We are particularly enthused to see the Planning White Paper proposals adopting and incorporating a lot of the language and thinking around digital and data in planning that we’ve been advocating for. Accordingly, our response to this consultation should be seen in this light. We have purposefully concentrated our focus on the following points;
- We encourage the incorporation of human-centric design in planning and in the digital transformation of planning;
- We advocate for the better collection and use of data to enable digital planning systems that can make the system accessible and promote collaboration in place-making; and
- We welcome the incorporation of digital technology, data-driven insights and consolidated standardisation to the planning system.
In general we support the reforms set out in the planning white paper, however we do also feel there is further work to be done to communicate the practical aspects of delivering on these reforms. We know that unless there are clear guidelines as to how the government will deliver and fund this, and an assessment on impact of the reforms carried out in full, there is a chance that these reforms could fall short of their best intentions.
We would like to highlight some key factors that do not fall under any specific questions below:
- We welcome change that is well-thought out and puts users at the heart of everything and we welcome the careful use and implementation of digital tools to support planning. We would like to stress the importance of understanding the implication and impact such reforms will have on people working across the sector as well as citizens who live and interact with the planning system. For instance, the cost of implementing digital tools for engagement and ensuring they don’t lock out any citizens.
- We also seek to understand the financial costs of delivering these reforms and in particular the approach that Central Government intends to deliver these. There will inevitably be an impact on local and central government, citizens, the development community and industry as a whole and we would like to understand these especially given that there is an imbalance on resources available across geographic regions.
- We also wish to draw Central Government’s attention to our principles for a digital planning system. We established the Plantech Principles with the Royal Town Planning Institute during 2019, based on extensive collaborative work with planners, academics, civil servants, community groups and technology experts. Our principles outline a shared ambition for a planning system built upon clear structures for the collection, use and sharing of data, and can guide the ongoing development, use and governance of digital within the planning system, particularly through providing clear next steps and responsibilities.
Specific Proposal Related
- Do you agree that Local Plans should be simplified in line with our proposals?
We support elements of Proposal 1, which seeks to simplify Local Plans, however we do not agree with the method of simplifying all land into three categories for the sake of communicating development type and simplifying them to this extent.
There are reforms later on in the document that propose the introduction of using visualisation and interactive web-based maps to communicate Local Plans. We would point out however, that a key advantage of being able to use data and computer aided visualisation is the ability to store meta-data or more information behind simplified images, so the concept of simplifying all land proposals under three categories is not really essential to make this work.
The advantage of digital technology and data-based spatial mapping techniques can allow for more comprehensive classification systems that would enable decision-makers to have access to highly nuanced and complex information, whilst also being able to simplify requirements when showing proposals to a non-technical audience.
- Do you agree with our proposals for streamlining the development management content of Local Plans, and setting out general development management policies nationally?
Proposal 2, proposes setting development management policies at national level and then being fed down to local plans. We support the streamlining of development management policies and in particular we are supportive of the concept of writing policy in a standardised way to make it accessible for all. We would also take this slightly further and acknowledge the concept of writing policy as code. While we appreciate this may not work for every single policy, we know from work done by pioneers in the Plantech industry (both private and local authorities) that this is possible for a vast majority of simpler development policies.
Translating planning policy into code will make development management more flexible and responsive to change and reduce the administrative tasks, freeing up planners to plan. We have highlighted in our second Plantech Principle that the investment in open source digital planning software for Local Planning Authorities are the building blocks of a digital planning system. We also identify that the weight and flexibility of different policies can create uncertainty for developers and the wider public. Digital technology can increase transparency by showing where policies are subject to discretion and flexibility and consequently increasing confidence in the system by users. (Plantech Principle 6)
- Do you agree with our proposals to make decision-making faster and more certain?
We fully support Proposal 6 which seeks to add certainty and speed to decision-making through the incorporation of digital technology. We would like to highlight it’s ambitiousness but also commend its timeliness. In order to make this happen, our experience has demonstrated a number of issues and opportunities that will need to be assessed in order to make this happen. The biggest challenge is the current system architecture and interoperability of digital tools with each other. In addition, to fully digitise the system, there is the danger of designing out the user (be it the planner or the citizen or even developer). It is important to get this right as digitisation for the sake of digitisation, or simply, digitisation without attempting to understand the impact of service journeys can cause issues further down the line. In short, we want to see technology used to improve upon system failures, not replicate manual processing errors into a digital form.
All of the above is also reliant on the people using and interacting with the system to reach a level of understanding to be able to use these tools too. Our Third Plantech Principle highlights the need for local planning authorities to have the digital literacy, skills and capacity to procure and deliver the most appropriate digital tools for their planning services. Equally important, we highlight in this principle the need for the skills to be able to use digital planning tools and interrogate their outputs.
Similarly, we also believe that a digital first approach to reforming the planning system must be inclusive and diverse. Our Fourth Plantech Principle identifies that everyone’s needs (that is, all potential users of a digital planning system) be considered, that services, data and tools be accessible to all including those without the confidence or skills to use digital. Accordingly, we recommend to Central Government to consider this principle carefully when developing a comprehensive resource and skills strategy.
This does not mean that a digital system should live in parallel to or alongside a manual one. Rather, we want to ensure that new tools and services can be adopted and used by all, without significant technical knowledge or skill. Applying Government Digital Service Standards as a default is the first way to ensure this.
- Do you agree with our proposals for accessible, web-based Local Plans?
We are in full support of Proposal 7, which calls for accessible, web-based local plans. Whilst this may seem like a simple proposal, we know from experience and the work we’ve done in and around this that this is far more complicated.
Our First Plantech Principle calls out for standardised common built environment language, processes, documents and data. These will be key to ensuring fully digitised, accessible and web based local plans. All published and commissioned documents, planning applications, local plans and spatial development strategies should be produced in machine readable formats. Standardised, machine readable plans with metadata sitting behind will allow for easy sharing of planning data, documents and methods, support cooperation between government, developers, infrastructure providers and wider civil society.
We believe that the key to faster and more effective decision making is through harnessing digital technology to enable participation, unpack the decision making process and communicate the impacts of development rather than dramatically alter the way people can engage with the decision making process. Engaging local communities earlier and more effectively in the planning process will help increase support and trust in the planning process, making it easier for planning officers to analyse large numbers of consultation responses.
We have committed, as part of our Seventh Plantech Principle to bring SMEs together to identify ways to standardise consultation data. We also acknowledge that there are already sufficient experiments in this space – running digital community engagement processes.
13(b). How can the neighbourhood planning process be developed to meet our objectives, such as in the use of digital tools and reflecting community preferences about design?
Neighbourhood plans are meant to put elements of local plan making into the hands of the local residents – however a lot of neighbourhood plans struggle to get to a stage where they are adopted as understanding how to set up a forum, how to engage and how to interact with the planning system continue to be a challenge for many who are not practised in planning.
Therefore we support Proposal 9’s aim to assist with neighbourhood planning by co-creating platforms and 3D visualisation technologies to explore proposals. The development of pilot projects and data standards to help with this are also a positive. This would need a consolidated effort from all sectors, and is a great opportunity to see if public-private-academia partnerships could deliver on such an objective.
Overall, we welcome the government’s approach to improving the planning system through digital reforms and look forward to continue leading on developing this emerging market with the Plantech community.
If you would like more information on our Plantech work or regarding our response to the White Paper, please email our Senior Urbanist, Nissa Shahid.