Never use ‘encourage’ in plan goals

Della Rucka

We don’t need the mealy mouth stuff we often get for goals. We need goals that our community understands, rallies around and works toward. If a goal does not make people want to act, then that goal is useless.

The word “encourage” should never appear in a plan’s goals or objectives. If I encourage my son to study for a test, “encouraging” him is not the goal. “Pass the test” is the goal. “Encourage” is a cop out, which is why officials sometimes like it for goals they don’t want to support. If you cannot get support beyond “encourage,” then define what the parties involved can support, or cut the goal out. You’ll do more good by leaving it out than by giving it lip service.

The Four Faces of the ‘Presumption’ #NPPF

The reason this blog was called Decisions, Decisions, Decisions was because it was supposed to be about geeky stuff to do with decision theory and its relationship with arguments in planning theory.

No such look the NPPF came along and took over.

But it helps to look at the key argument over the NPPF, over the ‘presumption’ from this perspective as it helps to tidy up certain confusion. I dont think we will be able to move on a ‘clarify’ the NPPF until this confusion is dispelled.

There are four logically distinct ways people have used the term in the debate.

A predisposition of the decision maker to a result, an expectation of a decision outcome by a user of the system, a statement of the burden of proof in evidential terms and as a decision tree of heuristics. Let me explain

1. A predisposition of the decision maker to an outcome

When people say that the planning system should be more ‘positive’ this is what they mean.  Now that outcome could be yes to everything as the term ‘default answer is yes’ phrase implies or only to certain kinds of development in certain places.

At the heart of this is the argument about whether planning should just be a neutral ringmaster waiting for things to come or should be actively seek to built the right things in the right places.  I should state that im firmly in the latter camp.  My hero are those like Patrick Geddes and Raymond Unwin who got good planning done even before modern planning legal systems existing.  But a presumption for the right things in the right places also logically implies a presumption against the wrong things in the wrong places.

Part of the confusion lies in the fear that a predisposition implies planning should become predisposed to cheerleading bad development rather than assessing it.

Lets say you have a case of the right thing in the wrong place?  Or the wrong thing in the right place?  This illustrates that planning is not just about assessing the sustainability of the development but ensuring that the use of land is the most sustainable it can be.

Give an illustration.

Lets say a site is zoned for a sustainable urban extension.

Along comes an application for a riding school on the same site.

Ok lets test if the development per-se is sustainable – yes – ok do you approve it? As a decision maker you are predisposed to positive outcomes, if an application comes along which is sustainable ill approve it?  But the application may also be preventing a more sustainable option for the same site.  If your predisposition is to positive outcomes where an application is sustainable and it is the most sustainable option likely to come forward for the site this might lead you to a completely different answer.

What this illustrates is that a positive disposition is never enough to make a decision – what you also need are clear decisions rules – what in decision theory are called heuristics.

Simplerly a decision rule by itself tells you little about what the likely outcome is going to be.  If the decision maker makes every opportunity to pick holes and find holes the outcome will be no whatever the decision rule.  Predisposition is about the culture of planning.

2. An expectation of decision outcome by a user of the system

Today I got up as an innocent many and hopefully will go to bed as one. This may sound strange but this labelling is important in English Common law.  You are presumed innocent until proven guilty.  This sense of the word, to avoid labelling and prevent abuse of the powers of the state is rather more difficult to apply to regulatory decisions.  Is my planning application ‘presumed’ to be approved before I have supplied any evidence or even submitted it?

What you presume will rather depend on what you political position is on private property.  If you hold a more Jeffersonian position you might feel you have every right to do what you want with it unless it harms the personal safety of others.  If you hold a more Hayeckian view you might feel that others have no right to do what they want with their property if it harms, without  just compensation, the value of your property. Others of course hold a more ‘commonweal’ approach to this issue.

Such an expectation will tell you nothing about the eventual mediation and decision outcome amongst these competing views, even amongst those with exactly the same political philosophy about property rights.  My thesis is that concepts of property rights have by themselves no bearing on decision outcomes  – unless you have an extreme ‘do what you like where you like’ view, one that only applies where you have no planning laws or the decision is made not to apply them.  Lay those arguments aside and move on.  The real issue is the public policy decision rule for resolving property rights disputes.

So this concept of a ‘label’ taken from criminal law helps us very little with issues of resolution of competing civil expectations.

3. A statement of the onus of proof in evidential terms

Whose job is it to show that a scheme is sustainable?  Can an applicant submit a scheme with no evidence and then could a decision maker then only refuse it if they have paid for evidence sufficient to knock it down?

There has been endless confusion over this issue.    Can you refuse an application for example for not providing a tree survey?   The DCLGs position on this has changed I believe over the course of the consultation, which is at least a sign of constructive engagement.  For example the mythbusters document refers to applicants having to show that a scheme is sustainable.

The onus of proof is different from the burden.  For example the fact that I have to supply evidence by itself doesnt not tell you if the burden is ‘on the balance of probability or beyond reasonable doubt.

4.  A decision tree of heuristics

This is really the nub of it the policy on how the decision maker makes planning decisions.  The NPPF as currently drafted is as clear as mud on this point.

The decision maker will in every case apply a series of heuristics to the decision.

Decision rule 1 in most public policy decisions is typically – do I have enough evidence to decide if all of the subsequent decisions rules have been met – if no go back to the applicant, if yes proceed to decision rule 2 – and so on.

Under out current planning law decision rule 2 would be – does the scheme comply with the development plan considered as a whole.  If yes …etc.

Then the decision trees branches concerning ‘other material considerations’  – weighing benefits and harm – it is unclear but this component of the presumption would appear not to have changed the decision tree but to have changed the burden of proof of this heuristic, no longer would you be able to refuse harmful development, the barrier is raised to ‘significantly outweigh.’  One can see days at public inquiries spent with arguments about just how ‘significant’ and ‘clear; harm is rather than looking at the evidence of the harms and benefits which is what the inspector will want to look at.


Though I would rather the word ‘presumption’ was banished from planning law to end such confusions I am relaxed about its use if these separate components are teased out and made clear.  This is what we have tried to do in the alternative draft.  Try to make sense of the ‘presumption’.







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.

Why do People get Lost?

Dr. Giuseppe Iaria has founded NeuroLab at  the University of Calgary, Calgary, Alberta, Canada.

Their website Getting Lost is dedicated to the science of why people get lost and how we find our way.  One of their interests is a richer understanding of Developmental Topographical Disorientation, the disorder of those that get lost very easily, including in extreme cases people getting lost in their own home.  I once knew a planner with this condition who feared going on site and dreaded a proposed office move.  When I took him on site once he was unable to describe the view in front of him.

Though orientation and navigation is undoubtedly complex, most people are able to reach their destination with little effort. This ability is produced by two primary behavioural mechanisms.

The first behavioural mechanism consists of making use of a variety of information (landmarks, body turns, distances, etc) in order to become familiar with the environment. This may either consist of learning a defined (fixed) route in the surrounding, or acquiring a more general knowledge of the environment including its layout and the spatial locations of landmarks available within it. Time spent in the environment as well as the information people decide to focus while navigating play a critical role on the ability that individuals will develop in orienting in that environment. The type of orientation that people adopt while learning and experiencing the environment mainly focuses on environmental landmarks and it is referred to as spatial memory.

The second behavioural mechanism happens unconsciously and is used while following habitual routes that individuals became very familiar with such as going from room to room in the house or workplace, or even driving from home to work along the same route for a long time. Navigation is guided by automatic motor sequences and can occur in the absence of landmarks. No explicit knowledge of turn sequences or landmark associations are required. This type of orientation is supported by procedural memory, the same memory system that produces learned motor activity such as riding a bike or playing a piano.

They don’t seem to give enough attention to the social interaction important in wayfinding.  For example we are the only primate with white eyes, we can see where our colleagues are looking and even babies have this interactive ability.  It seems to have evolved to enable early humans to undertake complex foraging rather than simply following game in a group, and point to our colleagues where the best places for food are.

Planning Decisions & Localism as an Ethical Issue – A Philosophers Take

Localism, as currently presented, presents complex issues that require exploration of their implications rather than treating it as a predetermined moral good.

A recent book by the American Philosopher  Robert Kirkman has an original take on this issue – looking at planning decisions as an ethical issue.

The Ethics of Metropolitan Growth- The Future of our Built Environment (April 2010)

Kirkman’s key issue is whether a place either constrains us or enables us to seek the good life.  The second consideration is how the identified good is distributed among people. Is it fair? The third consideration is how the identified good is distributed through time. Will it last? Finally, there’s the question of process, is it legiminate?

Kirkman recognises that planning issues raise difficult issues of justice, one person benefitting from a good place, might be excluding others.  A person with liberty to build where they like may be harming issues of well being valued by the people already living in the locality.  This become even more difficult when it comes to the issue of what scale a decision should be made.

“To the extent all of the different ranges of government pull against one another, each asserting its own rights and prerogatives, there is less likely to be an effective response to problems in the built environment. Perhaps most important, there is often a mismatch between the scale of problems and the scale of government authority with the power to address them.”

Kirkman conderiders the issue of housing allocations.   Almost everyone values a sufficient amount of housing affordable to residents with the range of incomes somewhere in their wider region, but the same people can exhbit Nimby tendencies about putting it in their own neighborhood, and few homeowners want to see their own  home become more affordable through increasing supply.

This of course is a classic case of the fallacy of composition, that the aggregation of individual and locality decisions about housing locally does not reflect the community will about housing nationally.

Approaching this problem with too small a scale, and you get inefficient fragmentation; too large a scale, and you’re apt to be insulated from what citizens actually want for their own community.

Kirkman therefore promotes decision making on housing allocations based on regions which arn’t too large for individuals and localities to participate in.

Planners would recognise this as planning on a sub-regional scale.

It is interesting then to see a coherent argument that decisions on metropolitan growth taken at too smal a scale can be unethical.

Decision Theory for Planners#115 Goals & Objectives – there is a difference

A properly structured series of goals, objectives and targets can and should achieve five things, it is important to clarify these as confusion over these concepts in rife in planning;

1)      Above all act as a framework for managing change and responding to the challenges that a place/organization faces – there is much to learn then from some simple concepts of management theory;

2)       Act as a focus in forward planning  on whether actions take you towards or goal or away from it; and solely focusing activity on removing constraints on achieving goals – this is a key insight from operations research and time management;

3)      Act as a framework for making rational decisions against multiple criteria on a common basis, and prioritizing goals and actions – this is an insight from decision theory;

4)      Act as a means as identifying spatial conflicts between land uses that meet different goals and how to rationally resolve spatial conflicts between land uses – this is a relatively recent concept from GIS thinking and its application to planning policy;

5)      Act as a metric for the evaluation of different policy options against some preset criteria – such as sustainability appraisal/integrated appraisal etc.

Each of these approaches are closely interrelated and have greatly influenced each other.  Taken together they can be used to create powerful, insightful, effective planning documents and processes.

Goals as a Management Tool

Goals as a planning tool will not be effective unless placed within a management context through which the ‘plan’ will be delivered.

A goal in this sense is a description of an end state that an organization wishes to achieve.  The management literature tends to use goals and objectives as interchangeable terms, but the full benefits of a structured approach towards goal setting is only achieved if a hierarchical approach is taken distinguishing between goals, objectives and policies (this is mandated in some jurisdictions).

Goals in this sense are the high level and short statement setting out where a place/organization wants to be after a period of time.

Objectives are the specific statements setting out measures to achieve a goal.

A target is a metricated objective, or a metric for an objective,  designed as a tool of performance management.

Example:  Goal:  Diversify the economy reducing reliance on oil and gas exports; Objectives in support of that goal:  Provide sufficient land for light industries/logistics for which Bahrain has a competitive exports advantage,  Allow for the planned expansion of existing heavy industries where there is a sustainability case for these to be located in Bahrain, etc. etc.

Notes:  These are designed to illustrate the point rather than being suggested goals or objectives.

Goals and objectives should begin with a verb.  This improves clarity of intent, implies action, and establishes a rhythm of ideas that enhances understanding. (Carr and Zwick).

The setting of goals and objectives is an iterative process, in particular at the early stages of a project up to and beyond the point at which tentative options are formulated.

From my experience 15-20 objectives is about the right number.  Beyond this paperwork and monitoring becomes onerous.

 The importance of Management by Objectives

The concepts that management should be about achieving the objectives of an organisation (Druker) and that objectives should be SMART[1] (Locke).  What is less well known is the origin in thinking about how people in an organization respond to objectives, and how organizations need to set goals to respond to changes in their environment.

Five Principles of Goal Setting (Locke and Latham)[2]

To motivate, goals must have:

  1. Clarity – Clear goals are measurable and unambiguous
  2. Challenge – People are often motivated by achievement, and they’ll judge a goal based on the significance of the anticipated accomplishment
  3. Commitment – Stakeholders are more likely to “buy into” a goal if they feel they were part of creating that goal
  4. Feedback – Feedback from stakeholders provides opportunities to clarify expectations, adjust goal difficulty, and gain recognition
  5. Appropriate for Task Complexity – For complex goals give the person sufficient time to meet the goal or improve performance and provide enough time for the person to practice or learn what is expected and required for success.

Backward Goal-setting

Or backward design, is used quite often in education and project management. The idea is to start with your ultimate objective, your end goal, and then work backward from there to develop your plan. By starting at the end and looking back, you can mentally prepare yourself for success, map out the specific milestones you need to reach, and identify where in your plan you have to be particularly energetic or creative to achieve the desired results.

This is important where actions must follow a sequence, e.g. construct a road to open up a landlocked development area, or where (as is often the case in planning) achievement of a goal requires delivery of counter-intuitive prior actions.

Competitiveness Strategy & The Challenge-Response Framework (Michael E. Porter[3] and Toynbee)

As set out by the highly influential work of Porter Competitiveness Strategy involves:

  • Performing a situation analysis, self-evaluation and competitor analysis: both internal and external; both micro and macro.
  • Concurrent with this assessment, objectives are set. These objectives should be parallel to a time-line; some are in the short-term and others on the long-term. This involves crafting vision statements (long term view of a possible future), mission statements (the role that the organization gives itself in society), overall corporate objectives (both financial and strategic) etc.
  • These objectives should, in the light of the situation analysis, suggest a strategic plan. The plan provides the details of how to achieve these objectives.

This work has primarily concerned corporations, although it has been influential in framing ‘business growth strategies’ that have been used by many municipalities internationally in determining priorities for growth of their private sectors.

This framework, primarily concerned with cost and competitive advantage, requires  adjustment when adapted to the public sector management of place, when factors more than primarily cost must come into play (although Porter does recommend a balanced score card approach) and the importance of civic responsibility and community leadership must be recognised.   I have found very effective, when working with political leadership, the ‘challenge-response’ framework originally formulated by the Historian Albert Toynbee, to be an effective substitute:

  • Cities and civilizations arise by the response of creative individuals to challenges presented by situations of special difficulty created by the external environment.
  • Progress consists in meeting difficulties by responding in creative ways;
  • The breakdown of society occurs when creative individuals fail to lead through the exercise of creative power, resulting in withdrawal of the allegiance of the majority and a subsequent loss of social unity.

Using this framework one can analyse the special challenges facing a place, with goals being those creative responses to these challenges.

As an example here is the most extreme example I could think of:

Maldives – Challenge – sea level rise will drown the country within 100 years.  Potential responses, persuade other countries to adopt carbon reduction targets of over 80%, or create new areas of reclaimed land and move population, or move population to an area purchased from another country (the ‘uganda’ solution[4]), or become a virtual country of refugees (like Palestine).  Not all challenges might have an achievable or desirable response!

[1] Specific, Measurable, Achievable, Realistic, Time Bound.

[2] “A Theory of Goal Setting and Task Performance.” Prentice-Hall (19 Dec 1989)

[3] Competitive Strategy: Techniques for Analyzing Industries and Competitors 1998.

[4] Named after the early british suggestion of resolving the Palestine question by creating a jewish homeland in Uganda.

Decision Theory for Planners #114 Breaking the Overton Window

Of the spectrum of all possible policy options the frame of all reasonable options is called the ‘Overton Window‘. It is named after its originator, Joseph P. Overton, former vice president of the Mackinac Center for Public Policy

By reasonable its means those considered reasonable in terms of the current political discourse, rather than the additional test of being reasonable in terms of practicality etc.

It is a means of visualizing which ideas define that range of acceptance. Proponents of policies outside the window seek to persuade or educate the public so that the window either “moves” or expands to encompass them. Opponents of current policies, or similar ones currently within the window, likewise seek to convince people that these should be considered unacceptable.

After Overton’s death the concept caused a lot of chatter amongst thinks tanks, expanding the idea so that new ideas entering the public discourse they can shift the window of what is considered reasonable. add the concept of moving the window, such as deliberately promoting ideas even less acceptable than the previous “outer fringe” ideas, with the intention of making the current fringe ideas acceptable by comparison.

Lets take an example.  A political party proposes education vouchers, this is condemned, but following public arguments a new ‘compromise plan is put forward which may be considered reasonable, whereas if this watered down plan had been put forward originally it may have at first been considered extreme.

The following diagram sums it up.

The technique has been used by many previously fringe think tanks to make their ideas seem mainstream.  A classic example is the very anti-planning discourse used by the Policy Exchange (see numerous posts here exposing there methods).  The term has even been taken up by that way-out king of conspiracy theories Glenn Beck as the Title of a dreaful novel.

It is a form of door in your face negotiation.  ‘Would you donate £5,000 to our organisation?  No ok how about £5′

The onslaught of essays, breakfast briefings and speeches by those, including those in No10,  proposing an abolsute minimalist and anti-planning approach in the new NPPF is a classic example.    At the end of the day the planning system might not be watered down as such extreme thinkers want but it might have been watered down considerably.

The problem  is that even giving credence to offbeam ideas can give them a false credence.  This is known as “Okrent’s Law” during his tenure asa news paper editor Okrents commented about his job  “The pursuit of balance can create imbalance because sometimes something is true,” referring to the phenomenon of the press providing legitimacy to fringe or viewpoints in an effort to appear even-handed.  Classic examples is undue press given to climate change deniers and opponents to evolution.

The problem is that applying an argument to moderation gives oxygen to extremists.  It is a logical fallacy, a false balance, as in:

“Some would say that hydrogen cyanide is a delicious and necessary part of the human diet, but others claim it is a toxic and dangerous substance. The truth must therefore be somewhere in between

So if you see someone trying to create an Overton Window there can be only one rational response, don’t compromise.