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.
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.
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.
Since my last blog on transition, I’ve been surprised at how quiet things are on this topic. At the PAS conference (Wolverhampton, July 2022) I presented a few ideas and hypotheses about the transition from the present planning system to the new ‘Levelled Up’ one. These are set out below along with some feedback from the conference attendees.
Some movement starting…?
The recent letter from Greg Clarke urging PINS not to fail Local Plans over the Summer may signal that some announcement is afoot (the heralded NPPF prospectus?) in Autumn. And the announcement from Dorset that ‘having spoken to Government’ that they’ll be taking a further few years to adopt their plan and (most interestingly) that they have asked to be ‘part of a pilot for a new national approach to local plans’.
Why is it quiet? Parts of the Levelling Up & Regeneration Bill (LURB) are receiving lots of attention e.g. the new Infrastructure Levy or being PAS work-shopped (Environmental Outcome Reports). Other parts are slowly becoming embedded such as design codes and the (oh so slowly) creeping digital agenda. But its largely silent on how we move to a new system for making a local plan – the thing that is going to hold all of this together.
In May the then Minister Stuart Andrew encouraged us to ‘keep on planning’ and that transitional arrangements were being worked on ‘at pace’. There was also some early conjecture about incentives to get your plan in place as soon as possible (e.g. that the 5-year housing land supply requirement may disappear for up-to-date plans).
December 2023 – an incentive?
DLUHC seem to have stopped referring to this date, however I am working pretty much exclusively with councils going full steam ahead to get plans in place by Dec 2023. Over half the councils at our conference are as well. Greg Clarke’s recent letter to PINS may spell good news for these councils, especially those at examination right now. For these councils, the requirements of straddling 2 systems while plan making will be for others to grapple with. It is the councils that are about to start a review of their plans that are going to have to pick up the baton on transition soonest – they’ll be the front runners that will be learning how to plan in the new system.
The biggest change/challenge is the timetable
Take away all of the noise, the aspiration and the detail (where there is any) and the LURB system local plan and process looks pretty similar to what we currently have – policies, maps, 2 consultations, examination.
The big change is the expectation that the plan making timetable will be CUT IN HALF from an average 5 years to 30 months. Everything that LURB is proposing on plan making will need to be condensed into at least half the time it currently takes. That is eye-watering. The ‘speeding up’ comes from 2 broad directions:
The mechanics – there are the new time-saving elements to factor in; front-loaded consultation, National Development Management Policies (NDMP’s), streamlined (proportionate?) evidence bases, mandating infrastructure providers to engage, Environmental Outcomes Reports (EORs to replace SA/SEA) – all good ideas to save time.
The process – the proposals for local plan commissioners, Gateways Reviews, a replaced Duty to Cooperate – again all good ideas on paper but how will they work to reduce time in the overall process?
There has to be enough time factored in to learn about, test and integrate these new and adapted processes into our plan making activity. How can we avoid a standing start? Hopefully more detail on these individual ‘speeding up’ elements and how they will all work together will be available soon. Once the detail begins to emerge, we have to be prepared / make time available to learn and bed things down. Anyone that has been in the improvement game knows that introducing improved ways / systems of working often causes a system to slow down in the short-term. Room and time have to be allowed to allow the changes to take root and for the first positive effects to begin to show and the learning transferred.
Less burden has to be accompanied by less risk
While changing the mechanics and inputs to the process we must also keep an eye on the more structural (and cultural to some extent) aspects of plan making that will need to change/adapt to make a new system work.
I can see how we will over time reduce the burden on evidence base production via digitisation as the updating of evidence in future becomes more streamlined, however there will be a period of bedding down. To deliver a system that requires a shorter and less information-intensive approach (e.g. 50-page Environmental Outcome Reports replacing sustainability appraisals) and a more proportionate and streamlined evidence base, the plan examination system has to adapt with it. There should also be some built-in recognition of / protection from legal challenge; QC’s are expert at finding chinks and gaps in the masses of evidence that support plans currently – how will a radically reduced evidence base hold up to the same scrutiny?
Front-loaded consultation and digitisation are heralded as the panacea’s for greater and better community consultation, and I think this is a broadly correct assumption. It does have to be more than reaching wider audiences through technology and presenting our plans and ideas on maps and using 3-D imaging – there is a fundamental requirement to make planning simple to understand – e.g. nothing digital or map-based is going to explain to our communities in logical terms how we currently arrive at the housing numbers we’d like them to accept. We can and must get better at all of this and we have to also be prepared to resource, manage and integrate greater levels of engagement as communities do become more planning ‘savvy’ and want to get involved to support and challenge what we are proposing in our local plans. Levels of engagement are already rising as communities, especially in constrained, and more and more councils are struggling to resource ever-growing consultation responses.
Back to my conference story. For the sake of starting a conversation/argument I presented a few made-up hypotheses about what transition might look like in terms of timing. Here’s what I set out:
Hypothesis 1 – December 2023 – the drawbridge goes down on ‘current system’ – councils will have to have their plan submitted by December 2023 otherwise the plan has to be prepared and produced in the new system under transitional arrangements.
Hypothesis 2 – January 2024 – New NPPF and Regulations are set with the requirements for new system local plans
In this world, councils will fall into 4 broad categories:
New System Plans – those councils intending to wait and begin their plan making process after January 2024. The first plans will be in place from June 2026.
Current world plans submitted on or before end December 2023 – Those that submit their plan to the December 2023 deadline and will arguably not have to think about starting the process of getting a new system plan in place before 2028.
Current / New World transition – those councils starting to review their plans now will find themselves straddling the current and new system completely – it’s for these councils that the transitional arrangements need to be clear – not least to avoid wasted work.
New Unitary councils – have 5 years to get a plan in place – will/how will the transitional arrangement affect them?
So what to do in the meantime?
I understand the reasons so many plans are stalling and why many are waiting for the new system. Why carry on if a new NPPF (prospectus?) is imminent? Why waste time, effort and cost? Then there is the hoped-for arrival of lower housing numbers. But is this really doing the best by our communities? The waiting game comes with risk as local plans and polices age and become vulnerable to speculative development and confuses communities as plans are ‘pulled’ to protect them from too much development (housing) and then housing sites are granted permission on appeal and in places not even allocated in the plan.
My view – keep going where you possibly can
I am asked constantly by councils for my advice on pressing ahead/slowing down/stopping. My (non) answer is always the same; I ask the following 3 very broad questions;
Do you have clear evidence that delaying, slowing, stopping the local plan will benefit all of the communities your council represents?
Have you fully weighed up and quantified the risks / uncertainties for your place that the absence of an up-to-date plan creates for your communities and investors?
Do you have the backing of your communities / investors for your preferred course of action?
The reasons for stopping and delaying can be either very narrow; “housing numbers are going to change” or very broad; “it’s too uncertain right now”. The narrow arguments betray a massive misunderstanding about what the local plan is there for and that housing, while important, is not the only thing we plan for. The broader argument just doesn’t hold water – the world we plan in is constantly uncertain, it is one of the fundamental reasons we make plans in the first place.
Plans will always needs evidencing, consulting on and need some form of testing/examination so I personally would recommend that councils keep their plan making and plan updating activity going. And I urge the government to consider in its transitional arrangements how it can reduce any burden (perhaps even ‘rewarding’) those councils that are, despite massive pressure to slow down or stop, demonstrably carrying on planning and trying to get their plans updated and in place.
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.
The 30 second summary is
Capacity – it presented as many things (fees, experience, churn) but finding more planner capacity is urgent and critical
Generally people thought the LURB and stated direction of travel for the planning system was a good thing
People were getting on with things, and the “levelling up” agenda plays very naturally into skills and aptitudes that feel very comfortable for planners
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.
Findings and reflections from a workshop on town centre regeneration at the PAS conference for Heads of Planning and Rising Stars, Wolverhampton July 20221
“Town centres are close to my heart” said one conference delegate as we made our way to the town centre regeneration workshop in Wolverhampton earlier this month. I share her sentiments, especially for my own town centre in Barnsley, South Yorkshire.
Sometimes a victim of ridicule in the past, and with previous plans beset by problems and delays, the regeneration of Barnsley town centre is never the less emerging as a great success. Just this spring, Barnsley was amongst the top 10 places for both footfall and spend recovery following the removal of Covid restrictions, and you only have to walk around the place to see the new businesses and numbers of people. I think Barnsley and many similar town centres have a good story to tell, as well as some real opportunities in the future.
With these thoughts in mind I joined over 40 other planners, representing a range of different authorities and types of town centre, at the PAS conference to discuss recent trends and the role of planning in the future.
Town centres and high streets have experienced many changes and challenges over recent years, but few as significant as the Covid-19 pandemic with official lockdowns, radical changes in consumer spending and moves to flexible (home-based) working for many people. This workshop was a chance to take a step back and think about the issues and opportunities now facing our town centres. In particular, we explored three questions:
What has been happening in our town centres over recent years?
What does this mean for the role of our town centres in the future?
As well as data and evidence, this workshop was also a chance to think more broadly and speculate about the factors likely to shape change in the future. We drew heavily on Mathew Carmona’s work on the existential crisis facing shopping streets and what makes a place attractive, which provides some good pointers on where planning practice should be focusing in a post covid economy, including the key factors shaping the way people choose to shop.
It would take too long to detail all the issues we covered, but I’ve attempted to capture the key points. Some of these reflect issues that are common to many town centres, but others suggest differing experiences in different type of centre or different regions of the country.
What has been happening in our town centres over recent years?
Many find it difficult to answer this question with confidence. Town centres are dynamic, with changing trends and patterns of decline or development that vary constantly. Frequent monitoring is often beyond the means of local planning teams. Added to this, the introduction of a new Use Class E in September 2020, which now covers the majority of town centre uses meaning that significant changes can take place on a high street without the need for planning permission or any formal interaction with local planners.
A few places, like Bolsover, are undertaking annual surveys of their town centre as well as utilising mobile phone data as a proxy for footfall. Others, such as Newbury, utilise data from a Business Improvement District. For many though, comprehensive evidence on the town centre is limited to local plan production or preparation of a masterplan.
Of course, anecdotal evidence is also an important source of information and there are some common experiences. The decline of town centre retail is not a new trend, but Covid has helped to accelerate this in many areas. Places as diverse as Canterbury and Plymouth, Colchester and Peterborough or Mid-Sussex and Beverley have all experienced the loss of department stores or familiar high street names.
Whilst this is common to larger towns, it is seen as less significant in smaller centres which have a stronger independent retail base and therefore less in the way of national multiples to lose. The differing experiences of larger and smaller town centres means generalisations are difficult and experience in places like Cheshire East and the East Riding suggest fewer problems for retail in their smaller towns.
A decline in retail has led to an increase in vacant units, but this contrasts with a boost in the number of food and drink-based businesses (including evening economy type venues) that is helping to re-animate town centres. It marks an increasingly important role for leisure in town centres, with planners from places as different as West Berkshire, Ipswich, Worthing and South Norfolk all experiencing the trend.
Many were also keen to talk about the increasing importance of town centre residential development. Given the introduction of a new Permitted Development Right (PDR) for the change of use from Class E to residential, this is a major part of Government policy and perhaps not surprising. But only a few places, such as Milton Keynes and Medway, report pressure for conversion of former offices to residential uses in significant numbers. Although it is a concern, PDR to residential is not yet seen as a significant trend in large parts of the country.
Instead, local councils are working hard to support new residential uses on planned sites as well as bring forward projects directly in partnerships with developers. The desire to attract town centre-based living in increasing numbers is an ambition that ran throughout the workshop and encompasses all areas. A good example is Dartford where town centre housing is not currently widespread, the new local plan encourages higher density housing, and the Council are addressing viability issues to bring forward difficult sites.
What does this mean for the role of town centres in the future?
More town centre housing, both higher and medium density, is something that many planners see as central to the future. This is based on the transport links and access to amenities that town centres offer, providing opportunities for sustainable housing on sites that become available as retail, commercial and other traditional land uses scale back.
Importantly though, planners are also alive to the benefits that a town centre residential community can bring in terms of increased spend and footfall for business as well the potential to attract new people to their district. At one end of the age scale, this may be younger professionals enjoying the opportunities of distance or flexible working and a town centre-based lifestyle. At the other end of the age spectrum, older and retired residents could be important town centre communities, benefitting from easy access to local services in amenities.
To support diversification, planners are also making efforts to introduce mixed-use development with many local authorities involved in direct investment to deliver hotels, leisure and residential alongside convenience retail schemes. For example, Cherwell Council are redeveloping a shopping centre with a hotel, supermarket, cinema and restaurant in Banbury, a significant financial commitment and long-term effort to diversify. In other places like Rochdale development is already underway and in Norwich change is being supported through City Deal and Transforming Cities Fund investment. Many councils have also taken ownership of vacant shopping space in preparation for new mixed-use schemes.
But this is not the case for all areas, and different town centres will pursue different strategies or seek to define themselves through different roles in the future. Participants talked about the Unique Selling Points (USP) they are trying to define for their town centres. For example, Canterbury is leveraging its heritage offer; whereas Worthing has an appeal through its seafront setting and proximity to the coast; and Bolsover needs to boost the provision of overnight accommodation to maximise potential for visitors to the castle and surrounding countryside.
Education also emerges as important, with some areas seeing positive impacts from the development of new further and higher education facilities. A new college campus alongside culture and leisure facilities is helping to transform a traditional town centre offer in Dudley, whilst Epsom has seen student footfall benefitting their town centre through a University of the Creative Arts. Peterborough is also seeking to establish a new university centre and Ashfield is introducing education hubs to its town centre.
What should planning be doing?
This was the question that generated the greatest amount of discussion and suggests town centres remain very much at the heart of local planners’ focus. Major areas of work for the future include:
Ensuring stakeholder engagement – looking beyond traditional consultation, this means actively working with and alongside local groups, businesses, and other public services to share knowledge, facilitate constructive discussions and create consensus on long-term objectives. It’s more than the usual argument about how many car parking spaces are needed!
Preparing comprehensive plans – many planners in the room are working on town centre master plans, strategies or supplementary planning documents. Although different plans will have a different planning status, they often bring together individual projects or schemes, set a policy framework and ensure that interventions are complementary or sequenced. A town centre plan can also help to build investor confidence as well as reduce the risk for Council assets in the town centre.
Consolidating retail areas – rather than extending a town centre, regeneration in the future is about consolidation. This means defining and then strengthening the core of a town centre’s retail area as well as enabling positive change to the surrounding areas. Many in the workshop talked about managing the contraction of retail space and identifying appropriate uses for sites that become available, i.e. residential, leisure or employment.
Delivering catalyst sites – town centres can contain several vacant sites or underused areas which rapidly become a barrier to progress or could be transformational if delivered in the right way at the right time. Planners are identifying these opportunities, and many shared their experience of using development briefs or masterplans to help bring them forward, often alongside bids for funding through the Local Growth Fund, Levelling Up Fund, Future High Street Fund and City Deals, etc.
Improving public realm and active travel – planners are seeking to use Community Infrastructure Levy income, Transforming Cities Funds and direct council investment to create higher quality and better designed town centre spaces, with more opportunities for enjoying time in the town centre as well as reducing the impact of motorised traffic so that walking and cycling is more attractive.
This is not a comprehensive list, with many other examples of activity in different localities. But it does suggest some core roles that planners themselves see as important to their work and which will be critical to the future of town centres.
And in conclusion …….
Reforms like the creation of a single Use Class for all commercial, business and service uses, or the introduction of PDR for residential uses, led many to suggest that there would be less of a role for planning in town centres.
In contrast, it appears from our workshop that planning and planners are at the forefront of town centre regeneration in many areas. Rather than responding to change, local planners are working with other stakeholders and taking a lead role in determining the future shape and success of their town centre.
Overall, this was a tremendously positive session revealing some of the energy and ideas that planners are bringing to town centre regeneration. We hope to build on that in PAS as we develop our work programme in this area and will maintain our support for LPAs as they continue with their plans.
I’ve always considered that the role of a planner is to be the storyteller. To develop the narrative, to shape the story and to provide well justified evidence that allows others to determine a satisfying ending. I was struck when researching for this article that unknown to me this is an academic school of thought and that there have been publications on storytelling as a model for planning over three decades. I really like this, and it led me to think about whether this would be a useful approach in helping to promote better governance across all areas of planning and in particular improved collaboration corporately across councils.
Local authority governance and the corporate role of planners within local authorities were common themes at our conference for Heads of Planning and Rising Stars last week, and so it seems timely to consider these types of issues in more detail.
Building on the work of others Tjark Gall and Sindi Haxhija (2020) wrote about two types of storytelling in the context of planning. The first they identify as “linear knowledge transfer” which is described as a transfer of information from planning, or storytelling of planning. The second is “cyclical knowledge mobilisation” which in contrast involves the process of knowledge mobilisation and is focussed on reciprocal exchange with an ambition to encourage co-creation.
As planners, we are sometimes criticised for providing “linear information” where our stories are delivered as information only with little to no opportunity for adaptation. This might be, for example, because parties have developed proposals that are contrary to the development plan. We often hear when working with council’s that there can be tension between planning and other parts of the council that are developing schemes and projects. Planning’s important role as an enabler for development can often be forgotten in a corporate setting and instead perceived as an obstacle to bringing forward corporate projects.
“Cyclical knowledge mobilisation” on the other hand is the type of storytelling where planners are working at their best and this is what should be embedded in good governance. At the heart of this is recognising the range of actors across an organisation and acknowledging that they might not all understand one another’s objectives. The aim is to encourage through organisational story telling greater awareness of each other’s stories and to use them in pursuit of corporate goals and in developing a shared vision.
This is all very lovely in theory but what does it mean in practice? In its simplest form it is creating the right framework and conditions to ensure that there is a forum in which these stories can be shared. Planning is an important statutory function, but it is also a key part of the council that can play a role in helping to shape, enable and bring forward corporate priorities. Critical to this, though, is that it must have a seat at the table. Engaging planning when projects are already well established and designed is not helpful as it becomes much more difficult to narrate a collective outcome and a linear dialogue is more likely to unfold.
My own fixation on good governance stems from years of writing planning briefs on complicated sites which required an organised and persuasive story that was adapted to address different needs and spatial perceptions. Watching these sites come forward for delivery has shown how important a shared narrative was and how positive collaboration (both with the local authority and more widely) alongside planning policy can guide and shape what might have otherwise been considered unacceptable development. Just last week I walked into the former St Mark’s Church, North Audley Street, London and was able to see the restored building in all its glory. It may no longer be in use as a church, in fact it is a street food market, but I took immense pride in knowing that a planning brief I wrote twenty years ago played a part in enabling this important historic building to continue to be used and that public access had been retained.
More recently my focus has been driven by the work that we have been doing to help councils improve their governance of developer contributions. Working with Inner Circle Consulting we have held workshops with about 30 councils over the last year or so which have involved multi-disciplined officers from across the organisations. The aim of this work has ultimately been to encourage a collaborative approach to allocating and spending developer contributions to ensure the delivery of infrastructure that supports development and is aligned to corporate priorities.
Some of the lessons from our work were shared at our conference last week. The most fundamental messaging, and one that is applicable to all areas of planning, is that for this to be successful and for aspirations to be delivered it requires a corporately endorsed, collaboratively managed and multi-disciplined approach to governance. It is clear from councils that are performing well in this area that this work requires ownership by senior leadership teams as well as strong collaborative working across the organisation. This area of work does not start and stop with planning functions, it requires corporate engagement and leadership – as do most other areas of planning.
Good and effective governance ensures that those who need to be involved are engaged with the entire end to end process. Planning might be able to write the narrative, but the role of the different actors and acknowledging their stories is critical in how this develops. Planners should use their storytelling prowess to raise the profile of this work, communicate shared goals and aspirations and provide a framework in which joint decisions can be made to provide a satisfying end to the story – that is an ending that provides for the delivery of a sustainable future in which people are able to live, work and play.
So, if you have thought about setting up a cross-council infrastructure board or local plans board, or perhaps a forum for consistent engagement with your estates teams and regeneration colleagues go ahead and remember your critical role as the storyteller. It is not always easy! There may be twists and turns or unexpected outcomes, there may be villains and heroes as well as a build-up of tension, but without the collaborative dialogue and the development of shared goals there would only be a linear story with most likely a pre-determined and unsatisfactory ending.
 Tjark Gall, Sindi Haxhija. Storytelling of and for Planning – Urban Planning through Participatory Narrative-building. Proceedings of the 56th ISOCARP World Planning Congress, International Society of City and Regional Planners (ISOCARP), Nov 2020, The Hague, Netherlands.
One of the joys of working in the PAS team is that I can spend my days talking to like minded Planners across the country, find out what they are up to and tell them about what others are doing well. Many Planners feel quite isolated at the moment and are reassured to know that they have the same pressures, worries and questions as others. I also come across some brilliant best practice so can get Planners to learn from each other and avoid ‘reinventing the wheel’ To save you all time here are my top 10 issues that Development Management teams are struggling with at the moment and the top 10 best ideas I have heard over the last year.
Top 10 issues (in no particular order)
The number of householder applications have (excuse the pun) gone through the roof and you are all struggling with the shear volume. Reasons seem to be due to the Covid effect of more home working and cost of moving.
Planners are in very short supply particularly experienced Planners who can manage those tricky Majors. The best case officers are being poached by the applicants!
Extension of times are covering up a whole multitude of sins and Heads of Planning are grappling with the need to be honest about performance versus ‘playing the game’ to avoid the threat of designation
Some Councils are getting themselves in a real pickle over validation and have a philosophical dilemma whether to treat it as a administrative process or a key part of providing a customer focused service
Desperate shortages of staff lead to desperate times and pre application normally is the area that suffers most. However when Councils stop pre applications they end up losing a vital discretionary income source and have poorer application submissions
Another consequence of staff shortages is for the remaining staff to stop answering emails and phone calls due to pressures of work. However this normally just ends up with more complaints and grief from councillors, agents and the public
There appears to be a higher expectation of Planners from the public in terms of both enforcement and determining planning applications. The world of work has changed and more people work from home so are more conscious of their local area. This means they have more time to nag the Planning Department.
Social media is targeting Planning Officers and councillors more and more in a negative way. People can view Planning Committees via a webcast and can more easily pick over every word uttered by decision makers and their officers.
The fear of challenge is leading officers to write ever more complex and long winded reports just at the time when time is at a premium. You need to be careful if you expect an appeal, legal challenge or complaint but most officer reports end up in the (virtual) back of the filing cabinet neglected and unread. Why are you spending so much time on the unread reports?
Some Councils get tied up in knots with their ‘Heath Robinson’ approach to IT. This sometimes results in very few people actually understanding how the IT system works and to a ‘single point of failure’ scenario. Successful Councils keep things simple and logical with a good backup of officers who understand how things work.
Now here are the Top 10 ideas (again in no particular order). I have purposely focused on the day-to-day ideas that help you run an excellent Development Management service. Others will tell you about the importance of aligning Development Management with the strategic direction of the Council, future proofing your service to respond to the Levelling Up and Regeneration Bill, addressing national policy etc. These are, maybe, the tips that you will not always be told about by others.
Pair the Chair of Planning Committee up with an LGA Member Peer as a mentor. It doesn’t matter how experienced the Chair is, the best way to learn is through peer-to-peer support
Have a learning through experience process where you learn from every complaint, compliment, appeal decision etc whether it is positive or negative. This is a great way to learn, show that you are learning and motivate your staff by recognising when your staff do well
Make a pact with the Section 151 officer on raising pre application income whereby you will go over and above to drive up income only if the income can stay in Planning. This a great motivational incentive for staff to drive up income and can provide the justification for recruiting more staff.
Change your job descriptions and staff structures so that staff can move around the department and gain promotion without having to apply for a new job. You must keep the best staff wherever they currently sit in the organisation otherwise someone else will poach them.
Become best friends with your nearest RTPI accredited Planning school. Then you can find out who are the best students and entice them to work for your Planning department
Introduce a ’10 minute’ officer report for the simple stuff. If a householder application has no objections and is recommended for approval it will only be the case officer and signing off officer who ever reads it so why spend more than 10 mins writing it?
Set regular meetings with senior managers to agree your position on certain key developments and ensure you are proactively delivering the things that matter to your Council. One Council calls them ‘Cobra’ meetings – you know who you are!
Invest in your website to maximise self help. Put your heads together as Planners and think about all the general questions you get asked on a day-to-day basis and then put them down in a Q and A section of your Planning pages. This means you don’t have to spend time answering phone calls and emails with the same old answers.
Get people who know very little about Planning – your partner, your children, your next door neighbour – and test the wording of Planning Committee reports and information on your website. If they don’t understand it then you need to change the wording. Remember Planning is public facing and so the public need to understand what you are saying.
Send out a pack of information with the Planning Committee agenda for Members alongside the officer report that includes plans, Google Map reference and photographs. Then at Planning Committee the officer presentations can be limited to no more than 5 minutes highlighting any key points that need to be highlighted to the Committee.
So there you go. If you already follow all the top tips well done and let PAS know if you have others that we can share. If there is something new, try it out and let us know how it went.
Most importantly keep the faith and remember – you are never alone.
At PAS I organise and manage the support for councils making Local Plans. My main Levelling Up & Regeneration Billinterest 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.
“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 landfor 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
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:
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
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.
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.
I have read with great sadness the article by Catrional Riddel in Planning Resource about the rock bottom morale for Local Authority Planners and Sam Stafford’s 50 Shades of Planning blog that supports this with personal experiences. In my role at PAS I see the stress that Planners are being put under and it is very worrying for the health of our wonderful band of Planning professionals and the future of Planning. Who would want to come into the profession when you get overworked, underpaid and abused across social media?
Well I want to try and convince you all that Planning is actually a wonderful profession. However I am going to do it from a rather unusual angle by relating it to being a ultra marathon runner. Keep reading as this will make sense soon…
As a head of Development Management at a big urban unitary authority I took up ultra marathon running partly to cope with the stress of the work. The theory being that I would be too exhausted to worry about the next Planning Committee agenda. However I soon began to realise that the disciplines for both are not so different – let me explain using Development Management as an example but it can equally apply to other areas of the Planning profession.
Breaking down a seemingly impossible task – when you run very long distances the task seems impossible. How can a mere mortal run for 100km or 100 miles without stopping? Well you don’t think of it like that. You aim for the next rest station in 5 miles, have a bit to eat and drink then reset for the next 5 miles, then do the same again and again until you finish. As a Development Management officer / manager you have a ridiculously high workload so you need to be ultra organised. What do you need to do today? What can wait? What needs to be pushed along so that it doesn’t cause a panic in a week’s time. Focus on what you can achieve today before you reach your next rest station and don’t panic that the journey seems impossible. Remember to rest at the end of the day so that you are ready for the next stage of your Planning journey otherwise you won’t complete your ultra marathon.
Visual the end point – when I am running an ultra marathon I always visualise crossing the finishing line or having a cold beer with a medal round my neck. This helps me work through the here and now pain and allows me to remember why I am out in the cold and wet when others are cosying up to the TV. As a Planner visualising the end point is easy because an applicant sends you the pretty visual and you can genuinely change a place for the better. You may want to visualise a tricky house extension being built with the design improvements that you made happen. You may want to visualise a new housing development full of families creating lives for themselves because of your hard work to get the application to approval. Not many people can visualise success so easily.
Be proud of what you have achieved rather than thinking of the uncertainties of what is to come – I always think about the miles I have run, rather than the miles I have still to run because I know I will never have to run those miles again in that race. This is a massive motivator for me. If you have a planning application coming to Planning Committee you will have done a lot of hard work to get you there. Stop, pause, reflect and be proud of your achievements so far. Planning Committee is an uncertain place and a decision can go against an officer recommendation for all sorts of reasons. If you have done a professional job you will come over as confident and convincing. If Members have a different view then that is for them and you should never take it personally.
Pain is temporary – I can never run an ultra marathon without having low points. I have even been known to cry with pain and exhaustion. However as soon as I have finished a race I want to do another. People are often horrible to you particularly in Development Management. Applicants think you are on the objectors’ side, objectors think you are in the hands of developers. However it is not about you, it is about the Planning situation that sometimes brings out the worse in people. How many times have you come across an objector who tells you that if you approve an application their lives will be ruined? How many times does that really happen? People over-react because they can and in reality you have probably found a good middle ground because that is what makes you a great Planner.
Finally collect the bling – I love looking at medals that remind me of the races I have run. I don’t remember the bad parts, I just remember the joy of taking myself out of my comfort zone and achieving something I am proud of. As a Planner we create better places, improve the lives of our communities and generate jobs for present and future generations. Who else can say that about their jobs. Your bling is a place where people want to live, work and enjoy themselves.
Be proud to be a Local Authority Planner…… being an ultra marathon runner is optional. #BeNiceToPlanners
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.