21st Century Slums? My own commentary on the Raynsford Review Feb 2019 - a forerunner to the White Paper
“It is about aspiration for a better future in which we and our successors can create places of beauty and opportunity, rather than accepting the poor-quality outcomes that are increasingly being generated by current arrangements. We make no apologies for setting our sights high. To do anything less would, in my view, be a dereliction of duty.”
Nick Raynsford 2018
It’s easy to feel beaten down as a Town Planner in the current climate, with so much negativity around the planning system; poor service from local authority planning departments faced with cuts to funding, the link being made between planning and the housing crisis and there not being enough affordable homes. Planning is often viewed as a barrier to progress, overly bureaucratic and ‘getting in the way’. This perception of planning frustrates and annoys me as an operational planner working in the industry, continually looking for ways to proactively drive progress.
I have always been passionate about geography, which lead to me becoming a Town Planner. This passion is rooted in my curiosity in the interaction of people with places. I have always been so excited and optimistic about the purpose of planning and its contribution to place making, the public realm and ultimately our quality of life; The unseen things people don’t realise about how they enjoy places and spaces such as the contribution planning makes to the control and use of green spaces, the scaling and mass of buildings, their form and shape and how this influences how people interact with buildings and places and make positive associations and connections with them.
The Raynsford Review of Planning was set up to identify how the government can reform the English planning system to make it fairer, better resourced and capable of producing quality outcomes. The latest publication ‘Planning 2020 ‘One Year On - 21st Century Slums?’ is a review and update since the publication of the final report of the Raynsford Review of Planning in November 2018.
Sadly, it is a sorry and well rehearsed tale of low morale within the planning system generally. Poor perceptions of planning have been fueled by significant Government cuts made to Local authorities. So many are working in departments stretched to capacity unable to deliver the quality of service they once could, frustrated at criticism from the public, the private sector and central Government over failure to meet targets relating to housing, processing timescales and Local Plans.
The National Planning Policy Framework (NPPF) reviews of 2018 and 2019 brought renewed focus and pressure to deliver new homes, whilst at the same time protect the Green Belt from encroachment, protect wildlife, create high quality places that meet onerous sustainability credentials in the wake of Climate Emergencies being declared across Councils, as well as delivering adequate infrastructure - roads, parking, community facilities and affordable housing; It’s a tall order.
The Raynsford Review of 2018 set out ‘an ambitious narrative for fundamental change.’ It put forward recommendations for a new planning system which would (to paraphrase) :
- “Have a clear purpose, with the aim of achieving long-term sustainable development, and the creation of places of beauty, safety and resilience;
- Offer greater certainty and predictability to all parties involved in the process;
- Provide a more logical framework for decision-making at the most appropriate level;
- Secure a fairer balance between the interests of landowners and the public in terms of sharing the uplift in value derived from development;
- Attract sufficient people with energy, talent and commitment into planning in both the public and private sectors to ensure an adequate supply of imaginative, skilled and committed planners to deliver inspirational place-making.”
So how are we doing?
In summary, not great. A year is not a long time given the scale of change The Review proposed, but it seems we are moving in the wrong direction, towards greater deregulation and continued lack of investment, which will not promote the aims the Review set out to achieve.
The report reveals that a year on there is still no clear purpose for planning, and if anything greater tension and confusion over what the purpose of planning should be. This is highlighted by the various Government commissions relating to improved design (‘National Design Guide. Planning Practice Guidance for Beautiful, Enduring and Successful Places. Oct. 2019, ‘Building Better, Building Beautiful. Feb. 2020), and the continued deregulation of planning with the relaxation of permitted development rights:
“The tension between the publication of a new government design guide and the outcomes of the relaxation of permitted development perfectly illustrates a system which lacks a credible and coherent narrative.” (page 6)
This is despite two major opportunities to address this in the 2018 and 2019 updates to the National Planning Policy Framework (NPPF), and the draft Environmental Bill.
There has also been no progress made in improving and strengthening the plan-led system, which still relies on a number of complex factors involving prolonged and protracted timescales and processes, which results in continued uncertainty for all those involved. There has been renewed emphasis on the role of neighbourhood plans but the reliability of these filling the policy void is described as ‘fundamentally flawed’ due to their discretionary nature. And whilst there has been renewed emphasis on Neighbourhood Planning and therefore the role of communities in planning there still exists clear disparities and power imbalances between communities and stakeholders, not least sceptical and under funded local authorities who regularly question the motives of Neighbourhood Planning groups and have little resources to engage with them.
There has been progress made on the role of viability within the planning system as a result of the 2018 NPPF review and associated Planning Practice Guidance. However, the appropriate mechanism for land value capture is still to be realised.
“One of the stand-out issues for the Review was how low the morale and capacity of the public sector planning service had become, and particularly how major budget cuts have driven this decline.” (page 8)
Whilst the Government introduced flexibility to increase planning fees and there has been some take up of Planning Performance Agreements, many Local Authorities are under resourced and suffering the consequences of an over stretched workforce not equipped or able to provide the quality of service needed to deliver ‘an effective, skilled and motivated planning service.’ I am regularly frustrated by not being able to get through to planning officers at local authorities on the phone or gaining any response to emails. Delays are a common occurrence.
The Review highlights a number of key ongoing challenges. What comes across strongly is that the relaxation of permitted development rights to allow housing to be developed without planning permission has opened the gateway for the creation of the ‘slums of the future’, and that this is a grave concern that will likely exacerbate problems of poverty and isolation for the most vulnerable people in society for years to come:
“Some people continue to argue that the provision of housing units, however sub-standard, is better than no homes at all for those in greatest need. This is not an argument that bears close scrutiny. Housing some of the most vulnerable people in our society in substandard conditions and unsuitable locations..or in high-rise office blocks..damages their health and life chances.” (page 11)
This for me is one of the saddest outcomes of further deregulation of planning and extension of permitted development. It undermines what the purpose of planning should be, which in my mind is to create successful places for people to thrive. What the review has shown is the ludicrous loopholes and poor planning that has resulted in warehouses being converted into residential units in isolated locations with inadequate levels of light and amenities to meet a person’s basic needs and to enable even a basic quality of life. Sadly the review confirms that ‘it is right and proportionate to conclude that government policy has led directly to the creation of slum housing’. It is ironic that this was exactly what the original planning act of 1947 was set up to address; post war slum clearance following the Second World War, and to impact positively on the rebuilding exercise of towns and cities.
This sentiment is reinforced by a quote from a senior planner in the Review:
“Some of the outcomes of permitted development applications are breathtakingly bad. It is a corruption of the planning system and corrosive to the morale of the department. None of us came into planning to make people’s lives worse.” (page 21)
Despite this I still hold much enthusiasm for planning and its purpose. There is much to be proud of that I see in my day to day work with my colleagues - people passionate about architecture, design and planning; like minded people who want to create successful buildings and places. In terms of The Raynsford Review’s initial recommendations there is in my view no shortage of people with ‘energy, talent and commitment in planning in both the public and private sectors capable of delivering inspirational place-making.’ The very existence of the Raynsford Review, made up of academics, politicians, policy makers and consultants, with a clear purpose and remit, gives me great cause for hope and optimism. The review has identified the existing flaws in the system and highlighted where changes need to be made to create a fairer, more transparent and equitable planning system and one that protects the most vulnerable in society.
The review does highlight examples of successful outcomes of the planning system, despite the existing system:
“The ingredients of success in these places have some common attributes, including a good understanding of the unique identity of a particular place, strong political leadership with a long-term vision, strong community and business participation, sufficient and well managed resources and skills within the public sector, and, of course, inspired and talented planners.”
It is always really positive to see good examples of successful place making, which act as models and case studies on which to base future ideas and projects.
Working within the system currently feels like there are too many competing interests that are all being put high on the priority list: Housing, Affordable Housing, Biodiversity, Flood Risk, Drainage, Transport Infrastructure, Heritage, CIL, Design, density, parking etc etc. The list seems to be building, creating a system that is unwieldy, protracted and difficult to navigate. This is to some extent what has driven deregulation; the current system has become unworkable.
Perhaps the new ‘clear purpose for planning’ the review is seeking needs to recognise the difficulties of placing too many deliverables at the top of the priority list.
In my mind successful places are, put simply, places that:
- Enable people to thrive
- Feel safe and inclusive
- Have been well conceived and designed
- Use good quality, sustainable materials
- Prioritise pedestrians and cyclists over vehicles
- Protect wildlife and plantlife
- Provide for their communities
Since joining Strides in August 2019 I have been fortunate to have been involved in a diverse range of projects, many focused on delivering quality outcomes for people through new education facilities, new health facilities, new housing and innovative projects that seek to broker new ground in terms of their use of technology.
In all cases I am fortunate to be working alongside highly skilled individuals, passionate about what they do and striving to deliver the best outcomes on projects to create successful buildings, something I’m proud to contribute towards.