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.


Local Plans & LURB: The Position on Transition

At PAS I organise and manage the support for councils making Local Plans. My main Levelling Up & Regeneration Bill interest is the transitional arrangements – how will councils be guided into the new system? The effectiveness of the support PAS provides hangs on understanding this. Word has it that these the transitional arrangements are hurriedly being finalised so hopefully we’ll see something soon.

While I wait, and to shape my thoughts, I’ve set out in simple terms below what I think the main scenarios/questions facing councils are. I hope to use this as a frame for thinking about the kinds of support councils might need and to get some wider (and hopefully better) views.

For most councils the questions will be: ‘what does this mean for our Local Plan?’ and ‘should we continue working on our local plan?‘. The answer how to proceed will reflect where you are in the plan making process.

The government is encouraging councils to get (‘current system’) plans in place asap, with Housing Minister Stuart Andrew recently acknowledging “….that work will be valuable work anyway”.

The government has also said alongside the Bill:

  “To incentivise plan production further and ensure that newly produced plans are not undermined, our intention is to remove the requirement for authorities to maintain a rolling five-year supply of deliverable land for housing, where their plan is up to date, i.e., adopted within the past five years. This will curb perceived ‘speculative development’ and ‘planning by appeal’, so long as plans are kept up to date. We will consult on changes to be made to the National Planning Policy Framework.”

This 5 year land supply thing is significant I wonder if this refers to plans being made now? There are 4 main transition scenarios and questions facing local planning authorities as I see it: 

Scenario 1 – The Local Plan has been submitted for, or is at examination right now

  • Key questions:
    • If found sound, will our plan be ‘up to date’ in terms of not requiring a 5-year housing land supply?
    • Are we facing any increased risks due to the proposals in / statements made about the LURB e.g. our plan being withdrawn from examination or not being adopted even if it is found sound?
    • Will we be required to do an immediate review of our plan under the new system?
    • How will we be affected by the new data standard requirements?
    • When should we begin preparing our LURB local Plan?
    • How will the ‘weighting’ of National Development Plan Policy operate for us?

Scenario 2 – Local Plan production / update is advanced (e.g. at least at Reg 19 stage) and aiming for December 2023 adoption:

  • Key questions:
    • Will there be an advantage/incentive (outside of simply having an up to date plan in place) for continuing to work towards getting our plan adopted by December 2023? 
    • If found sound, will our plan be classed as up to date in terms of not requiring a 5-year housing land supply?
    • Are we facing any increased risks due to the proposals in the LURB e.g. a challenging timetable, Duty to Cooperate challenges, examination issues – could the plan be delayed in favour of the ‘new, simpler, quicker’ system?
    • How will we be affected by the new data standard requirements?
    • When should we begin preparing our LURB local Plan?
    • How will the ‘weighting’ of National Development Plan Policy operate for us?

Scenario 3 – Local Plan production / review advanced, adoption planned for 2024

  • Key questions:
    • Will there be a transition period that allows us to continue preparing our plan under the current system post e.g. December 2023?
    • How much of the work we have, and are preparing to undertake will not be required or not fit for purpose post reforms e.g. when will data standards and new Sustainability Appraisal (Environmental Outcomes Report) requirements affect the work we’ve already done?
    • The Infrastructure Levy will change the way we plan for affordable housing and other infrastructure requirements to support development through planning policy. How do we take account of this?
    • What is the risk of us pausing to enable us to prepare a plan under the new system?
    • How will the ‘weighting’ of National Development Plan Policy operate for us?

 Scenario 4 – Not currently reviewing the Local Plan / early thinking.

  • Key questions:
    • How much work do we do while we await the transitional details?
    • What can we start doing now?
    • How do we work with Government to engage in the “Test” and “Learn” approach to some areas of reform?

Once we understand more on this we can begin to build our support programme. Many practical things aren’t going to change – the need for good project management, effective work on strategic issues, good evidence bases and effective engagmnent of members – so the focus of our current support work will roll on for a while.

Help me look ahead – I’m bound to have missed some key questions and scenarios – help me build a better picture.

Let’s get digital, digital – how the planning sector is taking baby steps towards a digitised dream destination

Let’s get digital, digital

I wanna get digital                                                                
Let’s get into digital
Let me hear your data talk, your data talk
Let me hear your data talk

Olivia Newton-John doing Lets get Physical but with my head on it!

It’s been a year of involvement in digital projects here at PAS and 2022 looks to be much more of the same with many of the more widely supported planning reform proposals for a digital revolution of the planning system having begun already. But what is actually meant by the word ‘Digitalisation’?? well to be frank it’s a non-word and is trying to capture various strands of change and innovation in the sector.  Some strands are related to modernising ways of working with increased transparency and some strands are about better use of data, new tools and automating processes. Within the wider planning world there is some criticism that the speed of change is coming too fast and that planners will all be replaced by AI robots. So, should we fear this digitisation steam-train coming down the track? Absolutely not, but we should be prepared to guide the digital agenda towards improvements in how we work for the better rather than change for the sake of change. Don’t get me wrong there are plenty of areas where improved data will be welcomed with open arms.

Before we take the initial step: right now, we do monitoring badly

The current state of affairs is we can even answer some basic questions such as ‘Do you decisions or policies work?’. Take, for example, the monitoring of housing; many planning teams still rely on counting net additions only once a year and using the yard stick of ‘is there a net curtain in the window’! For many other policies and decisions, we aren’t able to monitor the right indicators to know whether the plans we make are successful – we don’t even know what we don’t know. This is even more true for emerging issues, how on earth are we going to capture data on carbon impacts, water usage, health/wellbeing improvements????

Where is it all heading?: we need to keep our eyes on the destination

Everyone and by that, I mean everyone involved in the planning sector e.g. LPA officers, digital specialist, DLUHC need to start with the end goal of digitisation in mind. The journey to a digitised planning system is going to be a long one and there is a danger we will take our eyes off the end goal and simply look down at our feet, concentrating on the next step ahead and before we know it we have veered off the path & into the deep dark woods.

So, what is the end goal? what is the utopian dream of a digitised planning system? Well, if we look to other industries who have gone through their digital revolution such as retail, we start to get a few clues. For a start when tech is good it is invisible, you don’t even realise that AI and software platforms are involved everything just happens seamlessly and is integrated with other parts of your life, such as receiving a text that your order has been dispatched. Smart homes are another example of where the tools and technology are seamless at just making life easy.  Planning is definitely at the start of that journey towards an integrated and seamless utopia. We are starting to work on the small jigsaw puzzle pieces needed to make those initial first steps.

Over the last 18months I have had the privilege of having insight into a number of the digital projects and sprints being undertaken as part of exploring the possibilities for planning reform. Each of these bits of work have focussed on a particular part of the system or a process an LPA undertakes, for example some projects have looked at automating validation of planning applications, using A.I. to read and filter Local Plan reps, using GIS to create a fully geospatial local plan and creating data standards for how LPAs produce data on sites. What struct me during those projects was there is a clear need, while we create all these individual pieces of the jigsaw, to keep the one eye on that digitisation journey. Planning is not isolated from the rest of world and is not an abstract ‘thing’ in its own right – Planning is about the world so we need to make sure any progress we are making is all integrated. We must not lose sight of that.

While we’re on the road: don’t lose the planning magic

The more I learn about potential digital solutions or tech tools the more I realise these ‘bits of kit’ really are starting with the fundamentals of codes, formulas, data schemes, rules and shapes. But this isn’t where the ‘planning’ magic happens though! the most interesting bit of planning is the placemaking – that wibbly wobbly moulding of spaces and places that we actually got into the planning profession for. Data and rules-based assessment can help but there are some elements of place making and planning judgement that digitising the system will be unable to replace. The dream and the reality of what ‘digitisation’ of planning can achieve might be very different.

Each step should make life easier:  let’s not keep doing bad planning faster

So, with all these cautions, should we resist the coming tide of digitisation??? Well, I don’t think we can and, in any event, this is pushing at an open door. Most LPA planners I’ve spoken to in the last 18months say digitisation was the part of the ‘Planning for the Future’ proposals they were actually excited about. This is an area of planning reform which definitely has support across the public & private sector divide. Digitising the system will happen but only if makes the way we work easier, simpler and quite frankly more fun. When digital tools add burdens to workloads or don’t add tangible benefit, they tend not to be successful. A classic example is the brownfield register process, whilst it might be a shining example of collecting consistent information using set data standards in reality it hasn’t achieved its original aim of realising brownfield sites to the SME development market and many LPAs view it as yet another data collection they need to undertake with very little point. We need to ‘show the world’ through this journey to digitisation the extra value of placemaking and answer the question ‘what does the better use of data buy?’. The creation of tools to use, automating processes and creating digital versions of what once was a paper document is all well and good; but making things digital for sake of just being digital is not going to be good, it will just digital but bad.

Tools and tech to help processes such as assessing SHLAA sites or monitoring housing completions become easier and automated is great and I can see many time saving efficiencies. But tools are only as good as how we use them; let’s not keep doing bad planning but faster.

Who is up for the journey?: capacity building in planners

Whenever I hear industry commentators speak about the role digitisation in planning reform the issue of resources and skills in councils gets raised. There seems to be a lack of faith that a new digital way of working will be within the capacity of local authority planners. I respectfully disagree; there are plenty of amazing planners working in councils who have the digital/GIS skills and the ability to implement digitisation and would happily adopt new tools and tech into their work. The problem is they aren’t current given the headspace to innovate or the time to drive digital transformation. Digitisation simply isn’t in the core business of churning the apps and making a plan – the hamster wheel of a planning department! Most of the private sector involved in the digitisation of planning have extensive research and development programmes with new solutions being tried and tested, yet councils who have any time or resources for planning R&D are few and far between. This seems ridiculous as most of the solutions and innovations being created will have LPA planners are the ultimate primary user. Don’t get me wrong user research involving LPA planners is happening and is, of course, worthwhile. But what we gave LPAs themselves the creative headspace to come up with digital solutions that were actually tailored to the problems.

Over the next 5-10yrs the world, and how planning operates within that world, will be very different. A digitised planning system and using smarter data will have become a core part of how we make places. However, at this point in time, right now – LPAs are so busy doing the day job, it leaves the question where does the innovation come from?

Thanks to my friend Mary for the lovely photoshopped image of me as Olivia Newton-John having listened to me go on about digitisation all year @maryindevon (Mary Elkington – Figura Planning)

Biodiversity net gain – looking for perfection in an imperfect world?

I thought I’d write a blog to celebrate the 18th anniversary of when I started working in planning for the natural environment with English Nature in Kent. Looking back on my career, I feel we’re in a more positive place than we have ever been in terms of environmental planning, but we are also much more aware of the huge challenges we face – Monday’s IPCC report and its ‘code red for humanity’ bringing these into sharp focus. My feeling is we’ll only deal with these challenges if we take action now and learn as we go, not expecting any solution to be perfect, but taking small steps to move us forward all the time.

Over the past couple of months, I’ve been running workshops for local authority officers and Councillors to inform our PAS project helping LPAs get ready for mandatory biodiversity net gain. These have generated a huge amount of useful information and input both for our project, but also to pass on to Defra and Natural England as they develop details of how the scheme will work. 

There is a lot of positivity out there about this new initiative, but also significant concern about how it’s going to work. How can overwhelmed planning departments with no ecological expertise make decisions on whether an application is compliant? How do we avoid developers gaming the system? How do we make sure this actually delivers gains? Won’t biodiversity net gain make schemes unviable?

In the meantime, there have been some articles in the press criticising biodiversity net gain, seeing it as a spreadsheet exercise or numbers game and implying that it will lead to more habitat loss and environmental destruction, plus that it is incompatible with ‘re-wilding’.

At the moment, we don’t have all the details of how mandatory biodiversity net gain will work, as the Environment Bill provisions will be accompanied by secondary legislation and guidance. However, we do know that a number of key safeguards mean it should be a significant improvement on what happens now. An important point is that biodiversity net gain does not replace any of the existing protections for sites, habitats and species in place now, nor does it replace the ‘mitigation hierarchy’ of avoid impacts first, then mitigate them and only compensate as a last resort. We also know that net gain provisions will not apply to certain irreplaceable habitats (as yet to be confirmed, but undoubtedly to include ancient woodland) and that councils will receive ‘new burdens’ funding to implement the new requirements.

Undeniably there are issues with biodiversity net gain and it won’t (and doesn’t yet) work perfectly, but we need to compare it to the currently very imperfect system where the majority of unprotected habitats (outside designated sites, like SSSIs) are lost through development and not replaced in any way, even to achieve no net loss. 

The Biodiversity Metric provides a way of calculating habitat losses and gains to enable us to try and achieve a net gain. Yes, it’s not perfect and it does simplify things, but the new Biodiversity Metric 3.0 is a huge improvement on the previous 2.0 version (despite recent media reports, which almost exclusively related to issues with the old v.2.0). 

We need a system that is workable and given the complexities of nature and ecosystems, that will always have to simplify and cannot possibly take everything into account. Also, the metric is not the be-all-and-end-all, the system around it really matters. We need strategic planning for nature and the right resources and expertise to make good policy and decisions (on biodiversity net gain, but also existing nature-related planning provisions). This Natural England blog and Tony Juniper’s introduction to the metric on YouTube (about 4 mins in) explain this eloquently. 

Thinking back to 2003 when even trying to protect an internationally designated site for nature was a battle, I no longer feel like I’m waving from the sidelines. Biodiversity net gain, along with a number of other tools and initiatives, offer us a huge opportunity to address the crises we face and create better places for people and nature. 

Yes, we need to be aware of the issues with new approaches and try to resolve them, but we also need to start giving this a go and try it out – in the end biodiversity net gain is going to be mandatory in a couple of years’ time and we’ll have no choice but to get on and do it. That way, we’ll also be able to test and improve as we go (as has happened with the metric). 

I don’t think we’ll ever have a perfect solution – nature doesn’t follow rules – but BNG is a lot better than what we have now, where the majority of development leads to outright biodiversity loss, not even no net loss. So that’s what I plan to do with this project – help LPAs get started and give biodiversity net gain a go, sharing existing good practice and showing how it can work and move us another (quite big) step forward.

Infrastructure Delivery Plans: What if they actually delivered?

Last week I tuned in to the RTPI’s #Plantalk session with Sara Dilmamode, Director of Citiesmode, on infrastructure delivery plans. In the title of her presentation Sara raised a fundamental question that I think on reflection will resonate with many, that is “Infrastructure delivery plans: What if they actually delivered?”.

Sara and I have worked together recently on the development of the PAS advice note “Start with the spend in mind”. This is aimed at helping local authority senior leadership teams to understand the role(s) of the Community Infrastructure Levy (CIL) and Section 106 Planning Obligations (S106). At the heart of this advice note is the push for the recognition that local authorities have a fundamental role in leading from the front the coordination and delivery of infrastructure to support their areas. This will of course become ever more important as we reflect and plan for the impacts of the current coronavirus (COVID-19) pandemic in terms of how we continue to shape the places within which we live and work and what demands this places on existing, or the need for new, infrastructure.

Effective infrastructure planning, prioritisation and importantly the governance of spend are critical to supporting our communities and the delivery of sustainable development and growth. Like many things in the planning system infrastructure planning is continually evolving and it is imperative that this is reflected in an authority’s governance process. Developing Infrastructure delivery Plans (IDPs) as static evidence documents to support a local plan at a fixed point in time with no commitment to a periodic, and of course proportionate, update can render such documents in the longer term purposeless. IDPs often take the form of long wish lists that can become out of date very quickly and which fail to provide any form of prioritisation for bringing forward the infrastructure that is required to support the delivery of
the local plan.

Kept alive and up to date IDPs do have the ability to help an authority to prioritise and deliver the infrastructure that is required to support its area. But this needs to be a coordinated approach by an authority with strong leadership, clear processes, effective governance and a continual dialogue with infrastructure providers and users. There is immense value in getting people around a table and this is the number one lesson that I learned from my former boss, Graham King, when working on the redevelopment of Paddington Basin and the delivery of critical infrastructure back in the naughties.

There is other good practice out there, including Greater Norwich and Chichester District Council who are mentioned in the #Plantalk session and the PAS advice note. Their commitment to clear governance processes is enabling the delivery of infrastructure through the effective spend of developer contributions and other funding sources.

The requirement to produce an Infrastructure Funding Statement (IFS) by the end of this year should not be approached with trepidation. Whilst there will inevitably be for some authorities hard work to be undertaken to bring together the required information, an IFS offers the opportunity to showcase effective governance of developer contributions, infrastructure delivery and consensus for future priorities.

I would urge you and your leadership teams to watch the RTPI’s #Plantalk session with Sara and read our advice note “Start with the spend in mind”and raise the profile of this incredibly important area of work within your authority.

Speeding up plan making

It’s not a new discussion and it will always keep coming up but at PAS we have recently been considering how to speed up plan making.  With the inevitable delays that the Covid-19 situation will cause in many areas, the conversation seems even more appropriate at this time.

We were set the task as the PAS team to stop talking about speeding up plan making but to write out our thoughts on one side of A4 (no font size reduction or margin shifting allowed!). For something to be mentioned here, it needed at least three of us to have raised it. This gave five themes to discuss:

Better use of strategic planning: ensure that strategic planning is undertaken at the correct geography and not necessarily just at a Housing Market Area level and certainly not if that was just one LPA area. Creating the strategic vision is key in this document and ensuring no change will be made through follow on Development Plan Documents (DPD’s). These strategic plans should consider green belt, housing distribution, strategic sites and infrastructure delivery to allow Local Plans to be free from the arguments that always surround those topics.

Reduced but better consultations: there should be fewer formal consultation periods but more informal, constructive conversations particularly with infrastructure providers as the process develops.  It was suggested that deadlines should be set especially between the regulation 18 and 19 stages, but would there be a penalty for not adhering? Within the consultation material, officers should be allowed to offer a professional opinion more readily and earlier on regarding the real options that are available for the delivery of growth.

Early engagement with PINS; It was felt that the early engagement that took place with PINS was always useful and therefore being able to strengthen that early engagement between PINS and the LPA would be really helpful and may help in some way speed up the examination process. An ofsted style inspection was also suggested with planning teams and/or plans rated as good, outstanding etc. maybe a new light touch test?

Reduced evidence base: an easy thing to say but very difficult to undertake is to strip out the unnecessary evidence base and be more proportionate. This may ultimately require greater guidance, but it could help save time and money currently spent on evidence base. Any evidence base should use digital technology in a much better way and as a minimum there should be more use of GIS. Linked to this was a suggestion for the removal of deliverability form the test of soundness which would help to reduce some evidence base requirements.

More and more focused DPD’s: this may seem slightly counterintuitive to speed up plan making, but a suggestion was made for more DPD’s that cover specific sites and/or focused topics. This approach could offer greater flexibility and an ability to keep your planning policies up to date. Would you still need to produce a Local Plan, or could it just be a few pages long? Going one step further, a national Development Management (DM) DPD was proposed that would be used unless you replaced it with your own local policies which could help to reduce the policy vacuum when plans no longer follow current guidance.

Through undertaking this one side of A4 challenge, some of the notes from a retreat held not long before things started to ‘lockdown’ came out.  A few of the great and good of Planning were invited to a DM focused retreat. When first told, my mind immediately pictured Richard and Martin sitting about on low-slung chairs, yoga in the morning and evening, homemade vegetarian food with a cool ‘chatty’ vibe around Planning – I wasn’t actually there at the council offices in Wolverhampton so can only assume it must have been like that!

Speeding up plan making was a topic discussed through the retreat and all sorts of solutions were discussed, as you can when you have been given the time to think.  Some of the comments you would expect, others you may disagree with. One you would definitely have expected and most likely agree with is that infrastructure should come first and that there should be greater, and more proactive, levels of infrastructure planning across all sectors for growth in a coordinated manner. Viability came up and discussions were had about greater predictability for land value capture and anything else that could help to reduce (or stop!) arguments around viability.

The amount of land that LPA’s hold was discussed and how that could be developed in partnership with small medium enterprise builders, but with planners having a role in the master planning of the scheme. This would allow planners to be more creative, a skill that seems to be disappearing as the focus is all too often on numbers and tests and the risks associated with not passing them.

It was interesting to read that it was suggested that only 10 policies in a Plan are ever used, so why write anymore and rely instead on the NPPF.  If only I had known that back in LPA times, sweating over every word to be written in a policy! I must caveat at this point to say I am working off notes, so it may have been only one person said that, I hope so to be honest.

Zoning was discussed and it doesn’t appear that a conclusion was reached but issues such as needing to bring together all mechanisms were raised, as zoning wouldn’t just work as a planning tool and it probably wouldn’t deliver the level of housing required. Another fundamental shift in the planning system would be required and there will be very few planners with the experience to undertake this.

There are lots of interesting ideas to consider and all will be fed into MHCLG in some format or other. I really want this to spark some conversation around how to speed up plan making. A final thought, that arose from the retreat was…could a plan be produced in a year? Could it?

Reflections on Housing Delivery Test 2019

In advance of the official updates to our guide and templates, I thought I would share where I got to with my thoughts on the Housing Delivery Test and the very first set of Action Plans.

These thoughts are the result of the dozen workshops we held throughout spring and summer with representatives from 60 councils, along with some follow-up work on a mixture of action plans.

We will be doing some more robust testing and thinking when the councils action plans are published. This is a “seat of the pants” reaction to the many and various thought-provoking conversations I had with the wonderful delegates over the last 5 months.


To start with a few weasel words. This is the first ever cohort of action plans, and the timetable for their production couldn’t have been much worse. The clock started with without any proper lead-in on February 19th, and the six month deadline is therefore in mid-August.

Not only is August just a dreadful time to get sign-off and agreement on documents, but the fact that meaningful actions require the agreement and consultation with various other stakeholders means that the first iteration of these plans is likely to be low-key. Expect lots of “investigate further the reasons behind …” and “explore options with stakeholders” without much actual stakeholder engagement.

Part of what we asked councils to do was to understand their land supply and the causes behind slow and stalled sites. And it won’t be a surprise to anyone close to the work that the world of monitoring is not a happy place, with much of it manual, painful, and difficult to marshall into something useful at short notice. #plantech please come back all is forgiven.

Lastly, and this may be an obvious thing to say, there just isn’t a bunch of silver bullets lying around waiting to be fired by LPAs to “fix” the delivery of housing in a single bound. All councils are already trying a variety of approaches to boost housing, and most action plans will recount projects that are already to some extent underway.

Causes of housing under-delivery

“All happy families are alike; each unhappy family is unhappy in its own way.”

Tolstoy – Anna Karenina

I can’t now remember where I read it, but I was expecting to find that while there may be broad macro reasons for under-delivery there would be a local and specific story for each unhappy major site. I was expecting a complex patchwork of causes making my job of drawing out some common themese difficult.

Instead what I found was that many councils view is that the cause of failing the test is that the test is using standard method numbers, rather than locally appropriate numbers.

[as a slight aside, what I took away from many of these conversations is that the approach of Part 1 strategic policies / Part 2 allocations is a bad idea for many places. The regulatory goalposts move too quickly – the higher level plans move too slowly – the electoral cycle revolves. The allocations appear late (or not at all) which makes it difficult to bring forward big sites and leads to appeal friction. Far better for many LPAs to move to a simpler all-in and review every 4 years approach in my view.]

Slightly depressingly, when taken at face value, this suggests that the cohort are behaving towards the test in a predictable way. Don’t like the test result? Change the inputs to the bottom of the fraction and get a better result.

In the longer term I’m sure a more nuanced picture will emerge. It’s possible that lots of it will never appear on public documents but we have had many fascinating and slightly hair raising conversations about how delivery is tested at examination and how the various incentives align to create a conspiracy of optimism that quickly unravels.


This is the first time around the HDTAP loop and we were all learning together. I’m afraid I was quite unflattering about some of the action tables in draft plans. I struggled to articulate something more helpful until we had a very useful debate in Manchester about who the audience was for the action plan. Once the audience and purpose of the plan is clear, many other questions become easier to answer.

In short – you are not writing the HDTAP for the benefit of a civil servant in MHCLG. There are no marks for completeness, and no one is interested in your “list of things to do”. However, if the purpose of the action plan is to get some people to do things differently, write for them in their language and keep it tight so they don’t get bored.

In our KHub you can see my “top tips” that I delivered at our final “grand finale” event at AECOM’s office in London on the hottest July day ever. As someone said at the time, it would have been good to know them at the outset rather than the close but that is not the way inventing the art works.


It is obviously early days for the Housing Delivery test as a policy. My informal canvassing at our workshops suggests that while the policy attracts criticism for being one-sided, the requirement to understand delivery from other perspectives [and, importantly, away from the context of a local plan examination] has been extremely useful.

The test could lead to a culture change more generally, where planners are forced to confront the fact that delivery is a team game that requires local knowledge, intervention and creative thinking. It might also have a useful knock-on effect on local plans – framing them more clearly as delivery plans.

However all good projects start with evaluation and I worry that the most important voice of all is missing. Taken simply – the purpose of the test is to push councils into taking action to enable and facilitate development that might not otherwise have happened. The people who are in a position to judge this are developers. We need some way of capturing their perspective to ensure that the HDTAP isn’t just another annual report that no one reads.

Looking forwards

As mentioned at the top we learned alot along the way and we know how to make our guides and templates stronger. And even without any more input from us I’m sure the cohort of councils repeating the HDTAP process in November 2019 will be able to produce a better document than they could first time around, jut by virtue of having more time for meaningful consultation and input.

There is the updated PPG too, with a fairly clear suggestion of “assessment and delivery groups” and some other changes that need a bit more thought. The change of stance on annual position statements makes it clearer in my mind than ever that we need to rethink monitoring more generally, and get the most possible value from the least possible work. The current situation with a mishmash of different timetables and requirements is intolerable – I will ask some of my new, geeky, monitoring friends how we might reorganise and improve this shortly.


Ombudsman the bogeyman?

Ombudsman cases: does the risk warrant the reaction?

We’re starting another round of support for councils struggling to process applications quickly enough. A lot of our support helps councils make their processes slicker. One of the most common things to slow a process down is having lots of checks and hand-offs built into it.  These build time and cost into the process and, counter-intuitively, often make it more vulnerable to error (the next person will pick up anything I miss).

Many hand-offs and checks are built-in after an error, omission or failure-to-do-something resulted in an ‘Ombudsman Case’ (usually a few years ago). The checks and hand-offs are normally applied ‘across the board’, with little regard for the type/variety of work in the system and therefore no real understanding of the risk that an ‘Ombudsman Case’ really represents.

How big is the risk?

So, does the time and cost of the checks and hand-offs justify the risk/probability of a case ending up in front of the ombudsman? I did a 5 minute bit of research. You can search the Local Government Ombudsman website so I looked for cases that involved ‘planning applications’ over a 2 year period (April 2014 – April 2016). The number was about 2,400 cases. If you consider that councils process around 600,000 planning applications a year then my Ombudsman cases represent about 0.6% of applications.

A colleague recently worked out that you can save around 2 days of time if you manage to shave 1 minute off of the processing time of every thousand applications you handle. Consider how many minutes (hours, days) are taken up by unnecessary checking, hand-offs, and cases sitting in the backs of queues. So if every council in England saved itself a minute by eliminating a hand-off the sector would buy itself around 3 years’ worth of extra time to deal with planning applications.

Once bitten thrice shy?

I understand why checks are introduced – no one wants the expense and bad publicity of an Ombudsman case. But does the risk really justify the approaches taken by some councils? I know of at least one council that checks that the right consultees have been consulted at least 3 times during the processing of an application.

Now you may say that it is because of the checks and hand-offs that the ombudsman cases are so low. But even if every ombudsman case was a planning case that would still only amount to 20,000 (more crude research) a year – a mere 3% of total planning cases processed.

My research was quick and crude and a bit of idle fun (I am sure someone closer to the subject than me will challenge the numbers), but I hope it will help all of us feel a bit more comfortable about abandoning a lot of the unnecessary checks and hand-offs we’ve managed to strangle our planning processes with.

Putting your mouth where the money is

This blog is about a new initiative from the senior planning managers at Swindon Borough Council Called “Rising to the Challenge”.  They have rightly appreciated that to meet current challenges in local areas, it’s necessary that more than just the Planners and Economic Development officers understand the advantages of a managed, growing economy alongside all the other challenges of a healthy population and vibrant places.

Swindon Borough Council do have a strong wish to grow their economy.  They were the fastest growing area of the country in the 1970s and then had a bit of a decline in fortunes as the heavy industries that this blue collar town relied on moved away or died.  But now Swindon is back and hungry.

Swindon had an “Open for Business” peer challenge from PAS a couple of years ago.  They say that helped to make the step towards the planning service (officers and members) becoming more aligned to the needs of delivering investment growth through new developments and being responsive to the needs of businesses.  It also helped to foster an appreciation that success was going to be more assured if the development was high quality and aligned to a planned spatial strategy that set a framework for decision making.

The new initiative is to run a series of  seminars called “Rising to the challenge”.  The purpose of the Seminars is to help Swindon grapple with the big planning challenges ahead by getting in leading thinkers / practitioners to speak on the issues to help guide their approach.  Speakers are being brought in from a range of local and national organisations, other towns and other parts of the council.  The audience is as wide as they can manage from councillors, community voices , interest groups and people from a range of council services and public sector bodies and developers.  The seminars are hosted in Swindon’s great Steam Museum – a potent reminder of how heritage can be conserved and turned in the direction of the future – and a venue that made people feel good/valued at having been invited.

I went along to the seminar last week when the topic was  “Delivering Good Growth”.  Speakers included an inspirational talk from Peter Studdart about the Cambridge experience and a pithy talk about where Swindon is among the galaxy of similar (maybe competing) towns in terms of a range of indicators of economic health from Andrew Carter of the Centre for Cities. The afternoon sessions looked at working with the LEP and the work going forward in partnership with the HCA on a range of schemes especially delivering the necessary infrastructure for  essential town centre regeneration schemes and the housing urban extension at Wichelstowe (2 of several). The final speaker wrapped up the day with a great talk that pulled together all the threads of activity in their growth strategy, and set them in the context of the aligned local plan, business plan and economic development strategies.

The audience were clearly caught by the ideas judging by the animated discussion that followed.  I didn’t catch any whiff of NIMBYist “alright in principle, but…”.  There was plenty of talk about what was good design in terms of Swindon.

The seminar topics are

  • Good Design (presentations here)
  • Delivering Infrastructure to support growth  (presentations  here)
  • Delivering Good Growth (presentations here)
  • Planning for an ageing population ( seminar 15 December)
  • Planning for a Healthy Swindon
  • Citizen engagement in the Planning of Swindon

This was about a council really taking the time not just to do consultation with their community, but really pulling out the stops to change hearts and minds about attitudes to development – making the situation real, talking about consequences without shroud waving and showcasing the breadth of ambition across the whole local authority area… and it was being lead and coordinated by planners.




Getting It Together

When was the last time you sat in a room with your colleagues in Education, Highways, and Estates? Did you have the Director in the room too?

I helped run a session yesterday in Darlington. It struck me that this is something that all councils should make time to do. We hear too often about a ‘disconnect’ between the assumed priorities for different council services. This is not an issue purely for two-tier councils, although the physical separation of colleagues can make this more difficult.

But ask yourselves, is it better to be firing off emails and letters to colleagues, with a seemingly endless and often circular paper trail, or is it easier to set aside a whole day to discuss the big picture?

Darlington does not strike me as a place where relationships are difficult. The mood in the room was positive throughout. The contributions from all colleagues were insightful and asked just the right sorts of questions. As the discussion moved from the scale of housing need to potential location, all kinds of joining up was happening. There was instant feedback on potential issues, but also solutions, to many sites. You know the sort of conversation which, if in email form, would probably have taken weeks or months to have.

We then had a quick session on the key question that many people miss out on, as they chase processes. “What does success look like?” Whilst there were obviously some rather specific answers relating to each service area, it was clear there were some key themes that came up for everyone. What came out in particular was the theme of ‘making good places’. Place making, or place shaping as a term has fallen out of vogue, but if that’s not what we’re all planning to achieve, what are we planning for?

So if you do have regular get-togethers, then your plan, and the delivery of council services, is going to already be in pretty good shape. If not, what’s stopping you? If you’d like PAS to help facilitate or feed into the organisation of the day, just get in touch.