Plus ça change, plus c’est la meme!
I’ve returned from my mini sabbatical to a maelstrom of documents proposing change in how we plan for, design and deliver development. Some have a wide remit like the NPPF and some have a narrower focus like the Future Homes Standard but there are loads of them to digest. It would be easy to wonder how on earth they all fit together, let alone how to navigate the various requirements and what needs to be done, when. I’ve briefly considered the following updates in this blog:
New Towns Annoucement
National Housing Bank
Land Use Framework
NPPF (consultation closed 10 March)
Design & Placemaking Planning Practice Guidance (consultation draft)
Neighbourhood Health Framework
Future Homes Standard
Future Buildings Standard
EIA regime reform
It is by no means a summary of any of these but please do check out the many updates from learned friends like Nicola Gooch, Simon Ricketts and others if that is what you are after.
Thankfully, there are common themes and principles if you look across the board. You’d hope so, given that public and private sectors have acknowledged the shortcomings of the status quo and there have been a multitude of consultations to respond to (with more to come). What seems new and potentially a headache at first glance, does not seem so new when you look at the detail. Many of us in this industry have long been advocating a strategic and holistic approach and embedding the principles in our work. I’ve pulled out a few themes that I think are very positive and should accelerate progress to more sustainable living if done well, with one big caveat at the end.
Theme 1: Data data everywhere
We have always needed data to plan and design development. Indeed, data is heavily scrutinised through the Local Plan process, at planning committees and at appeal. We never seem to get it quite right though. Not enough data or it’s unreliable or inconsistent with someone else’s. Rubbish in = rubbish out when predicting or assessing anything. Public participation in planning is trickier when stakeholders don’t understand the data. Now across the proposed changes there is a sharper focus on getting data and accessibility to it, right. National spatial data is central to the Land Use Framework, which also links to the NPPF and new Spatial Development Strategies. Understanding data at a local, cross boundary and crossfunctional scale also underpins the Neighbourhood Health Framework and indeed, the new Environmental Outcomes Reports (EOR) regime, to replace EIA by late 2027 is underpinned by quality baseline data and digital forms of assessment. The Design & Placemaking draft PPG promotes digital innovation to improve participatory design. Behind the carbon reduction headlines of the Future Homes Standard is a rehaul of the methodology to provide more detailed and more accurate analysis of energy demand, striving to close the performance gap between design and operation of new homes. So, whilst using data in decision making is of course, nothing new, getting more consistent data in an accessible form is a welcome change and step forward to get things done quicker and better.
A separate but related point is the substantial weight proposed for data centres and AI industries in the NPPF (consultation closed 10 March). As power hungry essential infrastructure for our digital economy, this is a nice segway into theme 2.
Theme 2: Infrastructure first and linking social, environmental and economic
Hot off the press is the list of 7 new towns now up for consideration and the National Housing Bank (part of Homes England) that will help to unlock complex sites, support SME developers with low interest loans and leverage £50bn+ of public sector finance. Such huge sites need infrastructure first so that places are vibrant and sustainable from the get go, not just boxes on a green field nowhere near anywhere, where car travel is the only choice and school places are like gold dust. Similar proactivity and early consideration of infrastructure is implicit in the Neighbourhood Health Framework, which emphasises preventative healthcare and shifting the focus from acute care to being healthy at home in our communities with Neighbourhood Health Centres central to providing joined up day-to-day healthcare services. The Land Use Framework acknowledges that a thriving natural environment and resilience to the changing climate are the foundations of our economy. Hear hear! Shifts in the financial sector towards investments that take a longer-term view of return demonstrate that we are (still too slowly) realising that social + environmental benefit = economic benefit. They are not mutually exclusive. We just need those clever economists and bankers to make clever financial products more mainstream.
Theme 3: Resilience and flexibility
Nothing stands still does it? Definitely not planning as we well know! Of course, one of the most critical issues for our country is resilience: to the changing climate; societal trends; economic shocks (food security, energy security etc). All this has been brought into sharp focus by current geopolitics. One of the core purposes of the Land Use Framework is to increase resilience. The Future Homes Standard’s requirement for on site renewable energy builds in extra resilience in case of disruptions to the national grid (which could still suffer shortages and disruption even when decarbonised). Whilst there are rigid standards for building fabric, flexibility is still retained for design, for example, connecting to a heat network allows for more flexible emissions targets and such networks are also a resilience tool due to balancing demand at scale.
The Neighbourhood Health Framework seeks to ease pressure on hospitals and improve access to personalised and more flexible healthcare. By focusing on preventative action (which must be supported through good placemaking), our communities will be more resilient. Flexibility will be a core premise on which the new New Towns are built of course, with the announcement mentioning co-locating homes, jobs and transport together. A focus on adaptability and flexibility to accommodate changing lifestyles is also front and centre of the Design & Placemaking draft PPG, which will be key guidance for new settlements. There has been much industry debate about the need for a system that supports the largest development sites that will be built out far into the future and the need to be able to respond to serendipitous opportunity (see James Scott’s (Urban & Civic) musings on this, for he is an expert on the subject). Better data and forecasting will help build trust in not knowing all the answers right now, but data won’t tell us everything. We need to take a bigger leap of faith and put common sense building blocks into place now. It’s not rocket science. Trees, open space, sustainable transport links – make sustainable living the easy option. Again, many have been taking this approach for a long time, so it’s good to see these principles emphasised quite consistently across recent documents. The Land Use Framework sums up the approach we must take nicely: “multifunctional and adaptive by design”.
Anyone who has crossed paths with the EIA regime will know that assessing flexibility is a long developed, well- trodden and much litigated path. I am an optimist, so I’d like to think that under the EOR regime this might be simpler in that one would simply (!) consider how proposals with their inherent flexibility would contribute to the desired outcomes. Having spent a good chunk of my career relying on knowing key points of key EIA case law, however, perhaps this is naive!
Theme 4: Focus on outcomes
I think this is the most important theme and I’ve touched on it when discussing the previous three. Flowing through all the proposed changes I’ve mentioned here, including the return of strategic planning through Spatial Development Strategies and the EIA reform proposals is a focus on outcomes. What are the positive changes we want to see in our environment and society and how do we get there? Proactivity and forward planning rather than just mitigating negative impacts. This is not a new principle and there are many organisations who have been doing this well for a long time now. More consistent rollout is definitely positive. If we go back to basics, don’t all of us (well, most of us) want the same outcomes? A long and healthy life with the economic means and social and environmental fabric that allows us to have one?
And in conclusion...
There is a lot of positive stuff in all these change documents. Not all new but perhaps a fresh focus and impetus on making a holistic and proactive approach more widespread. The huge challenge is going to be the time it takes to get secondary legislation in place where needed, to pilot and stress test new systems and to upskill vast numbers of people from the public and private sector so that we don’t end up in a quagmire of backside covering, gold-plating and kitchen-sink throwing. Ideas on a postcard please!