Housing Delivery Test etc

1. Housing Delivery Test etc PAS Conference Richard Crawley 27th September 2019 www.local.gov.uk/pas

2. This session • Housing Delivery Test basics • The process of making an action plan • Action Plans - are they any good ? • So what?

3. Housing Delivery Test basics • You will have heard me say lots of this before • but that's no bad thing • especially as it's not having any effect • Fascinating to be in at the beginning • Lots of complexity • try hard to say simple things • obvious only in retrospect

4. Housing Delivery Test basics • 108 councils named on the list published in February 2019 • 104 planning authorities post LGR • 66 councils have published • 63% success • 37% fail • A few others saying “sign-off shortly”

7. Housing Delivery Test basics • What about the 37% ? • No action from Govt (I think) • We *are* expecting another cohort in Nov • but I am not putting bets on it • Revisiting HDTAP more quickly • second cohort focus on • quality / depth / engagement • other stuff ?

8. Housing Delivery Test basics • We supported about half of the councils • Through a series of workshops • And a report template, evidence template • I learned lots along the way • about the process of making a planning policy document • and about what good outputs look like

9. Process of making the HDTAP • The production process is owned by planning policy (almost entirely) • DM “too busy” • Generally welcome (ish) • thinking about monitoring / effectiveness again! • Often starting with “Action” rather than evidence • lots of rehashing departmental improvement plans • lots of following the NPPG list

10. Process of making the HDTAP • First HDTAPs not great (“low key”) • iteration and annual review • significant actions take agreement & time • So much else going on, low risk of intervention. • Less “hot” than we were expecting

11. Process of making the HDTAP • Feedback and accountability with developers • you said last time ... • an interesting exercise leading up to examination • Interesting space • intersection of housing, planning, investment, relationships • Interesting times • sharper focus on delivery and land supply management at examination

12. Evidence • Land supply pipeline is crucial ! • suitability / capacity • control / motivation / expectation • The easiest data is the least interesting • recent DM activity = easy = well understood • old / stalled / uncertain / uncontrolled = target ? • How do we adjust from an over-optimistic 5yLS to a more realistic HDTAP ? • Appeals in progress. Awkward

13. Evidence • Data is fragmented and all over the place • Local Plans • SHLAA / HELAA; AMR; 5yrLS; registers • Development Management • pre-app / applications / conditions • Corporate systems • assets (asset strategy); council tax; naming & numbering; building control • Improving (slowly) - see GLA's LDD

14. Evidence • Soon this will involve neighbourhood plans • Are NP's delivering, and is intervention required ? • Give them a RAG rating ? • unpopular ? • Easy to mistake cause and symptom • ”poor viability” • cause or symptom ?

15. “How does your action plan support your strategy?”* *Often it didn't

16. Evidence • Data doesn't need to be perfect • proportionate / pareto • types / samples • inform actions, not be perfect snapshot • Broader digital agenda • we are in transition (we hope) • open registers • better reuse • more automatic, less manual • developers keeping their numbers accurate (?)

17. Evidence • Lots of people presented action plans that were “de-coupled” from their development strategy • Approaching the issue from three directions helps:

18. The lightbulb moment • Who is going to read this thing ? • What is its purpose ? • Is it giving you bang for the buck ? • KISS • More numbers, fewer words • Clear actions and progress

19. 1. Who is going to read this thing? • Hint: not the government / an inspector • unless it is ! in a topic paper supporting your plan ! • Your developer community ? Your leader ? • Why should they? • No one wants to read your “things to do list” • “I'll turn to p. 14 and see what this means for me” • Think “inside” / “outside” [the council] • Think “big up Bolton” = promotion and intent

20. 2. What is its purpose ? • What is the purpose of the action plan ? • to “Pass the test” ? [not for many places] • to flag issues for others ? [eg Natural England] • to make different decisions at committee ? • to coordinate investment / LEP / regen ? • More political than at first sight • Actions congruent with local priorities • Reinforce key messages (“brownfield first”) • Unlikely to be a list of silver bullets

21. 3. BANG FOR BUCK • You are special and unique • You have powers that no one else has ! • What can only you do ? • Local and specific - even site specific • Avoid mundane and weak • “attend a meeting of” ... “review register of BFL” • Where are the biggest wins ? • Not all voices are equal • Not all typologies are equal

22. 4. Keep It Simple Stupid • Would the CEx recognise the narrative ? • Is it a neat parcel that ties things together? • think of a busy reader • Structure and TOC are free - just learn how to use styles please • Acknowledge context and hand-off not duplicate

23. 5. MORE NUMBERS • Projections, scenarios, predictions • Otherwise how will you know what your baseline is? • HINT: many peoples results will get worse because of the way LHN is phased in - the perception that your actions are making things worse is not good • are people avoiding bad news ?

24. 6. Actions • Actions like being in a table • what is the best table ? • Framed in ways your audience connects with • outcomes on their terms • Not enormous bounds but steps along the way • With previous completed steps still visible • Hint: there are no bonus points for completeness. Only clarity.

25. The best template for action...

26. Top tips • A bit naive, yes • you can't be seen to be too pro developer • nor short-circuit plan making • Did anyone listen ?

28. So what ? • We *love* feedback loops • the HDT is a feedback loop • encourages finding out / intervention • This is almost a good thing! • But it fails • cycle is too quick / mechanical • actions don't have time to produce results • why bother (and why bother with a plan either)

29. So what ? • Housing Delivery Test (only) • Assessment and Punishment by spreadsheet • no discretion / humanity / judgement • “Presumption” works differently • greenfield / greenbelt / urban • for many it doesn't matter • National regime lands differently • not “the naughty” that get caught, just the unprotected

30. So what ? • Can we give developers the forecasting job ? • and how might we minimise game playing ? • Can we make the HDTAP, the APS and the AMR the same thing / same timetable ? • they are all about land and delivery • include various registers too • How will we collectively learn which actions produce best results ? • hint: by asking developers not planners

31. So what ? • This could go either way • proactive / monitoring / intervention or • permanent presumption / appeal • Action Plans thus far underwhelm • and no one reads them anyway • The regime needs a bit more work • cannot rely on improving completions as evidence of being “good” - the lag is too long • Yes to feedback loop - make it more holistic

32. Questions? Email pas@local.gov.uk Web www.local.gov.uk/pas Phone 020 7664 3000 Twitter @Pas_Team