the proposal in the planning reforms/NPPF consultation that the Standard Method-derived housing number becomes ‘advisory’ only. Do I think it will mean councils will plan for fewer homes?

For me the ‘advisory’ thing is not that significant a change. The important change here is what follows later in the paragraph – the extent to which it will be easier/clearer for councils to calculate a housing need number using an alternative approach.

The important change here… is the extent to which it will be easier/clearer for councils to calculate a housing need number using an alternative approach”.

Many councils are already considering alternatives to the Standard Method. My colleague Rachael Ferry-Jones and I have been advising councils considering it. We’ve found that one of the issues is understanding the difference between housing ‘need’ and ‘requirement’. The terms are often incorrectly used interchangeably (including by myself). Below I have set out some thoughts based on the discussions we’re having with councils and weaved into this my thoughts on the NPPF consultation.

The basics aren’t changing

I think it’s helpful to start with what isn’t changing – the way that housing numbers in plans are arrived at. The indicative changes to the NPPF wording in Para 61 include additional wording that states that the ‘outcome of the standard method is an advisory starting-point mphasis).

Planning Practice Guidance (PPG)  currently says: ‘Authorities should use the standard method as the starting point when preparing the housing requirement in their plan’. In my view not a lot has changed; the word ‘should’ in the PPG is there in the sense that it is the recommended (but not the only) approach. The word ‘advisory’ is being used similarly to indicate that (as has ever been thus) that this number is not necessarily the number you have to plan for.

The number you have to plan for is the housing ‘requirement’ – the number that you end up with having taken the ‘need’ figure and considered the effect of constraints etc. before reaching the final figure.

We’ve been using this when we talk to councils:

Exceptional Circumstances to become ‘Local Characteristics’(?)

Hence, to my mind, the most significant change is not so much the Standard Method-derived number becoming ‘advisory’. It is how ‘exceptional circumstances’ (to justify using an alternative approach) will be re-cast that is of most significance. At the moment ‘exceptional circumstances’ aren’t defined, and from the advice to councils that I have seen, they face an almost impossible task to justify/establish that circumstances exist exclusively to/in a single place.

The NPPF proposed wording also says: ‘… also propose to give more explicit indications in planning guidance of the types of local characteristics which may justify the use of an alternative method, such as islands with a high percentage of elderly residents, or university towns with an above-average proportion of students’.

It appears that the term ‘exceptional circumstances’ is going to be dropped in favour of ‘local or (‘particular’) characteristics’. The students thing alone opens this up considerably for many places. The ‘more explicit indications’ could create a clearer route for councils to decide whether they are in a position to use their own approach to calculating housing need.

Yes this number may be lower than that derived from the Standard Method, but it isn’t guaranteed, and still needs to be agreed – how low is low enough?

Yes, an alternative approach may yield a number lower than that derived from the Standard Method, but it still a starting point and isn’t guaranteed to be lower. The number still needs to be agreed – how low is low enough? It still needs to be deliverable. And whatever method is eventually used it needs to be evidence based, reflecting current and future demographic trends and market signals and, for now, don’t forget the ‘unmet needs’ of neighbouring areas.

The planning department of 2025

I’ve been doing some thinking about the future of late. Partly because we are doing some gentle limbering up as we think about what the next set of planning reforms means for PAS, but partly because lots of recent discussions tend to end up heading in the same direction. This post is not much more than thinking out loud to see if anyone else has got better ideas or thoughts to contribute.

Working culture

One of the recurring conversations at the PAS conference was capacity and the competition for talent. It is really easy to lose people for a few more £ per hour or a better work environment. Managers find this churn unhelpful, but I wonder if this competition could be healthy – it might present an opportunity to reset what I have often described as the “macho-bullshit-long-hours DM culture”. When I first stepped foot in a planning department almost 20 years ago I was shocked at how often people worked long hours and right up to the deadline of planning applications.

It felt a bit weird, with heroic and last minute interventions seemingly required most days. It became a bit clearer when, in a different planning department, I can remember suggesting that giving new starters a caseload of 50 open cases might not be the way of getting the best out of people. I was quickly knocked back with a curt “this is how we all learned and this lot will have to learn the same way”.

In compensation for this tough workload in the DM office, good teams had a mutual appreciation for the work being done and the difficult circumstances it was done in. They had each others backs, could see the effort and had someone to talk to for a second opinion. People struggling would be noticed, and people ready to take more on could overhear useful conversations and look keen when volunteers might be needed.

These days good managers know that expecting people to carry on the same working practices but from home, without the compensating camaraderie is going to count against them in the competition for talent. And they know that simply mandating a wholesale return to the office isn’t going to work either. This culture question is not easy, and it won’t fix itself.

And what about customers? and digital engagement?

In a discussion that was meant to be about something else recently I had a tangential conversation about customer’s experience of planning services. As I feared, their perception is that remote working is further driving a wedge between customers and planning officers. Telephone calls are being replaced by emails and what we once used to call the “development team approach” is being done via async notes and the occasional teams call.

It reminds me of the findings of the customer survey work we did all the way back in 2015 (long since vanished from the internet, so you’ll have to take it on trust). We asked a 1000 recent customers about their experience, and asked them to choose from a pre-populated list of attributes the ones that mattered the most. The results were pretty plain (this text is lifted from the report of the time):

“Looking at the highest ranked attributes gives us the following two main messages:

1. Users want planners to help them avoid the time and cost of resubmission:

  • The opportunity to amend a planning application is the most desired planning service attribute.
  • This is mostly about achieving a positive outcome without the need for the additional time and cost inherent through resubmission, but can also sometimes be due to changing customer requirements.
  • Resubmission is usually a costly process for the local authority too as a new application will require the most of the processing cost of a first application but often without the accompanying fee.

2. Users want planning services that are designed around person to person contact:

  • Customers want to be able to talk to a planning officer to get planning advice. Such a service is rated much more highly than online guidance. As one customer put it: ‘Ability to talk to a duty officer before submission can be vital on some schemes. It would save time and cost to the local authority, likewise time and cost to the client.’
  • Customers also highly rate access to their case officer. Many of those who gave a lower score also used the free text entry field to mention problems with communication: ‘case officer could not be contacted’, ‘officer reluctant to speak to me’, ‘total lack of communication’, ‘impossible to communicate’, ‘Case officer virtually impossible to get a hold of’.
  • Quick appointments for pre-application advice are considered less important but are not insignificant.”
PAS Benchmark summary – 2015

We also provided the opportunity for comments and suggestions. More from the report:

“Our survey also provided a section that allowed users to add any other comments about the service they received from the LPA. Some applicants went out of their way to praise helpful officers who had provided guidance and suggestions to deliver a positive result. However, almost all of this feedback from users can be boiled down to one issue: communication.

When taken in totality the feedback provides a moderately positive picture of planning services, however, there were some clear messages on where users would like to see improvement.

  • Improvement effort should focus on improving communication with service users and ‘customer care’ in general.
  • A target culture reduces user satisfaction and probably increases service cost to users and planning services too.
  • Channel shift and approaches borrowed from high-volume transactions, such as the use of call centres, do not work well with high value and comparatively rare interactions.”
PAS Benchmark summary 2015

So, what does all this mean for the planning department of 2025?

Well, I think some of this provides some uncomfortable but timely home truths to those of us tasked with preparing the way for a new, more digital planning system. Over the next few months I’m going to lead the conversations with clever people I am fortunate to have as a fairly routine part of my work towards some of these ideas:

A new working culture needs to be thoughtfully designed: making a “nice place to work” that can attract and keep hold of people is going to become almost a competitive advantage for planning services. It will need to find new ways to support people working in teams, to help them develop their skills and (at times) allow them to have fun. It won’t happen by accident – it will be deliberate and consultative.

Customers will want to work with humans: many planning applications are the first step of an investment that will come with risk. The survey data is very old now, but I’d be prepared to bet that at key points on the life cycle of a project through planning its promoters will want to be in a real room with the real team who are going to assess it. And (obvious point) the development team members won’t all be in the same room at the same time without a working culture that prioritises it.

Digital is necessary but not sufficient: I think most of the underpinning “bets” of the digital planning work are the right ones. Improving the way that planning uses evidence, and reducing the friction of routine data management are essential but by themselves they won’t be enough. Those of us quite long in the tooth now know how dangerous it is to hope that the new digital tools will somehow bring good working practices with them. They won’t.

Alongside working culture, workplaces have to play their part: One of own bugbears this. Prior to the pandemic we had “new ways of working” which was short-hand for “more people than desks”. I don’t know about you, but the “clear desk” policy means that workplaces feel quite boring and lots of the helpful cues (in the old days it would be the number of cases on the validation shelf) are absent. In designing my own workspace I am careful to keep my important work and priority tasks out in the open. Make the work visible again! make the team’s priorities impossible to ignore!

We run an occasional event we call the digital showcase. Unlike many others we try to avoid rushing through a series of “show & tell” type presentations and poke at emerging projects. If you want to be part of it come along – I am interested in hearing how we can turn the undoubted cleverness of people and projects into a more wholesale change for the sector.

Transitional Arrangements for Local Plans: Top Ten ‘asks’  

Since my last blog on transition, I’ve been surprised at how quiet things are on this topic. At the PAS conference (Wolverhampton, July 2022) I presented a few ideas and hypotheses about the transition from the present planning system to the new ‘Levelled Up’ one. These are set out below along with some feedback from the conference attendees.

Some movement starting…?

The recent letter from Greg Clarke urging PINS not to fail Local Plans over the Summer may signal that some announcement is afoot (the heralded NPPF prospectus?) in Autumn. And the announcement from Dorset that ‘having spoken to Government’ that they’ll be taking a further few years to adopt their plan and (most interestingly) that they have asked to be ‘part of a pilot for a new national approach to local plans’.  

Why is it quiet?
Parts of the Levelling Up & Regeneration Bill (LURB) are receiving lots of attention e.g. the new Infrastructure Levy or being PAS work-shopped (Environmental Outcome Reports). Other parts are slowly becoming embedded such as design codes and the (oh so slowly) creeping digital agenda. But its largely silent on how we move to a new system for making a local plan – the thing that is going to hold all of this together.

In May the then Minister Stuart Andrew encouraged us to ‘keep on planning’ and that  transitional arrangements were being worked on ‘at pace’. There was also some early conjecture about incentives to get your plan in place as soon as possible (e.g. that the 5-year housing land supply requirement may disappear for up-to-date plans).  

December 2023 – an incentive?

DLUHC seem to have stopped referring to this date, however I am working pretty much exclusively with councils going full steam ahead to get plans in place by Dec 2023. Over half the councils at our conference are as well. Greg Clarke’s recent letter to PINS may spell good news for these councils, especially those at examination right now. For these councils, the requirements of straddling 2 systems while plan making will be for others to grapple with. It is the councils that are about to start a review of their plans that are going to have to pick up the baton on transition soonest – they’ll be the front runners that will be learning how to plan in the new system.

The biggest change/challenge is the timetable

Take away all of the noise, the aspiration and the detail (where there is any) and the LURB system local plan and process looks pretty similar to what we currently have – policies, maps, 2 consultations, examination.

The big change is the expectation that the plan making timetable will be CUT IN HALF from an average 5 years to 30 months. Everything that LURB  is proposing on plan making will need to be condensed into at least half the time it currently takes. That is eye-watering. The ‘speeding up’ comes from 2 broad directions:

  • The mechanics – there are the new time-saving elements to factor in; front-loaded consultation, National Development Management Policies (NDMP’s), streamlined (proportionate?) evidence bases, mandating infrastructure providers to engage, Environmental Outcomes Reports (EORs to replace SA/SEA) – all good ideas to save time.
  • The process – the proposals for local plan commissioners, Gateways Reviews, a replaced Duty to Cooperate – again all good ideas on paper but how will they work to reduce time in the overall process?

There has to be enough time factored in to learn about, test and integrate these new and adapted processes into our plan making activity.  How can we avoid a standing start? Hopefully more detail on these individual ‘speeding up’ elements and how they will all work together will be available soon. Once the detail begins to emerge, we have to be prepared / make time available to learn and bed things down. Anyone that has been in the improvement game knows that introducing improved ways / systems of working often causes a system to slow down in the short-term. Room and time have to be allowed to allow the changes to take root and for the first positive effects to begin to show and the learning transferred.

Less burden has to be accompanied by less risk

While changing the mechanics and inputs to the process we must also keep an eye on the more structural (and cultural to some extent) aspects of plan making that will need to change/adapt to make a new system work.

I can see how we will over time reduce the burden on evidence base production via digitisation as the updating of evidence in future becomes more streamlined, however there will be a period of bedding down. To deliver a system that requires a shorter and less information-intensive approach (e.g. 50-page Environmental Outcome Reports replacing sustainability appraisals) and a more proportionate and streamlined evidence base, the plan examination system has to adapt with it. There should also be some built-in recognition of / protection from legal challenge; QC’s are expert at finding chinks and gaps in the masses of evidence that support plans currently – how will a radically reduced evidence base hold up to the same scrutiny?

Front-loaded consultation and digitisation are heralded as the panacea’s for greater and better community consultation, and I think this is a broadly correct assumption. It does have to be more than reaching wider audiences through technology and presenting our plans and ideas on maps and using 3-D imaging – there is a fundamental requirement to make planning simple to understand – e.g. nothing digital or map-based is going to explain to our communities in logical terms how we currently arrive at the housing numbers we’d like them to accept. We can and must get better at all of this and we have to also be prepared to resource, manage and integrate greater levels of engagement as communities do become more planning ‘savvy’ and want to get involved to support and challenge what we are proposing in our local plans. Levels of engagement are already rising as communities, especially in constrained, and more and more councils are struggling to resource ever-growing consultation responses.

Transition basics

Back to my conference story. For the sake of starting a conversation/argument I presented a few made-up hypotheses about what transition might look like in terms of timing. Here’s what I set out:

  • Hypothesis 1 – December 2023 – the drawbridge goes down on ‘current system’ – councils will have to have their plan submitted by December 2023 otherwise the plan has to be prepared and produced in the new system under transitional arrangements.
  • Hypothesis 2 – January 2024 New NPPF and Regulations are set with the requirements for new system local plans

In this world, councils will fall into 4 broad categories:

  1. New System Plans – those councils intending to wait and begin their plan making process after January 2024. The first plans will be in place from June 2026.
  2. Current world plans submitted on or before end December 2023 – Those that submit their plan to the December 2023 deadline and will arguably not have to think about starting the process of getting a new system plan in place before 2028.
  3. Current / New World transition – those councils starting to review their plans now will find themselves straddling the current and new system completely – it’s for these councils that the transitional arrangements need to be clear – not least to avoid wasted work.
  4. New Unitary councils – have 5 years to get a plan in place – will/how will the transitional arrangement affect them?
My timetabled hypothesis for when councils at different stages of plan making will deliver their first 30 month plan.

So what to do in the meantime?

I understand the reasons so many plans are stalling and why many are waiting for the new system. Why carry on if a new NPPF (prospectus?) is imminent? Why waste time, effort and cost? Then there is the hoped-for arrival of lower housing numbers. But is this really doing the best by our communities? The waiting game comes with risk as local plans and polices age and become vulnerable to speculative development and confuses communities as plans are ‘pulled’ to protect them from too much development (housing) and then housing sites are granted permission on appeal and in places not even allocated in the plan.

My view – keep going where you possibly can

I am asked constantly by councils for my advice on pressing ahead/slowing down/stopping. My (non) answer is always the same; I ask the following 3 very broad questions;

  1. Do you have clear evidence that delaying, slowing, stopping the local plan will benefit all of the communities your council represents?
  2. Have you fully weighed up and quantified the risks / uncertainties for your place that the absence of an up-to-date plan creates for your communities and investors?
  3. Do you have the backing of your communities / investors for your preferred course of action?

The reasons for stopping and delaying can be either very narrow; “housing numbers are going to change” or very broad; “it’s too uncertain right now”. The narrow arguments betray a  massive misunderstanding about what the local plan is there for and that housing, while important, is not the only thing we plan for. The broader argument just doesn’t hold water – the world we plan in is constantly uncertain, it is one of the fundamental reasons we make plans in the first place.  

Plans will always needs evidencing, consulting on and need some form of testing/examination so I personally would recommend that councils keep their plan making and plan updating activity going. And I urge the government to consider in its transitional arrangements how it can reduce any burden (perhaps even ‘rewarding’) those councils that are, despite massive pressure to slow down or stop, demonstrably carrying on planning and trying to get their plans updated and in place.  

So, how is everybody in the world of Planning?

We returned to PAS “happy place” Wolverhampton recently to hold another Heads of Planning conference. It was slightly giddy. You can see lots of the presentations on our main site, and see reflections from other PAS people elsewhere on the blog. This post is an attempt to summarise the mood of the conference. After the first scheduled day we slightly bravely spent an hour without any presentations or agenda, and encouraged people to speak their brains. We then played it back to them on the second day, and asked them whether or not we’d got it about right. What follows is this synthesis, fleshed out a bit to make it stand up on its own.

Proof – we got them to vote on whether it was a reasonable summary of their views (it was)

The 30 second summary is

  1. Capacity – it presented as many things (fees, experience, churn) but finding more planner capacity is urgent and critical
  2. Generally people thought the LURB and stated direction of travel for the planning system was a good thing
  3. People were getting on with things, and the “levelling up” agenda plays very naturally into skills and aptitudes that feel very comfortable for planners
  4. Our ask of government is to help us to help ourselves – to get on with reform, to provide incentives for us to transform and to provide a positive framing for the work of planning and planners

Planning and capacity

I recently completed my 15th year in PAS, and for almost all of them people have been complaining about capacity. It would be easy for an outsider to roll their eyes. However it seems that recently something has changed- we already have a handful of councils designated for poor performance and many other councils are under water but hiding it with extensions of time and PPAs. Some councils are failing to recruit altogether, and others are doing only application work and letting everything else slide.

It is some comfort that this was picked up by both our DLUHC speakers, and our fantastic pre-dinner speaker from PINS helped reinforce the message that being a planner in a council could be a uniquely privileged and wonderful opportunity for nosy people. It is hopefully the case that the pandemic has seen the end of the long hours and huge case load culture often seen in DM teams, and it is no bad thing that managers need to think more carefully and deliberately about making an enjoyable work culture (more on this to come I hope).

However while it is no doubt a long-term problem there is no reason for a response to be a slow one. We don’t need more studies, thinking or consultation to begin. Finding new experienced planners to replace gaps like-with-like feels the slowest possible way, so we need to think more creatively.

Some teams are already using the apprenticeship levy to begin people at the start of their training, and others are using groups like public practice with great success to attract new types of people and making more diverse teams.

There were concerns that the proposed fee increase (25% & 35%) was not seen as especially urgent, and there might even be a risk that it would either be seen as a “cost of living” type burden and shifted later, or a “something for something” deal that would come with resource strings attached. There was also the obvious point that almost every service had a capacity deficit already. Both the changes required by the planning reforms and the additional work apparent in the Environment Act would require additional capacity on top of the existing deficit. We were less giddy at this point.

The LURB is a good thing

Over the day we spoke about the LURB as a thing in itself as well as unpacking some parts of it in more detail (most obviously digital – more on that shortly). Generally the vibe was positive. While our audience of chief planners put some of them (us) in a certain demographic there was little hesitation that a future that was more digital, more spatial and involved working smarter not harder was definitely a good thing.

Similarly, the change that was most obviously described in the transition from SA and SEA to the proposed EOR – ie the shift from process, risk and compliance to one based on outcomes was again widely seen as another good thing.

However there was a sense that the principle of “simplicity is better than complexity” is very easy to say but quite difficult to deliver. For example, the use of prior approval as some kind of easy short-cut to a consent has ended up with hugely stressful and difficult cases for councils and applicants (and neighbours!) alike.

People had heard the hope that the new planning system would require some co-design, and were keen to help at the outset to ensure that realism and pragmatism were used to design out unnecessary complexity or room for manoeuvre.

There was also talk on both days (some of it from me) about how planners needed to watch not only DLUHC but increasingly also Defra and their ALBs. It is clear from both the environmental side but also NSIP that there is a new seriousness in Government in aligning departmental activity behind national policy statements. It has since been overtaken by events, but there was a view that government could build on their progress on strategic outcomes for offshore wind (rather than treating them as a series of individual projects) and do something similar for nutrient neutrality.

Levelling up and planning

Levelling-up again got a pretty supportive response. The agenda is in part some of the things that planners have been working on for years – the changing nature of town centres, delivering improvements for the environment and peoples’ enjoyment of it and the other ‘place’ bits of the levelling up missions.

The jobs to be done in levelling up and reform also require some traditional skills that planners have always brought to the fore – negotiating, influencing designing systems and thinking holistically.

Yes the restriction on capacity is grave, and life would be far easier without the firefighting that often happens when skills and experience are short. However we heard from both speakers and delegates of some of the fantastic work they were already doing, and there was no shortage of ambition to deliver real improvements for places and communities.

We’ve had a chance to review the feedback on the event, and one of the lovely things that people report was that sharing updates and news on the exciting work already underway all over the country energised and refreshed everyone in the room. It was great – the team’s cockles are very warm at present. I’m very proud of them and our wider PAS friends & family.

Help us to help ourselves

In the end the ask from the HoPs was fairly straightforward. Everyone felt “up for it” but needed three things to help us deliver the new planning system and ways of working, and I don’t think any of them are a surprise:

  • Get the planning reform iceberg moving – it is clear to all that the LURB is only the initial bare bones of the reform. The whole package (primary, secondary, guidance, IL, design codes, EOR etc) will not be fully in place for some years, and once transition has been factored in we might be well into the next parliament. All the while “better and faster” is promised (alongside “no mutant algorithm”) most councils will find it terribly difficult to get consensus on a new local plan or making much progress at all. Show us what you’re going to do and when, so we can understand how to prepare.
  • Give us incentives to make progress and increase capacity. Nobody (not even Charlie Munger) considers incentives enough. Defra might imagine it enough that the Environment Act places a new duty on public authorities to consider BNG; DLUHC might think that a statutory timetable to make a local plan in 30 months is enough. Neither is right. Incentives are required – perhaps we can remember the lessons from the Housing & Planning Delivery Grant and find a new way to support the digitisation of planning teams?
  • Create a positive framework for talking about planning and the management of development. A growing proportion of councils have local “super objectors” convinced that LPAs are evil, complicit and incompetent partly because of a lack of honest and consistent national direction on housing and infrastructure. There is also a growing network of objectors convinced (perhaps correctly) that there isn’t enough of a holistic and thoughtful consideration of environmental capacity. We need a national conversation about what high quality development means – not in an abstract sense but in a “this is what it means for real places” kind of way.

Can planners help to save our town centres?

Findings and reflections from a workshop on town centre regeneration at the PAS conference for Heads of Planning and Rising Stars, Wolverhampton July 20221

My home town – the new Glass Works and public square, Barnsley

“Town centres are close to my heart” said one conference delegate as we made our way to the town centre regeneration workshop in Wolverhampton earlier this month. I share her sentiments, especially for my own town centre in Barnsley, South Yorkshire.

Sometimes a victim of ridicule in the past, and with previous plans beset by problems and delays, the regeneration of Barnsley town centre is never the less emerging as a great success. Just this spring, Barnsley was amongst the top 10 places for both footfall and spend recovery following the removal of Covid restrictions, and you only have to walk around the place to see the new businesses and numbers of people. I think Barnsley and many similar town centres have a good story to tell, as well as some real opportunities in the future.

With these thoughts in mind I joined over 40 other planners, representing a range of different authorities and types of town centre, at the PAS conference to discuss recent trends and the role of planning in the future.

Town centres and high streets have experienced many changes and challenges over recent years, but few as significant as the Covid-19 pandemic with official lockdowns, radical changes in consumer spending and moves to flexible (home-based) working for many people. This workshop was a chance to take a step back and think about the issues and opportunities now facing our town centres. In particular, we explored three questions:

  • What has been happening in our town centres over recent years?
  • What does this mean for the role of our town centres in the future?
  • What should planning be doing about this?

Along the way we looked at evidence showing the different rates of recovery from Covid lock downs last year, as well as more recent data on the level of food and drink spend in different centres. Add to this the phenomena of “Zoom Towns” and a rapid increase in the number of remote or flexibly based jobs being advertised in some places, and it is clear that something very interesting is happening in many areas.

As well as data and evidence, this workshop was also a chance to think more broadly and speculate about the factors likely to shape change in the future. We drew heavily on Mathew Carmona’s work on the existential crisis facing shopping streets and what makes a place attractive, which provides some good pointers on where planning practice should be focusing in a post covid economy, including the key factors shaping the way people choose to shop.

It would take too long to detail all the issues we covered, but I’ve attempted to capture the key points. Some of these reflect issues that are common to many town centres, but others suggest differing experiences in different type of centre or different regions of the country.

What has been happening in our town centres over recent years?

Many find it difficult to answer this question with confidence. Town centres are dynamic, with changing trends and patterns of decline or development that vary constantly. Frequent monitoring is often beyond the means of local planning teams. Added to this, the introduction of a new Use Class E in September 2020, which now covers the majority of town centre uses meaning that significant changes can take place on a high street without the need for planning permission or any formal interaction with local planners.

A few places, like Bolsover, are undertaking annual surveys of their town centre as well as utilising mobile phone data as a proxy for footfall. Others, such as Newbury, utilise data from a Business Improvement District. For many though, comprehensive evidence on the town centre is limited to local plan production or preparation of a masterplan.

Of course, anecdotal evidence is also an important source of information and there are some common experiences. The decline of town centre retail is not a new trend, but Covid has helped to accelerate this in many areas. Places as diverse as Canterbury and Plymouth, Colchester and Peterborough or Mid-Sussex and Beverley have all experienced the loss of department stores or familiar high street names.

Whilst this is common to larger towns, it is seen as less significant in smaller centres which have a stronger independent retail base and therefore less in the way of national multiples to lose. The differing experiences of larger and smaller town centres means generalisations are difficult and experience in places like Cheshire East and the East Riding suggest fewer problems for retail in their smaller towns.

A decline in retail has led to an increase in vacant units, but this contrasts with a boost in the number of food and drink-based businesses (including evening economy type venues) that is helping to re-animate town centres. It marks an increasingly important role for leisure in town centres, with planners from places as different as West Berkshire, Ipswich, Worthing and South Norfolk all experiencing the trend.

Many were also keen to talk about the increasing importance of town centre residential development. Given the introduction of a new Permitted Development Right (PDR) for the change of use from Class E to residential, this is a major part of Government policy and perhaps not surprising. But only a few places, such as Milton Keynes and Medway, report pressure for conversion of former offices to residential uses in significant numbers. Although it is a concern, PDR to residential is not yet seen as a significant trend in large parts of the country.

Instead, local councils are working hard to support new residential uses on planned sites as well as bring forward projects directly in partnerships with developers. The desire to attract town centre-based living in increasing numbers is an ambition that ran throughout the workshop and encompasses all areas. A good example is Dartford where town centre housing is not currently widespread, the new local plan encourages higher density housing, and the Council are addressing viability issues to bring forward difficult sites.

What does this mean for the role of town centres in the future?

More town centre housing, both higher and medium density, is something that many planners see as central to the future. This is based on the transport links and access to amenities that town centres offer, providing opportunities for sustainable housing on sites that become available as retail, commercial and other traditional land uses scale back.

Importantly though, planners are also alive to the benefits that a town centre residential community can bring in terms of increased spend and footfall for business as well the potential to attract new people to their district. At one end of the age scale, this may be younger professionals enjoying the opportunities of distance or flexible working and a town centre-based lifestyle. At the other end of the age spectrum, older and retired residents could be important town centre communities, benefitting from easy access to local services in amenities.

To support diversification, planners are also making efforts to introduce mixed-use development with many local authorities involved in direct investment to deliver hotels, leisure and residential alongside convenience retail schemes. For example, Cherwell Council are redeveloping a shopping centre with a hotel, supermarket, cinema and restaurant in Banbury, a significant financial commitment and long-term effort to diversify. In other places like Rochdale development is already underway and in Norwich change is being supported through City Deal and Transforming Cities Fund investment. Many councils have also taken ownership of vacant shopping space in preparation for new mixed-use schemes.

But this is not the case for all areas, and different town centres will pursue different strategies or seek to define themselves through different roles in the future. Participants talked about the Unique Selling Points (USP) they are trying to define for their town centres. For example, Canterbury is leveraging its heritage offer; whereas Worthing has an appeal through its seafront setting and proximity to the coast; and Bolsover needs to boost the provision of overnight accommodation to maximise potential for visitors to the castle and surrounding countryside.

Education also emerges as important, with some areas seeing positive impacts from the development of new further and higher education facilities. A new college campus alongside culture and leisure facilities is helping to transform a traditional town centre offer in Dudley, whilst Epsom has seen student footfall benefitting their town centre through a University of the Creative Arts. Peterborough is also seeking to establish a new university centre and Ashfield is introducing education hubs to its town centre.

What should planning be doing?

This was the question that generated the greatest amount of discussion and suggests town centres remain very much at the heart of local planners’ focus. Major areas of work for the future include:

  • Ensuring stakeholder engagement – looking beyond traditional consultation, this means actively working with and alongside local groups, businesses, and other public services to share knowledge, facilitate constructive discussions and create consensus on long-term objectives. It’s more than the usual argument about how many car parking spaces are needed!
  • Preparing comprehensive plans – many planners in the room are working on town centre master plans, strategies or supplementary planning documents. Although different plans will have a different planning status, they often bring together individual projects or schemes, set a policy framework and ensure that interventions are complementary or sequenced. A town centre plan can also help to build investor confidence as well as reduce the risk for Council assets in the town centre.
  • Consolidating retail areas – rather than extending a town centre, regeneration in the future is about consolidation. This means defining and then strengthening the core of a town centre’s retail area as well as enabling positive change to the surrounding areas. Many in the workshop talked about managing the contraction of retail space and identifying appropriate uses for sites that become available, i.e. residential, leisure or employment.
  • Delivering catalyst sites – town centres can contain several vacant sites or underused areas which rapidly become a barrier to progress or could be transformational if delivered in the right way at the right time. Planners are identifying these opportunities, and many shared their experience of using development briefs or masterplans to help bring them forward, often alongside bids for funding through the Local Growth Fund, Levelling Up Fund, Future High Street Fund and City Deals, etc.
  • Improving public realm and active travel – planners are seeking to use Community Infrastructure Levy income, Transforming Cities Funds and direct council investment to create higher quality and better designed town centre spaces, with more opportunities for enjoying time in the town centre as well as reducing the impact of motorised traffic so that walking and cycling is more attractive.

This is not a comprehensive list, with many other examples of activity in different localities. But it does suggest some core roles that planners themselves see as important to their work and which will be critical to the future of town centres.

And in conclusion …….

Reforms like the creation of a single Use Class for all commercial, business and service uses, or the introduction of PDR for residential uses, led many to suggest that there would be less of a role for planning in town centres.

In contrast, it appears from our workshop that planning and planners are at the forefront of town centre regeneration in many areas. Rather than responding to change, local planners are working with other stakeholders and taking a lead role in determining the future shape and success of their town centre.

Overall, this was a tremendously positive session revealing some of the energy and ideas that planners are bringing to town centre regeneration. We hope to build on that in PAS as we develop our work programme in this area and will maintain our support for LPAs as they continue with their plans.

1 see the PAS website for presentations and information from the conference

Storytelling for Planners: Shaping the narrative

I’ve always considered that the role of a planner is to be the storyteller. To develop the narrative, to shape the story and to provide well justified evidence that allows others to determine a satisfying ending. I was struck when researching for this article that unknown to me this is an academic school of thought and that there have been publications on storytelling as a model for planning over three decades. I really like this, and it led me to think about whether this would be a useful approach in helping to promote better governance across all areas of planning and in particular improved collaboration corporately across councils.

Local authority governance and the corporate role of planners within local authorities were common themes at our conference for Heads of Planning and Rising Stars last week, and so it seems timely to consider these types of issues in more detail.

Building on the work of others Tjark Gall and Sindi Haxhija (2020)[1] wrote about two types of storytelling in the context of planning. The first they identify as “linear knowledge transfer” which is described as a transfer of information from planning, or storytelling of planning. The second is “cyclical knowledge mobilisation” which in contrast involves the process of knowledge mobilisation and is focussed on reciprocal exchange with an ambition to encourage co-creation.

As planners, we are sometimes criticised for providing “linear information” where our stories are delivered as information only with little to no opportunity for adaptation. This might be, for example, because parties have developed proposals that are contrary to the development plan. We often hear when working with council’s that there can be tension between planning and other parts of the council that are developing schemes and projects. Planning’s important role as an enabler for development can often be forgotten in a corporate setting and instead perceived as an obstacle to bringing forward corporate projects.

“Cyclical knowledge mobilisation” on the other hand is the type of storytelling where planners are working at their best and this is what should be embedded in good governance. At the heart of this is recognising the range of actors across an organisation and acknowledging that they might not all understand one another’s objectives. The aim is to encourage through organisational story telling greater awareness of each other’s stories and to use them in pursuit of corporate goals and in developing a shared vision.

This is all very lovely in theory but what does it mean in practice? In its simplest form it is creating the right framework and conditions to ensure that there is a forum in which these stories can be shared. Planning is an important statutory function, but it is also a key part of the council that can play a role in helping to shape, enable and bring forward corporate priorities. Critical to this, though, is that it must have a seat at the table. Engaging planning when projects are already well established and designed is not helpful as it becomes much more difficult to narrate a collective outcome and a linear dialogue is more likely to unfold.

My own fixation on good governance stems from years of writing planning briefs on complicated sites which required an organised and persuasive story that was adapted to address different needs and spatial perceptions. Watching these sites come forward for delivery has shown how important a shared narrative was and how positive collaboration (both with the local authority and more widely) alongside planning policy can guide and shape what might have otherwise been considered unacceptable development. Just last week I walked into the former St Mark’s Church, North Audley Street, London and was able to see the restored building in all its glory. It may no longer be in use as a church, in fact it is a street food market, but I took immense pride in knowing that a planning brief I wrote twenty years ago played a part in enabling this important historic building to continue to be used and that public access had been retained. 

More recently my focus has been driven by the work that we have been doing to help councils improve their governance of developer contributions. Working with Inner Circle Consulting we have held workshops with about 30 councils over the last year or so which have involved multi-disciplined officers from across the organisations. The aim of this work has ultimately been to encourage a collaborative approach to allocating and spending developer contributions to ensure the delivery of infrastructure that supports development and is aligned to corporate priorities.

Some of the lessons from our work were shared at our conference last week. The most fundamental messaging, and one that is applicable to all areas of planning, is that for this to be successful and for aspirations to be delivered it requires a corporately endorsed, collaboratively managed and multi-disciplined approach to governance. It is clear from councils that are performing well in this area that this work requires ownership by senior leadership teams as well as strong collaborative working across the organisation. This area of work does not start and stop with planning functions, it requires corporate engagement and leadership – as do most other areas of planning.

Good and effective governance ensures that those who need to be involved are engaged with the entire end to end process. Planning might be able to write the narrative, but the role of the different actors and acknowledging their stories is critical in how this develops. Planners should use their storytelling prowess to raise the profile of this work, communicate shared goals and aspirations and provide a framework in which joint decisions can be made to provide a satisfying end to the story – that is an ending that provides for the delivery of a sustainable future in which people are able to live, work and play.

So, if you have thought about setting up a cross-council infrastructure board or local plans board, or perhaps a forum for consistent engagement with your estates teams and regeneration colleagues go ahead and remember your critical role as the storyteller. It is not always easy! There may be twists and turns or unexpected outcomes, there may be villains and heroes as well as a build-up of tension, but without the collaborative dialogue and the development of shared goals there would only be a linear story with most likely a pre-determined and unsatisfactory ending.

For guidance on improving the governance of developer contributions that includes top tips and best practice that are relevant to all areas of planning please visit the PAS webpages on improving the governance of developer contributions.


[1] Tjark Gall, Sindi Haxhija. Storytelling of and for Planning – Urban Planning through Participatory Narrative-building. Proceedings of the 56th ISOCARP World Planning Congress, International Society of City and Regional Planners (ISOCARP), Nov 2020, The Hague, Netherlands.

Don’t panic! You are never alone

Picture taken in ‘Young Ones’ student house in 1986 – but which one is Pilgrim Pete?

One of the joys of working in the PAS team is that I can spend my days talking to like minded Planners across the country, find out what they are up to and tell them about what others are doing well. Many Planners feel quite isolated at the moment and are reassured to know that they have the same pressures, worries and questions as others. I also come across some brilliant best practice so can get Planners to learn from each other and avoid ‘reinventing the wheel’ To save you all time here are my top 10 issues that Development Management teams are struggling with at the moment and the top 10 best ideas I have heard over the last year.

Top 10 issues (in no particular order)

  1. The number of householder applications have (excuse the pun) gone through the roof and you are all struggling with the shear volume. Reasons seem to be due to the Covid effect of more home working and cost of moving.
  2. Planners are in very short supply particularly experienced Planners who can manage those tricky Majors. The best case officers are being poached by the applicants!
  3. Extension of times are covering up a whole multitude of sins and Heads of Planning are grappling with the need to be honest about performance versus ‘playing the game’ to avoid the threat of designation
  4. Some Councils are getting themselves in a real pickle over validation and have a philosophical dilemma whether to treat it as a administrative process or a key part of providing a customer focused service
  5. Desperate shortages of staff lead to desperate times and pre application normally is the area that suffers most. However when Councils stop pre applications they end up losing a vital discretionary income source and have poorer application submissions
  6. Another consequence of staff shortages is for the remaining staff to stop answering emails and phone calls due to pressures of work. However this normally just ends up with more complaints and grief from councillors, agents and the public
  7. There appears to be a higher expectation of Planners from the public in terms of both enforcement and determining planning applications. The world of work has changed and more people work from home so are more conscious of their local area. This means they have more time to nag the Planning Department.
  8. Social media is targeting Planning Officers and councillors more and more in a negative way. People can view Planning Committees via a webcast and can more easily pick over every word uttered by decision makers and their officers.
  9. The fear of challenge is leading officers to write ever more complex and long winded reports just at the time when time is at a premium. You need to be careful if you expect an appeal, legal challenge or complaint but most officer reports end up in the (virtual) back of the filing cabinet neglected and unread. Why are you spending so much time on the unread reports?
  10. Some Councils get tied up in knots with their ‘Heath Robinson’ approach to IT. This sometimes results in very few people actually understanding how the IT system works and to a ‘single point of failure’ scenario. Successful Councils keep things simple and logical with a good backup of officers who understand how things work.

Now here are the Top 10 ideas (again in no particular order). I have purposely focused on the day-to-day ideas that help you run an excellent Development Management service. Others will tell you about the importance of aligning Development Management with the strategic direction of the Council, future proofing your service to respond to the Levelling Up and Regeneration Bill, addressing national policy etc. These are, maybe, the tips that you will not always be told about by others.

  1. Pair the Chair of Planning Committee up with an LGA Member Peer as a mentor. It doesn’t matter how experienced the Chair is, the best way to learn is through peer-to-peer support
  2. Have a learning through experience process where you learn from every complaint, compliment, appeal decision etc whether it is positive or negative. This is a great way to learn, show that you are learning and motivate your staff by recognising when your staff do well
  3. Make a pact with the Section 151 officer on raising pre application income whereby you will go over and above to drive up income only if the income can stay in Planning. This a great motivational incentive for staff to drive up income and can provide the justification for recruiting more staff.
  4. Change your job descriptions and staff structures so that staff can move around the department and gain promotion without having to apply for a new job. You must keep the best staff wherever they currently sit in the organisation otherwise someone else will poach them.
  5. Become best friends with your nearest RTPI accredited Planning school. Then you can find out who are the best students and entice them to work for your Planning department
  6. Introduce a ’10 minute’ officer report for the simple stuff. If a householder application has no objections and is recommended for approval it will only be the case officer and signing off officer who ever reads it so why spend more than 10 mins writing it?
  7. Set regular meetings with senior managers to agree your position on certain key developments and ensure you are proactively delivering the things that matter to your Council. One Council calls them ‘Cobra’ meetings – you know who you are!
  8. Invest in your website to maximise self help. Put your heads together as Planners and think about all the general questions you get asked on a day-to-day basis and then put them down in a Q and A section of your Planning pages. This means you don’t have to spend time answering phone calls and emails with the same old answers.
  9. Get people who know very little about Planning – your partner, your children, your next door neighbour – and test the wording of Planning Committee reports and information on your website. If they don’t understand it then you need to change the wording. Remember Planning is public facing and so the public need to understand what you are saying.
  10. Send out a pack of information with the Planning Committee agenda for Members alongside the officer report that includes plans, Google Map reference and photographs. Then at Planning Committee the officer presentations can be limited to no more than 5 minutes highlighting any key points that need to be highlighted to the Committee.

So there you go. If you already follow all the top tips well done and let PAS know if you have others that we can share. If there is something new, try it out and let us know how it went.

Most importantly keep the faith and remember – you are never alone.