How does the Government’s beauty agenda fit with its other policy agenda to widen permitted development rights to deliver more homes

Our Director, Ian Harvey shares some perspectives on permitted development rights and the tension with the beauty agenda.

Last week, there were two key launch events: the Government’s Building Beautiful Places Event launching its vision and the new Office for Place and the Place Alliance’s new excellent research report, The Design Deficit, examining the design skills and practices in England’s local authorities.

You can watch the videos of both events here: Building Beautiful Places event  and UDG/Place Alliance event

There is much to digest in the Place Alliance report, but a key finding was that ‘whilst urban design and related skills in local authorities have stabilised, they remain at a low ebb and far below where they need to be in order to address the ambitious national agenda on raising the design quality of new development.’ It found that two fifths of local planning authorities still have no access to urban design advice; almost two thirds no landscape advice; three quarters no architectural advice and currently, only 14% of local authorities produce design codes in house.

This finding perhaps comes as no surprise to civic groups, who have consistently told us that local authority resourcing is one of their key concerns with the Government’s proposals for planning reform. It is pleasing to see the Government announce a further round of local authority pilots of the National Model Design Code – the knowledge, outcomes and lessons learned from these pilots and the 14 which are already underway must inform the ‘comprehensive resources and skills strategy for the planning sector’ the Government promised in its Planning White Paper of August 2020. Government seems fixated on codes, but we will continue to emphasise that other design tools are available. Codes are part of a solution, not the solution. Even if every community was to get a design code, how would that code be applied alongside PDR policies? 

It is clear that the Government has big ambitions for raising the design quality of places and wants to but beauty at the forefront of planning reform. Much of this is to be commended. However, at both events, the elephant in the room, but not in the chat, was how the Government’s beauty agenda fits with its other policy agenda to widen permitted development rights to deliver more homes. As Andrew Taylor from Countryside commented on Twitter afterwards, “While the speeches and presentations were interesting the discussion in the zoom chat was really interesting!”

On the one hand, Government is saying that it wants to empower local authorities and communities to demand beautiful development and reject poor quality design, while at the same time, reducing local authority control over the location, quality and type of new homes created under permitted development.

At the Government’s event, a question was asked about this tension between beauty and permitted development, but no clear answer came from the panel. Similar questions were raised in the chat discussion at the Place Alliance report launch too but again, no answers came forward.

We are concerned that the delivery of high quality design will be undermined by the widening of permitted development rights preventing a planned approach to our town and city centres and by limited local authority resource, capacity and skills as set out in the Place Alliance report.

The Government needs to urgently explain this and be much clearer in its messaging, if it wants communities to really believe that its new design announcements will be backed up by actions and are more than just warm words.

How does the Government’s beauty agenda fit with its other policy agenda to widen permitted development rights to deliver more homes

Civic Voice and APPG for Civic Societies call on all civic societies and community groups to monitor prior approval applications and tell us what is happening on your high street and in your town and city centres.

As ever, in the planning world, it’s been a busy week of press releases, launches, reports, new policies, and guidance. Whether it’s the launch of the Government’s new Office for Place, the new National Planning Policy Framework or the new National Model Design Code – all of which we will be digesting and briefing Civic Voice members on shortly – we wanted to cut through the ‘noise’ and highlight a couple of key things you may have missed.    

This week, Civic Voice held an excellent ‘In conversation’ session with Clive Betts MP, Chair of the Housing Communities and Local Government (HCLG) Select Committee where Clive explained in an accessible and balanced way, the Committee’s review of the Government’s proposed planning reforms. We were delighted Clive was able to join us to discuss the Committee’s independent report and explain the next steps and if you haven’t seen the session yet, you can watch it here:

It seems it’s been an equally a busy week for the Committee as, on Thursday, it published its findings into a review of Permitted Development Rights. You can view the report here.

The successive changes and widening of permitted development rights and prior approval in recent years has been of real concern to the civic movement. Civic Voice objected to the Government’s most recent proposal to bring in a new right to allow properties in Class E (high street uses) to change to residential use because we were concerned that it could:

  • Be harmful to the diversity of high streets, town and city centres.
  • Create poor quality homes and living environments
  • Lead to loss of historic character in Conservation Areas through inappropriate development and unsympathetic alterations. 

Civic Voice welcomes the Committee’s report and is pleased to see an independent review of the recent changes. We are particularly struck by the Committee’s recommendation that ‘the Government pause any further extensions of permitted development rights for change of use to residential, including the new class MA right, which is due to take effect on 1 August, and conduct a review of their role within the wider planning system.’

Whilst there is broad support for the intention of the policy to introduce more housing in town centres, there is very little support for the mechanism being used – through the permitted development and prior approval process – because of the unintended consequences. Indeed, because of the level concern around this we are talking with both the APPG for Town Centres and the Association of Town Centre Managers on this issue.

As it stands, however, the new permitted development right comes into effect on 1st August 2021. So what can we, as a movement, do?

We need examples.

We want to be constructive and support the government to find the right solutions for our high streets and communities. We want to encourage more housing in town centres, but we must ensure that the right checks and balances are in place to mitigate against the unintended consequences.

Today, we are launching a study into the impact of the new permitted development right to change to residential and we need your help to be the eyes and ears on the ground. We call on all civic societies, community groups and place managers to monitor the prior approval applications coming forward and tell us what is happening on your high street and in your town and city centres.

The results will be shared with both the APPG for Civic Societies and APPG for Town Centres and inform our further policy and campaigning.

Next steps

To find out more about the study and how you can get involved, we are hosting an online webinar to explain the process and to help you get started.

Register for you place here:

4th August Webinar:

Ian Harvey, Executive Director of Civic Voice, said:

Ian Harvey, Executive Director of Civic Voice, said:

“We accept that our high streets, town and city centres are currently facing acute challenges and they will need to adjust and, in some cases, contract in response to changes in shopping and leisure habits. More housing is part of the solution. However, Civic Voice believes this needs to be done in a planned and curated way by local communities through their local planning policies, not by allowing the market to decide in a random and potentially counterproductive manner. The recent HCLG Select Committee report found that ‘permitted development rights have made a contribution to the supply of new homes*… Given the acute housing shortage in this country, we welcome this additional housing, but we have serious concerns that some of these homes are of poor quality and that some of the people living in them do not have the option of living elsewhere.‘ We agree with the Committee’s findings.”

Harvey continued by saying: “As we have seen with the previous widening of permitted development rights, which the Government’s own commissioned report concluded that they create “worse-quality residential environments”, our fear is that this will be exacerbated by the latest widening of rights. We are also extremely concerned that the new right now applies in conservation areas and the potential impact on our everyday heritage. Will our fears be borne out? Perhaps the actual impact will not be as negative as we fear, perhaps it will have a positive effect? Only time will tell and that is why we are undertaking this study to consider the real impact on our high streets, town and city centres. I urge all civic societies to get involved.”

   *The Government says that in the five years to March 2020 change-of-use PDRs created 72,687 new homes

Civic Voice and APPG for Civic Societies call on all civic societies and community groups to monitor prior approval applications and tell us what is happening on your high street and in your town and city centres.

Planning is changing. How will communities fit into this new system? Could a formal voice for civic societies be the answer?

In Civic Voice’s response to the Planning White Paper, we said: “We would like to further explore how civic societies could have a more formal role in the new system to help deepen meaningful engagement with the wider community in helping to shape their local area.

Our Director, Ian Harvey shares some personal thoughts on how he sees the future for civic societies.

Could a formal voice for civic societies be the answer?

The planning system as we know it, is changing. Whether it’s new style Local Plans, Zones, Design Codes, or successive widening of Permitted Development Rights and changes of use on High Streets, change is coming.  But how will communities fit into this new system?

Regular followers of Civic Voice will recall that the Government published its Planning White Paper in August 2020, promising to radically reform the current planning system to make it a ‘significantly simpler, faster and more predictable system’. The Prime Minister’s ambition in the foreword to the paper is for a system that also ‘gives you a greater say over what gets built in your community’. A bold claim. So, how might that work in practice?

Well the Planning White Paper gives us some clues as to Government thinking and what might be coming down the tracks in a new Planning Bill later this year – A streamlined Local Plan process (max 30 months), with two opportunities for public consultation:

  • Stage 1 [6 months] – Call for sites/areas under the three categories with ‘best in class’ public engagement.
  • Stage 2 [12 months] – Local authority prepares its Local Plan.
  • Stage 3 [6 weeks] – Local authority submits the plan for examination and publicises the plan for consultation with ‘best in class’ engagement. Responses will have a word limit and those seeking changes must explain how the plan should be changed and why.
  • Stage 4 [9 months] – Planning inspector examines the plan against the sustainable development test and makes binding changes where necessary. All those that submitted comments on the plan would have a ‘right to be heard’.
  • Stage 5 [6 weeks] – Local plan map, key and text are finalised and adopted.

Make no mistake, whilst we support making the Local Plan process shorter and more accessible to communities, this timetable is, to put it mildly, challenging. Some might say, impossible.

But if that’s what’s coming, where do civic societies or other organised community groups fit. Do we have a responsibility to our communities to get a formal voice – to ensure someone participates in the process? 

In a survey of our members, conducted towards the end of the Planning White Paper consultation period, 79% stated that they believed community groups would have less influence in the system; 77% thought it would be a less accessible planning system to engage with and 86% thought the proposals to introduce zoning and reduce the right to respond on individual planning application would make it a less less democratic system.

We know that the best civic societies play a vital role in scrutinising plans and planning applications, acting as a ‘critical friend’ to local planning authorities, providing advice on heritage, design and raising awareness of key development proposals amongst the wider public. They care about where they live and want the best for their areas. 

In this new system, the key role of civic societies needs to be acknowledged and given sufficient weight in the system. Particularly, if there are only going to be two limited opportunities for public consultation on Local Plans. NB Civic Voice opposed this specific proposal – see question 12 of our full response to the Planning White Paper here.

This is even more important as the Local Plan will be the place where the ‘big stuff’ will be decided. If the Government’s plans go ahead, in the new system, there will be no more planning applications for civic societies to comment on in Growth Areas or potentially Renewal Areas and there may be far fewer in Conservation Areas too, with the recent permitted development rights changes. So the Local Plan will be the main place to get involved to help shape your local area. 

If the Government’s ambition really is for ‘world class civic engagement’ surely civic societies must have a formal voice in this process? Formal status would recognise the time, effort and expertise and added value civic societies could bring to the process and give ‘teeth’ to their considered representations. Could a formal voice for civic societies in developing Local Plans, specifically at Stage 1 and Stage 3 be something we call for in the Planning Bill? Could this be part of the answer to the Government’s ambitions for ‘best in class engagement’?

Ahead of meetings with MPs about the APPG for Civic Societies, I believe that the number one priority for Civic Voice and the APPG should be to establish Civic Voice members with a formal voice in the new planning system.

Of course, a formal voice in the system, would bring change and responsibilities on both sides, civic societies and local planning authorities, but in a wholescale review of the planning system, our role as a civic society is likely to change anyway. We know that 77% of civic societies prioritise responding to individual planning applications, but with the options set out in the White Paper, that is inevitably going to change. What will you do instead?

The reason I wrote the blog is just to have a discussion about our future, because I think we are changing as a movement, without discussing it. What I do know , is that effective change doesn’t just happen by chance, and any plan you make has to be right for your organization. I also know we need to do better.

Maybe now is the time to review the purpose and role of civic societies?  


What do you think to Ian’s suggestion? Should we work with the APPG for Civic Societies to campaign for formal voice at Stage 1 and Stage 3 of the Local Plan process in the new planning system?

Get in touch at:

Planning is changing. How will communities fit into this new system? Could a formal voice for civic societies be the answer?

Ian Harvey shares some of our latest thinking on design codes and guidance.

Ahead of a Civic Voice webinar hearing from Abergavenny District Civic Society’s experience of producing a community-led design guide, our Director, Ian Harvey shares some of our latest thinking on design codes. 

Civic Voice’s response to the Planning White Paper welcomed the greater focus on design and the intention that design guides and codes will be locally produced with input from local communities. Since then, we have held a series of roundtable discussions with members to explore this in further detail, exploring the following questions:

  • What skills and capacity are available amongst civic societies to implement and help shape design guides and codes?
  • What are the most effective ways for Civic Voice to support community groups to have the skills to develop local design guides and codes?
  • What interest exists within the civic movement to take forward community-led design guides and codes?

We had a total of 48 civic societies involved in the roundtable conversations. Civic Societies seem to be more worried about having a lack of capacity than a lack of skills in taking forward the design agenda with 53% confident that they have the skills to appraise new developments. However, a key issue that came out of the discussions was clarifying what the civic movement’s role and involvement could and should be. Some civic societies do not want to participate in developing design codes and do not see them as being a game-changer that is needed to drive up design quality, whereas others say that they want to be in the room discussing and shaping them. A clear and consistent message was that all think that well-resourced councils are best placed to deliver and enforce codes, but worry that councils will not have the capacity to prioritise codes. It is clear that not enough good design codes are in operation at the moment. Clear feedback has been that sharing best practice and good examples is important and something civic societies are keen to see, and Civic Voice will respond to this feedback. 

It is also clear to see that civic societies do want to learn more about the various design processes and tools available to improve design quality such as; design guides, design review, assessment frameworks e.g. Building for Life and design charrettes/workshops, as well as design codes. People are mixed on training needs – some are happy with ‘taster’ sessions, whilst others want more detailed practical information. We will bear all this in mind as we develop our next set of webinars and training programme for 2021. Societies also want to know more about the benefits of using design codes. Design codes are an established idea, but, to date, infrequently applied tool in England. Prof Matthew Carmona produced a blog in 2013 on design codes saying that in excess of 120 design codes are estimated to have been prepared between 2006 and 2013.   

Why does it matter if civic societies do not think that they will drive forward design-codes? Well, research undertaken by Public Practice surveying local authorities has given an estimated cost of adopting a Design Code for an area of c.1,000 homes as high as £139,000.  Assuming approximately two thirds of the 337,000 homes a year required by the Government’s new Standard Method will be in Growth Areas, the total national annual cost of producing Design Codes would be £31m. 

At a time when we can expect public sector spending to further decrease, we need to be inspiring and supporting communities to believe that codes can be part of the solution to raise the standard of design quality.  Without their participation and support, I fear that codes may become documents that ‘sit on the shelf’ and are impossible to enforce locally. A code will only be as good as the buy-in from the local community. Government may need to think about how the ‘message’ around design codes is being percieved locally.

You can see Public Practice’s research via:

In a time of challenging budgets, surely we must be looking to unlock the capacity of organised community groups to drive forward community-led design guides and codes? Our roundtable discussions and brief survey of our membership is a simple approach to help our wider thinking, but it does resonate with conversations I have had elsewhere. 

It is why we are continuing our Modern Methods of Meaningful Participation series by inviting Southgate and District Civic Voice and Abergavenny Civic Society to join us on Wednesday 16th December as we look at some of the design processes that are available to communities. 

Register here:

Do you know of any local codes that we could highlight? We want to hear from you on your experience of local design guides and codes. Are you aware of any design codes or guides that have been prepared in your area perhaps by the local authority or developer? Has your civic society been involved in the development of a design code? Have you written one yourself?  

Get in touch at:

Ian Harvey shares some of our latest thinking on design codes and guidance.

Civic Voice supports the Healthy Homes Bill

Civic Voice is the national charity for the civic movement. We are campaigning for a more accessible, balanced, collaborative, and democratic system, as set out in our Manifesto. Since we set up in 2010, we have been joined by hundreds of volunteer-led, community based civic societies with over 76,000 individual members.

According to research by the Place Alliance, during the first lockdown, a sixth of individuals were either uncomfortable or very uncomfortable in their homes. At a time when the nation was ordered to stay at home, it is shocking to think that, extrapolated across the UK , it would represent 10.7 million uncomfortable people. Lockdown provided a unique opportunity to stress-test our homes and their immediate environments, and to gauge whether or not they have supported our everyday needs. It failed for many.  As we sit here in Lockdown 2 and you read this blog, these same people are experiencing that feeling again. This is wrong. We must do something to change this.

That is why we’re proud to support the Town and Country Planning Association’s Healthy Homes Act campaign calling for a new piece of legislation: a Healthy Homes Bill.

Change is needed and we must accept that the current planning system is not perfect, has become over complex and is not providing enough high-quality places or high quality homes. Even the government’s own Building Better, Building Beautiful Commission remarked of PDR in its final report that the policy has “inadvertently permissioned future slums”.  As the Government’s planning white paper completes the consultation process, we call on communities to consider embracing design codes and guides and implementing the Healthy Homes Act principles at a local level.

48% of Civic Voice members agree with the need to build 300,000 new homes a year, but consider that we should be building the right homes in the right places, of a high-quality standard. The elements set out in the Healthy Homes Act. If the Government is not going to take the Bill forward, we call on communities to act locally and to consider using design guides and codes to help them implement these ideas.

Without exception, all new and newly converted homes should be built to decent national minimum space standards and in a manner that prioritises good environmental conditions in the home: access to fresh air, daylight and good insulation against the transmission of noise.

When done well, design codes and guides can support these aims and allow adoption considerations such as open space and windows to be coordinated at an early stage with design, development and planning matters, and set out specific standards for rigorous enforcement, where necessary.

By enshrining a series of ‘healthy homes principles’ into law, this bill would put individuals and communities’ health and wellbeing at the heart of government decision-making on planning and building control. Addressing issues such as accessibility, access to green space, noise and light pollution, size of windows to allow natural light, safety in relation to the risk of fire and secure, these principles, at an absolute minimum, define a healthy home and neighbourhood.

Our members have made it clear that they support growth, with 71% accepting the need for more housing and 48% broadly supportive of the
Planning White Paper housing target of 300,000 homes. We do have a housing crisis, but it’s not just the numbers that are built. It’s an affordability crisis. But whoever builds the homes, must build them
that are fit for purpose. The call for a Healthy Homes Bill, led by TCPA, will help to reinforce that, which is why Civic Voice is pleased to support the call for these ten key principles to be adopted to drive forward the development of better homes and places.

For more information on the campaign, please visit or contact Jack Dangerfield


Civic Societies as Statutory Consultees Some thoughts from David Evans

This blog states my personal views and not those of Chester Civic Trust. The recent CV mailing asking civic societies for their views on becoming a statutory part of the planning system pointed out that societies have a range of views on the subject. This is not surprising since, whilst it appears a simple issue, the more you look into it the more complex it becomes.

Key Points

  • Civic Voice should seek a formal role for civic societies within the planning system. However, this will be of limited benefit unless there is greatly improved engagement – participation, not just “consultation”.
  • The engagement should not just consist of the ability to object to proposals but to contribute positively to their development.
  • There needs to be a two-way process, with meaningful feedback given by LPAs to consultees on their proposals and objections.
  • Individual civic societies must be able to decide whether to be registered as formal consultees and to opt for differing levels of involvement in the planning process.
  • There will need to be an acceptable way of defining a “Civic Society” – unless all community groups are to be given a formal role. There is a significant opportunity for Civic Voice to have a role in this process, as detailed below.

Consultation and Engagement

Being a statutory consultee can be of very limited benefit. It is, of course, helpful if a planning authority is required to ask for our views but what really matters is whether they are then considered seriously. The relationship between the LPA and the civic society is a key element in this. Where societies are viewed (fairly or not) as nimby troublemakers, their views will be disregarded whether or not they are statutory consultees. If they are seen by the LPA as critical friends their views are more likely to be taken into account. Parish Councils are Statutory Consultees and I spent 20 years as a Parish Councillor. More often than not, our comments on planning applications in our area were ignored. There may have been good reasons for this; many of the objections raised were doubtless “nimby” in nature or not in accordance with planning laws. What frustrated the Parish Council, however, was that there was no mechanism for the Planning Authority to give any feedback or explanation of the reasons why their submissions were discounted.

Feedback on the outcome of consultation would have helped to develop the planning skills and understanding of the PC members and would have made consultation much more meaningful. It would, of course, increase the workload of planning officers but Local Plans and NDPs already require the reasons for discounting an objection to be given. If we are looking for “best in class” consultation, surely meaningful feedback to consultees must be an essential element.

Whether or not the other proposals in the White Paper are adopted there is a welcome recognition that the current consultation system does not really work. Too often, the only way of commenting on a proposal or application is to enter a formal objection, even when you may support the proposal in principle but want to suggest improvements. This can create an unnecessary sense of confrontation and negativity. What is needed, as Civic Voice has been saying for years, is much more community involvement in the formulation of Local Plans and development proposals. Unless the system changes in this way, a formal role for civic societies will not help much.

Capacity, Expertise and Accountability

There are also concerns about the extent to which Civic Societies may have the capacity and expertise to be statutory consultees. Clearly, in order to have a formal role in the system, a society will have to be registered in some way with the LPA. The issue of capacity could easily be dealt with by a system that allows societies to decide whether or not to be registered as consultees.

They should be able to define the geographical area where they wish to operate and it should be understood that they will not wish to comment on each and every application. The reforms envisaged in the White Paper mean that the drawing up of local plans and design codes will be the key areas for consultation and involvement. This would lead to an intensive period of engagement with these processes for (maybe) 30 months followed by a hiatus until the next review in (say) 10 years’ time. This could be challenging for many societies but it is vital that they are involved if at all possible.

The movement of Local Plans to a digital format may cause problems for some societies and there needs to be a requirement for LPAs to facilitate access to the system (e.g. from libraries and council premises) particularly in areas where broadband access is poor.

The issue around “expertise” is, in my view, a red herring. The whole point of consultation should be to obtain non-expert as well as expert views. Provision of feedback, as proposed above, should enable societies to develop understanding of what is and is not possible within the system.
A thornier problem is the extent to which civic societies can be seen as representing the views of our communities. We are essentially self-selecting and we have no democratic accountability. We see our role as to improve the places we live in but other inhabitants may have differing ideas about what constitutes “improvement”. Societies do sometimes undertake consultation exercises to gauge community opinion but it doesn’t happen often. In reality, most civic societies’ responses to planning applications are made by a small group of members and don’t necessarily even reflectthe views of the wider membership.

How to define a “Civic Society”. A role for Civic Voice?
If I were a Minister or civil servant considering a proposal to give civic societies formal status in the planning system, the first question I would ask is: “What constitutes a Civic Society?” If our role in the planning system is to be enshrined in law there needs to be a way of defining what we are. There are many other community-based pressure groups. What is it that makes us different and entitled to a formal status?

In the past, civic societies were registered with the national Civic Trust and had to have their constitutions approved by the national body in order to be accepted. With the demise of the Civic Trust and the creation of our new “bottom-up” national body that system has disappeared. It would be tempting to insist that the criterion for being considered a Civic Society should be full membership of Civic Voice but, given the number of societies that are not members, it is unlikely to be acceptable.

Nonetheless, Civic Voice could take the lead in running some kind of “kitemark” scheme under which civic societies (and possibly other amenity groups) could apply for an approved status which would then allow them to be registered for a consultative role with their LPA. Taking on such a role would be unreasonable with our present resources but, if MHCLG were supportive of the principle, they might be willing to provide grant funding to operate such a scheme. There would need to be agreed criteria for acceptance and possibly a panel of civic society representatives to oversee the process. This could be an opportunity to cement the status of civic societies as an integral part of the planning process.

David Evans
Civic Voice Trustee and Chester Civic Trust

Civic Societies as Statutory Consultees Some thoughts from David Evans

What should happen to strategic planning?

As part of our collaborative approach to responding to the Planning White Paper, we continue to share ‘drafts’ to individual questions. We are doing this to give as many people the chance as possible to what civic societies are saying to us, and to give you a chance to influence our final submission as it evolves.

The latest question is about the Duty to Cooperate. Share your thoughts with us via:

7(b). How could strategic, cross-boundary issues be best planned for in the absence of a formal Duty to Cooperate?

The first part of our answer deals with the proposal to remove the Duty to Cooperate and the second part with possible alternatives.

Principle of removing the Duty to Co-operate

The proposed removal of the Duty to Co-operate is worthy of discussion, as feedback from our members has been that it has not been an effective replacement mechanism for regional spatial strategies, abolished in 2010, and we are aware of Local Plans that have failed the legal test at the examination stage[1], having to start the process again.

Common queries from civic societies about the ‘duty’ is that the process is a mystery to communities, inaccessible and not a transparent part of the planning system.

There is some suspicion that local authorities who do not want to adopt a local plan because it may be politically contentious are using the Duty to Co-operate as a ‘get-out’ clause. One Civic Society commented that it is a ‘duty to engage’ and not a ‘duty to agree’ and that for it to be really valuable, early and open engagement needs to happen – with political will to support the planners. It is much easier to blame the Planning Inspectorate as to why a local plan has not been adopted than for local politicians to show leadership and make difficult decisions. With difficult decisions comes political accountability. 

Communities recognise that the Duty to Co-operateis flawed, because local politics in neighbouring authorities can often have conflicting local visions for growth. With the current Duty to Co-operate, we query, where is the incentive for local authorities to plan positively to meet development needs across administrative boundaries, when there is no requirement to agree? This is particularly acute where there are constraints such as Green Belt, when such development has become so highly politicised.  

Civic Voice welcomes the Government considering alternatives to Duty to Co-operate, but we would not support removing the current duty without fully considering all options and introducing a workable solution for the whole country, as we believe a vacuum in strategic planning in the interim could lead to further delays and make it exceedingly more difficult to ensure that enough new homes are planned for.

Civic Voice urges Government that before the Duty to Co-operate is removed, we have a certainty over its replacement. It is essential that we have ‘larger than local planning’ to ensure that we positively plan to meet needs and tackle the bigger issues that cross boundaries such as addressing climate change, providing strategic infrastructure to support economic and housing growth and tackling regional inequalities through the ‘levelling up’ agenda. This is where collaboration between Government and stakeholders, including communities, is needed. For it to be valuable, early, and open engagement needs to happen, to help build public trust.

Possible alternatives

Currently, there is a messy picture of strategic planning arrangements across the country with some statutory joint strategic and local plans, a regional plan in London, and a series of non-statutory strategic growth frameworks/plans. Some parts of the country have Combined Authorities and Metro Mayors and we aware of the Government’s plans to for further devolution and reorganisation of local government. There are also 38 Local Enterprise Partnerships (LEPs) within England with different geographic boundaries to local authorities and joint/strategic plans. With this in mind, we believe that any replacement must be mindful of the existing strategic plans and bodies, provides some consistency across the country and ensures that the ‘sum of the parts meets the whole’.        

Collaborative strategic planning must be carried out to address the most pressing issues facing the nation such as economic recovery, meeting housing need and demand, climate change and reducing inequality.

It may be appropriate for Mayors of combined authorities to oversee the strategic distribution of housing and other development requirements, however, without complete coverage across the country, this proposal alone would not address the collaborative strategic approach that is needed for areas without a Mayor. We also believe that any strategic planning bodies going forward such as Combined Authorities must have an accessible, balanced, collaborative and democratic process, which involves communities at an early stage, to ensure that any strategic plans remain rooted in local communities.

LEPs could also play a role, but we would want the Government to make clear that it expects to see civic society and communities represented on such groups.

Should we go back to the regional level?

It is interesting to note that further consideration is being given in the White Paper to how to plan for strategic cross boundary issues

We already have a regional plan for London, so why not elsewhere? Whether you were a fan of them or not, the implications of the abolition of regional strategic for levels of housing development are still being felt today. The abolition of Regional Spatial Strategies has been a major barrier to the effective delivery of housing and infrastructure. It has led to a ‘messy picture’ of how planning is delivered across the country – from neighbourhood planning, to combined authorities, to the National Infrastructure Commission. It has highlighted the development of an ad hoc planning system driven by bespoke devolution deals. This is not strategic planning.

Clearly RSS were unpopular in many parts of England, with some people accusing them of being undemocratic, however, they did provide a framework for developing strategic planning and housing policies, including facilitating debate and mediation on the broad distribution of development and housing. Supporters of them still talk about their comprehensive, strategic view of planning across each region.

However, limited it might be, even something setting out a Regional Vision with objectives would be a start but to have an effect, it would need ‘teeth’ and be recognised. We have to stop saying ‘it is politically toxic to talk about regions’.

To a ‘National Plan’ and beyond!

To quote the UK 2070 Commission[2], “Currently, the future of the UK is being shaped by the incremental, short-term and ad hoc nature of government policy”.

We should not be looking for the popular decisions but should be looking for good decisions and the right solution. We support the UK 2070’s commission call for a national spatial plan:

Civic Voice supports the need for a national spatial strategy which sets national priorities and within that framework you have regional or sub-regional planning.   A national spatial strategy would be a planning framework to plan for the whole of England, with aims to improve, balance up, and deliver the objectives of the country from housing, climate change, infrastructure, social equality and would be the place to meaningfully start to tackle the national ‘levelling up’ agenda.

There is potential to start this work quickly by appointing a new body, chaired by the Planning Minister, with the ability to reach across government departments and bring together existing national organisations such as the National Infrastructure Commission, HS2, Northern Powerhouse and Homes England. Without the national leadership, we will not address the challenges we face. This could be the single biggest change to the system that could form part of the radical solution that the Government wants.



What should happen to strategic planning?

Do you agree with Government proposals for improving the production and use of design guides and codes?

Over the next few weeks, we are going to start sharing our draft responses to some of the Planning White Paper consultation questions. We want to do this so that you can see what other civic societies are saying to us, and give you a chance to influence our final submission as it evolves.

The first question and draft answer (available below) we are sharing is in relation to the question 17:

Tell us what you think to this response via:

17. Do you agree with our proposals for improving the production and use of design guides and codes?

[Yes / No / Not sure. Please provide supporting statement.]

The emphasis on design codes and good design is clearly welcomed by Civic Voice members. Based on 151 responses to a Civic Voice survey (undertaken in Sept 2020), 79.6% respondents supported the idea for design guides and codes to have a more central role in the system. We also highlight the National Housing Audit research (January 2020), that The most effective design governance tools are design codes and design review but they are used far less than other more generic approaches.

However, the clear concerns from our members are focused on (1) how the codes are created and (2) how they work in practice to ensure that the quality of development is improved.

We have 3 substantial comments to make:


We do not think it is realistic to expect a local authority to be able to code all land within a local authority boundary. The resources, time and cost needed to undertake such an exercise would be so large, it would never be a strategic priority for a council.

However, we see the potential for local authorities to produce design codes for specific sites/areas e.g. growth areas or protected areas. We struggle to see how codes will work in renewal areas, which would appear to cover much of our existing built up areas.

There should be a sensible transition period in which communities can concentrate on getting guides/codes in place (plus funding and up-skilling), during which the current discretionary approach should remain.

At what point should a community group start to campaign for their local authority to produce a local design code? Whilst we have lots of interest in this proposal, there will potentially be a period of two planning systems while we transition from the current system to the proposed one in the White Paper. If a community were to try to implement a code, based on the forthcoming National Model Design Code, how much weight would it have? Would it quickly become out of date? Can you produce design codes before the local authority has allocated its growth, renewal and protected areas through the new style local plan?

With the emphasis on local authorities producing local plans within a shorter timeframe than ever before, we think it is unrealistic to also expect them to prioritise design codes until local plans are in place.  

We welcome the expectation that local design guides and codes will be prepared with community involvement but still consider formal consultation should be required before local design codes are adopted. We welcome the proposal to measure public support for codes but are unsure at this stage how ‘empirical evidence of what is popular and characteristic’ could be gathered.  

We think that any community group that is named in the Statement of Community Involvement should be allowed to prepare local design codes, with access to funding and expert support from the proposed national body, not just neighbourhood planning groups. 

If the default is the National Model Design Code, is this really localising decision making? How much weight will the National Model Design Code have when its published? What is the incentive for a local authority to decide to take forward a local design code when they are under resourced and being pressured on local plan issues, when the default position is the national code? Why should they do it? The sceptic in us fears that under these circumstances planning departments will think, let’s just use the National Model Design Code and not worry about the public engagement and producing our own. We say this as we know that numerous local authorities have not wanted to encourage neighbourhood planning for similar reasons. What carrot and stick approach will Government use if certain local authorities choose not to take forward design codes?


We welcome several comments within the consultation, particularly paragraph 3.8, with specific reference to:

“It will be essential that they (design codes) are prepared with effective inputs from the local community considering empirical evidence of what is popular and characteristic in the local area”

We acknowledge the fact that developers can bring forward design codes but welcome the statement that it must be with effective inputs from the local community:

‘To underpin the importance of this we intend to make clear that design codes should only be given weight in the planning process if they can demonstrate that its input has been secured from the community’

The two key phrases here are defining “effective” community engagement and the “weight” given to local design codes when that has been achieved. We recommend that the National Model Design Code should define these terms and set standards for the level of meaningful community engagement that is to be expected.

We would expect that as a basic, local councils and developers are expected to follow the current design guidance that says: “Community panels or forums can be set up by local planning authorities or third sector organisations, such as civic societies, to represent the views of local communities by scrutinising plans, policies or applications” (paragraph 22).

At present, it is unclear as to what status the local design codes will have. Will they be equivalent to the existing ‘supplementary planning guidance’ or will they have the same statutory status as a local plan? This needs to be clarified by Government. Local design codes must have strong statutory status if they are to have the confidence of the public.

‘We will also make clear that decisions on design should be made in line with these documents’

It would be pointless for a local authority to produce a design code if they then chose to ignore it because of pressure from a developer. Therefore, if a developer brings forward a different design code that does not accord with the local authority’s, it should be rejected. However, the developer would be free to pursue their proposal through a discretionary approach and subject to local scrutiny, justifying their reasons for the departure.


We welcome the commitment that “It will be essential that they are prepared with effective inputs from the local community”, but the challenge will be to ensure that “effective input” is followed through. It is critical that local communities can positively engage in the preparation of local design codes to make sure developments truly reflect local character and environmental sensitivities.

We support the idea that local design guides/codes must be produced with community involvement to deliver provably popular housing. Civic Societies will have an absolutely essential role to play here.

We know that many local authorities have different success rates when it comes to engaging with communities. A local planning team does not always have the necessary local knowledge about an area and that is why it is critical that local communities are engaged in the process. Sufficient resources and training must be available to all local authorities and the wider community, who are being asked to prepare them.

If the point of design codes being introduced is to help communities support development, those same communities must be involved at local plan process. The success of design codes will be judged by the involvement of communities.

We believe that Statements of Community Involvement could be the bedrock of community involvement but, unfortunately, far too many have become too long, out of date and out of touch documents. We recommend that the Government implement a ‘National Statement of Community Involvement’, that showcases ‘best in class’ engagement at the different levels of consultation.

We recommend that the Civic Societies registered on the central database with Civic Voice are classed as ‘Consultees’ on all design codes being created in their area of geographic benefit.

Whilst we applaud the Government’s ambition around digital engagement – which we also want to see – this should be in addition to other methods of engagement as a range of approaches are required to engage the widest cross-section of the local community. We could not support this if it led to the loss of other methods of engagement.

We recommend that exhibitions / workshops / open meetings and discussion groups and independent but informed facilitation continues. It is important that various platforms are utilised to debate and explore ideas and, in our experience, no one size fits all when engaging communities, and ‘best in class’ engagement needs to recognise this.

There should be formal consultation with the wider community before local design codes are adopted.


Over the next few weeks, we are going to start sharing our draft responses to some of the Planning White Paper consultation questions. We want to do this so that you can see what other civic societies are saying to us, and give you a chance to influence our final submission as it evolves.

Tell us what you think to this response via:

Do you agree with Government proposals for improving the production and use of design guides and codes?

What does the White Paper say about meaningful participation in planning?

With so many proposals contained in the White Paper, we thought we would try to demystify some of the key themes one by one, go beyond the headlines in the press, and explore what is actually being proposed. Today, we are looking at public participation in the plan making process. So, what does the White Paper say and what will change?

Up front, the White Paper says:

‘We wish to… move the democracy forward in the planning process and give neighbourhoods and communities an earlier and more meaningful voice in the future of their area as plans are made, harnessing digital technology to make it much easier to access and understand information about specific planning proposals. More engagement should take place at the Local Plan phase.’


‘Local councils should radically and profoundly re-invent the ambition, depth and breadth with which they engage with communities as they consult on Local Plans. Our reforms will democratise the planning process by putting a new emphasis on engagement at the plan-making stage’

But how does the White Paper propose to achieve this?

The key proposal is for ‘meaningful public engagement’ from the very start of the process with ‘best in class’ ways of achieving public involvement for where development should go and what it should look like. Little detail is provided on how this should be done. However, Christopher Katkowski QC, a member of the taskforce that helped to write the White Paper highlighted on a London Forum webinar earlier this week, that the focus of the White Paper is on big ideas and he said that this is an opportunity for all civic societies to put forward ideas on how this could be achieved.

We want to ask, ‘How should communities be involved at the plan making stage? For example, should civic societies be statutory consultees at the local plan stage? Could citizen juries or assemblies be part of the solution? Let us know what you think. Tell us your ideas and examples of good practice and we will feed this back to Government. Fill in the survey here:

You can read the full White Paper online here. The Government is consulting on the proposals until 29 October 2020.

Our director Ian Harvey, has started to explore some of his own ideas in a blog here.

What does the White Paper say about meaningful participation in planning?

Can citizens’ assemblies rebuild trust in our planning system?

A report was published on Thursday, 10th September by Climate Change UK.

On its own, a report being published with the aim of influencing Government is not major news. So why was this report given such prominence on Channel 4 news and by the BBC website?

Perhaps it was because it was a report that was published by a non-party political group of 108 people, a group that was setting out how the UK should respond to and become net zero by 2050. It was a report from a ‘Citizens Assembly’.

Their final report is available here. This blog is not about the report though, it’s about the process they followed to get to the recommendations.

What is ‘A citizens’ assembly’

The group, or citizens’ assembly, was set up by six government select committees – groups of MPs who look at what the government is doing and scrutinise policy.

Members of the Climate change assembly were chosen to represent a spectrum of views from all over the UK and committed 60 hours of their time to studying and debating climate change. The assembly members met over six weekends in Spring 2020 and they heard balanced evidence on the choices the UK faces, discussed them. They then worked together to put forward the recommendations to the Government.

Citizens’ assemblies have been used all around the world, including in the UK, to help shape the work of governments and parliaments, but as we currently engage with Government on the Planning White Paper, I wonder whether citizens assemblies could be part of solution to ensuring meaningful participation at the plan making stage?

The Planning White Paper says:

 We wish to:

move the democracy forward in the planning process and give neighbourhoods and communities an earlier and more meaningful voice in the future of their area as plans are made, harnessing digital technology to make it much easier to access and understand information about specific planning proposals. More engagement should take place at the Local Plan phase.

Despite the importance of working with communities – and lots of nice words, consultation features very little in the white proposals. This is a cause of concern.

Bringing democracy forward is something we have long championed and I wonder, if the Government is serious and wants to be radical, should we be looking at formally introducing Citizens Assemblies into the planning system.  Should we be bringing people from all walks of life come together to debate, discuss and decide – on planning issues.

What is to say that at the plan making stage in the new proposals, local authorities are required by law to establish Citizen Assemblies to decide on the major issues – where to designate protected land/growth areas etc and where to allocate housing sites. Anyone who works in planning will tell you that it is hard to get a community excited and engaged about local plans.

They would be 100-150 randomly selected people that live in the local authority area. They would be required to come together over a series of days – think jury service – and they would be presented with the data, documents, and debates.

Housing developers could present evidence, so to the local civic society, so to the council. But when all is said and done, it is the group of individuals who vote and decide on the issues. It removes the politics from the system and would certainly speed up the process. You could say it is democracy in action? It works for climate change. Why not the planning system?

Whilst we accept that some communities think that the Government’s Planning White paper are trying to move towards cancelling out any meaningful local input into planning application decisions, we also have to recognise that for a number of years, Civic Voice members have overwhelmingly called for greater participation at the plan-making stage. We accept this might not be at the cost of having no voice at the individual planning application state.

The obvious weakness of citizens’ assembly is that only a small number of citizens can participate, and they are relatively expensive to organise. Turning this around though, by having a smaller, randomly selected group, it allows the group to discuss and debate the issues. Other citizens can have faith that they are not playing party politics and trying to deal with the issues in front of them. By removing local politics, would this change the system into one that we trust our fellow citizen to make the decisions.

It would require strong leadership from local government to accept the proposals. But it would also require strong leadership from communities too!

Local councils will be asked to demonstrate best in class engagement in the preparation of the local plan. Please do share your experiences of consultation with Civic Voice via:

Can citizens’ assemblies rebuild trust in our planning system?