40. When is guidance not guidance?

Hot on the heels of the NPPF and its underpinning rationale of dramatically shrinking the nation’s planning policy (1,000 pages to 47) comes the draft (Beta) version of the new online Planning Practice Guidance (PPG), exhibiting a similar determination to shrink the existing 7,000 pages of assorted practice guides down to what the Minister has characterised as ‘a simplified set of clear, concise guidance’.

Whilst I have been a supporter of the NPPF and its approach of articulating a clear and focused national policy for planning, and of desisting from attempting to specify every detail of policy from the centre (see Urban Design Matters: ‘Design and the NPPF’), I am less convinced about the validity of applying the same approach to national guidance on planning where less is not necessarily more.

The nature of planning guidance

In making this argument it is important, first, to understand what the intentions of national planning guidance have typically been.  I would identify three:

  1. To positively guide, but not to direct, local planning practice
  2. To explain, expand on, and articulate key planning processes, policies and concepts
  3. To inform and educate where key knowledge is lacking.

Second, we need to understand who planning guidance is for, because, if it is not directed at the right audience there is little chance of it ever achieving its purpose.

On this latter issue, and specifically in relation to the PPG, the Government conflates and therefore confuses two very different potential audiences: the everyday public who may have an interest in local planning or come simply up against it in their daily lives; and the professionals and politicians charged with actually delivering planning.  Whilst this division is less clear cut in the context of localism where ‘the public’ may become more engaged in actual planning themselves, neighbourhood planning is still a minority sport in comparison to local planning and development management and, arguably, this tail should not wag the dog.

Yet in launching the PPG, the Minister was explicit: ‘Planning shouldn’t just be the preserve of technocrats, lawyers and council officers. To be effective our planning system needs to be supported by practical guidance that anyone can consult and follow’.  The result is a draft that has largely done away with comprehensive technical guidance on planning practice in favour of what might be described as a layperson’s guide.

Design and the PPG

A case-in-point can be found in the design paragraphs of the draft PPG which, following recommendations made in Lord Taylor’s review of planning guidance, will replace five stand alone guides: By Design, Urban Design in the Planning System – Towards Better Practice (2000); Better Places to Live By Design, A Companion Guide to PPG3 (2001); Safer Places: The Planning System and Crime Prevention (2004); Planning for Town Centres: Guidance on Design and Implementation Tools (2005); and Preparing Design Codes – A Practice Manual (2006) (see Urban Design Matters: ‘Bye-bye By Design’).

The new guidance is divided into three parts:

  • Why does good design matter in planning?
  • Why is design review important?
  • When should a design code be considered?

Each of these is concisely written in, respectively, three, two and two pages (when printed) with links to an additional ten pages that, most notably, expand on seven ‘outcomes of good design’, largely repeating those from By Design (the latter’s seven objectives are included below in brackets for comparison against the new objectives to which they best relate).  The PPG calls for places that are:

  • Functional (legibility)
  • Support a mix of uses and tenures (diversity)
  • Produce successful public spaces (quality of the public realm)
  • Are adaptable and resilient (adaptability)
  • Have a distinctive character (character)
  • Are attractive (continuity and enclosure)
  • Encourage ease of movement (ease of movement)

Confusingly, the objectives are immediately followed by eleven ‘areas where special consideration should be given’, some of which repeat the objectives (although in slightly different words): ‘character and landscape’, ‘local context’, ‘quality of the public realm’, ‘ease of movement’, ‘adaptability’ and ‘diversity of uses’; whilst others are subsets of objectives: ‘scale’, ‘detailing’, ‘access for disabled people’; or are concerns not previously mentioned: ‘designing out crime’, and ‘passive solar design’.

Together, the objectives and special considerations cover many of the key bases that one has come to expect from such guidance.  So what is the problem?

Boilers and dummies

Here an analogy might be helpful.  My boiler recently stopped working.  Digging out the paperwork that we had miraculously retained, I discovered two documents.  First, a simple instruction manual for owners, a few pages telling me how to programme the thing and how to diagnose a simple fault such as the pilot light going out.  Second, an installation guide with horrendously complicated looking wiring diagrams and technical specifications that made no sense to me whatsoever, but which the engineer who came to fix the boiler immediately referred to in order to diagnose that it had been wired up incorrectly when installed (probably a case of the original engineer not bothering to read the guide!).

In a comparable fashion my new computer (on which I now type) came with a similar set of guides: a simple printed ‘How to get started’ guide, which I read, and an electronic file giving the full spec. and explaining obscure functionality, which I will never use, but that is there for those who understand and like that sort of thing.  Even the instruction manual for my now aging car has a summary of useful information for owners, followed by a long and technical guide, similarly unsullied by human hand (at least my own), but no doubt useful for those who are that way inclined.  In none of these cases did I feel affronted by the fact that I did not understand (or even wish to understand) the technical guidance, I simply took it for granted that life is too short to be an expert in everything, renewed my respect for those who are, and read what I needed to know.

Our cities, towns and villages are of course totally unlike boilers, computers or cars … in fact they are infinitely more complex!  Similarly, their guardian – planning – is arguably amongst the most complex of public services.  Planning, through its operationalization, and essential purpose, is political, discretionary, open to challenge, and capable of many paths to implementation, yet whilst other public services continue to operate in a context of guidance overload – witness the eye-wateringly detailed national curriculum or the various guides to clinical commissioning – planning, it seems, is to be the subject of the latest Guide for Dummies, rather than the serious technical support that it continues to need; not least in design.

A springboard to excellence

To my mind it is entirely appropriate for Government, as it always has, to seek to influence local practice through the publishing of informative and useful guidance to the different processes, practicalities and purposes of planning.  We need real experts to manage our cities and their regions, and if guidance can help them do the job better, then that should be fine, even if it isn’t the most stimulating read for non professionals.  Moreover, if prepared on the basis of robust evidence and the pursuit of best practice – activities that the government used to fund, but that have largely been a casualty of austerity – then it should be possible to create high quality, readable and up-to-date guidance that is of real value to practitioners without unduly interfering in local practice or needlessly filling shelves with unnecessary guides

As such this is not an argument for over-complicating things when they don’t need to be, or for keeping the existing ad hoc, often out of date and over-lapping guidance; and it is certainly high time that modern technology was used to establish a dynamic and internally consistent suite of advice that is easy to update and use.  But in sweeping away in one fell swoop all the old guidance (regardless of its value) and replacing it with a stripped down, lowest common denominator set of notes, I fear we are throwing the baby out with the bathwater.

We seem to be ending up with something that is easy read, but says little more than the policy it seeks to illuminate, and is certainly of little use in informing the work of professional planners in need to real resources, some of which will be unashamedly technical, to assist them in their day to day work.  After all, planners are not technocrats, but hard working professionals engaged in delivering a service of immense public interest and high technical expertise.  To my mind we need to see more ambition than the PPG has so far shown: a ‘springboard to excellence’ rather than a ‘guide for dummies’, although that, just like the manual that came with my boiler, also has its place.

So when is guidance not guidance?  When it fails to understand the needs of the audience it is seeking to address.  As it stands, I fear that the PPG falls into this category, although it is early days and it can only get better!

Matthew Carmona

Professor of Planning & Urban Design

Bartlett School of Planning, UCL


Sept. 2013