On Examining and Saving Strategic Plans

Planning Resource

The housing ministry has said it will consider whether a planning inspector’s recommendation that a group of Essex councils remove proposals for two garden communities totaling 34,000 homes from their emerging joint local plan “raises any questions for how large sites are examined in the future”.

The system of binding local plan examinations was forged at a time when plans had to conform to strategic plans where reports were advisory to the SoS.  So in many cases there were long delays when panels took against aspects of a strategy, such as the Eddington Report on the East of England plan, strategies always moved forward.  No-one envisaged or designed a system where plan would move backwards for years.

Similarly the introduction of binding inspectors reports in the 2004 acts was designed to prevent LPAssimply rejecting inspectors reports even where they were very critical.  However the later introduction of ‘soundness tests’ in regulations set high barriers, which many failed.  The intention in in parliament was for there to be a ‘presumption in favour’ of soundness.  The lawyers put paid to that as it was never reflected in statute or national policy.  Rightly so as it prevented poor, spatial plans (such as the original Stafford core strategy) getting through.

A difficult valence is needed.  It must be seen as transparent, independent and fair. All the values of PINS; but not be so hard that impossible barriers are set which lead to ‘no planning’.  For example cllrs in Braintree are now saying they may be forced to develop a non strategic local plan that simply disperses development to villages. How can that be more sustainable than one based on garden communities linked by a rapid transit solution with uncertain delivery?

A few basic principles:

  1. It should be rolling starting at the early stages of choice of strategic options.

The rolling examination has become the norm.  However it still begins very late in the process based on the principle that a plan should only be submitted once it is considered sound.  However by that point it is too late as key problems such as DTC and SEA fails occur from the very beginning of the process.  In some cases LPAs have relied on PAS advice which subsequent inspectors have disagreed with.  This seems to have happened when the communication between the LPA and the consultant has not included challenge from groups which later challenge the plan.    This is unacceptable.  This should be replaced by an open process of rolling continuous improvement and challenge initiated at the early critical stages of plan making.

2.  Utilise Panels

A few inspectors have been criticised for idiosyncratic decisions.  Sometimes fairly more often not.  Panels are now standard on larger examination (e.g. Oxford) and should be universal.  The extra cost pays for itself in not having to go back through stages.

3.  A More Open Process for Determining Options

Often plan making authorities are scared to death of consulting on strategic options for fear of whipping up opposition.  We often get a  smoke filled room process by leading groups only where the options emerges only at the last stage of preparation. often preceded by a beauty parade of options presented by developer consortiums.   As such plans are easy to oppose by opposition groups and even easier to throw out.

What is needed is an open, exploratory mutual gained based approach for determining the set of reasonable alternative options that will be tested via SEA.  There is only likely to be trust in such a system where the SEA itself is conducted independently.  This is the step that has been going most wrong and where most attention is needed on fixing.

4.  A revised standard system for OAN

The government is finally now acknowledging problems with its OAN system, which reallocates household growth from areas with weaker markets such as the Midlands and north of England to the South of England without any acknowledgement of how this relates to migration and employment growth.  In any event the system was broken with the latest household projections and households not forming because of lack of housing to form into, together with the huge uncertainties over international in migration and student numbers.  With a likely house price recession the system is shakier than ever.    In any event the system did not account for land constrained areas such as London and relied instead on the failed DTC mechanism.  So it simply perpetuated in different forms the cyclical logic of undershot housing numbers leading to low completions leading to low household formation rinse repeat.   What is more the whole system lacked transparency with a lack of an open portal bringing all the info together and displaying what the numbers are on a per authority basis.  Now is the perfect time for a refresh.  A new system should be based on a target level of housing consumption and target level of employment growth per region – based on a macroeconomic regional ‘levelling up’ model such as Ireland uses.  This should be based on long term trends of 25 years or more than short term demographic and economic jiggles.  The models should output regional and per authority numbers with regional groupings of authorities given a deadline to redistribute based on opportunities and constraints.  If they fail to do so the government should have a reserve power.

5.  A slimline proportionate approach to evidence

The days of inspectors asking 500 questions at the opening of EIAs has to end and has to end now.  An evidence base that fits into several skips does not lead to more accurate plans.  It is a fallacy.  This was the main subject of my lecture tour this year.  Planning and PINs is still weighed down by a traditional and discredited notion of planning rationality that more evidence is better.  It is not.  Gathering evidence has an information cost.  In nature creatures that spend too much time processing information and too little acting die.  Hence we evolve ‘heuristics’ simple methods of making decisions.  All the evidence shows these mechanisms are better not sub-optimal means of making decisions in many real world cases.  My approach has been to adopt a GIS based approach to data simplification and options evaluation that is suitable to the ‘big’ decisions that strategic plans have to make.  I.e. choosing strategic growth locations.

6.  New Mechanisms for Funding Regional Transport Infrastructure

Carbon free development patterns, including Garden Communities, wont work unless there are new regional networks such as BRT, given the capacity constraints of existing road and rail.   As the NIC notes this has no preexisting funding structure and is given too little national priority.  What is more, with a few hard won exceptions such as Oxfordshire, local authorities are not geared up to study or deliver sub-regional infrastructure.  Study and funding timelines are often well behind  plans, such as in Essex key road alignments being put in place after plans are agreed (or rejected) so what is the point.

7.  Collaborative Central /Local Arrangements

Is strategic planning a joint central/local government endeavor.  If it is central government should facilitate, if the latter it should  get out of the way.   We see long term problems with the Highways Agency and the Environment Agency.  It is not good enough to simply state that these should facilitate.  They are safeguarding central government policy objectives, and to facilitate housing the balance and trade off of policy objectives need to change.  A good example is the refusal of the government to fund upgrades to an M25 junction to facilitate a Garden Community in Tandridge.  One suspects the Highways Agency doesn’t like new communities on the M25, even if they are next to a railway. One thinks then where does the Highways Agency want new communities.  It has no view- it is not tasked to answer that question.  If Garden Communities and Local Plans are to get anywhere then they need to have a view.

8.  Stop Throwing in Problems Caused by Combined Authority Mayors 

Combined authority mayors were deliberately set up as an alternative source of power in areas with mainly labour local authorities.  Wherever it has been introduced teh split in power has been nothing but a source of confusion and delay, notably in Greater Cambridgeshire and the West Midlands, with the government being notably obstructive  in Greater Manchester and London favouring Boroughs of their own parties.  Furthermore if you want to see spectacularly complicated local plan governance arrangement look at those relating to SDSs of combined authorities.  A total dogs breakfast.  Abolish the distinction between SDSs and combined local plans and inyriduce simple joint boards everwhere.


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