Guest article by Alastair Brown Director of Arete Management & Consultancy Ltd
The value to national aspirations of an efficient and effective development control system should not be understated. The Centre for Cities recently published a report which highlighted the failure of the planning system to develop sufficient housing and office space as one of the main reasons that London’s productivity hasn’t matched that of some of its global peers.
With the UK entering a new era of resilience planning with the recently published UK Government Resilience Framework (UKGRF), how will the policy that controls development in the UK assist us in making our communities and the businesses within more resilient?
The changing face of resilience in the UK
The UKGRF is proposing to take a whole-of-society approach to resilience planning. Resilience planning in this context is not solely about response. Tactical preparation and testing of response, of course, will continue to be essential. But resilience planning will now also need to consider building resilience through recovery, strategy, and bouncing back stronger.
Stresses, such as economic downturn, gaps in business provision or poor housing, affect the fabric of communities and the businesses within and have a major influence on resilience capability. If the pandemic taught us anything it is that understanding the interdependencies between community, economy and place is critical. Poorer housing, multi-generational households, working in front-line services, and lower income were all higher risk factors for COVID. A town, city or country is only as resilient as its least resilient community. The pandemic was a harsh lesson for us all that inequality is a real barrier to resilience.
Evidently, if we are to be better prepared and able to bounce back stronger, local resilience planning must become more than the reserve of blue light services and emergency planning teams. The business community and local community groups will have to be more engaged. After all, who best to understand the needs of an area. But what of the role of local development planning?
The role of development planning
The National Planning Policy Framework (NPPF) provides guidance on development and is the enabler adhered to by all planning authorities when drawing up local planning policy and in all local planning decisions. It covers new development and change of use and will guide the shape of tomorrow’s communities and business. It is not legislative but is mindful of relevant legislation. The latest update to NPPF has been delayed but is awaited in consideration of the UK government's consultation on the Levelling Up and Regeneration Bill in 2022. NPPF acknowledges environmental, social and economic objectives but it offers little by way of guidance to planning authorities on the approach to resilience. The word ‘resilience’ only appears four times in a document of 75 pages - twice concerning public safety and twice on climate - and the comprehensive glossary at the end does not offer a definition for resilience.
What should we expect from planning for greater resilience (and what more do we need to do)
If we are to enhance the capability of local communities and businesses to improve their resilience, we evidently need to bring development planning into the equation. How might we do this?
Regulation - Planning is a statutory function. The primary statute is the Town and Country Planning Act 1990 (1997 Act for Scotland) with regulations made thereunder. Resilience has no such statutory status in the UK, although, regulation can be provided through specific legislation, such as the emergency powers under the Civil Contingencies Act 2004. This Act, though, is mostly based on dealing with specified emergencies and civil protection. Planning officials would generally have no expectation to be involved. The UK government is due to review existing regulatory regimes for their applicability to resilience and will have to consider development planning as part of this.
The UK government’s recently published Levelling Up and Regeneration Bill has quite significant implications for local planning but apart from references to the need to consider mitigation and adaptation measures concerning climate in spatial development, it offers little on broader planning for resilience. Localis, a not-for-profit think tank promoting neo-localist ideas, has recently been calling for a Local Resilience Act as a means of expanding local planning for climate resilience. It sees a Local Resilience Act as consolidating the role of local government and ensuring funding and revenue streams are provided to bring about the necessary climate actions needed in areas such as transport, buildings, local businesses, land use and biodiversity.
New legislation or not, the move towards addressing some of the climate risks in the next iteration of the NPPF or in the Levelling Up and Regeneration Bill is welcome. However, it is important to realise that local planning centres on change of use and new development and will not address existing issues, such as, housing on an area of increased flood risk. NPPF has also focused up to now on flooding and offers little on other potential resilience issues, such as, in relation to energy or food or the provision of the community facilities that bring the cohesion that enhances the resilience of a community. There are, therefore, evidently gaps in UK regulation and guidance that will need to be addressed if local planning is to aid resilience plans.
Data and standards – local planning policy already uses data to evaluate current, and to project future, requirements. But for resilience planning to work in the UK will require co-ordination of data that supports both resilience plans and local development plans. Standards and measurements of resilience will need to be accessible for development planners and must consider what is already available for development planning and for buildings. Future planning and design standards will need to go beyond what is currently in use and encourage local development planning to consider resilience support. For example, design standards currently seek reassurances on energy use but do not consider potential mitigation measures such as shading, building orientation, growing space or rainwater harvesting. And planning conditions, as current, encourage climate adaptation but offer less on facilities for agriculture, energy or community cohesion, all of which could help to boost local resilience for communities and businesses.
What are we to make of this? In short, we need to have those responsible for development planning in the UK effectively engaging on resilience planning. This hasn’t been the case up to now but with a new resilience regime coming into play it is essential that we utilise all skills and knowledge to enhance the resilience of local communities and their businesses.
There are some promising signs – the University of Kent, for example, has a resilience module in its curriculum for planning students. The University of Ulster has recently introduced similar, and the Royal Town Planning Institute has been bringing resilience into discussions when accrediting university planning courses. The UK government has also committed to setting up a UK Resilience Academy designed to broaden training and development for resilience professionals.
The Environment Agency, too, recently emphasised that every £1 spent advising on flood risk matters in spatial planning applications resulted in an estimated £12 saved in future flood damages.
There is much more that can be done in this space, though. Development planning is not in itself a resilience function. However, having a development control system which understands and contributes to our resilience is essential for effective resilience planning.
The UK government is committed to reviewing existing regulatory regimes for resilience to ensure that they are fit for purpose and to introduce standards for resilience where these do not already exist. It is also committed to providing guidance for businesses, communities, households, and professionals on resilience and on what should be expected from each sector. Planning regulation is already covered by statute and has the relevant framework in place to support the planning process and advise local development planning. It is imperative that the guidance available for planning authorities is periodically reviewed to ensure that it encourages effective resilience in local areas. It is also imperative that any future guidance includes advice for planning authorities on what is expected from them to enhance local resilience, for example, through the provision and sharing of data and in the future review of local planning policy. The new UK Resilience Academy must include an understanding of development planning in its teaching for resilience professionals.
Ultimately, the co-ordination between authorities, the private sector, the various professional groups and local communities will need to work and work effectively if we are to achieve the level of resilience that is essential to support future growth and well-being. Planning authorities and those working with businesses and local communities on development control will need to be brought into this space and understand the value that they, too, can undoubtedly bring to resilience planning.