Open response to DLUHC

Making local plans more accessible, comprehensible and user-centric lies at the heart of the design of Objective Keyplan, a market leading solution for local government authorities to research, draft, consult and publish local plans.

Read our response below, to the open consultation on the implementation of plan-making reform published by the Department for Levelling Up, Housing and Communities (DLUHC).

Introduction to the consultation on implementation of plan-making reforms

The planning system in the UK aims to promote sustainable development through the creation of local plans and minerals and waste plans. These plans are meant to facilitate the construction of homes and development while preserving and enhancing the natural and historic environment. The government envisions making plans more user-friendly, accessible, and community-driven. The Levelling Up and Regeneration Bill is designed to streamline the plan-making process, making it faster and more efficient. It will reduce policy redundancy, establish clear timelines for plan preparation, and enhance community engagement. Plans will transition from traditional formats to digital, becoming shorter, map-based, and built on standardised data.

A significant emphasis is placed on open data and community participation. The consultation published by the Department for Levelling Up, Housing and Communities (DLUHC) on a new style of local plans, also introduces the concept of "Community Land Auctions" to optimise land value capture. These changes will be supported by additional reforms in the broader planning system, and a phased rollout is proposed from autumn 2024. The government is committed to supporting planning authorities in adapting to these changes through a capacity and capability program. This consultation outlines these proposals and seeks feedback from various stakeholders in the planning and development sectors.

Objective's response

Question 1: Do you agree with the core principles for plan content? Do you think there are other principles that could be included?

We recognise the importance of making local plans (and minerals and waste plans) more accessible and comprehensible, a key aspect of DLUHC's vision for the future of planning. Objective Corporation (Objective) is rooted in the core principles of maintaining a single source of content whilst providing a platform of improved user-friendliness, addressing diverse user abilities and preferences.

Our stance strongly supports DLUHC's aim for local plans to be more straightforward and visually engaging. We firmly believe that local plans should be easily navigable for the general public, ensuring effective community engagement and understanding.

We also acknowledge that individuals have varied abilities and preferences for accessing and interacting with local plans. In line with DLUHC's objectives, we endorse the introduction of a "policies map" and a "web experience" to cater to these diverse preferences. These additions will contribute to making the plans more user-centric.

Recognising the broadest of uses, retaining the PDF format for local plans should be an option for those in the community who still rely on printed content and those who prefer comprehensive, linear access to the plan content. Reviewing a local plan from beginning to end lends itself to this format. It also lends itself well to a point in time published event that could become important when reviewing past decisions made against the then-in-force plan.

Having the policies captured as data and written into a plan-centric platform further improves accessibility by means of breaking them down into manageable distinct content. This creates the foundation for multiple types of digital outputs from a common source, opening up the process to allow the public and stakeholders to review and digest relevant policies quickly and easily regardless of their format preference, and potentially to have data feeds of relevant policy into downstream systems of use.

We stand firmly behind the Objective Keyplan system, which allows content to be published in various formats from a single source. This approach offers the efficiency and adaptability needed to address different user preferences and ensure consistency. Objective Keyplan enables the generation of HTML, web and print-ready PDF, and Data outputs directly from the system - aligning with DLUHC's vision for more accessible and user-friendly local plans. This ensures that plans are more accessible and engaging for all stakeholders. 

Question 2: Do you agree that plans should contain a vision, and with our proposed principles preparing the vision? Do you think there are other principles that could be included?

The shift in focus to evidence-based policymaking is noticeable in England and is already in effect in Scotland. According to the local authorities we are engaging with, having the evidence front-loaded at the start of the planning process leads to a quicker and more successful resolution of policymaking.

Having a system in place that links policy decisions to its evidence base, maintaining a single-source of the truth, significantly demonstrates the justification and traceability of the policy.

Additionally, clear and measurable policies that are machine-readable bring plans to life and close a longstanding gap between policy and Development Management. Removing ambiguity and continuously monitoring the efficiency of policies introduces multiple benefits for all involved, notwithstanding local authorities and the local community.

Objective Keyplan aligns with this proposed approach for strengthening links to the evidence base in local planning. It simplifies the process of connecting policies to the research, consultations, and external reports, ensuring that the plan's vision is consistently and transparently reflected throughout.

By creating direct links to all supporting information, Objective Keyplan establishes a chain of evidence from the beginning to the end of the planning process. This enables stakeholders to trace the evolution of policies and understand the rationale behind them. It makes the evidence readily accessible to a broad range of stakeholders and all interested parties, promoting a shared understanding.

This approach supports well-informed, data-driven decision-making by providing clear links to evidence, ensuring that policies are grounded in sound reasoning.

Question 3: Do you agree with the proposed framework for local development management policies?

The proposed framework for managing National Development Management Policies and Local Development Management (DM) policies is welcomed by Objective and is relatable to successful policy-making that we have seen elsewhere.

We already see this in place from the successful implementation of such a system in the State of Victoria, Australia, where 79 LPAs have adopted the Objective Keyplan system for statewide policymaking that is then specialised and expanded upon but Local Authorities. Another jurisdiction where Objective Keyplan is in use is New Zealand, where national planning standards have been in place for some time.

For National Development Management Policies, we acknowledge the efficiencies to be gained by centralising the creation of consistent policies to prevent duplication and overlap. This would work well to cascade national decision-making and allow centralised research on specialist or complex topics. This approach aligns with DLUHC's goal of streamlining processes and ensuring effective policy dissemination.

Where possible, National Development Management Policies should be adaptable to Local Development Management Policies to suit local needs without the need to be written from scratch.

We propose that the NDMPs are hosted in a centralised repository where local authorities can pull the latest versions, and adopt or refine them using a digital template system for efficient drafting, review, and consultation. This digital template approach can then be wholly or in part automated through Objective Keyplan, ensuring alignment with DLUHC's vision by providing a structured and standardised method for developing local policies. It enhances governance in the planning process, making it more transparent and efficient.

Objective has supported other jurisdictions with this approach, most notably the state of Victoria (Australia). 

Question 4: Would templates make it easier for local planning authorities to prepare local plans? Which parts of the local plan would benefit from consistency?

The use of digital templates to streamline the production of local plans represents a significant step forward in improving the planning process. We have observed examples where a similar approach was taken in Regulated Industries, where regulators specify the template or at least the content requirements and, in some cases, the industry themselves form a representative body to agree on a common template. This includes Ofwat’s recent approach to the Price Review 24, International Sustainability Standards Board and the IFRS standard, and the activities of industry representative bodies in Template definition, such as the Financial Services Council in Australia. All examples where Objective’s digital template system is being applied.

A template-based system would play a central role in managing a complex process by facilitating reuse and ensuring the consistency and integrity of policies. This is the case with Objective Keyplan in the State of Victoria, Australia, where the system seamlessly distributes updates to dependent parties when changes are made at the source. The adoption of Objective Keyplan in the UK can be a catalyst for streamlining the local planning process and addressing several issues:

1. Standardisation and Consistency (DLUHC Requirement Background 33): The use of digital templates with Objective Keyplan, resolves the issue of inconsistency in local plans. This aligns with DLUHC's recognition of the problem and promotes clarity and efficiency for users.
2. Nationally-Defined Digital Templates (DLUHC Requirement Proposed Approach 35): We support DLUHC's proposal to create a series of templates, offering standardised approaches to various sections of the plan. The use case of Objective Keyplan across Australia and New Zealand demonstrates the effectiveness of such an approach.
3. Flexibility and Local Innovation (DLUHC Requirement Proposed Approach 36): Our response recognises the need for flexibility within the templating system, aligning with DLUHC's vision of allowing for local adaptation while maintaining key standards where necessary.

The adoption of digital templating, as demonstrated by the Objective Keyplan system, is a well-aligned and practical solution for addressing DLUHC's requirements. It offers a proven path toward standardisation, transparency, and efficiency in the local planning process while allowing for local flexibility and innovation where needed. This approach will ultimately contribute to more effective local plans that meet the needs of the community. 

Question 5: Do you think templates for new style minerals and waste plans would need to differ from local plans? If so, how?

From a technology perspective, the same design pattern can be adopted across all styles of plan, policy and documentation. 

Question 6: Do you agree with the proposal to set out in policy that planning authorities should adopt their plan, at the latest, 30 months after the plan preparation process begins?

Objective supports the proposal to set a 30-month deadline for the adoption of local plans. In England’s plan-led system, having up-to-date local plans is critical to drive suitable development and economic growth. Whilst this timeline may appear challenging with current practices and resources, we are confident it can be achieved successfully, provided LPAs receive the necessary support during the transition.

Many LPAs throughout the UK are using outdated processes and platforms that simply aren’t designed for this purpose. Reduced availability of Planning professionals and increasing expectations have exacerbated this – there is little time to innovate practices or improve efficiency and once the Plan is Adopted then learnings and institutional memory are lost before the next round. Ironically, technological innovations that already exist in some solutions like Objective Keyplan are left under-exploited.

Individually, LPAs have made their best efforts to achieve what they need. In reality, this is best achieved at a national level where performance data can be monitored to help identify and resolve slower moving parts of the local plan. Furthermore, if the plan is broken down into its constituent parts, there is likely to be a policy that could or should evolve more rapidly than others.

An alternative approach we have seen elsewhere is for each policy element to have its own lifecycle, rather than a single 30-month deadline for the entire plan. This supports the idea that a plan is always ‘adopted’, but introduces a new dynamic where proposed changes to elements of the plan may come from elevated issues or focus areas constantly being evaluated.

Objective Keyplan is specifically built to manage the planning policy process. It can be adopted and distributed centrally by the government and/or adopted by individual or combined authorities. Objective Keyplan’s core benefit is to provide visibility and traceability throughout the entire process along with significant efficiency gains. It also supports a model of a single planning document objective or where elements of a plan could evolve at a different cadence from each other.

Question 7: Do you agree that a Project Initiation Document will help define the scope of the plan and be a useful tool throughout the plan-making process?

Taking a project management approach to Planning and policy creation is to be welcomed as the Project initiation document enables a structure to be developed and then followed through the process.

By standardising the approach ‘digital templates’ can be created centrally for use by the LPAs. These can be easily managed with Objective Keyplan. Full version control and traceability are automatically applied to the content and can be managed centrally to ensure that LPAs are always using the latest version.

At a local level, significant efficiencies can be achieved, with;

• Having a document already partially completed and only having to make ‘small/local’ changes (not having to reinvent the wheel each time).
• The ability to reuse content (keeping a single source of the original while automatically keeping multiple policies updated with the latest version).
• Enabling multiple authors to collaborate in real-time and eliminating the cumbersome formatting and document management issues when using multiple software applications such as the M365 and Adobe product suites.
• Workflows can be set up to manage tasks, assess progress and ensure content is managed by the right reviewers and approvers.

Question 8: What information produced during plan-making do you think would most benefit from data standardisation, and/or being openly published?

A data schema is the cornerstone of a future-ready planning system. It not only enhances data standardisation but also unlocks numerous advantages in the planning process. We have witnessed numerous examples of where data standardisation and open publication is particularly beneficial:

1. Policy Documents: Policies should be authored in a standardised format that strips out style and preamble to focus on content as data. It should ensure compatibility with various digital platforms, from the initial planning stages to Development Management. This uniformity facilitates the integration of digital tools, making policy interpretation, implementation and monitoring more efficient.
2. Thematic Data Integration: It is crucial to establish data connections between policies and their associated thematic elements right from the outset. This approach enables real-time monitoring of citizen engagement throughout the planning process. It ensures that policies remain aligned with evolving community needs and preferences, making the planning process more dynamic and responsive.
3. Consultation Responses: Standardisation is essential for consultation responses. Compliance with industry standards streamlines the sharing of feedback with regulatory bodies like the Planning Inspectorate. Digital tools, such as interactive dashboards, can be employed for sharing responses. Inspectors can then directly analyse and query these responses, eliminating the need for lengthy reports. This contributes to the overarching objective of expediting the examination process and achieving quicker decision-making.
4. Planning Goals: Clearly stated goals in a standardised data format would allow downstream systems to measure performance and success, at an individual and aggregate level. This would then support an important feedback loop of whether policy is working or needs further development.

By implementing these improvements, the planning process becomes more agile, transparent, and efficient, aligning with the digital transformation goals outlined in the Levelling Up and Regeneration Bill. 

Question 9: Do you recognise and agree that these are some of the challenges faced as part of plan preparation which could benefit from digitalisation? Are there any others you would like to add and tell us about?

Many of the challenges faced today are a legacy from when technology and data usage were in their infancy. Some of the aspects of plan-making have not evolved with technology. In other instances single-point solutions were adopted but are not interoperable and have resulted in a poor experience all around.

The biggest factor in this technological change is to focus on the data underpinning the entire planning process, from early stages to examination and adoption. Once planning policy is thought of as ‘data’, the experience can be shaped to suit different needs.

Some examples of challenges addressed by treating policy as data include:

• "PDF-based plans are static"
  With planning policies managed as discrete content, the limitation of being ‘static’ is overcome by surfacing the policies in multiple formats, including interactive media, maps and other user-friendly platforms. This is in addition to the ability to create a PDF from the same source. By making the plan engaging and interactive, we aim to enhance community involvement and understanding of the planning process. Users can explore the plan visually, which can result in greater engagement.
• Monitoring policies
  Determining whether policies are working effectively is critical. By transitioning to data-based policies, these evaluations can be performed more easily and with greater frequency. This data-driven approach empowers decision-makers to track and assess the impact of their policies in real-time, enabling swift adjustments and improvements.
• Inclusive Engagement and Accessibility
  Whilst it is convenient to consider digitalisation as Web delivered interactive content, caution is needed to avoid excluding parts of the national community. We evidence this by the large percentages of non digital representations currently received in statutory consultation. In our opinion, digitalisation should mean capturing the elements of the plan as data and that this data can be published in different formats for different purposes; a single record of truth with different output formats.

Our solution, Objective Keyplan, is tailored to alleviate these challenges. It provides dynamic, data-driven policies that are accessible across platforms, while also making planning content engaging and interactive. We firmly believe that digitalisation in plan preparation is not just a choice but a necessity to meet the evolving needs and expectations of today's stakeholders. 

Question 10: Do you agree with the opportunities identified? Can you tell us about other examples of digital innovation or best practice that should also be considered?

Objective is committed to playing a pivotal role in driving innovation and facilitating the transformation of planning policy into data that serves as the foundation for the entire planning process.

Our approach encompasses a comprehensive range of strategies, including visualising plans, policies, and spatial data, implementing templates for standardising data, offering informative dashboards for a quick overview of the process, deploying efficient search tools, and utilising AI for sentiment analysis and representation processing. These are designed to address the challenges and opportunities associated with plan-making and align with the DLUHC's requirements.

Key barriers to innovation have been the availability of budget, decentralised decision making, and the systems of procurement that artificially stifle the risk/reward equation. Decisions are routinely made on the basis of what can be afforded rather than the value that can be delivered. The PropTech Innovation Fund and DLUHC’s engagement on this has been a welcomed change. 

Question 11: What innovations or changes would you like to see prioritised to deliver efficiencies in how plans are prepared and used, both now and in the future?

A consistent nationwide approach should be taken to create template-based processes to aid the plan preparation, leveraging a top-down approach by creating a digital toolkit specifically tailored for various tiers of authority. Different levels of government or organisations may have unique requirements, and these templates can be customised accordingly to meet those needs. By doing so, these commonalities can be incorporated into the planning process, reducing redundancy and promoting consistency.

To enhance the efficiency of plan preparation a focus should be on implementing a consistent, data-driven approach that encourages the sharing of plans. This approach should aim to streamline the entire planning process.

Building a library of templates and documents is beneficial. This repository would be a valuable resource for planners, enabling the quick adaptation of successful plan components. It would also promote best practices and save time in drafting plans from scratch.

These innovations will not only benefit the current planning processes but also pave the way for more effective and agile planning in the future. 

Question 12: Do you agree with our proposals on the milestones to be reported on in the local plan timetable and minerals and waste timetable, and our proposals surrounding when timetables must be updated?

Objective supports the proposal regarding the milestones in the local plan and minerals and waste timetables, as well as the suggested update schedules. It's essential to emphasise the integration of digital templates and data standards into the process. This approach not only provides a more holistic view but also significantly enhances the visibility of the entire end-to-end process.

By leveraging digital templates and data standards, we can enable more frequent and systematic reviews of timetables. This, in turn, transforms timetables into valuable datasets that can drive innovation and decision-making. This approach aligns with the evolving needs of efficient and data-driven planning, offering improved transparency and adaptability. 

Question 13: Are there any key milestones that you think should automatically trigger a review of the local plan timetable and/or minerals and waste plan timetable?

Considering that a local plan is a collection of policies, it may be beneficial to think of each policy in its own merit and timeframe.

There are aspects of a local plan that have longer impact timeframes and may need little change, some elements that require faster evolution, some that need heavier research and consultation, and some elements that may need to respond quicker to current national or local priorities.

A single timetable for review of a local plan was appropriate (perhaps nearly impossible to avoid) when a local plan consisted of a single lengthy document. A modern system like Objective Keyplan allows for each policy to be treated as data, with its own performance metrics and appropriate lifecycle. 

Question 14: Do you think this direction of travel for national policy and guidance set out in this chapter would provide more clarity on what evidence is expected? Are there other changes you would like to see?

Objective supports the direction of travel for national policy and guidance as presented in this chapter, as it provides more clarity on what evidence is expected in the local planning process.

The emphasis on establishing a clear linkage between evidence and the policies being proposed is a positive step in the right direction. Objective Keyplan can provide a framework for ongoing monitoring and evaluation of the approach's effectiveness. It allows for the collection and analysis of data related to the evidence-policy linkage, enabling adjustments and improvements as necessary. It supports well-informed, data-driven decision-making by providing clear links to evidence, ensuring that policies are grounded in sound reasoning. 

Question 15: Do you support the standardisation of evidence requirements for certain topics? What evidence topics do you think would be particularly important or beneficial to standardise and/or have more readily available baseline data?

Objective supports the standardisation of key evidence, bringing greater clarity and efficiency to planning processes and reducing debates over specific methodologies during examinations.

Standardisation offers valuable opportunities to leverage data and digital tools effectively, ensuring planning authorities can establish a consistent and high-quality baseline of evidence. There should also be provision of a national repository of research and evidence to ensure a baseline trusted source and quality.

The nature and scope of standardisation may vary by evidence topic, these topics include:

1. Development Need: Standardising evidence related to development needs, such as economic development assessments, would promote consistency in how these assessments are conducted. This is crucial for fostering sustainable economic growth and resource allocation.
2. Site Identification, Assessment, and Selection: For areas like housing and employment land availability assessments, standardisation can provide a consistent and transparent framework for evaluating potential sites. This ensures that planning authorities make informed decisions about land use.
3. Impact Assessments: Standardisation of impact assessments, like transport assessments, would improve the quality and reliability of data used in evaluating the effects of projects on the environment and communities.

Leveraging standardisation in evidence and data, particularly in areas such as development needs, site assessments, and impact evaluations, holds the potential to significantly improve the efficiency, transparency, and quality of planning processes. It will not only simplify decision-making but also support sustainable and informed growth in our communities. Objective Keyplan can be a pivotal system in supporting the end-to-end planning process providing the robustness and transparency of data and evidence. 

Question 16: Do you support the freezing of data or evidence at certain points of the process? If so which approach(es) do you favour?

Objective is centred on information management, governance, and version control where all our solutions are designed to preserve the integrity and clarity of evidence throughout the entire process. We understand the necessity of freezing data or evidence at certain points in the process to ensure transparency, auditability, and accountability. This approach is consistent with our commitment to robust information management practices.

Our system, Objective Keyplan, enables the creation of immutable snapshots at crucial milestones in the planning process. These snapshots capture a read-only version of the data, ensuring that the state of evidence at specific points in time is securely preserved. This capability guarantees that submitted documents related to the soundness of a plan remain intact and can be referred to without any concern about the integrity of the data.

Our platform incorporates advanced version control systems that track changes made to evidence over time. This feature facilitates the comparison and analysis of different versions of submitted documents, and if necessary, the ability to revert to previous versions. The complete history of changes provides the means to thoroughly assess the impact of any amendments and make informed decisions regarding the soundness of the plan.

Objective Keyplan includes built-in audit trails that track every interaction with submitted documents. This ensures transparency and accountability within the decision-making process. The comprehensive audit trails also serve as a deterrent against unauthorised or inappropriate changes to evidence, facilitating proper assessment and tracing modifications to the responsible parties.

We have implemented stringent access control measures to limit who can make changes to the evidence. Our platform grants access only to authorised stakeholders and their permissions can be managed, reducing the risk of unintended or unauthorised amendments to the submitted documents, and ensuring they remain relevant to the soundness assessment.

Objective supports the freezing of data or evidence at various points in the process, and our approach combines multiple strategies to maintain data integrity and clarity. Our primary focus is on enabling transparent and secure management of information and evidence, ensuring that the impact of any changes is properly assessed and well-documented. 

Question 17: Do you support this proposal to require local planning authorities to submit only supporting documents that are related to the soundness of the plan?

Objective Keyplan allows for the processing of all data aspects relating to the plan. This can be presented in a number of ways allowing the authority to select the relevant document for inspection.

Decisions made leading to the submission are automatically recorded within our system providing the traceability of evidence in the process. This can then be shared if relevant. 

Question 18: Do you agree that these should be the overarching purposes of gateway assessments? Are there other purposes we should consider alongside those set out above? 

Objective has no views or comments to add regarding this question. 

Question 19: Do you agree with these proposals around the frequency and timing of gateways and who is responsible?

The timeframes are ambitious but can be achievable following the adoption of modern technologies and a purpose-built system capable of managing the process from beginning to end. 

Question 20: Do you agree with our proposals for the gateway assessment process, and the scope of the key topics? Are there any other topics we should consider?

We broadly welcome the introduction of gateways and key topics. It is important for Local Authorities to have regular opportunities to confirm expectations regarding reporting and digital relevance to ensure plans are progressing to the stated objectives. 

Question 21: Do you agree with our proposal to charge planning authorities for gateway assessments?

In response to your proposal to charge planning authorities for gateway assessments, we, as a supplier to planning authorities, are acutely aware of the significant budgetary pressures. While we understand the need for a sustainable funding mechanism for gateway assessments, it is important to acknowledge that many of our customers do not welcome the introduction of a mandatory fee-based system for the gateways.

The upcoming fee increase, while providing some respite, might still present challenges for planning authorities, particularly smaller or underfunded ones. These planning authorities are often faced with limited financial resources, and introducing mandatory fees can add to their financial burden. It's vital to consider the potential consequences, such as delays in planning processes or resource constraints, which could hinder the overall efficiency of planning authorities. 

Question 22: Do you agree with our proposals to speed up plan examinations? Are there additional changes that we should be considering to enable faster examinations?

Objective agrees with the proposed idea that stronger evidence should correlate with shorter examination times. Furthermore, a plan submitted as data should also support plan inspection that can be navigated non-linearly. For example, it should be possible for an Inspector to navigate from a policy to the chain of evidence that supported that decision as efficiently as following a hyperlink.

Our system Objective Keyplan, is designed to support the planning policy process, aimed to enhance the overall efficiency and transparency of the examination phase. A core capability of Objective Keyplan is to facilitate the traceability of consultation representations, thematic considerations, and the evidence base during the examination process. The in-built consultee database meets the requirements of the process by creating linkages between citizens, comments and content.

One additional change to consider involves the handling of representations received from organisations, as opposed to individual citizens. Encouraging these organisational representations to be submitted online is becoming increasingly relevant, capitalising on the breadth of digital consultation tools available. This approach not only streamlines the submission process but also promotes accessibility and ease of reference, further contributing to the overall goal of expediting examinations. 

Question 23: Do you agree that six months is an adequate time for the pause period, and with the government’s expectations around how this would operate?

Objective has no views or comments to add regarding this question. 

Question 24: Do you agree with our proposal that planning authorities should set out their overall approach to engagement as part of their Project Initiation Document? What should this contain?

Objective supports the proposed idea of planning authorities incorporating their approach to engagement within the Project Initiation Document.

The notion of making the engagement process more user-friendly is highly welcomed. It acknowledges the importance of ensuring that stakeholders find it convenient and accessible to participate in the planning process. This, in turn, encourages greater community involvement and results in more inclusive decision-making.

The suggestion to provide digital toolkits for planning authorities is a significant step in the right direction. This provision will empower planning authorities to leverage digital tools, streamlining their operations and making the engagement process more efficient. By reducing the effort required, it will encourage the adoption of these modern solutions, which benefits the overall planning process.

While the proposal references technology explored as part of the PropTech Innovation Fund, we strongly recommend that innovation should not be limited to this. Central Government and Planning authorities should remain open to exploring a wide range of innovative solutions. This will ensure that the most effective and efficient approaches are adopted to fulfil the objectives of the planning process. 

Question 25: Do you support our proposal to require planning authorities to notify relevant persons and/or bodies and invite participation, prior to commencement of the 30 month process?

Objective welcomes the introduction of a “notify” and “invite” system and would prefer to see this go further – encouraging stakeholders to adopt digital tools to participate in the process. We have consistently heard from planning authorities that the number of representations received externally to the consultation platform ranges between 50% to 90% regardless of the platform used. This becomes a particularly time-consuming exercise to manually capture all views with the traceability and quality required. 

Question 26: Should early participation inform the Project Initiation Document? What sorts of approaches might help to facilitate positive early participation in plan-preparation?

Objective has no views or comments to add regarding this question. 

Question 27: Do you agree with our proposal to define more clearly what the role and purpose of the two mandatory consultation windows should be?

Objective has no views or comments to add regarding this question. 

Question 28: Do you agree with our proposal to use templates to guide the form in which representations are submitted?

Objective endorses the idea of implementing templates as a means to shape the format of representations submitted. This approach not only facilitates the submission of representations in a manner that bolsters accessibility for communities but also streamlines the processing for planning authorities.

In our interactions with planning authorities, they consistently report that a substantial portion of responses come in external formats such as letters or emails, accounting for anywhere between 50% to 90% of all the feedback received. To fully harness the advantages of digital technology, it is important that all stakeholders are involved in maintaining the digital cycle. We support the notion outlined in the Bill that encourages the submission of 'machine-readable' content whenever possible, instead of defaulting to PDF format.

To illustrate this point, seeking views on a pre-submission plan is best done when comments relating to specific parts of the plan are viewed and captured in situ. A recent example of where this has been successfully achieved is with Wiltshire Council, where responses were pre-codified with themes for easy reporting using Objective Keyplan.

By contrast, separating the survey form from the plan often results in data points that are not directly linked to the content they relate to. This provides multiple challenges and introduces unnecessary delays in processing submissions. 

Question 29: Do you have any comments on the proposed list of prescribed public bodies?

Objective has no views or comments to add regarding this question. 

Question 30: Do you agree with the proposed approach? If not, please comment on whether the alternative approach or another approach is preferable and why.

Objective has no views or comments to add regarding this question. 

Question 31: Do you agree with the proposed requirements for monitoring?

Objective supports the proposed requirements for monitoring as this emphasises the importance of creating a more structured and policy-centric approach to the entire planning process.

Monitoring plays a pivotal role in establishing a stronger and more transparent link between Development Management and Planning Policy. This link is important as it ensures that planning policies are not documents but are treated as actionable data points, driven by a policy-centric planning process.

The proposal can facilitate the process by providing progress against plan-making activities, assessing the implementation of key policies, and providing transparent insights into the plan's performance. This structured approach to monitoring is essential for reinforcing the integrity of planning policies.

Objective believes that this is a critical step towards building a more policy-centric planning framework. These requirements create a transparent and data-driven process that aligns with our vision of policies being at the core of planning decisions, ensuring that they are not just words on paper but actionable guidelines for the development of our communities.

Objective’s approach

Many of the challenges faced today are a legacy from when technology and data usage were in their infancy. Some of the aspects of plan-making have not evolved with technology. In other instances single-point solutions were adopted but are not interoperable and have resulted in a poor experience all around. Objective's approach leveraging a fit-for-purpose system, Objective Keyplan, offers a practical solution to address DLUHC's requirements and facilitates more effective, user-friendly, and evidence-based local plans that better serve the needs of communities in the UK. The adoption of these proposed changes has the potential to significantly improve the planning process, speed up the adoption of local plans and create a more transparent and efficient system for all stakeholders.