Is the planning system now in a holding pattern until the general election? It certainly feels that way.
The consultation announced in December 2022 over proposed changes to the NPPF (see my 22 December 2022 blog post It Will Soon Be Christmas & We Really Don’t Have To Rush To Conclusions On This New NPPF Consultation Draft) led many authorities to delay or withdraw their local plans (see for instance Local Plan Watch: The 26 authorities that have paused or delayed their local plans since the government announced housing need changes (Planning Resource, 27 April 2023 (subscription)) and Delayed Local Plans (HBF, 27 March 2023)). The thought occurred to me this week when I was speaking with Peter Geraghty at a TCPA event (congratulations David Lock for your well-deserved Ebenezer Howard medal): if Trussenomics described the event that led to last Autumn’s economic crisis (the repercussions of which persist), what should be the word for that 22 December announcement?
Even if the policy thrust set out in the 22 December announcement was appropriate and worth some short-term process turbulence, it has already stalled. So, what really was the point (aside of course from its politically necessary signalling of capitulation to Conservative backbenchers’ concerns over the prospect of development taking place in their constituencies)? Consultation closed on 3 March 2023. The Government was to respond to the consultation and publish the revised NPPF in Spring 2023. There was then to be consultation on proposed changes to the rest of the NPPF and on more detailed policy options and proposals for National Development Management Policies (supported by environmental assessments), once the Levelling-up and Regeneration Bill had passed through all its Parliamentary stages shortly thereafter. But the Bill is still in the Lords. Lords Report Stage will be on 11 and 13 July. We then have the summer recess (Commons from 20 July, Lords from 26 July) and the Bill then needs to return to the Commons – so there is no prospect of Royal Assent before Autumn 2023. I can’t see how the LURB’s plan making reforms can be implemented this side of the general election.
And yet the Government criticises local planning authorities – and indeed developers – for not getting on with things….
In the meantime, we have little flutters of activity, the latest being Michael Gove’s endorsement this week of a paper published by Policy Exchange (the Government’s de facto policy incubation hub), Better Places: A Matrix for Measuring & Delivering Placemaking Quality, which is an exercise to see whether determining the quality of place making can be reduced to a “universal tool capable of measuring how successful developments will be, (or are) at placemaking for the very first time.”
“The Placemaking Matrix contained within this paper sets out a series of questions whose answers can be used to calculate a score which then reflects the placemaking quality of any new development. Combining the two words of its title and conveniently appropriating the Latin word for peace, the score will be known as the PAX rating.”
“The matrix questions are divided into three groups, those that relate to the Physical, Socio-Economic and Psychological elements of any new development. In this alone the rating system forms a pioneering departure from conventional placemaking practice, while it is relatively easy to define physical attributes and, to a slightly lesser extent, socio-economic ones, no previous study or standard has attempted to quantify the psychological content of places and yet these are arguably the most important when assessing their human impact. The PAX system does just this.”
Aside from the substance of the paper, one thing it really calls out for is some sub-editing and proof-reading. Mark these passages on a range of 0 to 4:
“It is important to note that the Placemaking Matrix does not present itself as a definitive ‘magic formula’ that can conclusively determine design quality and character. While the Matrix sets out to be a universal tool, the localised nature of placemaking will inevitably require adaptation to local contexts and conditions. Consequently It is not our intention that the current set of questions are forever fixed in stone forever. While the paper acknowledges that there are objective, observable truths that define good placemaking, it is not so ideologically rigid as to suggest that a tool such as this must attain pure, unqualified universality. We see our paper as the earliest development of the matrix and we hope and anticipate that with time, testing and hopefully trust from the industry, the questions can be modelled, adapted and evolved to strike the best possible balance between universal best practice and the localised, contextual nuance that also helps drive placemaking success.”
“Furthermore this paper emerges as the latest addition to a Policy Exchange Building Beautiful programme that has attempted to distil the very essence of beauty into an objective standard rather than a subjective instinct, a challenge that now form a central part of the political housing debate.”
So, it’s to be a “universal tool” but (I like this phrase) not “forever fixed in stone forever”. The paper is “not so ideologically rigid as to suggest that a tool such as this must attain pure, unqualified universality”.
Reader, my head was hurting. And then I entered the Matrix: 272 questions, each to be marked on a range of 0 to 4. The percentage score of each of 12 sections is then averaged out. 70% outstanding, 60% good, 50% average, below 50% poor. The questions are quite specific but in large part call for subjective responses. Their relevance is wholly dependent on the scale and nature of the scheme and its location. Some examples:
- Does the development incorporate cycle lanes?
- Does the development maintain a cycle hire scheme?
- Does the development contain fountains?
- To what extent do building uses integrate into existing usage patterns in the area surrounding the development site?
- Does the programme design incorporate opportunities for impromptu street performance?
- Does any programme apparatus incorporate audio-visual, tactile, sensory or play equipment?
- What level of healthcare facilities have been provided on the development?
- Has a letterbox been provided within the development?
- Will any properties offer commonhold ownership?
- Does the development incorporate audial stimulation? (i.e. church bells, wildlife habitats)?
- Does the development promote a visual brand, motif or logo?
Why on earth add yet another technocratic process to the system, to be gamed by all concerned? I would say it’s tick-box but it’s worse than that!
This would all be classic “silly season” stuff. Except for Michael Gove’s endorsement by way of his foreword:
“…it is because placemaking is crucial to the country’s long-term health that Policy Exchange’s newly devised Placemaking Matrix promises to be an indispensable resource. A universal tool that can be used to score a range of elements seen in new and existing developments, it can help build confidence in the wider social value of new residential schemes during the planning process and so unlock much-needed new housing supply.”
“For too long, quality has been viewed by many as a planning impediment. The Placemaking Matrix could help transform it into an incentive. Ike Ijeh’s brilliant new paper for Policy Exchange is no less than a detailed instruction manual for how we can create the good places of the future. I hope it receives the welcome it deserves.”
I don’t disagree with the final sentence incidentally.
Simon Ricketts, 23 June 2023
Personal views, et cetera
Photo extract courtesy of Rafael Ishkhanyan via Unsplash
SIMONICITY 