#NPPF Politicians Confused or Weak – Kirkwalls

From the excellent Kirkwalls Planning Blog

If Government are not running scared – they are certainly giving a confused message. Every time someone says “the NPPF is going to change the world as we know it” – and deliver Government policy of more growth. Up pops a Minister to say “Oh no it won’t”. If Andrew Stunnell is right – and he has saved 30 areas from concrete. Where is this growth? Ministers need to make their minds up quick, and stop the mixed messages. Or we will have land shortages. Replacing one system with another is Government’s job – failing to back your own system is confusing at best, and at worst downright weak.

What’s the Obsession with Activity Based Costing in Planning? – It Doesn’t Work

Both PAS and the DCLG seem obsessed with activity based costing as a means of estimating the real full cost of processing planning applications.

But its bunkum.

In both the public and private sector its largely discredited.

The 2008 Review of Policing for the Home Office by Sir Ronnie Flanagan concluded that  that manually driven ABC was an inefficient use of resources: it was expensive and difficult to implement for small gains, and a poor value, and that alternative methods should be used.  Barely 4 years after its use had been mandated by the home office.

I know some private sector consultancies where staff spend up to 10 minutes every hour time recording.  Are they happy then raising their variable cost base by 17% in this way!

Many would claim, apart from the time costs, it just doesn’t work as an accurate means of accounting.  For example the field of throughput accounting many examples have been found of where cost accounting gives false results and if private sector bodies followed it they lose profits and if public sector bodies did they reduce productivity (Corbett, T. 1998. Throughput Accounting. North River Press.)

Lean accounting and throughput accounting have given us more accurate metrics so why does the planning profession use a method that is falling out of use elsewhere and is just plain flawed.

Lean accounting lesson – All you need to measures costs is to measure throughput and inventory once you have made an accurate assessment of labour and on costs for each person in a process.  Now lets say you have 100 planning applications – for sake of argument all the same complexity – generating Y income.  Divide your staff (again for simplicity assume all cost the same) costs x by Y you have your throughput over the period (lets say six weeks).  If staff have 4 weeks target to process then if there intray stacks up you are loosing money/productivity, if it goes down if you gaining it.  That’s all you need to measure the inputs and outputs.  The same applies to staff commenting.  It only gets complex with applications of different types.  But if you set staff time processing targets for different categories of application – and you can benchmark these – you can apply the same input-output metrics. What is more such metrics will tell you if you are eating into or building up a backlog and whether you are gaining or losing productivity.

Activity based costing is a bit like trying to measure the GDP of a country by measuring the cost of every single transaction – an impossible task.  All you need to measure is the changes to balances.

#NPPF Select Committee Response Part 2 – Fitness for Purpose & Usability

Does the NPPF give sufficient guidance to local planning authorities, the Planning Inspectorate and others, including investors and developers, while at the same time giving local communities sufficient power over planning decisions?

The document is punchy. Reducing from 1,097 pages[1] to 55. But puchiness does not mean that the document is clear or fit for purpose. Wales (Planning Policy Wales[2]) shows that is is possible to reduce national policy considerably (in their case to around 200 pages) without losing its essence or clarity – following four iterations it has been widely praised and easy to use (as a planning practitioner). There are aspects of English national policy where the editing pen has gone too far – deleting crucial national policies. I shall turn to these in later evidence..

There will be those who will rightly argue that England needs something like the Wales Spatial Plan or the Scottish National Planning Framework. Spatial policies stating how infrastructure will ‘join up’ and the role of different areas in the nation. They are right. How can you judge, for example, HS2 without a national vision of transport and the connectivity of regional cities? How could a site for an additional hub airport, and the linking infrastructure for it, be chosen if the decision was made to develop one? But that is an argument for another day as such a document would take over a year to develop and the priority now is to put in place simplified subject based national policy. I would hope that your committee urge the government to look again at this issue once the NPPF is complete; if only to ensure that billions of investment is well spent and the National Policy Statements on major infrastructure are linked up.

Above all the document needs to be accessible to non-professionals. The document though is riddled with phrases that can only have meaning to planning consultants and lawyers because of the considerable ‘baggage’ they hold in terms of past precedent. To give just one of many possible examples ‘obviously poor design’ (para 121) which many lawyers have argued in public inquiries in the 1980s and 90s (it is a resurrection from circular 22/80) means that arguably poor design, slightly poor design or the merely dull and mediocre are acceptable. Also many parts of the document interlock in complex ways, you need to draw up flowcharts to understand its operation. Some aspects of policy are only comprehensible at all, notably policy on flooding, if you have the old policy being replaced alongside you. As this is supposed to be a comprehensive standalone document this shows it is not fit for purpose. Inspectors and recovered appeal (by the SoS) decisions will ne needed to set precedents about what some underbaked parts actually mean. Therefore users will need a planning encyclopedia of precedents along side it to make it work.

Before 2004 you often saw local plans and UDPs that ran to 500 pages or more. In climates where there was a strong presumption in favour of development there was a feeling you needed a policy for everything. In putting forward the concept of core strategies in 2003 the idea was to make local strategies shorter by removing the need to repeat national policy. But if too much national policy is stripped away, for example on adverts in the countryside, agricultural workers dwellings etc, then you could see, indeed you are seeing, pressure to ‘fll in the gaps’ that have been created and see plan balloon and take longer to complete.

A better crafted document of 100-150 pages could have set the right balance between brevity and clarity.

The fitness for purpose of the NPPF also depends on the tone it strikes. Inspectors will want clarity. Developers will want certainty or where and whether they will get consent. Environmentalists will want hooks to enable various impacts to be controlled or prevented. Planning professionals will want stability. Local politicians will either want the untrammelled ability to say no to unpopular development or an unequivocal order from a third party to plan for it – so they can blame that party. This means that planning will always be conflictual. But it does not mean that these stakeholders do not have shared objectives and that in many cases these cannot be partially reconciled. Above all good planning can help reconcile these objectives by ensuring that needed development goes in the right place and is well designed. It can also have a vision of the positive role of planning in ensuring this.

This is where the NPPF falls down the most. Its impoverished and negative view of planning – effectively saying get out of the way of developers. The almost universal perception of the NPPF is its imbalanced nature. Even those of use who consider that the planning system had become too anti-development can see it for what it is, a developers charter. This means that the backlash from the shires and suburbs could be so great that it could actually mean that the can kicked down the road many times before, where new large scale development goes, gets kicked down the road further. Too often we have seen before ministers such as Patrick Jenkin and John Prescott panic under opposition to changes to crudely loosen the taps of development and react by tightening them too much.

Though English National Planning Policy there is nothing English about the document at all[3]. about what our distinctive challenges and solutions as a nation area – very uninspiring. Indeed ministers have wrongly made statements that they are responsible for planning in Britain[4] – rather than England, whereas the British isles has 7 separate statutory Planning Regimes. The NPPF covering only the English part.

Finally on this point the document is repetitive, using one phrase four times and the word ‘presumption’ 25 times.

1 in 10 UK shops/leisure premises hit by #ukriots #londonriots – Local Data Company

Almost unbelievable figures from property research firm the Local Data Company.

Reports that 48,404 shops, pubs and restaurants have been directly or indirectly impacted by the recent riots and looting. The LDC has found reports of 28 town centres that have been affected, as well as standalone supermarkets and retail parks, such as in Croydon. They track 475,809 such premises, with 10.2% affected. They also report that 66% of those hit were independents.

DC director Matthew Hopkinson said of the results:

“These figures are horrifying in terms of the damage that has been done to an already struggling sector. The retail sector is a major contributor to inner city regeneration projects as well as employing thousands of people. The fact that over 65% of those affected are independents, shows how random and thoughtless the actions of this criminal minority are. These businesses are the livelihoods of many people and the ability to bounce back from this has yet to be seen. It is the last thing that the high street let alone the country needed. It is important that the law abiding majority offer as much support as they can to these affected businesses.
“These figures are horrifying in terms of the damage that has been done to an already struggling sector. The retail sector is a major contributor to inner city regeneration projects as well as employing thousands of people it is the last thing that the high street, let alone the country, needed.”

Of course with the vast majority of town centres and local pubs unhit, the damage is disproptionate. In my own closest centre Woolwich around 2/3rds of the shops on the main drag Powis Street have been hit. Given that glazing and shopfitting firms are oversrreached it is probably going to be several months before emergency boarding is removed.

RICS back #NPPF – Letter

Their letter to the Prime Minister

Dear Prime Minister,
Draft National Planning Policy Framework
RICS is the world’s largest organisation for professionals in property, land, construction and related environmental issues and our members are involved in every aspect of the built and natural environment.
RICS is governed by a Royal Charter which requires it to act in the public interest.
Delivering sustainable economic growth is in everyone’s interest whether it be badly needed employment or equally important affordable housing. The existing planning system however well intentioned has failed to deliver the homes, infrastructure and jobs/investment that UK Plc needs as an urgent national priority.
The reforms proposed by Government to bring about a planning system which is more workable for the local community and more responsive to public need are therefore to be welcomed.
RICS welcomes the Government’s draft National Planning Policy Framework as a significant step forward in enabling the growth the UK requires. We are pleased to see this concise outline of strategic national planning policy which retains its focus on economic development but emphasises the need to achieve this in a sustainable way. Businesses and other potential employers need the clarity and certainty which RICS believes the Government’s draft NPPF provides. We also believe that the draft strikes the right balance in safeguarding the environment and promoting strong, vibrant and healthy communities.
The NPPF sets out clear and concise guidelines for local authorities to ensure that the English countryside is protected and improved. The Government’s recent Natural Environment White Paper will also be a key document in helping to deliver this protection by setting out how communities will be able to protect vitally
important green spaces whilst ensuring necessary development occurs sustainably. RICS welcomes the Government’s clear intention to protect the UK’s natural environment whilst seeking to encourage the sustainable development the UK needs.
RICS is now consulting with members on the NPPF and will be responding to Government in detail in due course. RICS is also consulting with members on two pieces of guidance to accompany the NPPF, ‘Financial Viability in Planning’, to support paragraphs 39-43 and ‘Place Making and Value’ to support paragraphs 114 – 123.
RICS will continue to engage constructively with Government to ensure its proposals deliver a vibrant and
sustainable property market, an improved natural environment and ultimately, a strong economic recovery. RICS would be pleased to facilitate meetings for Ministers and their officials with senior expert members in planning, rural and environmental specialisms to discuss the proposals and to ensure they are workable in practice.

Such letters would not be necessary if the government was not losing the argument would they.

The Place making and Value reference must be to the CBRE research – which is highly recommended by the way.

Gold is NOT money

Gold is NOT money – even though its on the upside in this uncertain times

Exhibit 1
At times of hyperinflation even gold has proven worthless – all that matters is a claim on food. This shows that nothing is an intrinsic store of value

Exhibit 2

Ron Paul doesn’t get it – Forbes http://www.forbes.com/sites/afontevecchia/2011/07/13/bernanke-fights-ron-paul-in-congress-golds-not-money/
“Gold’s at about $1,580 [an ounce] this morning, what do you think of the price of gold?” asked Rep. Paul. A stern-faced Bernanke responded people bought it for protection and was once again cut-off, with Ron Paul once again on the offensive.
“Is gold money?” he asked. Clearly bothered, Bernanke told the representative, “No. It’s a precious metal.”
After Paul interrupted him to note the long history of gold being used as money, Bernanke continued,”It’s an asset. Would you say Treasury bills are money? I don’t think they’re money either but they’re a financial asset.”
All assets are subject to price fluctuations which can take them above or below the monetary rate of exchange – which leads on to

Exhibit 3
Steve jobs used to be a goldbug – but his performance in improving stockholder value is 45x greater than his investment advice – Gold price hence does not reflect underlying macroeconomic reality of the economy as a whole

Exhibit 4
You cant take it to the store and buy stuff with it – The Economist

Exhibit 5
Capitalism didn’t properly take off in 17th C England and Netherlands until there was a shift from specie to paper and credit

Exhibit 6
Even in gold backed currencies its only function has been to as means of fixing the supply of ‘high powered money’. This supply can be very very small – as the Taiwan miracle shows. What matters is the changes to the money supply and the attractiveness of the currency.

Exhibit 7
Read FoFoa

Exhibit 8
At times of expanding population Gold is deflationary if used a currency peg, and at times of recession gold is doubly deflationary. A little inflation is a very good thing, and at times of indebtedness quite welcome. Gold simply aids transfer of wealth from younger to older people (that is a more complex argument). Price stability is important but growth is more important.

#NPPF The Political Endgame ‘a system on a collision course from the outset, that can only end one way – in favour of the grassroots Tories’

There is a very interesting discussion at Building between Nigel Moore, former conservative councillor and planning consultant (who had quite a hand in drawing up open source planning) and Roger Humber advisor to the HBF. The level of discussion is well above the norm.

Roger Humber

If we look at the reforms both from the point of view of what the NPPF tries to do positively, and also in the context of the abolition of the regional spatial strategies, I have real fears about this. While the local authorities are being told to plan positively, I fear that they are not going to be willing to do this. It’s the political dynamic in the absence of housing numbers that I really worry about. Let’s face it, [communities secretary] Eric Pickles is a very political character. I don’t think he’ll want to fight to the death and die in a ditch.

I agree with Nigel on welcoming the reversal of the political intention [of the default position being no]. I just wonder about the deliverability of it when they take away the principal weapon they had for ensuring it happens, which was the central housing numbers. It seems a tragedy to wipe away the housing numbers, and then introduce such a positive NPPF with the risks there.

NM: But the [housing] figures are there in the ether, because the evidence base that has come out of [the research done to draw up the individual] regional strategies, is there. In Oxfordshire the figures approved by the [inspector’s] panel and subsequently adopted by the government are now guiding the councils. It’s going to be a question for the inspectorate [but] it seems to me they will give a lot of priority to this evidence base.

RH: I agree, the evidence base is there. The problem is that we know there are other [local authorities] who have said “we can now scrap all of this and just start all over again”. There’s a risk of plans being taken forward that don’t reflect the evidence base. The inspectorate will say it’s not sound. This should open the door for the presumption in favour and for the secretary of state to grant appeals until such time as they adopt a sound plan.The problem is that’s a system on a collision course from the outset, that can only end one way – in favour of the grassroots Tories. No secretary of state is going to sit there for too long and allow this to happen.Over the last 25 years, we’ve always seen ministers flinch in the face of backbench revolts. Obviously an awful lot of this conflict will only unwind much closer to the election, and that’s the time the coalition will be starting to unravel, and pre-election positions will be starting to be taken.

(note the situation in Oxfordshire is not as simple as Nigel suggests because of the ‘floating’ leftover from the Oxford Growth/SE Plan JR and how this relates to the ‘duty to cooperate’)

On Targets – Building asks if they worked

Contrary to everything [housing minister Grant] Shapps says about the housing numbers being like Soviet tractor targets, government statistics show clearly they were working. Between 2001/2 and 2007/8 the housing numbers – total net additions – had risen by 58%, and the trajectory they were going at would have seen them get to about 240,000 homes per year, by next year.

The statisticians are telling the truth that the politicians did not want to acknowledge, that the figures were on a virtuous trajectory pretty well opposite to the position portrayed by Shapps.
I’m not saying it didn’t need reform – but at least the housing numbers were coming through.

NM: The difficulty is to disentangle whether that was a reflection of those targets, or benign conditions in terms of the housing market itself. We both agree that the figures won’t really go away; they’re in the system. We need to find a way of making sure the system reflects that. But ministers aren’t going to be prepared to sanction the tractor targets again.

Roger wraps up with another obituary to localism of the form that many thought they were getting

There’s quite a lot of smoke and mirrors on this and at some point the government is going to find itself held to account and asked some very hard questions by people who believe in localism and thought they were going to have quite substantial localism.

There were obviously those who hoped that the first thing it would allow them to do was virtually have a standstill on development if they choose to do that. At the moment the government is signalling to them no, that’s not what it means.

The NPPF is creating interesting political bedfellows. Those that see we badly need more development but fear that the NPPF and the abolition of regional planning will create chaos and a backlash, and those that oppose development per-se. The only way out of this for the government in the medium term is to prevent a chaotic free for all, although there are some, especially in Downing Street and the Treasury, who seem determined to introduce that for ideological grounds – rather stupidly if it results in a counterproductive backlash – however political reality will see those voices isolated, as they were on the NHS.

Sooner or later the government will be looking for ideas for an out. That I think will have two components. Providing more structure to the ‘Duty to Cooperate’ and inspectors look like imposing that anyway given half a chance, and secondly providing a short window to get up to date local plans, under that cooperative structure, in place before the full force of the ‘presumption’ kicks in.

Greg Clarke has said he is willing to listen on both counts, so we need to think through how this might work.

The Top School that Pimps Images of its Blonde Six Formers

Chris Cook in the Financial Times provides fuel for feminists.

It is a well-worn observation that even respectable newspapers like to illustrate their coverage of A-level results day with pictures of delighted and pretty (usually blonde) girls. This year August 18 is the nervously awaited date when hundreds of thousands of English 18 year-olds get their exam results. But judging by the photos used by Fleet Street, one would be forgiven for thinking that boys (and brunettes) receive their results on another day.
This is partly because many journalists are moral degenerates. QED. But what might shock you is the enthusiasm with which schools encourage the use of pictures of pulchritudinous blondes. Indeed, a little cadre of English private schools compete to supply attractive young women to the national press.

Last year, I received an unsolicited voicemail from the press liaison at Badminton School in Bristol: “Hi Chris, . . .Just wanting to give you some details of some absolutely beyootiful girls we’ve got here who are getting their A-level results tomorrow. Some lovely stories . . . They’re amazing girls.” Bedales School in Hampshire helpfully supplies photos to journalists, sending out pictures of some of its pupils celebrating GCSE results. Oddly, it seems to forget to send out any photos of its male students (or its dowdier girls).

Most alarmingly, another (very grand) private school invited the FT education correspondent to an end-of-year sports event. I was, alas, too busy. It was a shame, I was informed by a senior teacher. He said that watching the girls playing sports would have given me a unique opportunity to pick out promising candidates for A-level day pictures.

Taking a look at the images Bedales and other top school send out, or national newspaper send their own photographers to, you get his point

Withington Girls School