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4. Evidence gathering.............................................................................17
4.1.1 Writing a clear brief ......................................................................... 17 4.1.2 Prioritising evidence ........................................................................ 18 4.1.3 Taking a proportionate approach..................................................... 18
1. Introduction
This case study looks at how 13 authorities have developed action area plans (AAPs) and other development plan documents (DPDs). The authorities have used innovative ways to deliver identified needs. This study will highlight good practice and key things to consider when writing your own plans. The study examines five key themes and the different ways that authorities have approached them: advantages of area action plans governance and buy-in evidence gathering community engagement monitoring and flexibility.
It should be seen as a starting point, offering ideas and options for you to consider, rather than a rulebook to follow. Area action plans are one useful tool in ensuring a proactive, managed approach to change in an area. They are part of the development plan and provide certainty to developers and the community. Produced in the right way, they are community-owned and set the priorities that council and residents alike want to see delivered. We think that action area plans will remain part of the planning framework, but in any event, some of the experiences outlined here will be useful for future local and neighbourhood plan making. The authorities visited were: Birmingham City Council and Bromsgrove District Council Hull City Council London Borough of Barnet London Borough of Redbridge London Borough of Wandsworth Newcastle City Council Plymouth City Council and South Hams District Council
Royal Borough of Kingston upon Thames South Cambridgeshire District Council Southwark Council Wakefield Council
Practical benefits: An AAP shows a commitment to delivery that leads to increased interest in investment from developers and attracts funding from partners. It raises the corporate profile of planning. Involving the community from the outset leads to buy-in and ownership. It is one way of introducing new policy where there is a gap.
and the Strategic Flood Risk Assessment (SFRA). In particular, carrying out joint consultation meant that the community were also not subject to consultation fatigue.
Taking a supplementary planning guidance approach to the district centres meant officers could do something simpler in about a year for these centres. The council produced a regeneration strategy that supports and supplements other documents, and the core strategy. It is also area-based guidance. The council still did local consultation, but didnt need the policy framework for the district centres, over and above that in the UDP. However, the strategies will still be used as a document for bidding purposes. Having a regeneration strategy rather than relying on higher-level policy and a number of plans means the council is taking a holistic view, rather than a piecemeal approach. This leads to a far better chance of coordinating investment and delivering aspirations. Officers were of the view that there was already a satisfactory overarching policy framework. There was nothing inherently wrong with any of the policies, unlike in the town centre, and so it was more a question of just trying to improve the areas, but in the direction already set out in the UDP. There is therefore a choice to be made about the approach that you take in bringing forward plans for an area, which will depend on the policy framework as well as the scale of change proposed.
Richard Grant added: The AAP is the template and statement of aims and objectives what you show to an investor and developer first. AAPs are almost marketing brochures. Through them you should be looking to tell a story and persuade people to come in and invest. Both councils acknowledged that things have happened at a greater rate and of higher quality in the past 10 years than any other time previously. These plans attract the developers. However, Lee Bray suggests it is important to note that it is the entire process you go through that helps get the investment, not just the final plan. All the engagement work is crucial. If the developers are aware of work on an AAP, then their contributions can be picked up to help shape the evidence base and see how it fits into the overall picture. Having the AAP prevents piecemeal development and individual interests coming forward.
A mix of two policy officers and a regeneration colleague worked on the project. The Leader was also interested in promoting investment opportunity. He was excited by the opportunities the AAP generated and wanted to put it in an inspiring and easy to look at format. The council sent a specification to a number of IT suppliers with an urban design bent. It transpired there were very few around who could do that. Virtual Viewing had access to a lot of expertise in a variety of fields. They had people who could provide a local government urban design feel, and who understood that what the council was after was quite different and unique. They also had the IT capacity. Redbridge provided the background data and information on sites, working on a storybook approach. Overall, the work cost 50k. It is a flexible tool, and can be developed and updated as information is available. This can be updated in house in future. It provides a strong case for the inward investment function of regeneration. The council owns the intellectual property, and there has been a lot of strong response in the authority. The Ilford Blueprint was launched at investor conferences. It has already won an award: The SOCITM 2010 Local Government IT Excellence Award. The council may set up an inward investment unit to deal with the level of enquiries now coming through.
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ensure cross-authority councillor (and MP) buy-in. It also set out to all those on the task force that they needed to have economic-led regeneration on the site meeting strategic needs, brought forward through an AAP. That was agreed by the councils, either via the formal decision-making process or signed off by Leaders. In Southwark, the council prepared an AAP for one of the most deprived estates in London. This was part of a bigger, corporate project for the Aylesbury Estate, which was in need of some major work. In preparing the AAP, they set up a client team. The chair was director of the project, and they had housing, planning, property, and New Deal for Communities (NDC) representatives. The team met every couple of weeks. There was an Aylesbury Regeneration Board, comprising the head of regeneration, as well as colleagues from housing, planning, and property. All of these were internal. Planning was one of the things regularly on the agenda, but so was housing management and other issues. Below this, there was a separate project manager for the AAP. This project manager was linked to the planning team to check everything was being produced to time. The group widened out as appropriate to check on different workstreams. The appointed consultants also had a project manager, and they met regularly as well to go through the programme. As a council priority, it was well funded, but this kind of team approach is only set up for the bigger priorities. Working with someone who had the job of implementing the plan was also useful. It is crucial to have that link in order to bounce ideas off them about viability and other aspects not traditionally dealt with in planning. This enabled officers and partners to have some of the more difficult conversations early. It can be seen that it is really useful to set out what the key priorities that the plan will deliver are at the outset. This then leads to a need to formulate a group of key people from both within and outside the authority. Work can then be shared across the group, rather than falling on the council to carry out.
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councillors commissioned the housing need survey). Lee Bray says: You dont win buy-in, you have to let councillors come to their own conclusions. In the end, having a strong vision adopted under one administration may have even meant the new administration made some decisions against their own ethos, such as Sherford. But this shows the importance of sharing the information and letting councillors make their own decisions. Once the AAP was adopted, councillors saw the need and were happy to go along with it. They have taken some brave decisions to support the growth agenda. Their support has been crucial to guiding the officers through. Councillors werent persuaded by officers, but by the information. Getting councillors actively involved In Hull, they found that a more proactive use of councillors has been the key to getting support. Planning got local councillors involved throughout the process, both formally through committees and informally through regular small briefings, giving them updates on the plan process and consultations. The key partner to the council, the Gateway, has programme managers who deliver the policies set out, and they do a lot of work with the councillors, getting them fully involved and treating them on an equal footing. The councillors are happy to be getting professional advice, but also know the area, so they did their own consultation in one of the areas too, in order to get the ideas for themselves. Portfolio holders sit on the delivery boards and regeneration partnerships (which are locally led). There are also neighbourhood regeneration offices. Having the regeneration team located in the area helps, and councillors were also publicising this. It is a comfort to councillors to be able to tell residents they can go to the regeneration office in their local area. At events, councillors were always invited as an integral part, and were sometimes used to speak or facilitate. This provides a very clear and visible link between the councillors, the community and the work. A committee-led approach In South Cambridgeshire, they took all decisions at all stages of the plan to full council. The development plan was pretty much the only thing dealt with by the full council. As such, all DPD preparation saw the full council rolling its sleeves up. Keith Miles, Planning Policy Manager at South Cambridgeshire, took the view that as the council has to agree the plan in the end, he wanted to take them through at each stage. All stages of preparation were agreed at key consultation stages, and also they agreed changes as a result of feedback from consultation. This was a phenomenal amount of work for councillors as well as officers, but it meant the plan was their plan, and they had total
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ownership of it. The risk of speeding things up without fully involving councillors throughout wasnt worth taking. A delegated approach In some ways, the experience at Wakefield shows the potential benefits of an alternative approach to the one at South Cambridgeshire. In terms of councillor involvement, decisions about preparing DPDs are delegated to the Corporate Director for Regeneration and Economic Growth. This is done in consultation with a cross-party LDF sounding board consisting of eight councillors, currently chaired by the Deputy Leader and Cabinet Member for Regeneration and Economic Growth. This has allowed them to save time, as they dont have to go to council/committee at each stage. The arrangement also gets political buy-in inherently in the process. They can then go to council with the version to be published and submitted.
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At Wakefield, the council has developed a close working relationship with the Environment Agency, benefitting both organisations. Officers have worked successfully with them, as flood risk is a key issue in central Wakefield. The Environment Agency came to support the council in the Examination in Public (EiP). They had carried out two SFRAs, one at a broad level for the whole of the borough and one more detailed for central Wakefield. There is an informal agreement to regularly liaise with each other. They held several meetings to discuss key issues and entered into a lot of correspondence as well.
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4. Evidence gathering
This section looks at some different approaches to determining the level and scope of evidence to be used in making a plan. It also looks at some different approaches to working with others to gather evidence. In times of scarce resources, there are decisions to make about what to do in house, as well as how to procure consultants to ensure you get the most out of them. The LDF system has freed up what you call evidence, and how you can get it (for example, through consultation and engagement, not just through studies and surveys). This is important in the context of moving from statutory consultation through to a more continuous engagement approach. Some of the authorities carried out the work on their DPDs prior to the core strategy. This seems to have had an effect on the amount and type of evidence gathered in some circumstances. Some clear learning points in this section are: write a clear brief if you are working with consultants Also, determine what can be done in house before going to procurement prioritise evidence and concentrate on delivery rather than strategy think about impact and a proportionate approach take a pragmatic approach to ensure proportionality cover what you need to support the document, the strategy and the delivery.
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frontloading the process, and they had a specific public relations and marketing team to deal with that. The council took an innovative approach to the selection of consultants, asking for a consortium to come forward to work on different streams: the spatial plan, marketing and communications, business planning and project management. The consultants agreed to gather evidence, do consultation, carry out the preferred options report, and then Newcastle City Council took over. The council did the consultation on preferred options and then took the AAP forward to publication. Consultants were retained as a critical friend in the latter stages. Officers then wrote the submission draft, and took everything to the board at every stage. As part of the review of information that came back, they realised that they had to redo or make more robust evidence. This was already part of the brief to consultants, to review evidence at that time, carry out a gap analysis and so on. Having a well-written brief therefore really helped at this stage, as it was not additional work to be procured or costed.
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needed what evidence, and also what impacts they would have, to determine the scale of evidence. They decided they didnt need to do the number of studies and type that were needed for the core strategy, regardless of the fact the core strategy was yet to be in place. For example, the employment review, carried out for the core strategy, was not needed for the AAP. In terms of employment, there was more of a look into skills and training. The retail study on the estate was much more limited in scope. This shows that there is a definite proportionality to evidence gathering to suit the document and area covered. However, the housing supply and demand model that was developed for calculating affordable housing has since formed part of the core strategy evidence. There is also a need to re-house people whilst the estate is being redeveloped, so the model is being used to look at other areas. Officers put into the pipeline every scheme they knew about, including the scale and proportion of affordable housing that they could support. The planning officers worked with housing colleagues to reconcile records. Housing colleagues were able to share what they knew about registered social landlord (RSL) work in the pipeline and the planners added this to their records. This work fed into the Strategic Housing Land Availability Assessment (SHLAA), so there was a mapping exercise in working out capacity, phasing timetables and contacting landowners to see what their aspirations were. At Wakefield, the development policies document needed very little evidence. It is more about demonstrating that policies are consistent with the core strategy, and the core strategy with regional and national policies. This was done by way of simple tables, including links to how policies meet up the chain and down to sustainability appraisal objectives and guiding principles. The Planning Inspectorate (PINS) found this helpful. One of the differences Neville Ford has found between the development policies DPD and an area action plan the council has adopted was the scale of evidence needed. However, they still adopted a proportionate approach, looking only at where evidence from the core strategy needed to be supplemented.
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The council did a separate sustainability appraisal for the area action plan. This was distinct from the core strategy work, but informed by it. They modified the sustainability appraisal objectives that were set out for the core strategy but made use of quite a lot of the data that sat behind the objectives. Sustainability appraisal work on the development policies DPD was also combined as the core strategy and development policies were done together. This definitely saved in terms of efficiency and resources.
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5. Community engagement
This section looks at community engagement and how different approaches can be drawn out depending on which stage the document is at. This section is also a useful starting point when thinking about neighbourhood plans in the future. Although the AAP is a plan defined by and set out by the council rather than the community, the influence of the right kind of engagement is clear. These examples illustrate good practice that will be relevant in helping the community develop neighbourhood plans. Key points here are: Whats the starting point what do you know about the community already? Remember there are more than just residents. Have a flexible approach for different audiences and stages. Use consultation events and exercises already planned by others. Make the most of existing networks, which the community already understand. Think about rural and urban areas differently.
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this sense, Kingston kicked off with a big open day inviting the local community, interest groups and statutory organisations. The council held the event on a Saturday morning in one of the recently opened clubs in the centre. They set up walking tours and asked people to record what they liked and didnt like with cameras and on Post-its. The participants then came back and reported what they found, and what their aspirations were. In a similar vain, at South Cambridgeshire, there was an issue over how to engage on a new settlement where the people who will be living there are not necessarily in the area at present. With no existing community to consult, they took some of the lessons from Cambourne, a now-established new settlement in South Cambridgeshire. Here, the greatest response came from neighbouring communities. The council was keen to work with these communities in order to show there would be benefits to having the new settlement, as well as being able to demonstrate how the existing communities could be protected and enhanced. The council ran workshops, exhibitions and meetings to explain proposals and give locals an opportunity to help shape them.
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Newcastle also took a flexible approach to feeding back information to the community. Engagement is a two-way process and following on from events, the council was keen to feed back in the most meaningful way possible. There was a workshop at St James Park, and they employed a film crew to capture the event. Very shortly afterwards, a feedback report was sent out to keep the interest alive. They also sent out a newsletter to everyone. There was a series of events held under the banner 1 Big Week. For this, they took a consultation vehicle around the area. The idea was clearly to go to the people, not have the people have to come to you. To some degree, and owing to a lot of previous council work in the area, there had already been death by consultation. However, this wasnt wasted by the council, who reflected this back. They were able to keep showing the thread by saying: You said this, we did this now what should we do more of/do differently? The earlier consultation had been carried out for a different purpose, but was asking the sort of questions the AAP issues and options consultation would have been asking. Despite not setting out a formal issues and options consultation, the Inspector was satisfied that the due process had been followed. This shows the advantages of linking work in with what other departments (particularly regeneration) may already have done, or be doing, in an area. In addition, the council prepared a parameters report, which was basically consulting on the baseline. It set out what the evidence showed, what previous consultation said. This went to the statutory agencies. They didnt do an issues and options report because there had been regeneration plans since the 1970s, and other more recent initiatives in the area. Therefore all issues and options had been carried out under these existing schemes. The council was happy to be able to show a clear audit trail, and the Inspector supported this. The council wanted to make it a bit easier to read, so they produced a summary document in plain English. A questionnaire went out with that, and that is what they consulted on. The council wanted qualitative and quantitative responses, so the questionnaire set a few key issues out. It asked certain questions covering topics such as What types of houses are needed to help regenerate the area?, rather than asking Is affordable housing needed? However, for all the statutory consultees, they did send out the full AAP. This approach shows flexibility and dealing with different stakeholders in a proportionate and appropriate way.
Gateway resolved to still have standalone events of their own, but also to use others, already organised, and support ones that may not otherwise have happened. This presented them with much wider opportunities for engaging the communities. Gateway and the council organised a lot of events. The brand was made clear, and as well as music, sports and arts events, they made it clear that there was a conversation to be had about the area. Working with the partners is more about the overall area than the land use only approach. This style of engagement reflects this very strongly. There were concerns about the communities being over consulted. Pathfinder developed NewAnd as the brand, which was created by combining the names Newington and St Andrews, the two wards being consulted. The two wards had always been viewed separately by the council, but are now looked at as a whole. This prevented the council from carrying out the same consultation at different times in adjoining neighbourhoods, or duplicating consultation. This branding also stretched to how the AAP was viewed and sold to the community. The council did little to sell it as an action plan, but more as a neighbourhood regeneration plan, making it more relevant and realistic. It also ensured that the document related to a place people could recognise. In Plymouth and South Hams there was a huge depth of evidence around Sherford, and the councils worked very collaboratively. The Princes Foundation became involved, and for a district like South Hams, the cache that comes with that may have given the work the right ring, but the inquiry by design work really shifted the focus. From 7,000 objections to Sherford in the early work on revising the local plan, there were then only 300 representations on the Sherford AAP, some of which were in support. This helps illustrate the value of getting out and engaging and helping the community to understand the process. In Plymouth, the council even set up workshops to help people make representations. This was a key part of ensuring the plan is the citys plan.
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Plymouth also has a dedicated community engagement co-ordinator who isnt a planner. This has proved really useful in getting the engagement with different communities. She has led on all the engagement work. With a more easily defined community, such as the existing estate in Southwark, the council was able to use the neighbourhood team. They were able to take the residents through the decision-making process as the council saw it. One effective exercise involved playing a game looking at the relationship between density, value and design. They put a grid over the estate, covered in tiles. Residents were then tasked with reducing the funding deficit by reducing densities and improving the relationship with surrounding areas. This led to residents quickly realising that as higher land values could be generated in areas overlooking the park, they set out higher densities in those areas. Sometimes there is a readily available and independent resource that can be accessed locally to help bring in a different approach. In Newcastle, the council had Planning Aid come in on consultation on preferred options, in particular with schools and faith groups. The officer involved was excellent. He devised a regeneration play, performed by the children, and lots of people came. While they were there, the council could talk to residents in a more jovial, relaxed way. They also went to more diverse groups events. The idea was very much not to make events where people had to come to, but to go to existing events.
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absence of a swimming pool and library. Officers were able to show to the public how the AAP can join up the issues, set a framework and manage the provision, so you can start to deal with that provision. Community forums in the area are set up on a more informal basis, but the council invited service providers along to meetings. This allowed them to say how their plans fit in. It also opened up the community to talk about other issues like housing, which wasnt always high up on the agenda. These community forums were set up after the issues and options stage, and used as the way of doing continuous informal consultation rather than a preferred option report approach. Each event was a mix of presentation and discussion. Ward councillors were also invited to the community forums. Councillors carried out Saturday morning walkabouts of the area. Five or six key people were involved, and this core group organised a community festival, and other events, to help showcase the plan and get more local buy-in. The council also tapped into local groups such as Take Action for Seven Kings. These contained more vocal people, but they organise events in their local area. They have local leaders, religious leaders and a new business partnership with members of the business community on the forum. Ward councillors also walked up the high road and put posters in windows. In this way, you can maximise impact with minimal effort. Use existing meetings without having to devote your own staff time and resources. Some of these key people, such as the religious leaders, received council information directly and then put it on their own websites. In this way, one single message goes to a larger number of people.
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building block of community engagement. About a third have risen to that, a third didnt quite get it, a third didnt want to. So instead of trying to go to 60 individual parishes, the council clustered them around the market towns. There has been a variance in engagement, and willingness. Both authorities took a very flexible approach. They couldnt just go down the public meeting approach. Workshops are where people discuss and express their own views most clearly. In this setting, it is far easier to get people to explain what they want.
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At Barnet, there are monitoring indicators in each AAP. These will be added into the AMR for this year. There is indicative phasing in the Colindale AAP, and set key infrastructure phases, but these depend somewhat on development. More work on this is coming through the infrastructure delivery plan and how that will be updated. They are continuing to meet with the stakeholder group and will do so for the life of the AAP. The larger sites are yet to have applications on them. If there isnt the level of development originally anticipated, then there are some contingencies. Mill Hill East (MHE) had developers involved, so there were no surprises for them. Setting quanta of affordable housing is now different from when the AAP came in. The MHE AAP has some built-in flexibility in its policies in that it has ranges rather than set levels of provision. This was important as it was recognised that the site would come forward in a piecemeal fashion rather than as one site, and therefore what may be achievable in one area may not be appropriate in another. Planning obligations are covered at the end in a flexible way, setting out more of a shopping list approach to what may be contributed towards. In Colindale the developer work included some high-level testing of affordable housing and code for sustainable homes numbers. They asked the question: How would the market be hit by insistence on certain levels of affordable housing and a certain code (4)? The basic response was that S106 only delivers so much, and there would be a squeeze on affordable housing or code level. The levels were set in line with the London Plan but everything will be viability tested. The council will look at the priority for each of the parcels of land, and say these are the things that must be delivered, with flexibility on other targets.
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At Kingston, they have looked at what is working corporately and applied it to the monitoring of the AAP. All the proposed monitoring of policies and proposals are contained in tables at the back. The AMR also has monitoring of the AAP in there. The council has now developed an annual implementation plan, which is what they do for most council plans. This will start from early 2011, and is more of a business plan in terms of monitoring. It will be a new concept corporately to treat the AAP (a planning document) in this way. Normally only corporate delivery plans are subject to this type of implementation plan. It is a sign that the AAP is seen corporately as a delivery plan, rather than a land-use plan. Richard Grant at Plymouth feels that it is not important to look at individual policies, but results on the ground. Ask: Is what you set out to happen being delivered? You need to work to help make the right things happen. Work with the sector and communities to make the plans work. Theres so much more than the quantum of development. Officers recognise the need to talk about impacts. What has gone in, not how much? What has that done to GDP? This is the way you will end up seeing the plan leading to change on the ground. At South Cambridgeshire, Northstowe is now designated as a second phase eco-town. Although the new settlement at Northstowe has yet to be begun, a gap analysis has been done to see what is needed to lift the AAP from the existing position to one that will meet the eco-town standards. The key driver will be those eco standards, and its likely to lead to a lower-density development, so some related issues will be re-opened. This is a more proactive use of monitoring, referring back to key principles and seeing how those will impact on development of different levels and to different standards.
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Planning Advisory Service Local Government Improvement and Development Layden House 76-86 Turnmill Street London EC1M 5LG Telephone 020 7664 3000 Email pas@local.gov.uk www.pas.gov.uk The Planning Advisory Service provides consultancy and peer support, learning events and online resources to improve local government planning. Sign up for email updates online at www.pas.gov.uk/register PAS is a Local Government Improvement and Development programme and part of the Local Government Group. We are funded directly by the Department of Communities and Local Government. Cover image: Ilford High Road, with kind permission of the London Borough of Redbridge
Local Government Group, August 2010 For a copy in Braille, Welsh, larger print or audio, please contact iHelp on 020 7664 3000. We consider requests on an individual basis