Our response to the Government’s Planning Consultation

We strongly believe that any changes must protect effective engagement with communities

The Government’s consultation on radical changes to the planning system ‘Planning for the Future’ closed last week. 

If it goes ahead, this will be the biggest shake-up to planning since the Town & Country Planning Act 1947. The Act has been amended since, but still forms the basis of the modern planning system. This potentially fundamental change has had a mixed reception with fears that local councils and communities will be disempowered, together with a resulting free-for-all for some developers.

There’s a lot to admire in the proposed changes, but there are many areas that need much more detail for there to be confidence about the outcomes. We also strongly believe that any changes must protect and respect effective engagement with communities in plan making. 

And while it’s tempting, it isn’t right to solely blame the planning system for the lack of housing in the UK. Gaining planning permission can be a long and complex process, but there are many developments that have received planning permission and just haven’t been built. Recent analysis by Shelter and the House Builders Federation shows that 40% of homes granted planning permission in England go unbuilt. That backlog of unbuilt homes has grown by 100,000 in the last year alone.

dxw responded to the consultation and focussed on those areas we know well from our work with councils like Southwark and Hackney, and with the Ministry of Housing, Communities and Local Government. Below are some of the points we raised about the proposals.

Simplifying Local Plans

dxw’s Head of Transformation Alex Yedigaroff has written about the importance of Local Plans

Standardising and simplifying the structure of Local Plans is a positive thing. It makes it much easier to build a picture of planning policy on a regional and national scale. It also opens up opportunities for neighbouring planning authorities to work together. 

But this must not be done at the expense of Local Plans being able to respond to community needs. Taking a broad brush approach to standardisation where local differences can’t be reflected would reduce local planning authorities to compliance operations. 

This isn’t an easy thing to get right. Local Plans are, by their nature, complex and domain expertise is essential to navigate the messy reality they exist in.

Streamlining the development management content of Local Plans

We support speeding up the production of Local Plans and making sure they are based on more recent data. Plans must be able to respond to unexpected developments like Covid, which create significant changes in the amenity and service needs in a local area. The current planning cycle makes this difficult.

However, if streamlining is focussed too much on time and efficiency, there’s a danger that valuable opportunities for scrutiny and challenge will be lost. Streamlining the process must not happen without the checks and balances needed to reflect community needs.

The proposal to develop general management policies nationally risks making Local Plans even more disconnected from local needs. There must be a community and resident centred approach to consultation, so local communities are able to properly influence and engage with plan making. 

It’s a fact of life that plans are built on data which becomes obsolete almost immediately. So it’s important to keep pace with changes in local areas and where local needs will inevitably diverge from a national plan. It’s not clear if, or how, this will be done.

Communities should be involved at all stages of the planning process, from commissioning evidence, to designing policy, outcomes and the Local Plans themselves. Digital provides opportunities to do this and to create feedback loops to understand the impact and effectiveness of plans. 

We’d like to see far more emphasis on the full potential of digital, including measuring the outcomes of Local Plans as part of an ongoing planning process. 

Making decision-making faster and more certain

If it’s not done in the right way, the proposal to shift decision making into the plan making stage risks further reducing the level of community engagement. Getting it right will be expensive. 

Most community engagement at the moment happens when planning applications are made, and Local Plans have traditionally been developed with poor levels of community involvement. A human-centred, community-led approach to the design of the new planning system is crucial if community involvement is to be increased, not severely restricted, by removing this crucial aspect of the current system. 

Community involvement at the plan making stage while potentially more effective, is harder to deliver and will be costly to implement successfully. The proposals lack detail on how this can be achieved within local authorities’ existing, stretched resources.

Accessible, web-based Local Plans

We strongly support Local Plans being machine-readable, based on common standards and comparable with each other. Though making them visual and engaging for use by local communities will be challenging. 

Most local authorities struggle to produce accessible web services, and will need to be supported as they don’t have the right capabilities or teams in place. Trust and accuracy are important, and if this is handled badly it will disengage local people. 

Rather than digital tools and platforms, it’s better to think in terms of digital services that are simple, easy to use and well supported. Following good service design practice and complying with the Government Service Standard and W3C accessibility standards is important. Services that aren’t designed and iterated around user needs will exclude more people than they serve. 

The investment needed here is significant, proptech entrepreneurs alone can’t solve this problem.

Developing the neighbourhood planning process using digital tools

Government has a long history of creating digital tools that replicate existing products and services already being used by communities. We suggest starting with a mapping exercise to understand where communities currently engage with the planning process and what works, rather than trying to build new platforms from the off.  

Again, developing digital tools of the standard needed to be successful and accessible to communities will need significant investment.

Improving the production and use of design guides and codes

The consultation paper talks about “effective inputs from the local community, considering empirical evidence of what is popular and characteristic in the local area.” This assumes a high level of design expertise to support the local planning process which also comes at a cost. 

Individual tastes and design trends are notoriously fickle and hard to measure. The consultation talks about Georgian and Victorian mansion blocks, many of which were destroyed by 1960s planners who also tried a more systematic approach to planning. The conservationist movement of the 1960s went into battle to preserve the Victorian fabric of the inner cities, in much the same way that some now want to protect the modernist styles of the 60s.  

Even if it is possible to create a design code and guide, it’s not clear how it will be enforced. Monitoring will be easier in a world with machine-readable planning data, but will need to be properly resourced to be effective.

Establishing a new body to support design coding and building better places, and  a chief officer for design and place-making for every authority

We think this is a great idea but it’s not clear how this body will be funded and operated. If the intention is to operate it from within local government, this will create a new capability for already stretched authorities and is unlikely to be a priority in the current climate.

It will also be difficult to balance the necessary autonomy of a local chief officer for design with an increasing drive for centralisation. If the role is about compliance with centralised policies, it isn’t really a design role. 

National standards and some support with recruitment will be needed to get people with the right capabilities in place. 

What next?

There are many opportunities presented by the planning consultation, but also many risks. The success or failure of the reforms will be determined by how they are implemented. 

We look forward to seeing the outcomes of the consultation and the Government’s response and stand ready to play an active and constructive role in the reshaping of the UK’s planning system.