One message we have been banging on about for the last couple of years is “get on and make a plan”. The NPPF and transitional arrangements are only the latest reason to mean this message is true.
We are putting the greatest share of our resources into helping councils get a plan in place. But which councils needs the help most ? People at the final stages are all taking advantage of PINS excellent front-loading visits, but what about people further back in the queue ? Many councils are completely competent, and we should focus our attention on those that are struggling and need some outside assistance.
Spotting strugglers should be reasonably easy. There is a published timetable for making a plan. It’s called the Local Development Scheme (LDS). One probable indication of a project in trouble is missing the milestones as set out in the LDS.
But very few, if any, Councils hit their original timetable as expressed in the LDS. In hindsight, they all suffered from optimism bias, and failed to reflect the vicissitudes of life in a changeable, resource constrained environment. We’ve all seen ‘Grand Designs’ (home of the “we’ll be in by xmas” line), and we understand how human these sorts of failure are. But we need 330-odd local plans and each one is itself a similar investment to a Grand Designs project. We in local government can get better at this.
The Planning Fallacy (or why the LDS is often just lies)
What’s happening has been called (by coincidence) the planning fallacy. This phrase has been coined* to describe plans and forecasts that:
- are unrealistically close to best-case scenarios
- could be improved by consulting the case statistics (time, money) of similar cases
Fortunately, we can mitigate the planning fallacy. As Bent Flyvbjerg snappily puts it “The prevalent tendency to underweight or ignore distributional information is perhaps the major source of error in forecasting. Planners should therefore make every effort to frame the forecasting problem so as to facilitate utilizing all the distributional information that is available“. He is talking about getting better at forecasting how long an olympic stadium or HS2 will take to construct, but this is true for the process of making a local plan itself.
Put simply, we should use the actual, historical timetable of Councils with adopted plans to sense-check people’s LDS. Chances are, if it took 20 other councils an average of 9 months to get from stage ‘A’ to ‘B’ then your timetable of 6 weeks is naive. And if you’re allowing 12 months for a stage that your peers knocked out in 12 weeks then you might consider pulling your finger out.
And rather than simply measuring an end-to-end time, we can break it down into the key stages. So that we can understand and share how long each section actually took. These averages don’t replace the detailed planning and thinking that each council must do, but they provide an outside-in perspective that provides a benchmark to prevent unrealistic timetabling driven by the planning fallacy.
We will shortly have a new bunch of research people on our supplier framework. This will be my first job for one or two of them:
- We begin by defining classes. This means we group councils by type (districts / london / mets / parks etc). These classes dictate how the information is collected and averaged.
- We collect data on how long it took councils within each class to actually make their plan. This is broken down into the 5 or 6 key stages of a plan. We do this by asking them, while it is fresh in their minds.
- Note that this is not a narrative. We’re not making case studies. We don’t care that Council ‘A’ had a change of political control, which is why they took so much time to get through Reg 28. This is about getting enough councils in the mix to get a decent average.
- We collect and publish. For each class of council we know how long it really took to go through each stage of making a plan.
- Now each council of the same class without a plan can sense-check its LDS. To put it in academic language they can do ”reference class forecasting‘. This means they can mitigate one of the biggest errors in forecasting. And, perhaps, we can become confident enough to attempt more joint plans.
What about updating a plan ?
Quite soon the bulk of councils will have a plan. But this approach will remain just as useful for people trying to answer the question “how long does it take to do a single issue review ?”. As they start to appear we’ll be doing some counting, and perhaps refining the reference classes a little.
So, if someone contacts you shortly to ask you about how your plan schedule really went please share. We’re not telling tales, just assembling some real world averages.
* This post borrows heavily from chapter 23 ‘The Outside View” of Thinking fast and slow by Daniel Kaheman. The whole book, and particularly the middle section, I found really helpful and it is already scheduled for a repeat read.
In simple terms, in our experience, producing our overall full LDF has taken a similar length of time as it previously took to prepare our former (now superseded) UDP, ie. about 7-8 years from start to finish. We commenced our LDF issues and options stage in summer 2004 (under the ‘jumping the gun’ transitional arrangements post P&CP Act 2004), and ultimately adopted our final DPD in April 2012, with just one final SPD to be finalised for adoption later this summer.
Fair enough, it took only about 3 years to get our Core Strategy through (one of the first when adopted back in June 2007), but then there was also our 3 town centre-based AAPs (2 adopted end 2008, 1 in Autumn 2010, with another abandoned after draft stage following final RSS changes), development management policies DPD (end 2011) and site allocations DPD for the rest of the borough (Spring 2012), and not forgetting 20 SPDs (including 11 conservation area plans), all being produced alongside one another and on different overlapping timeframes as staff time and resources allowed.
In comparison, our previous UDP (plus suite of SPGs) commenced preparation in 1991/92 and was adopted in 1999.
Hence, my personal opinion is that (regardless of the procedural changes, etc.) a new Local Plan is realistically likely to take a similar overall timescale from start to finish – probably with a strategic level DPD programmed to come through within about 3-5 years, followed by (but prepared partly in parallel with) a separate borough-wide site allocations DPD.
And not forgetting fitting in preparing a CIL, SCI and SPD reviews, plus maintaining a reasonably up-to-date evidence base, undertaking SA/HRA, etc., as well as ‘technically assisting’ with any neighbourhood planning activities and advising on planning applications and development proposals, etc., etc., etc.
Unfortunately for most planners the LDS isn’t a real part of the Project Plan, it’s essentially a statement of intent and subject to an ‘acceptability’ test. It might take most people a set length of time to complete a certain stage, but the LDS has to be acceptable to a variety of project partners (officers and politicians) which means it effectively becomes meaningless for actual project planning. As Andrea has said above, it seems to take a certain length of time to complete a plan/core strategy. I understand the route of allowing appropriate ‘class’ benchmarking, but in reality aren’t the reasons for delay more important in identifying what is happening? Plan makers need to factor-in periods of purdah, you need to allow extra time for consultation, and then allow additional time for consultation periods, you need to allow for a change of national policy….there is a lack of realism in the overall scheme as the optimistic view will curry more favour.
I will read the book though!