The Planning Theory of Everything...
In my very first article for The Planner, I compared the planning system in England to a marble run. A delicately balanced system, where just one misplaced piece could spew marbles everywhere.
I have changed my mind.
Planning is an indicator species in a complex, fragile, ecosystem that governs how we interact with public services, the state and each other. In short, everything is connected to planning and planning is connected to everything.
In many ways, planning is the bureaucratic equivalent of the bee - buzzing away in the background, doing its work, and easy to ignore until the consequences of its absence or decline become apparent.
This may seem like a massive digression, even for me, and I am known for my ability to run with a tangent, but bear with me. I have a point. I promise.
Over the weekend, my attention was drawn to an FT article (paywall) which contained the following statement “The last time UK house prices were this expensive relative to earnings was 1876.” There are graphs and charts to back that statement up. It is not an unsupported claim.
This article has landed at the end of a few weeks, which has also contained:
- News that Mid-Devon District Council currently has no specialist enforcement officers - due to difficulties with recruiting and retaining staff.
- Rumours that the introduction of the statutory requirement for BNG is likely to be delayed by a few more weeks at least;
- News that yet another local authority is considering issuing a s.114 notice; less than a month after Cheshire East stated that they may need to consider issuing a s.114 notice because of costs incurred preparing for HS2.
- New guidance from DLUHC on how to navigate possession proceedings; and
- The launch of not one, but two, reports focussing on the need for a more integrated solutions to our housing crisis.
As both the National Housing Federation report and the new report by the University of Sheffield and the LSE point out, all of these stories are connected*.
To quote from the NHF Report from a second:
"Across every community in the country, millions of people are being let down by a failing system. This crisis is affecting our health, our life chances and our financial security. It’s holding back our economy and costing our country billions. It’s breaking down our communities and driving families and keyworkers into financial hardship, away from work, schools and support networks."
Or, as Lord Heseltine's forward to LSE and the University of Sheffield put it:
“The provision of decent housing is of the first priority. If people are to enjoy the sense of security that a home provides and the conditions that make life healthy, comfortable, and secure we are far short of meeting that ambition. The failure to provide adequate housing has serious cost implications for employment and the health service Disparity of income, of age and health will inevitably lead to a demand for different forms of tenure. Most people aspire to own but it is important to recognise that many cannot afford to do so or are in no position to shoulder the responsibility. Particularly, elderly people need more sheltered accommodation.”
In short, the planning system, and the housing and employment sites it enables. is a golden thread** that winds through so many aspects of our daily life, and wider society, that great care needs to be taken when seeking to amend it. When it comes to our planning system, the law of unintended consequences can have significant results.
If the FT article did not provide examples enough, here is a more immediate one.
Zack Simons published a Planoraks blog earlier this week highlighting just one point of potential confusion arising out of the publication of the new NPPF. The blog focuses on the meaning of the new paragraph 226 of the NPPF and whether it require authorities to demonstrate 4 years of housing against their 5 year target; or whether it requires authorities to demonstrate 4 years worth of deliverable housing sites against a 4 year target. Zack comes down firmly in favour of the latter interpretation. On reflection, I think he is probably right. I am also pretty certain that this is not necessarily what DLUHC intended.
The correct interpretation here really matters. Not least as I have heard anecdotally of some local authorities recalling planning applications back to committee on the basis that they fall into the category of of LPAs who no longer need to demonstrate a five-year housing land supply (and can show a four-year supply against a five-year target). It matters for appeal decisions, it matters for plan-making, it matters for individual applications…. and whilst the next set of housing supply figures are not due out until 24 January, I suspect that they will show that ongoing uncertainty when it comes to housing policy is… unhelpful…
Another case in point, the revised NPPF has not done anything to update its retail or town centre planning policies in light of the creation of Class E. As such, we still have a sequential and impact test that has to be applied to new-build developments for town centre uses; whilst changes of use remain largely unregulated. This does not necessarily help local planning authorities who are trying to revitalise declining town centres.
Given that we are likely to have general election at some point in the next year; I would like to send up a plea to our next government - whatever form it takes. Please recognise just how essential, and integrated, planning is both to, and with, our wider society.
To quote that LSE report again “A road map to a coherent housing policy' notes that there has been a seemingly unending stream of reports, over decades, saying that the housing system is broken. These usually stress a particular problem, often new build, and advocate a solution which would actually change, very little. Without an integrated strategy covering housing as a whole which includes providing housing of a safe and acceptable standard, individual policy solutions are likely to bring very limited success.”
The same holds true for planning as a whole. Solutions that focus on just one aspect of the system - say the use of extensions of time - without recognising the pressures on the system as a whole will likely only make things worse, not better.
After all planning is an indicator species. And from the data we have at the moment, it is indicating that we all have quite a lot to get to grips with….
*it may help to imagine a cork board, photographs and a lot of red string at this point…. It is all a little ‘Only Murders in the Building’
**see what I did there
The breakdown of the housing conveyor belt has huge and diverse impacts. Studies show that the inability to afford a home causes people to postpone starting a family or simply not have children at all. High housing costs also divert individuals away from productive places and
activities, and dramatically increase inequality in wealth and between regions”
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