The Justification of Local Plan Strategies – the Problem and how to Fix it?

At last weeks MCHLG Planning White paper hearing there was a discussion over sub-regional planning (the minister used the term) where he rightly said the DTC wasn’t working as it should and gave an example – SW Devon (he could have added Newcastle Gateshead) as an example of where it worked. Of course there are so many more where it has fallen apart – such as Greater Exeter, North Essex, Greater Manchester and West of England. The DTC ensures that plans that fail to plan strategically fail. But does nothing to ensure strategic planning succeeds.

This is the greatest problem with strategic planning now, less the lack of it, the bigger problem is when it is tried it fails. This is the central problem my forthcoming book – Big Planning – aims to tackle – and it gets quite technical with GIS and other techniques used around the world. The underlying theme though is very simple. Big problems need to be reduced to small world problems.

Planning is still fixated on the more evidence the better. Even though Herbert Simon’s dictum that there is never enough time to gather all the information you need – so decisions will not necessarily be optimal is well understood the underlying dictum is that this is somehow sub-optimal and explains ‘irrational’ decision making.

This is not rational. Producing and digesting evidence consumes time and energy. This can be counterproductive. The consumption of time and energy has a cost, and if animals such as humans consume too much they can risk their survival. It is only rational to spend time on energy on evidence if the cost of gathering it outweighs the delay and benefits of making a faster and more frugal decision earlier. This new approach is called ecological rationality.

The greatest and consistent source of Non DTC failure at plan examinations is failure to plan for realistic options – typically leading to failure of the SEA directive.

In terms of evidence all you need is JUST enough evidence to reliably differentiate between a limited number of realistic options. Any more you risk taking so long to gather the evidence it will be out of date.

Here PINS are often to blame – such as issuing 150 questions, have you done this have you done that – at the outset of examinations.

Most planners of this generation have been schooled in the doctrine of Eric Reade that too much planning in the past was not evidence based. He was right but now the bigger risk is evidence overload.

I would add the need for three techniques to go on an evidence diet (more details in my book).

The first is structured simplification of the data;

The second is to provide a common reporting structure for the data you need to differentiate options

The third is to produce a simple, consistent model to produce the outputs needed for that structure.

The first and third of these require longer treatment than this blog post. There are examples of projects from several countries in my book.

This post refers to the common reporting structure.

Evidence for a plan is of two forms Baseline (self explanetory) and Options Report.

The report is the same as the environment report for SEA, they are not seperate things

Each option is a table, anticipated development by when, so the impacts of an option at various phases can be tested.

One of the most contentious things at examinations these days is years to start and completions per year. This means the majority of completions take place after plan end date. This is not a big deal when a garden community say meets a strategic need. However where and how strategic needs shall be me met is not even covered by national policy. It is entirely unhelpful. To simplify planning the Government needs to set down standard assumptions such as no more than 5 years from a development corporation stating to first completions – unless there are unusual infrastructure perquisites – and 4-600 units a years completions (as achieved at the peak on MK completions). Nor should it be assumed that a few hundred completions before say a major junction is upgraded is a big deal – the extent of additional harm will be minimal and then the problem will be fixed. This is precisely where the Government and Homes England need to proactively derisk strategic developments through land value capture and near zero interest rate borrowing – and make all the silly circular arguments that developments are unviable because of hope value go away.

Back to the common reporting structure. Not a bad one is Home England’s Garden Communities prospectus (though it is very inconsistent with the prospectus) form. Some of the financial requirements are excessive and it needs to have more info on options considered and their planning implications, but is a structured starting points. PINS should not be asking for more unless it relates to pressings and specific local circumstances.

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