The moment any government starts to rely on any metric to incentvise performance that metric immediately become unreliable and policy based on that metric becomes harder to deliver with further incentives often having the unintended consequence of slowing down the achievement of the policy objectives intended.
This insight is known as Campbell’s law and explains what housing delivery and the NPPF has become such a battleground with limited delivery compared to the effort and resources, public and private, expended on arguing around its particular metric – the 5 year supply and how that is measured objectively assessed need (OAN)/deliverable housing sites.
“The more any quantitative social indicator (or even some qualitative indicator) is used for social decision-making, the more subject it will be to corruption pressures and the more apt it will be to distort and corrupt the social processes it is intended to monitor.”
It is not that this is unknown to policy makers in the English Civil Service.
in 2006 Rebecca Boden and Debbie Epstein of UWI published an analysis of evidence-based policy, that New Labour Mantra. In the paper, Boden and Epstein described how government that this end up producing corrupted data because of those in power whom
Neo-liberal states need to own/control the production of knowledge and prioritise its use…This need [for evidence] has been reified in the UK and elsewhere, as routines of ‘evidence-based policy’-making have been hardwired into the business of Government. Intuitively, basing policies that affect people’s lives and the economy on rigorous academic research sounds rational and desirable. However, such approaches are fundamentally flawed by virtue of the fact that Government, in its broadest sense, seeks to capture and control the knowledge producing processes to the point where this type of ‘research’ might best be described as ‘policy-based evidence‘.
Yes that is the origin of this phrase.
Distortions seem to be universal across public services. Classic examples include how school test scores become unreliable and how they distort outcomes through ‘teaching to the test’. Crime statistics are another classic example quoted in Campbell’s original paper, few now trust crime statistics are the police are incentive not to record certain events as crime as the performance of chief constables is measured by crime statistics. Campbell is of the opinion, and had sources to back it up, that the apparent reduced crime rates after Nixon’s crackdown on crime did not actually reflect a reduction in crime as much as they reflected an increase in under reporting, and in downgrading of crimes to less serious classifications. Just as as happened here.
Is the former USSR metrics were used to measure how well factories performed such as output weigh they would focus exclusively on producing the heaviest possible items (a nail factory would focus exclusively on the largest size of nail). If the metric was ‘number of items produced’, this had the opposite effect, encouraging factory workers to devote themselves to the easiest item (the smallest nail).
English planning is a smallest nail factory. Quick consents on small sites are incentivised irrespective of whether they are in the best locations, where needed or are capable of scaling to produce the highest outputs over the long term.
No one trusts OAN SHMA figures because the system perversely incentvises LPAs to push them down, hence they are subject to years of argument. Similarly the incentive is to overestimate the deliverabilty of sites to get them in the 5 year figure. This creates a system of constant conflict and wasted effort seemingly only benefiting lawyers and planning consultancies as each side seeks to prove its own interpretation of OAN and the 5 year supply is the correct one. Fat reports are repeated even down to a S78 appeal for a single unit. How could anyone claim this is a rational and consistent system. Imagine Steve Quartermain explaining this to a visiting delegation of Chinese officials.
‘So how sir do you ensure that you get these 6 million houses built?’
‘Well a developer prepares a large report saying why their calculation is right’
‘And then the local authority prepares a large report saying why it is wrong’
‘And for how many houses is this a quarter of a million?’
‘No much, much less, often for a single house’
‘A single house! The delegation begins to roll around the floor laughing.
‘A single house Mr Quartermain you are so funny now you can stop joking and explain to me how it really works, even our most notorious Mandarins ever wasted so much paper for such little result, though we did not come to England to learn of your successes in housebuilding ‘.
Their is only one way out of Campbell’s law which is to:
a) ensure the setting of the metric is independent of the implementing body;
b) ensure the monitoring and reporting of the metric is independent of the implementing body.
Which means specifically that OAN should be set by a completely independent agency like the former NHPAU, that alone would take years off the typical local plan production. Practically it would be a two way process of exchange of information between joint SHMA bodies and a national agency ensuring quality and consistency and producing data in default if need be, as well as ensuring statistically that each migration assumption adds up nationwide.
We have independent verification of OAN through local plan examinations but no set timeable for these, so it doesnt work, but if the timetable for OAN was taken out of LPA hands half of the incentive for stalling on local plans would go away.
I would go further and say the publication of SHLAAs and agreement of the deliver ability status of sites should be in the hands of local land availability standing conferences (at the same scale as the joint SHMAS), similar to what happens in Wales. Then it would not be for inspectors to have to decide site by site what the years of supply were, that would be set by the rolling conference and agreed and updated by them over the course of a year as new consent are granted. Then LPAs could focus on what is important, agreeing which sites and where should be allocated in the local plan. Similarly the dead loss to planning consultants would o as they would know in advance whether a 5 year supply argument was winnable.