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


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.

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.

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.

What planning reform is going to leave unchanged

We in PAS are change agents. We like the new, and can’t really look at the way things are without wanting to improve it. I think it’s important that people under pressure in this year’s budget round are also nudged to think about what is coming over the horizon so we won’t stop doing this, but it’s not the whole story.

Sometimes it’s worth stepping back and thinking about what is not going to change. When you can identify things that are going to be as true in 10 or 20 years as today, then the work you do to improve them cannot be wasted. For an online retailer, it might be price and speed – for them there is no alternative future where people are going to want things to cost more and slower to arrive. For us in planning though – what things should we be “doubling down” on? I offer three:

Development is about change

Development Management is about telling people that their environment is going to change and hoping they agree that the short-term disruption is worth the long-term benefit. But humans hate change, and it leads to a lop-sided process where the people who have most to gain (people will have houses to buy!) are absent and the people with the longest exposure to the status quo find it natural to organise against the unknown.

We call this “community engagement” at the moment, but I think the underlying issue is human psychology. We need to work on reducing the friction and fear of change, and ensure that development brings tangible benefits to everyone.

Planning is about choices

One of the things taken as read in the conversation about “speeding up” the planning system is the sense that there is only one obvious thing to do. But rarely is there only one solution, instead it is a choice between ‘A’ or ‘B’ or even “do” or “not do”. A wise person once told me they saw planning as “structured decision-making” and I think I can now see what they meant.

This is why having a clear sense of the future is so important. Assessing an application becomes a structured decision along the lines of “does saying ‘yes’ to this application get us closer or further away from our future?”. Obviously the more discussed and understood the future is the better use it is. Not saying that it’s easy. Does every adult have a private car in our place’s future?

Planning is judo with the market

One of the many reasons that planning is interesting is that in different places it does different jobs. Sometimes it encourages and helps, sometimes it resists and refuses. What it normally boils down to is trying to make the market do something it wouldn’t do otherwise (or wouldn’t do as well, or as much).

I learned from our early work with the Housing Delivery Test that some planners had a deep knowledge of their local markets and relationships with the people active in them. Others had almost no connection to that world, and simply collect evidence in quite a passive way. But there is no posible future where development happens without an economic angle, and to attempt to influence the market without understanding it is hopeless.

So, what difference will planning reform make?

This is not to suggest that planning reform has no relevance to us, more that local leadership comes first. The best places have a strong sense of what they are trying to achieve and mostly how to get there. National policy is important but only as a way of understanding how to work with the grain of the planning system rather than against it.

I worry that some people have downed tools and are waiting to find out their housing numbers. But rather than deferring starting at all, I hope that the best places are working on the things that won’t change. How to frame development as a positive force that brings us closer to a sustainable pattern of living, in a way that is economically literate for land owners and that allows a more diverse discussion on benefit and cost. These things are hard, and will be hard in 10 years time too – that’s why they are worth constant work.

Planning and “nutrient neutrality”

I have written before about how good it is to work at PAS. Almost by design you are exposed to the most difficult, novel and complex areas of planning policy and implementation. At the moment across the team we are dealing with land supply, town centres, article 4 directions and how to shift towards a more digital planning system. In my opinion, soaring above them all in terms of brain ache is the issue of “nutrient neutrality”.

While nutrient neutrality is on the surface fairly straightforward and has been beautifully explained by Simonicity here and here. What makes it hard to work through is not the concept itself [which I think of as “when you’re in a hole stop digging”] but the number of agencies involved and the very well organised stakeholders who all look at things in their own way. We ran some events recently on this topic and what follows are my reflections on what I learned and have been thinking about since.

  1. We are changing, and change is hard. All organisations that receive the advice from Natural England go into shock. Plan allocations are called into question, housing schemes get stopped in their tracks. I have helped several places with the early stages of “What Now?” following an advice note and have found the Kubler-Ross model of grief is actually quite helpful. People’s initial response is denial – or at least denial that there is anything except a choice between housing and the environment.
  2. We should accept a part in fixing this situation. Quietly, privately, I think many people will agree that planning has been too focused on housing for many years. The thinking has been one-dimensional. A more balanced and holistic view of development is totally within our gift and many planners welcome it. But set against that is a clear and common-sense view that the planning system should not tie itself up in knots while other actors carry on undoing any hard-won improvements every time it rains. Any response has to be collective and proportional. I think you know what I’m getting at.
  3. We must help to invent a new art. It would be easy to play “Wait and See” to learn what the Environment Bill (and habitat regs) do in combination with a new Planning Bill. There is no shortage of new regulation coming our way but I think it is naive to sit back and ask the Government to tell us what to do in precise detail. We can start right now – for example by running a call for sites with a twist. Not just about housing, not even housing + infrastrcture but a “Green Call for Sites”. We probably need new heuristics and better GIS skills but we can extend what we have learned about assessing sites for housing to include assessing sites for ecological improvements too.

As I write this my twitter feed is full of people exasperated with the failure of sewage-based amendments to the Environment Bill. Perhaps naively, I really hope that some of the historical and structural problems that surround how we use, manage and price water get fixed. That stuff all feels slightly beyond my pay grade. For planners, though, I think it means:

  • Think big. Many of the government teams I work with are quite specific. Their job is to “land” a policy area like BNG or NN and they resist what they see as scope creep by broadening out thinking or implementation. However I think we must resist these narrow policy boxes and think as natural systems work – holistically. My advice – think about “bundling and stacking” and the best possible use of sites right from the get-go. This must be where we push LNRS and a broader strategic thinking on the environment.
  • Play to our strengths. Most people in planning forget what a useful bundle of tools it represents. We bring statutory consultation, political consensus, legal agreements, the ability to think long-term and in a coordinated way about land use and infrastructure. Some of it could do with a bit of a brush-up (monitoring & enforcement, I’m looking at you) but what a potential powerhouse it is.
  • Learn by doing. We know housing sites take years, and so will good environmental schemes. Don’t wait for certainty, and don’t worry about changes to (for example) Section 106 agreements undoing your work. The environment is a big wobbly and uncertain place and we will all need to try, learn and iterate what we’re doing to get the best environental bang for our buck.

Yes, nutrient neutrality remains difficult and I can’t yet point at many schemes and places that I think have totally cracked it. But on my optimistic days I think we should be pleased that we are at the beginning of a new and better way of placing development in a natural context. Place-making (at least for me) has always had an urban flavour, but I think the principles of good placemaking might equally apply in natural systems. We just need to get better at it – collectively.

Digital local plans take two

We’ve written before about our initial work on local plan standards, and how it began a series of increasingly basic conversations that left us a bit baffled. Fortunately we have a long tradition in PAS of having lots of extremely clever people as friends and colleagues and picking their brains to make ourselves look more competent. We held our first session last week- there was lots of excitement and creativity. What follows are my initial thoughts – so you can be the judge of whether our tradition is working. 

It’s not the book it’s the library
It’s tempting to think of a local plan as a book – so a digital local plan is just an online version of that book. It’s true that ultimately the local plan process ends up producing something that looks like a book, but it is also at different times and for different audiences a whole set of proposals, data sets and conclusions drawn from the data. I live in the wonderful borough of Lambeth – you can see their local plan evidence base neatly marshalled in a library. The library is used to inform the debate and choices through consultation and ultimately examination at which point its importance fades. 
For me, there is limited benefit in doing a make-over of a local plan. Sure it would be interesting to see a “before” and “after”, and improving engagement and accessibility of the finished product is definitely important but if our goal is engaging, responsive and more open plans it’s got to involve the underlying data – that’s why it’s got to be the library and not just the book. 

A “rules based” system of assessing sustainable development involves everyone
To go back to basics for a moment the job of a local plan is to answer the question “is this application sustainable development?”. The goal of the current reforms to the planning system is to provide greater certainty to the answer of this question by shifting the balance away from discretion (planning judgement) and towards rules. 
Clearly the process of applying rules is going to work better for some concepts than others. Traditionally it’s where “building control” sits allowing “planning” to be a bit more human. 
But for a system of rules to work they need to be relatable to everyone. The rules have to be debated at local plan stage by local people, they are codified in the plan, they are acknowledged by architects and applied in a context in applications. It’s an end-to-end thing that involves everyone speaking the same language. This is a big ask, and our starting position is that we don’t have a national way of measuring floorspace or counting bedrooms – let alone rules about [cough] “beauty”. 

Eating the elephant
Where should we start? This is going to be the most important question – and is far more difficult question in this context than for any other project I’ve ever thought about. For example, I have begun many “transformation” projects on how planning applications are dealt with. Almost all planning applications take a few days to complete – you can just begin trying new things and the feedback loop tells you how its going in a week or two. The cycle time for an application is a few days. By contrast, a local plan cycle time is measured in years, and worse the cost of a plan is measured in millions. At some point we are going to roll up our sleeves and try new things but what we can’t do is to try a whole plan in one go and wait to see what happens. 

The startings of a manifesto?
So – a great conversation started to unpack some of the issues, hopefully to make me sound a bit cleverer. And, it’s clear that this is an interesting problem with long-term benefits around openness, cost reduction and understanding / managing development better. But what next? We could keep having sparky conversations and there are lots of interesting projects already underway out there – but perhaps we need a manifesto or some other way of organising the next year or two. 
Alongside the obvious stuff like “find out what the rest of the world is up to” and “ensure we understand the capabilities of what we already have” it feels like the next phase is going to need to deal with three topics:

1. Establish the design patterns for local plans. One of the most important things the Government’s Digital Service did in its very early days is to establish what were known as design patterns. These are the rules for how to deliver core elements that crop in many different contexts (eg how to ask for a credit card). We need to work out the common elements that inform a local plan, so we can see the opportunities for a standard approach and platform. I’m imagining patterns might include things like “ask people what they think about a rule expressed as a number” and “make site information findable” and even “allow people to suggest changes to a shape on a map”. 
2. Make an example “rule based system”.  I can remember a long time ago (12 years!) I tried to make an XML “expert system” to describe permitted development. It was hard. It neatly demonstrated that until the regulations are written in a rule-like way the judgement has to be deferred to a human operating the rules (“is this the principal elevation?”). We need to out a rule-based system end-to-end. How about adverts? Neat, specific and lots of experience and competence out there. New regs, new rules, and a language that connects them to a site. 
3. Talk numbers. All this stuff is exciting and there is already some great work underway, but at some point we are going to need to understand the costs and benefits. Getting datasets and policies to a defined standards (and quality!) is an enormous undertaking for LPAs and we should be clear about how much this transformation is going to cost. And, to re-use my “library” metaphor, is it all data equally valuable and are there any opportunities to reduce cost by maintaining some of it nationally?

Weeknotes 10

w/e 17/07/2020

Release the albatross. 

What are you thinking about?

I’m thinking about infrastructure. Still. And programme management. I might change this opening question as I don’t think I change what I think about often enough to sound cosmopolitan and interesting. 

Who did you talk to outside of your organisation?

I spoke to a peer team about a job we’re doing next week. It’s the second time we’re working on something that might appear in Private Eye. Brings a certain frisson. 

What did you learn / read this week?
I learned that Singapore have got a really groovy bunch of people doing their digital planning work. It was amazing, and showed what was possible if you have a Venn diagram of
* a zonal system of controlling land use
* a one-stop-shop of government
* seemingly POTS of money and lots of talented people, which may demonstrate
* a seriousness about the future and how to make land work hard
Very very impressive. When a feedback loop appears on the first handful of slides you know it’s going to be good. 

I also got a lot out of a post from our one-time buddies dxw. There is a lot going on just under the radar at the moment, with both “devo” and “planning” likely to get a thorough shakedown. There is lots of organisational girding of loins – with some of the opening positions being published and mutually supported. Uncharitably some of it looks like defending the status quo, which I don’t think is a great look. Interestingly it is dxw (a private outfit) that in my view does a better job of showing the problem with centralisation and makes the case for diversity and local accountability. And listening. 

What did you make / achieve?
I made a trading account for our consultancy business, which isn’t very exciting but a necessary part of keeping the show on the road. Repeat after me: a job cannot make any money until it is invoiced. 

I have also taken a big step forward on an old stinky project. I have worked out where the friction points are, and started the process of minimising the grief that is going to come along with it when we do finally publish our updated guide. 

What are you looking forward to next week?

I’m looking forward to finding out just how well peer work can be delivered via skype. I’m sure we’ll do something good enough, but interviewing people (especially agitated people in groups) is hard and relies on a whole range of perceptions that probably don’t work very well down a tiny screen. Learning by doing. 

I’m also going to need to set out my stall for the IFS work, which is going to be a squeeze but the conversations I’ve been having in small groups need to be constructed into something and shared more widely. 

Weeknotes 9

w/e 03/07/2020
Raining. Thinking. Being proud of the team. 

What are you thinking about?
I am thinking about what we learned over the course of last year, and what might be just around the corner in this one: 

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300m results 16.6 KB View full-size Download

Who did you talk to outside of your organisation?
This week was the big set-piece review of 2019-20 in front of our sponsors. Inevitably it felt slightly overtaken by events, but it is one of those rare opportunities to speak truth to power. We were offered (and took) a couple of moments to tell them how we might change things to make the planning system slightly fairer and less friction-y. 

I also spoke to a couple of punters about what they need from us (calmness and structured approaches mainly). 

Lastly I spoke to a group of our suppliers about how we might package and define the work we want to procure over the next chunk of the PAS programme. I’m not sure I know all the answer yet but I think I feel less worried and more confident that this disruption represents an opportunity to be more creative and free. I’m almost looking forward to procurement – and I don’t think I’ve ever said that before. 

What did you learn / read this week?
I had the pleasure of dipping my toes into neighbourhood CIL this week. It’s amazing how something that should be fairly obvious can become byzantine and faintly dodgy with the application of forms, process and ill-judged paternalism. 

What did you make / achieve?
With the help of my lovely team we made a slightly dry round-up of the year and a more zingy presentation of 2019-20. I also made my first two baby steps helping advise people with their s106 / CIL work. 

Oh yes, and I completed couch to 5k. I now need to work out whether I enjoy running enough to continue. 

What are you looking forward to next week?
Next week is a short week, as I am shipping the eldest back to university and taking some time out to think through a family investment. 

However I am looking forward to the first meeting (for me) of the POS CIL network, seeing the second cohort of our suppliers and taking to a district council about how we might do some peer work virtually. I am also seeing a slightly different bit of government to see if we can knit together a new alphabet soup of SA and EIA alongside BNG and some new ones I can’t remember in a big environmental package. 

Weeknotes 8

w/e 26/06/2020
Hot. Typing. Applying styles to things. 

What are you thinking about?
I don’t want to sound like a stuck record, but I’m still thinking about the infrastructure funding statement. This is OK because it is my job to think about it.

Who did you talk to outside of your organisation?
A quiet week. I spoke to some peer friends about various bits & bobs, and had a couple of low-key updates with my sponsors and policy peeps at MHCLG. 

I don’t want to add any weight to the idea that PAS sits somehow outside the LGA, but I also spoke to some of my LGA colleagues this week for the first time since lockdown. Everyone moans about their employer, but I have to say the SLT at the LGA have been great throughout the pandemic. At our webinar earlier in the week we were asked a question about how we saw the future. It’s early days but it seems to me:

  • the office as a place to work every day is finished
  • in the short term there is lots of talk about choice and personal circumstance which is lovely and fluffy.
  • our open place office is poorly laid out for what we need it to do, which is to host whole teams turning up specifically to be with each other to talk / collaborate / feel connected
  • more / bigger meeting rooms for more lumpy and random attendance. This is going to be hard to predict & provide. I predict a riot rota.

What did you learn / read this week?
I have almost finished my GDS content design training. It is great – I recommend it. In week 3 they introduce Hemingway as a way of grading your content for readability. It is brutal:

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low score is better 111 KB View full-size Download

I also was one of 120-odd people in the launch of the centre for cities “cure the housing crisis by zoning planning” report. Oh to be so certain. 

My database exploration hasn’t moved. I’m waiting for there to be a Venn diagram of feeling cleverer than usual and a clear couple of days in the diary.

What did you make / achieve?
I have finished my bit of the website, which is nice. I also commissioned some design work for our post-decision surveys – it is getting close!

I have also agreed the structure for our IFS materials, as well as beginning the first draft. Hemingway doesn’t like it.

I have also persuaded moodle to live on our little scratchy server we use for messing about. We are trying out a little MVP on councillor training to see how it works. 

What are you looking forward to next week?
Next week we have a review of 2019-20 in front of our key audience, so I will have my sleeves rolled up  for that. I’m thinking if it goes well we should find a place to publish it more broadly. 

I’m also picking the brains of our supplier network to hear from them what virtual and online working means for the way we should package and buy the support we put in place for councils. I’m expecting to hear that the status quo should prevail…