Journal Article 1 of 2…

We are told that ‘those who cannot remember the past are condemned to repeat it’- an important point given the introduction in the Levelling Up Act of Neighbourhood Priorities Statements. As some have noted, there are echoes here from the 1990s, mainly of Parish Plans but also Village Design Statements. There are lessons to be learned from those initiatives, although I worry that they will be ignored by the powers that be and an unfortunate history is very likely to repeat itself.

Having virtually retired from his work with Place Studio, Jeff Bishop still keeps a keen eye on neighbourhood level planning and design activity because that was the core part of his work for so many years. That explains what follows in this rather pessimistic journal piece, but the next journal piece that follows will offer potential ways forward.

Design Statements

I will start with Village Design Statements (VDSs) because that is where the story started.

In the early 1990s, the then Countryside Commission’s research highlighted serious public concern about the poor standard of design of buildings, especially housing, in the countryside. Because the Commission did not employ anybody with design skills, they came for help to me and my business partner Ian Davison, mainly because of our wide experience on design and planning. We started with some research about rural design, but Commission staff then made a first suggestion: a national, if just rural, Design Guide!

Given our commitment to community engagement, and the recent emergence of ideas about local distinctiveness*, we turned that first idea on its head. We suggested that local distinctiveness should be the starting point and that the best guardians of that (even if they needed help) were those who lived in a village or town. (* Also see my long paper on local distinctiveness and planning: https://placestudio.com/local-distinctiveness-crucial-but-at-risk.)

As a result, we developed the idea of Village Design Statements built on a strong theoretical underpinning and to be produced, in line with careful guidance, by local communities. To have any real clout, we knew that VDSs would have to knit into the planning system, so we engaged with officials in the then Department of the Environment, with the Minister, and with CPRE, Housebuilders Federation, NALC and others. The result was national agreement that VDSs – if done well – could become Supplementary Planning Guidance (SPG).

In the mid 1990s, with Commission support, we produced the guidance for VDSs to achieve SPG status, helped to set up a grant regime that could support communities, wrote (with others) a whole medley of articles and publications, produced videos (one paid for by the HBF!), and ran courses all around the country for planners and parish councils. We also helped numerous communities with their specific VDSs. By the new millennium, some 2,000 VDSs had been produced and the idea morphed into slightly more complex Town Design Statements (TDSs). An evaluation of VDSs done around 2000 showed that those VDSs that had gained SPG status had had a positive effect on design standards.

Now the problems and lessons, and not just for Neighbourhood Priorities Statements as will be seen. First, a good number of VDSs/TDSs never secured SPG status because, having not been prepared following the guidance, they simply stated that ‘we love all our old buildings and anything new should look exactly like them’. Secondly, some local planning authorities (LPAs) refused to adopt VDSs as SPG, even really good ones, and the shift to Supplementary Planning Documents has led more LPAs to not support them; all for no apparent reason.

Parish and Town Plans

A few years after VDSs started, the Commission started to receive complaints from Parish and Town Councils. They loved VDSs/TDSs but wanted to know why this community-led approach could not be used to give local people more control over many other issues, some more important to them than design. They wanted to produce their own wide-ranging, local level plans and wanted them to also become SPG.

The Commission’s planners then developed Parish Plans and, later, Town Plans to be done by Parish and Town Councils. The range of issues to be covered was extremely broad, including some relevant to the planning system, some a bit borderline and some certainly not land use related. The methodology for preparing a Parish/Town Plan was very simple – do a survey of community issues, views and aspirations, then produce a plan based on the results. That was it. There was no encouragement, format or guidance for the production of the sort of planning-compliant evidence necessary for statutory land use plans.

Communities were told that their completed plans could be sent to their LPA and adopted as SPG. Sadly, the Commission did not do the lobbying that we had done for VDSs, so there was no national level support for Parish/Town Plans to gain SPG status. After a bit of a fanfare to launch Parish and then Town Plans, it was no surprise to see many communities starting to prepare them.

Parish Councils began submitting their plans to their LPAs and then all hell broke loose because LPAs would not accept them as SPG. This caused anger amongst Parish and Town Councils, but the planners were right! Having seen many such plans, they could nearly all be described, if a little over-bluntly, as ‘wish-lists’, lacking the evidence base now required for NDPs and including issues that could not be addressed, even marginally, through the planning system. To be fair, the best Town Plans became, in effect, robust action plans used to encourage their local authority, sometimes successfully, to support a playground here, some youth initiatives there and so forth. But that was not what people had hoped they might achieve.

The text above has no doubt alerted you to worrying lessons we ought to be learning ready for the full arrival of Neighbourhood Priorities Statements (NPSs). Those lessons are elaborated below.

Neighbourhood Priorities Statements

NPSs are not mentioned in the main part of the Levelling Up Act – where the changes to NDPs are described – but only appear much later as section 15K in “Schedule 7 – Plan making”, buried in details mainly about Local Plans. There is no mention of or link to anything about NDPs in section 15K. This may give a clue to the importance attached to them.

There is no clarification of the “qualifying body” mentioned in section 15K but Landmark Chambers believe this means ”a parish council or an organisation or body designated as a neighbourhood forum”. That last term is relevant because NPSs have been developed specifically to encourage action by communities in urban areas where communities have been shown to be reluctant to engage in the complex processes required for a NDP. (It is not clear whether NDP type Steering Groups could ‘qualify’.)

The matters stated in the Act to potentially be considered in a NPS are worth listing:

“(a) development, or the management or use of land, in or affecting the neighbourhood area,

(b) housing in the neighbourhood area,

(c) the natural environment in the neighbourhood area,

(d) the economy in the neighbourhood area,

(e) public spaces in the neighbourhood area,

(f) the infrastructure, facilities or services available in the

neighbourhood area, or

(g) other features of the neighbourhood area.”

This starts off reassuring because it is similar to the agenda for a NDP, but alarm bells ring with point (g) about “other features”. Bassetlaw District’s work, where a DLUHC pilot project has been underway, confirms the ringing of bells because they state that a NPS “could also inform the delivery of other public services, not solely related to land use planning”. And this from an authority involved in a government pilot project!

As another example, to avoid a review of their made NDP, Hassocks Parish Council are already preparing a NPS. They used a Parish Plan type survey seeking community views on priorities typical for a NDP but also others such as “improvement to the frequency and connectivity of bus services“, “provision of more community events” and “funding and development of our schools …..”. This is classic Parish Plan material, well beyond the remit of any land use plan. Those alarm bells are ringing again!

Many who have worked on NDPs have no doubt gone to an opening meeting and, as we have, been asked ‘when can we start the survey?’ or even ‘we have done our survey, can you just help us write the plan?’. That old Parish Plans history is still influencing community approaches to NDPs.

And what about the status of any NPS, i.e. what degree of clout might it have with the LPA? According to Cornwall Council, “NPSs would also be used as a formal input to the local plan process with local authorities required to consider them”. No other government and website mentions refer to SPD or other formal status, instead using terms such as “take it into account” or “have regard to”, i.e. rather damning with faint praise. This is exactly what authorities said in the late 1990s about Parish and Town Plans and does not bode well given informal experience of how even made NDPs are, or are not, used by LPAs.

Those old Parish/Town Plan habits are clearly difficult to break but, unless something is done very quickly, there will be another tranche of highly motivated people (like those in Hassocks) soon to be disabused of the value of their work.

And, of course we await clear guidance, standards, the meaning of terms such as ‘have regard to’ (status as above) and possible grant aid – all absolutely crucial, as the VDS/TDS experience shows,

Though the points about Parish/Town Plans are the most important ones, it is also valuable to consider design issues and hence Design Codes. Codes appear in section 15F of Schedule 7 in the Levelling Up Act, they “must” be produced for the “whole area” of any LPA and should be part of or link into the Local Plan. Apparently, if an authority fails to produce a code or codes, the national Office for Place could step in and do it for them.

At the same time, there has been government encouragement for groups preparing NDP groups to include material about design, perhaps even a policy, in their plan. This happens already as policies in some but not all NDPs, for example:

  • “Proposed new development in the Plan area should respect the existing layout, character and historic design features of the village (and) relevant to the site concerned.”
  • “Development will be considered which would make a positive contribution to that character and be of good design and quality.”

Astonishingly, such policies pass examination despite almost always lacking the background evidence of thorough character assessment to properly explain the “existing layout, character and historic design features” to which any new design should “respond”. (To be clear, some plans are backed up with assessments.) Aspirations – ‘policies’ – as above could have their place in a NPS but that takes us back again to the status any authority might – or should – give to such bland and unevidenced statements, i.e. probably very little, if any.

To gain any real clout, character assessment, guidance and design codes can and should be done by local communities, but that would have to be to a level appropriate for a NDP. Placing such material in a NPS, especially any more rigorous and detailed code, would make it out of place and no doubt prejudice its later impact. It would almost certainly be a waste of people’s time.

As stated at the start, I have a fear that key lessons will not be learned but watch this space for the next blog that outlines some ways in which NPSs could play a valuable role for both communities and planners alongside other initiatives.

Now onto the next blog article, NEIGHBOURHOOD PRIORITIES STATEMENTS: A WAY FORWARD? that offers potential ways forward….