Anyone who has ever seen me deliver presentations will be unsurprised to learn that I prepare what I think quite carefully, but not so much how I’m going to say it. At our opening PIPE event I mentioned (in an unplanned aside) that I thought agent accreditation was wrong. Several people challenged me on this, so I offer my opinion in two parts. Today I’ll try to set out why these accreditation schemes are fundamentally wrong. Shortly I’ll share some thoughts on what might be a better way.
Even more than usual I’m grateful to colleagues in local govt, several of whom have shared their thoughts and inside knowledge on agent accreditation schemes.
How do agent accreditation schemes work ?
Briefly, the premise is that there are good agents and bad agents. Good agents can submit good applications that are ready to proceed, bad agents submit sloppy applications that require rework before they can go on to consultation.
Good agents submit a certain number of flawless applications to a particular authority – usually 3. Following this test, they receive a “gong” – they become an official accredited agent. Presumably their name is listed somewhere on the council website, and they can use this gong as evidence of some kind of competence in their own promotional material. Because they are now an accredited agent, any subsequent applications they submit bypass the initial validation process and go straight to a planner – reducing cost and time.
So what’s the problem with agent accreditation schemes ?
Before we begin, just take a short pause. We are (all of us) conditioned to think of process being bad. Process = red tape. Anytime a process can be removed, don’t think or question. Just strike it through. I’m asking you to set aside these Pavlovian responses for a moment. Let’s begin by examining the claims made for these schemes:
Accredited agents bypass validation. For those that are not close to the process of planning applications, this is the skinny: The validation process is almost the first thing that happens to an application. Recent news coverage would suggest that it involves collating the newt surveys, and ensuring that the design codes have been modelled in sonar for the bat consultation groups.
Actually, the bulk of the validation process is about ensuring that the proposed development is clear and complete so that neighbours can understand what it looks like to them. A suprising number fail to include all the sections, or use projections in a slightly interesting way.
It is the duty of the planning authority to ensure that the correct information is made available to consultees. So, I asked a long-term accreditor of agents, what happens when an unchecked application goes out for consultation and it’s wrong ? The temptation is to think that somehow the risk has been transferred from planning authority to agent. But that’s not so. When I pressed, it became clear that the council could not (and would not) bear the risk of maladministration. So, they gave accredited agents a “light touch” validation rather than bypass validation.
How much time is saved by moving from a “full and thorough” process to a “light touch” validation ? I suppose it depends on the application. I can tell you averages. But that’s not what’s important. What’s important is that when you discuss time and productivity with validators you’ll discover that they already know who is a good competent agent and who isn’t. They already offer a “light touch” service to agents that they know, and understand how that council likes things to be done. The accreditation scheme buys you nothing – your people are already differentiating between good and bad agents.
Accredited agent schemes reduce cost and time
It stands to reason that reducing process (no! let’s call it bureaucracy !) reduces costs. And, perhaps I’m wrong in the previous section. Maybe the validation process really is bypassed in councils and I’ve just found a couple of makework people in backwards councils.
How do we reduce costs? And has anyone done it ?
Let’s start with an awkward fact. The validation process takes up 4.2% of the resources of a planning department. Really. You think you can reduce headcount from this ? When most departments have a headcount of about 40 ?
And the agent ? The accreditation process demonstrates that the agent can jump through the hoops, not that there are fewer (or simpler) hoops. Moreover, she is now bearing the risk of the consultation process being found faulty and therefore really annoying the council*. I can’t see that this saves cost for her either. And nowhere does there appear to be critical review of whether the council has adopted a sensible approach.
And time ? I don’t know. It’s entirely possible. Let’s not guess. We already know whether online applications are quicker than paper. Someone will give me a dataset at some point in the future and then we’ll know.
Accredited agent schemes improve service
The accredited agent gong feels to me somewhere near nudge theory. Applicants will choose agents who have a gong, therefore all agents will want one and so the quality of applications improves.
But. Let’s be clear about this. We are talking about a small part of a whole. Applicants should not need to know (or care !) about the validation process. Does the gong demonstrate that applications are determined quicker ? Or that they’re more likely to be approved than the average ? [Spoiler: see more on this in my next post …]
More worryingly for me is the council-centric view of life that goes along with this position. This is a monopoly service that sets out what “correct” looks like and then marks agents against it’s own version of reality. The agent accreditation scheme is a reward for playing the game by our rules. And are our rules congruent with the needs and wants of our customers ? Ah.
And, in some other work that I’ve never polished up for publication, I’ve done the analysis comparing agents across councils. Some of my forward-thinking pilot people recognised that their validation requirements were open to interpretation, so put their own performance up for comparative review. The dataset is smaller than I’d like, but as you would expect there are agents who achieve good rates of “valid on day 1” at council A and poor rates at council B. Councils should not further exercise their monopoly by treating “them” as the problem and never “us”.
It’s not often we say “that’s wrong” in the improvement sector. It feels slightly non-collegiate. And it is true that I’ve written to provoke discussion. But let’s set it out in summary:
The gains are (at best) marginal. We don’t have to argue this out – someone will give me a dataset and then we’ll know. But my off-the-record sources tell me that it does not do what it says on the tin. Although I feel sure that the agent forums and other, more open forms of communication that accompany these schemes must themselves improve the situation.
* No one has talked about removing accreditation. There is an inbuilt problem with accreditation, even if it is dressed up as impartial. If the gongs are valuable, then losing one is going to hurt. Councils have a terrible track record of coping with challenge, and if the gong does end up providing competitive advantage then a new source of challenge can be expected to appear.
This scheme has been set up with the wrong “customer“. The scheme puts the council’s validation service in the role of customer – the scheme delivers a reduction in work to the validators. This is the source of the problem. [as an aside, I have another improving book to commend to you – especially if you struggle to define your customers]. I’d say more on this, but this is going to be covered properly in my next post.
But, just so we’re clear, these are all fixable problems. And this is not a “pop” at the places who have introduced an accreditation scheme – I know most of the people at the heart of this and they are genuine in their struggle to make things better for everyone. And maybe I’m wrong – discuss.