If you fail to maintain the tyres on your car and are unlucky enough to hit a cluster of potholes puncturing all four tyres at once, speeding up will not solve the problem of arriving at your destination. You may lose all control and arrive in a ditch at the side of the road.
Squinch was momentarily optimistic when Boris Cummings announced that reform of the planning system was a key target and necessity in order to “Build Back Better”. The planning system is indeed too slow, cumbersome and costly. Failing to understand why, does not permit a quick fix. The vehicle has more than worn out tyres. It has been neglected for years. It has been left out in the rain too long, gone to rust and needs serious investment and expertise to get it rolling again.
Amongst the latest White Paper proposals is investment in enhanced digital access to local planning portals with a new ‘app’. After the debacle of the Covid-19 tracking app, one awaits this app with extreme reservation. Concern also arises over its use and potential for manipulation. Information is a poor substitute for knowledge. Planning consultation by Twitter? No, thank you.
Local plans seem like a good idea in terms of devolution and input of local expertise. Regrettably the process of preparation is flawed. Most have taken seven or more years to prepare and be adopted. Many under-resourced Local Authorities (LAs) find their Local Plans rejected by the inspectorate, and hence attempt to deal with applications without agreed parameters. This causes uncertainty for officers, committees and applicants. Uncertainty equals risk, cost and delay. Seven years is too long a timeframe to deal with evolving market conditions and too short to encourage real long-term urban, rural and regional strategies.
The intent to produce overriding Common National Planning Guidelines so that LAs can focus on local issues seems to have the potential for providing much needed clarity and consistency. However it is in danger of being oversimplified and has been tried before. The proposition that swathes of land can be simply designated as ‘Growth’, ‘Renewal’ and ‘Green Belt’; this is a gross overgeneralization, with the former two holding a presumption in favour of permission whilst ‘Green Belt’, and other protected areas have a presumption against development. Regrettably, given the UK’s population versus land availability, most ‘Growth’ areas are, in reality ‘Green Belt’. Catch-22 at the first fence. In fact, this is the very reason that Local Plans have been taking so long to agree. To meet Government housing targets, growth has been dependent on the allocation of green belt land.
“The National Planning Policy Framework (NPPF) does not apply and is overridden by local policy” has slipped from the mouth of more than one planning officer with the power to advise rejection of an application. This has been the case even where a local plan is either out of date or unadopted. Investment in recruitment and training of qualified and knowledgeable planning staff is a prerequisite to speeding up the system.
“Design Guides to be prepared by local authorities rather than developers.” Again, this seems sound, but again the expertise and resources no longer exist within LAs. The wheels fell off and were not replaced. Twenty-five years ago, Squinch was commissioned by a wealthy, then-well-resourced central London planning authority to prepare a conservation area ‘Design Guide’. Even then the expertise had to be outsourced. CABE (the Commission for Architecture and the Built Environment) attracted top level expertise to produce, commission and publish a series of brilliant design guides between 1999 and 2011, but these were rarely adopted as policy by LAs. CABE was merged with the Design Council on April Fool’s Day 2011 as a Government cost saving. CABE documents could and should have been implemented as part of National Planning Guidance.
Consistency over financial contributions should provide much needed certainty for development funding, whether commercial, residential or community. If the levy were to be paid on occupation rather than start on site, it would reduce the risk and cost of interest during construction. This will require great understanding to draft effectively since its predecessors, the DLT (Development Land Tax), Section 106 Agreements and the CIL (Community Infrastructure Levy) each had qualities and pitfalls. The idea that the reduction of risk and bank interest might improve the quality of developments or reduce end costs to occupiers seems like naïve optimism.
The whole pre-application and outline consent process requires simplification if the system is to deliver development more swiftly and economically. The pre-app process has been used by underfunded planning teams to delay development. It often requires highly advanced (hence costly) design schemes almost to the stage of a detailed planning application, which misses the purpose of early consultation before design development.
The target of achieving carbon neutrality by 2050 is too slow to meet the real consequences of climate change. The environmental performance of projects should fall under Building Control; this is where proper regulatory control over construction, sign-off and expertise does exist. Government should be promoting and subsidising investment in green technologies and manufacturing to meet future challenges whilst generating new employment.
The idea of creating the role of ‘Head of Placemaking’ at Local Authorities is just wonderful! The title calls for individuals of outstanding perception, passion, understanding and experience. They do exist within the design community but LAs have not had the funds to employ such individuals for too long.
Wanted: Many brilliant, knowledgeable, experienced mechanics.