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The Planning White Paper: misconstrued problems, misinterpreted evidence, misconceived solutions

Roger LevettPartner, Levett-Therivel roger@levett-therivel.fsnet.co.ukJune 2007

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On the bright side ...The Planning White Paper (PWP) includes:• Sensible procedural improvements (though

many just undo problems created in 2004)• Role for planning in carbon reduction, energy

efficiency, renewables (though no concrete actions beyond those aready announced in Ruth Kelly’s Dec 2006 package)

• Excellent rhetoric on the value and importance of planning for sustainability.

BUT ...

Levett-Therivel

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InfrastructureRationale: decisions too slow, costly, uncertain:Creates blight, delays / prevents projects we need.

Proposed solution:• National policy statements define infrastructure needed• Independent Infrastructure Commission applies policy

to decide individual cases

Model:

• Government sets inflation targets

• Monetary Policy Committee controls Bank of England interest rate to deliver the targets.

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Levett-Therivel

Some evidence

(from PWP)

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Speed: is there really a problem?‘The [planning] process can take too long to deliver decisions, impose substantial costs’

Really big, complex cases are a tiny minority.

Of Barker’s 6 picked examples, only 2 took over 43 months: Heathrow T5 and Dibden Bay.

Ministerial decision often adds months. Often because of funding, wider policy consequences.

This will still take time … unless the Commission has power to commit major public expenditure?

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Misleading case: Dibden Bay portBarker presents as example of delay (over 3 1/2 years) and costs (£45M). But:

•Environmental downsides well known before•Costs show how long and hard the developers fought despite knowing these•Time reflects planning’s fairness & transparency: weighing all evidence, not ‘bought’.Developers should ask themselves whether it was responsible to try so hard - not criticise the planning process for scrutinising thoroughly.

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Blight?‘… generate large amounts of uncertainty. This can extend planning blight, severely affecting the lives of individuals directly affected by proposals.’

MIPs usually ‘in the air’ for decades:•W Oxfordshire reservoir discussed since 70s•All London airports threatened since 60s•Central Rail on and off since 80sPlanning time only a fraction of total gestation,often concurrent with funding (etc) negotiations.

It’s the threat of development that causes blight, not planning for it. If we want less blight, the answer is less new development.

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Diminishing returnsInfrastructure inevitably gets harder to fit:

• The best sites get used first: eg valleys where a small dam and a small area stores lots of water near consumers; flat direct transport corridors with least landscape and community damage.

• Each increment inevitably does more damage per unit of benefit.

• Land fills up (often around infrastructure) because of population and prosperity growth.

• Health, environmental, amenity standards rise.

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Holding back the UK?‘… can delay delivery of key infrastructure, with harmful knock on effects for communities, business, the economy and the environment. And it can, in some cases, deter promoters from bringing forward projects in the first place, threatening our ability to deliver the infrastructure we need to continue to thrive as a nation.’

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Infrastructure gives us ...Road (inc motorway) ‘improvements’ to:•allow & stimulate traffic growth (inc long trips)•erode local cohesion and distinctiveness•deepen the disadvantage of not having a car

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Gas power stations to:•squander premium fuel at low efficiency•make us dependent on ex Soviet bandit states•encourage energy waste from low prices•dump social costs (eg mining communities)

Airport expansion to:•increase net outflow of tourism spend•stimulate a totally unnecessary ‘air culture’•grow energy intensive food imports•make negligible difference to business

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Climate change‘National policy statements would need to address the vital issues of mitigation and adaptation to climate change. The potential impact of infrastructure on carbon dioxide emissions, and how to minimise this impact as far as possible, would have to be considered in developing national policy statements …

National policy statements would also need to reflect the physical impacts of climate change on projects and the need for resilience throughout their lifespan …’

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Climate change: realitiesIPCC, Stern etc, acknowledge:• Risks of catastrophic climate change greatly increase

above 2° temp rise / 450 ppm CO2

• Averting this requires at least 80% cut by 2050

Politically easy options won’t achieve this:

• Eco-efficiency improvements are at best preventing further emissions increases

• Emissions Trading Scheme ineffectual (EAC)

• Carbon offsetting often a sham … or a scam

• Anyway trading only moves the problem around: someone, somewhere, has to actually cut CO2.

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Implications for infrastructure Serious emissions cuts necessitate much less •motor traffic•energy consumption•air travel (people and goods)•rubbish needing disposal.

Resilience requires much less reliance on long distance trade, resource flows, travel.

We’ll need less centralised infrastructure not more.

For National Policy Statements to genuinely ‘address’ climate change, they must presume against growth in centralised infrastructure.

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A really sustainable approach?(1) Obviate infrastructure:• Buildings comfortable with less energy

• Good local services that people don’t need to ‘choose’ to avoid:

(2) Local, distributed, closed loops• Microgeneration, district heat / cooling / power• Market gardens, local food processing • Waste digestion, pyrolysis, gasification, burn• Rainwater, grey water, purification, recharge(3) Sustainable methods:• renewable energy• walking, cycling, light/heavy rail

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The shape of things to come?‘The 2003 Air Transport White Paper explained the need to expand our airports but to do so in a way that took account of environmental and other considerations.’On Government/industry scenarios, aviation growth will cause 1/4 of UK total climate impacts by 2050. Independent scenarios: up to 4X total. BAA argue Stansted expansion inquiry should not discuss climate change because ATWP already ‘takes it into account’.

National policy statement invoked to suppress examination of a huge policy contradiction.

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Misleading case: gas storageBarker: ‘the UK is moving towards increasing [gas] import dependence ... new infrastructure is needed to increase the UK’s capacity to import and store gas, with the market planning to deliver some £10 billion of projects by 2010.’ Implies it will be planning’s fault if stops ‘the market’ reacting quickly to keep us secure.

Actually, gas insecurity was a widely predicted result of Thatcher privatisation. If 20 years later ‘the market’ is only now responding, we need more energy planning not less. And better to reduce demand than hustle for supply.

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An unsuitable modelBank of England Monetary Policy Committee pulls one policy lever to manage one numerical variable. All collateral effects left to other instruments.

Barker sees infrastructure planning by analogy as a one-dimensional task of clearing developers to pour concrete fast enough to keep up with business demands.

This ignores all the complexities and conflicts that make planning necessary.

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Conclusions on infrastructureThe country’s economic well-being is not imperilled by an inability to make snap decisions to build ports, airports, railway lines, motorways, reservoirs, power stations and such like in places nobody had ever thought of doing so before.

If current planning process really has ‘deterred’ some infrastructure, this is a benefit.

Putting the word ‘sustainable’ in front of aviation expansion, energy supply, economic development (etc) does not magically make them so.

White Paper’s climate change rhetoric bears no relation to its proposals.

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Damage limitationNew process could be made less damaging if:• Commission appointed by local government,

environmental / social NGOs, academia - not ministerial patronage.

• Wellbeing as prime test of development. Growth or commercial profitability not assumed to be identical to or even consistent with wellbeing.

• Independent sustainability appraisal of national policy statements, with teeth.

• Options hierarchy: (1) avoid / obviate, (2) local close loop solution, (3) most sustainable mode / trechnology.

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Economic development‘We will amend the statement of general principles to … recognise the benefits that development, if properly planned for, can bring, including those that can flow from economic development ... in determining planning applications, local planning authorities must pay full regard to the economic, as well as the environmental and social, benefits of sustainable new development.’

Barker asserts that planning system is biassed against economic development. Example: IKEA expansion thwarted by planning.

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Misleading case: IKEA‘With average 750 staff per store, would have increased employment and driven competition in the sector.’ But IKEA is competitive because•standardisation/automation allows low staffing•sourcing from low cost countries

So more IKEAs likely to mean:•net loss of UK retail and manufacturing jobs•existing retailers forced to copy or go bust•less in-town retailing, more out of town.

Job losses might be offset by sector growth. But:•no attempt to compare + with -•does more Weetabix furniture make us happier?

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Misleading case: IKEA‘[IKEA expansion] also had potential to lower long-distance drive times: over 30% customers drove > 2 hours due to lack of local stores.’Yes, some of them will probably drive less far.But more people will drive to the new IKEAs …And more still will have to when new IKEAs have killed their town centre competitors.

Again Barker makes no attempt to compare + and - effects.

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Misleading case: IKEA‘… despite some local authorities wanting to attract to their area.’Doesn’t mean more IKEAs makes UK better - merely that if you’re going to get the disbenefits anyway, you may as well try to get benefits too.‘IKEA has now changed its business model, making a major retailer cause less traffic and inequity is a success!but this may lead to higher construction and operating costs and lower capital returns …’ ie lower multinational profits, better communities, buildings, lower externalities. This too is success!

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Misleading case: waste projectsBarker: ‘90% of waste applications are granted [but] there is some anecdotal evidence that a number of applications for waste disposal or recovery do not come forward at all.’

No end of applications are possible. If any ‘do not come forward’ because everyone sees they cannot meet requirements on (eg) noise, smell, traffic, access or proximity, planning both prevents undesirable development and saves everyone time.

Principle applies to all kinds of development. Barker presents no evidence that any proposals deterred by planning would have been desirable.

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The ambiguity of refusalsBarker and PWP assume that refusal of planning permission means loss of economic benefit.

High refusal rate could mean:•plan unreasonably restrictive•plan unclear, ambiguous, poorly explained •planners make capricious/inconsistent decisions

Or that potential profits are so high that developers keep ‘trying it on’ (Eg London?)

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The ambiguity of refusalsLow refusal rate could mean:•plan effectively encourages good development•good planner-developer partnership •development the plan seeks is also profitable

Or plan is too weak, planners overstretched, councillors too craven, to stop bad development.

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The ambiguity of refusalsRefused development may be a net loss to the community whose planners foolishly spurn it.

Or it may:•avoid blocking something more beneficial•go somewhere else more suitable•come back improved, and be accepted•be good riddance to bad rubbish.

Barker:•only acknowledges a few of these possibilities•makes no attempt to assess relative prevalence.

… so no meaningful conclusions can be drawn about whether refusal rates are good or bad news.

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Benefits or disbenefits?Barker: ‘The planning system will rightly have a negative impact on investment in some circumstances due to its need to consider economic, environmental and social objectives. Turning down applications that will have a net cost to society is an important function of the planning system. An application likely to damage the local environment, or impose a poor quality of design on a community, may often be correctly refused.’

Quite so.

But ...

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Benefits or disbenefits?Barker quotes evidence only business downsides.

Even this is either pre-2000 or uncorroborated, uncontextualised business anecdotes.

No attempt to identify or assess the social or environmental benefits of planning, let alone compare these with the business costs.

… a staggeringly unbalanced and flimsy basis for arguing that the planning system needs to be rebalanced in favour of development!

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